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21
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.
22
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.
23
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".
24
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