Changing labelling policy for food allergic consumers in Europe
Submitting Institution
Brunel UniversityUnit of Assessment
Psychology, Psychiatry and NeuroscienceSummary Impact Type
PoliticalResearch Subject Area(s)
Medical and Health Sciences: Immunology, Nutrition and Dietetics, Public Health and Health Services
Summary of the impact
A 14 month research project funded by the Food Standards Agency (FSA) has
informed national policy on allergens and food labelling, EU negotiations
by DEFRA on Food Information Regulation and Food Standards Agency advice
to industry. The project involved the development of a novel method for
eliciting consumer views about food labels, the details of which have been
communicated by the FSA to relevant government departments. The results of
the project have been presented to FSA, at industry events, within
academia and allergy charities, while references to the project have been
widely circulated on social media and appear on policy and industry
websites.
Underpinning research
Recent estimates suggest that over 120,000 children aged 13-19 suffer
from challenge-proven food allergy in the UK. The incidence of anaphylaxis
over all age groups has been estimated as high as 103 episodes for 100,000
person years, with food causing at least 30% of these (ref). In the light
of this the Food Standards Agency needed to better understand the dietary
patterns and food choices of food allergic consumers in order to
contribute to policy relating to thresholds of allergens in food and the
labelling that would need to accompany this [1]. Food allergy limits
quality of life and impairs psychological well-being (ref)
Through a competitive tendering process FSA awarded the project to a team
led by Julie Barnett — initially based at the University of Surrey (Feb
2009 - Sept 2009) and then later at Brunel University (Oct 2009- April
2010). Whilst at Brunel as Reader in Healthcare Research Dr. Barnett
collected more than two-thirds of the data, led the compilation of the
final report, the submission of all of the publications reporting the data
collected in the study and X gave associated conference presentations
This study investigated how people with peanut and tree nut allergies use
food labels and other pack information when making choices about what food
to eat and buy, and what types of strategies they adopt when selecting
foods (shopping and eating out) to minimise the risk of triggering an
allergic reaction. The team led by Dr Barnett (Brunel University) included
Prof Shepherd and Dr Raats (University of Surrey) and Dr Lucas (University
of Southampton) and an independent consultant (M.H.Gowland).
Thirty-two adult volunteers with a doctor diagnosed peanut and/or tree
nut allergy were recruited to the study from 5 sources across the UK
(recruited participants had no other food allergies). The study protocols
were developed in close consultation with the FSA in a series of
bi-lateral meetings. Following significant challenges to recruitment due
to the stringent recruitment criteria the project was extended and the
increased costs this involved were met by the FSA.
Each participant took part in three tasks which were designed to gather
qualitative information on how food allergic consumers make their food
choices and food purchasing decisions. These tasks were:
- An accompanied shop in their usual supermarket where participants were
asked to talk aloud about what they were thinking when they chose each
food product (methodology for this `think aloud' task was trialled and
refined prior to use)
- An in-depth semi-structured interview which followed on (on the same
day) from the accompanied shop and was conducted in each participants
own home
- A Product Choice Reasoning Task (PCRT) designed specifically for this
study with input from the FSA and food allergy experts. Each participant
was given 13 packaged food products (these were real and mainstream
foods sold through major retailers) chosen on the basis that allergy
experts believed that they would pose particular dilemmas for nut
allergic consumers. Participants were asked to `think aloud' and say if
they would be happy to buy the product and how they reached their
decision
Participants used a range of strategies (rules of thumb) to make choices
about what foods to eat and buy when food shopping and eating out. These
included 1) personal experiences, preferences and sensory judgements
(participant based characteristics), 2) product based characteristics, and
3) characteristics of the food producer, including trust accorded to
brands and supermarkets
- Food labels were used as well as previous experience of eating a
product e.g. particular brand names they trusted more in terms of
quality of products and labelling [4, 6].
- Most relied on the allergy advice box over and above the ingredients
list. However they did not understand the voluntary nature of allergen
advice boxes. Expressed and revealed preferences for ingredients lists
or allergy advice boxes did not seem to relate in any systematic way to
allergy severity, and absence of an allergy advice box was wrongfully
interpreted by many as an indication of absence of allergens. [4, 5]
- Participants had a complex and detailed range of views about `may
contain' labelling. Although many participants chose to respond in
consistent ways to may contain labelling, most participants considered
that the underlying message of `may contain' labelling was not credible
or desirable, and many discounted the `may contain' label in their
decision making [5].
