Allergeni:l’indicazione cautelativa non basta

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È di questa estate l’ennesima notizia che porta agli onori della cronaca (ancora una volta) la morte di una ragazza per shock anafilattico a causa di ingestione di cibo, somministrato in un ristorante nel luogo dove la stessa viveva, e contaminato da sostanze considerate allergeni alimentari.
Gli allergeni sono sostanze alimentari, o componenti di esse, che in una certa percentuale di persone possono provocare (interessando il sistema immunitario) delle reazioni avverse capaci di coinvolgere diversi apparati (respiratorio, gastrointestinale, epidermico, ecc.). Le reazioni avverse prendono il nome di allergie alimentari che possono risultare più o meno gravi, tra queste ultime un famoso esempio è lo schock anafilattico, una condizione estremamente grave nella quale la pressione sanguigna cala rapidamente e il soggetto colpito, nel caso in cui non si riesca ad intervenire in tempo, può morire per arresto cardiaco.
La nomenclatura degli allergeni, proposta inizialmente dall’Accademia Europea di Allergologia e Immunologia Clinica (EAACI) è stata, in seguito, pubblicata dalla Word Allergy Organization (Organizzazione mondiale di allergologia).
In Europa, vista la pericolosità di taluni alimenti con l’entrata in vigore del Regolamento UE 1169 del 2011 detto anche regolamento FIC (relativo alla fornitura di informazioni sugli alimenti ai consumatori) il legislatore ha deciso di dare indicazioni precise in merito a tale argomento, al fine di evitare inutili e gravi rischi ai danni dei consumatori.
Grazie a diversi progetti di ricerca (1) capaci di valutare la prevalenza, la base e i costi delle allergie alimentari molti dati sono stati acquisiti in materia.
Studi effettuati nel tempo hanno evidenziato come gli alimenti descritti quali responsabili di allergie alimentari siano stati oltre 120, ma effettivamente solo un numero ristretto di essi è stato valutato come capace di causare la maggior parte delle reazioni allergiche.
Ecco perché con la nuova normativa europea, entrata in vigore nel 2014, sono solo 14 gli allergeni per i quali esiste l’obbligo di indicazione in etichetta (2) nel caso essi vengano impiegati per la preparazione/produzione di un prodotto alimentare, sia a livello industriale che nelle attività di somministrazione e naturalmente nella ristorazione collettiva. Nel primo caso l’obbligo delle indicazioni è da riportare nell’elenco degli ingredienti, nel secondo caso le indicazioni sono da riportare nel menù del ristorante o sul quaderno degli ingredienti presente all’interno della struttura.

A seguito dell’adeguamento normativo sull’etichettatura, specificatamente agli allergeni, la Commissione europea ha rilasciato circa un anno fa una comunicazione [C (2017) 4864 final del 13.07.2017] con la quale l’organo europeo ha inteso coadiuvare imprese ed autorità nazionali nell’applicazione delle nuove prescrizioni del regolamento (UE) n. 1169/2011 relative all’indicazione della presenza di talune sostanze o prodotti che provocano allergie o intolleranze (articolo 9, paragrafo 1, lettera c), e allegato II del regolamento) sia per gli alimenti preimballati che per quelli non preimballati.

Nel documento che si compone di 5 punti:

  1. INTRODUZIONE
  2. ELENCO DEGLI ALLERGENI (ALLEGATO II DEL REGOLAMENTO (UE) N. 1169/2011)
  3. MODALITÀ DI FORNITURA DI INFORMAZIONI SUGLI ALLERGENI IN RELAZIONE AGLI ALIMENTI PREIMBALLATI (CON PARTICOLARE RIFERIMENTO ALL’ARTICOLO 21, LETTO IN COMBINATO DISPOSTO CON L’ARTICOLO 18 DEL REGOLAMENTO).
  4. INFORMAZIONI SUGLI ALLERGENI NEL CASO DEGLI ALIMENTI NON PREIMBALLATI
  5. AGGIORNAMENTO DELL’ALLEGATO II .

si ribadisce come con il Regolamento FIC si abbia l’obbligo di fornire sempre ai consumatori informazioni chiare in merito alla presenza degli allergeni, rammentando che gli Stati membri possono tuttavia adottare disposizioni nazionali concernenti i mezzi con i quali le informazioni sugli stessi debbano essere rese disponibili sui prodotti non preimballati, e stabilendo, al contrario, modalità con le quali le informazioni sugli allergeni debbano essere fornite sugli alimenti preimballati (articolo 21).

