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AOAC ISPAM "Food Allergen" Working Group Questions/Comments Form
2016-12-09 14:10:08
Melanie Downs
University of Nebraska-Lincoln
mdowns2@unl.edu12-09-2016
Title, Line 3; Section 2, Line 18: With respect to the use of both the words "chicken"
and "whole", a bit more clarity in the intent would be beneficial.
By inserting "chicken" to describe the source of egg, it may unintentionally disqualify
ELISA methods that detect chicken egg but also react with other bird eggs (e.g. duck,
turkey, etc.). While the primary purpose of the methods would be to detect and quantify
chicken egg, the SMPR should perhaps address what types and/or levels of cross-
reactivity with other species will be acceptable.
The use of "whole" may imply that egg white and egg yolk should be detected
equivalently. Most methods, however, would primarily detect egg white proteins, even
when whole dried egg is use as the method calibrant. It may be beneficial to discuss
and describe the extent to which methods are required to detect egg yolk and egg
white fractions independently.
Section 4, Lines 38-40: In the Definitions section, it would be useful to give some
thought as to whether definitions for both "allergens" and "commodities" are necessary.
If "allergens" are to be defined as allergenic source foods (similar to how most
regulations define food allergens), then a definition for commodities may create
additional confusion.
Section 4, Lines 76-78: The definition given in this section seems too specific to a
particular product for the purposes of this SMPR. The definition given is that of
refrigerated liquid whole eggs, as defined by the USDA FSIS. Given the complicated
regulatory authority for eggs in the United States (i.e. the FDA regulates in shell eggs,
while the USDA FSIS regulates egg products), it may be difficult to apply a regulatory
definition of whole egg for the purposes of this SMPR. (The FDA also does not have a
regulatory definition for "eggs", per 21 CFR 160.100.) It would be beneficial for this
working group to agree upon a simple definition for egg that suits the purposes of the
SMPR.