- Nut allergic individuals tended to adopt an avoidance and
communication strategy to manage the risk of triggering an allergic
reaction when eating outside the home. Particular problems when eating
abroad were identified and translation cards were reported as useful.[2]
- Participants generally asked restaurant staff whether a dish contained
nuts or not or asked them to inform the chef they had a nut allergy. The
most helpful scenario for eating out in restaurants was when staff were
responsive and when the allergic consumer was recognised and known by
restaurant staff — many participants reported embarrassment at drawing
attention to their allergy in a restaurant setting [2].
References to the research
[3] Barnett, J., et al., The strategies that peanut and nut-allergic
consumers employ to remain safe when travelling abroad. 2012. Clin Transl
Allergy. Jul 9; 2(1):12. http://dx.doi.org/10.1186/2045-
7022-2-12
[6] Barnett, J., Vasileiou, K., Gowland, H.M., Raats, M.M.& Lucas,
J.S. (2013) Beyond Labelling What Strategies Do Nut Allergic Individuals
Employ to Make Food Choices? A Qualitative Study, PlosOne 8(1): e55293. http://dx.doi/org/10.1371/journal.pone.0055293
Details of the impact
Impact on Agency policies/policy development/advice:
This research has had a substantial impact on health and welfare, helping
in particular vulnerable patient groups and informing decisions by
relevant regulatory bodies and industry. Food Standards Agency says that
this project (Source [S] 1) has provided them with `a wealth of new
information' [S2] regarding how nut allergic consumers use the food label
and other information to inform their decision making and about what the
issues are for them when eating out. This was identified as a contribution
to the evidence used by Defra in conducting EU level negotiations. This
research has also had impact on public policy and services. Sue
Hattersley, Head of Food Allergy at the FSA, said: 'This research shows
the importance of clear allergy labelling on food products' [S3]. This
evidence informed the development of regulations that will affect the
practice of all food manufacturers and retailers as well as the purchasing
practices of nut allergic consumers. Specifically, in the FSA summary of
the project, sent to all delegates in of the Food Allergy and Intolerance
Research Programme Review meeting (November 2012)[S2], the FSA states
that:
- They regard the methodology developed in the shopping basket task as
novel and say that this method is likely to inform future research on
consumer decision making in relation to pre-packed food. Accordingly,
they have shared details of this methodology with other relevant
Government Departments
- The findings have informed work to develop management
thresholds/action levels for cross-contamination of pre-packed foods
with allergenic foods — the research has informed the Agency's thinking
further regarding the likely need to try and move away from the phrase
`may contain' if and when such thresholds are rolled out because of the
preconceptions regarding interpretation of the phrase in addition to
many disregarding it entirely.
- The work has been used to inform EU negotiations on the new Food
Information Regulation (FIR). The findings of the research were shared
with DEFRA who are leading on the UK negotiations on the FIR,
highlighting the need to ensure consumers are pointed towards the
ingredients list as the primary source of allergen information because
other information (e.g. the allergy advice box) is not always present.
The FIR (now published) [S4] has included a requirement for allergens to
be in highlighted text in the ingredients list so this should help to
address this issue.
- The work has been used to inform EU negotiations on the new Food
Information Regulation (FIR). The findings of the research were shared
with DEFRA who are leading on the UK negotiations on the FIR,
highlighting the need to ensure consumers are pointed towards the
ingredients list as the primary source of allergen information because
other information (e.g. the allergy advice box) is not always present.
The FIR (now published) has included a requirement for allergens to be
in highlighted text in the ingredients list so this should help to
address this issue.
- The results of the `eating out' part of the research will inform the
Agency's guidance to UK industry regarding provision of allergen
information for foods sold non-prepacked which is a new requirement of
the FIR.
- The finding that many nut allergic consumers refer to the allergy
advice box as the first point of allergen information has informed the
Agency's correspondence with industry where we now specifically
emphasise the importance of manufacturers ensuring that the allergy
advice box matches the ingredients list as regards allergens present.
