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To correctly list potential cross-contaminations on labels, it is important not only to properly complete a VITAL analysis, but also to check it extensively for any errors. Here is an overview of the most common errors.
Consumption size and portion size are often not the same thing. Yet it is common to use portion size when completing a VITAL analysis. A calculation generally assumes the worst case scenario, where the assumption is that a consumer will not stick with one serving size.
The consumption size refers to a maximum amount of a product per meal time. It is based on the P95 of the RIVM's Food Consumption Survey (VCP). This often shows that the consumed quantity of a product is generally higher than the indicated portion size of the product in question.
The rule of thumb in a VITAL calculation is as follows: the higher the consumption size, the lower the action limit. The risk that arises when assuming portion size is that the action limit indicates a higher value than when assuming consumption size. In this way, the total PPM of cross-contamination allergenic protein often remains below the relevant action limit and is (wrongly) not included on the label.
When entering data for homogeneous or point contamination, confusion arises as to what physical form the allergen enters the production process in and the corresponding values required for a correct calculation. If the contamination occurs because a powder is used, or a slightly more fluid form such as a smooth paste, then it is a homogeneous contamination. This is because the allergen can then be easily mixed throughout the product. If it involves pieces or, for example, whole nuts or grains, then it is a point contamination. Here the allergen is concentrated in one place in the product.
Added to this, it is not always clear what further values are required for the calculation. For homogeneous contamination, the PPM allergen protein in the respective raw material is considered at the raw material level, and the process considers the PPM based on residual product in the entire production batch. For point contamination, the raw material level looks at the percentage protein of the allergen, and the process looks at the PPM based on residual product in the consumption batch.
Because values for homogeneous contamination are still sometimes entered when it comes to point contamination, this leads to anomalous results. Here, too, you run the risk of unnecessarily mentioning, or rather missing, cross-contaminations on the label.
In VITAL, the different gluten-containing cereals are grouped together in a group with the same reference dose. For the different nuts, this concerns three groups: cashew/pistachio, walnut/pecan and other, each with its own reference dose.
Because of these aggregations, when checking a calculation it is not always immediately clear for which nuts or grains the cross-contamination applies. Hereby, there is a danger of unnecessary mention of allergens on the packaging, which may cause certain groups of (allergic) consumers to prefer to avoid products. The goal is therefore to clearly state which nuts and grains are used at the production site and therefore pose a risk. This avoids unnecessary confusion on the part of the producer, the control body and the consumer.
Nowadays, there are several organizations that have developed their own calculation tool in addition to the possibility of taking a VITAL training. Because these calculation tools are all slightly different in format, use and presentation of results, they cannot always be compared one-to-one and it takes effort to check them accurately. The risk here is that erroneous data may be overlooked. This results in unnecessary cross-contaminations on labels. In the worst case, a cross-contamination may actually not appear on the label because the VITAL is not in order. By making calculation tools clear and easy to use, such errors can be detected and resolved early.
Generally, producers always have only a few employees who have taken a VITAL training course and can therefore correctly apply this knowledge in their own organization. This ensures that the knowledge (transfer) sticks to a limited group. When the employees in question leave, much of the knowledge will be lost, which can result in erroneous VITAL calculations in case they need to be adjusted due to change. This in turn complicates things for control because it is not known where values come from, nor is it always known how to fix it.
On the other hand, organizations may actually be hired to take this work off your hands. In this way, you are assured that the VITAL calculation is performed correctly. The disadvantage, however, is that the knowledge always remains with this organization and you as a producer are therefore dependent on it.
We are happy to help. You can contact us at +31 30 65 66 010 or email info@precon.group
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