AOAC

Hazelnuts and peanut are not defined in sense of their variety while milk and egg are not defined

in sense of their origin

A method developer should validate the differences between different

varieties of hazelnuts and peanuts in sense of traceability and

measurement uncertainty.

A method developer should validate different species that deliver milk

(cow, goat, sheeo etc.); same for egg. Maybe an in‐silico analysis of

peptide sequences is sufficient.

Species names were added to the SMPR. The working group

group did not agree to requireing different varieties.

The term "allergen" is not defined

The SMPR should contain a clarifying chapter or clause that explains

that the term “allergen” is used in an analytical and not immunological

way. “Allergen” could also mean a specific protein from hazelnut that

differs between regions and varieties.

No change recomended.

Although the term "allergen" itself is

not defined, the identification of food allergens types in the

SMPR provides all of the needed information for method

developers. No definition were found that weren't circular. i.e.,

an allergen is a molecule causes an allergic reaction.

A general problem of this SMPR is traceability of results. In detail, an LC‐MS/MS user prepared

peptide solutions on a weight by weight basis and uses reference materials also on a weight by

weight basis. Are these reference materials of a higher order in the calibration hierarchy or are the

peptides of higher level? Furthermore, how should we re‐calculate to the “analyte” which is for

example “milk”. There is no conversion factor to re‐calculate from “weight whole milk powder

from NIST” to “milk”. Even more problematic is the recalculation from “peak area of a specific milk

peptide” to “milk”.

At a minimum, each validation report should contain a chapter that

clearly describes how the validation manager solved this fundamental

problem for each allergen or describes the limitations of quantitative

results.

Working Group agreed that all results to be "reported as ppm of

the target allergen in food commodity".

I have developed a sign system for the 14 allergens which, according to the European Union, must

be indicated in food packagings. It has being the work of 7 months for my final grade in Graphic

Design.

Implement your standard regulation by applying the sign system for

the allergens (eggs, milk, nuts, peanuts, celery, sesame, mustard,

sulphites, fish, crustaceans, mollusks, gluten, lupin and soy). It would

help to the interpretation of the ingredients independently from the

country where people live or the language that they speak. Thank you

No change.

Irrelevant