In an open meeting of Northern Ireland Food Advisory Committee (July
2011) the research was summarized as providing [S5] `insight into consumer
views about all aspects of food choice, labelling, and most particularly
around "may contain" type labelling. It has helped the [FSA} Agency to
have a better understanding of the patterns of food consumption by groups
of food allergic consumers. This information is being used to inform
Agency dietary advice to consumers with nut allergies and to input into
ongoing European discussions on the Food Information Regulation'. Hazel
Gowland, Food advisor to the Anaphylaxis Campaign, notes how the research
has `helped her campaign for easily visible understandable labels,
improved information provision and better allergen controls in catering,
general food allergy awareness among food handlers and clarifying the
needs of food allergic people travelling. I feel more authentic and
evidence-endorsed in the messages I am communicating' [S6]. Policy debate
has been moved forward by the research evidence in this case. Findings
appeared in the FSA survey protocol on advisory labelling [S7]. Barnett
presented this work at TO7 Programme reviews for the FSA in 2010, 2011 and
2012 and as an invited speaker at the Anaphylaxis Campaign Corporate
Conference (2011) [S8]. The research programme is cited by the FSA in
their research specification for future research as an example of research
`informative in drafting tender documents and the conduct of proposed
research' [S9] Findings of the study were reported in the leading online
trade journals Foodmanufacture.co.uk, covering the food and drink
manufacturing [S10], Food Science and Technology (published by the
Institute of Food Science and Technology)[S11] and RSSL, serving the food,
drink, pharmaceutical,
healthcare, biopharmaceutical and consumer goods industries [S12].
Sources to corroborate the impact
[S1] Civil Service Corroborative Evidence received from Food Allergy and
Intolerance Research Programme Manager, Food Standards Agency (FSA),
confirming the research impact on FSA regarding their negotiation with
other EU member states on changes to food allergen labelling legislation;
in addition, a full project report from FSA:
http://www.food.gov.uk/science/research/allergy-research/allergy-labelling/t07058/#.UJfQCHhn3FA
[S2] Delegate booklet, Food Allergy and Intolerance Research Programme
Review 2012 (hard copy available). TO7 Programme Review
http://www.food.gov.uk/science/research/allergy-research/more-allergy-research/allergy-prog-
review-2012#.UkLzqtKshcY
[S3] Interview in Food Law news (23 June 2011) `Labelling — Research on
allergy labelling use' http://www.foodlaw.rdg.ac.uk/news/uk-11030.htm
[S4] EU Food Information for Consumers Regulation http://www.food.gov.uk/enforcement/regulation/fir/labellingproposals/
[S5] Statement from the Northern Ireland Food Advisory Committee
www.food.gov.uk/multimedia/pdfs/papersnifac110704.pdf
(p. 163f)
[S6] A statement received from Hazel Gowland, Food advisor to the
Anaphylaxis Campaign
[S7] A Survey of Allergen Advisory Labelling And Allergen Content of UK
Retail Pre-packed Processed Foods. Survey Protocol. September 2011.
http://www.food.gov.uk/multimedia/pdfs/allergen-survey-protocol.pdf
[S8] Outlook: The Anaphylaxis Campaign Magazine. Spring 2011, giving
conference details (p. 7) and information about the research (http://www.anaphylaxis.org.uk/userfiles/files/Outlook49.pdf
).
[S9] "The preferences of those with food allergies and/or intolerances
when eating out". Research Specification FS305013. Food Standards Agency
specification document. Paragraph 1.26ff.
https://fsa-esourcing.eurodyn.com/epps/cft/prepareViewCfTWS.do?resourceId=55671.
Detailed call document from the FSA available from at Brunel on request.
[S10] News Foodmanufacture.co.uk `Endangered consumers ignorant of
allergy labelling, FSA study' (23 June 2011) http://www.foodmanufacture.co.uk/Food-Safety/Endangered-consumers-
ignorant-of-allergy-labelling-FSA-study
[S11] Renewed risk focus is recipe for food brand protection. Food
Science & Technology, vol 25, issue 4 (Dec 2011), citing Barnett et
al. Allergy journal publication (2011)
https://www.fstjournal.org/unrestricted-magazine/archive/25-04-2011/index.html#/40/
[S12] RSSL, a specialist scientific consultancy food e-news (Edition 525:
5-19 Oct 2011), citing Barnett et al, BMC Public Health journal
publication (2011)
http://www.rssl.com/sitecore/Content/rssl/com/Website/Services/Food/Foode-news/Edition501-
550/Edition525.aspx