Nonostante la normativa dia indicazioni e specifiche, su come comportarsi, non sempre il lavoro degli Operatori del Settore Alimentare (OSA) sembrerebbe risultare di così facile applicazione. L’obbligo rivolto a tutto il comparto alimentare ha indotto, infatti in questi anni, gli operatori del settore ad impegnarsi per garantire la sicurezza dei propri prodotti, rispetto agli allergeni, non solo mediante l’utilizzo delle etichette quale informazione rivolta ai consumatori, ma soprattutto utilizzando sistemi di gestione della sicurezza alimentare quali Sistema HACCP, analisi dei rischi, punti critici di controllo, ecc..

Il rischio “allergeni” però si è riscontrato essere in diversi casi di difficile gestione rispetto alla presenza non intenzionale di tali sostanze, non riuscendo ad assicurare con assoluta certezza la produzione di alimenti a rischio zero. Ed è proprio per tale ragione che nelle etichette si trovano quasi sempre frasi cautelative quali “potrebbe contenere tracce di …” o “preparato in uno stabilimento che utilizza …”, frasi che i produttori inseriscono quasi a voler giustificare l’eventuale presenza di una sostanza potenzialmente pericolosa che non dovrebbe essere presente in quel contesto.

Il forte limite di una dicitura di questo tipo si basa fondamentalmente su alcuni fattori. In primis i produttori dimenticano che una dichiarazione cautelativa non può sostituire il sistema di gestione della sicurezza alimentare nella quale rientra pienamente anche il sistema di gestione del rischio, legato alla eventuale presenza degli allergeni. In secondo luogo il fatto che una simile scritta, riportata sull’etichetta di un prodotto, appare agli occhi del consumatore fuorviante in quanto lo stesso non è in grado di non comprende bene se il rischio di una contaminazione crociata dell’alimento con l’allergene sia avvenuto davvero o meno, non mettendo di conseguenza il consumatore in una condizione di assoluta chiarezza interpretativa (la stessa che la legge impone), ma ponendolo al contrario di fronte a una scelta difficile: non acquistare quel prodotto e tanti altri privandosi del piacere di gustare un alimento o decidere di acquistare comunque il prodotto, rischiando di imbattersi in una reazione allergica.

Infine, l’uso ingiustificato di etichette cautelative, al posto di un uso corretto delle stesse, si è visto come possa rischiare di provocare, proprio in virtù del messaggio fuorviante di cui sopra, l’eliminazione non necessaria di scelte sane dalla dieta da parte dei consumatori allergici o ancor peggio generare nel pensiero comune una riduzione della credibilità delle etichette con la conseguente assunzione di rischi nei confronti di tali alimenti da parte di consumatori vulnerabili.

 

Una soluzione dunque quale potrebbe essere?

Ad esempio l’inserimento da parte del legislatore di chiare indicazioni riguardo soglie di sicurezza, ossia l’indicazione di quantità minime tali da causare nei consumatori “vulnerabili” reazioni allergiche che, se ben precisate, rassicurerebbero il produttore su quali dichiarazioni sarebbe necessario inserire nelle etichette una volta superati i limiti percentuali previsti, invece di servirsi, come succede di questi tempi, di ambigue indicazioni cautelative.

Oltre ad essere di valido aiuto per i produttori la soglie di sicurezza sarebbero, naturalmente, di valido aiuto per le Autorità Competenti (aspetto non da poco) che nello svolgimento delle loro attività ispettive, grazie ad una chiara regolamentazione, avrebbero nei confronti di basse percentuali di allergeni riscontrate negli alimenti, atteggiamenti e reazioni armonizzate nell’intera Comunità Europea a differenza di ciò che oggi accade.

Per chi fosse interessato all’argomento si consiglia di approfondire la normativa e la comunicazione della Commissione europea del 13.07.2017

  • Uno degli studi più completo sugli allergeni, finanziato dalla Unione Europea, è stato lo studio EuroPrevall della durata di 4 anno, dal 2005 al 2009.

  • Allegato II del Regolamento UE 1169/2011.

© Produzione riservata

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Dr.ssa Sabina Rubini

Biologa ed Esperta in Sicurezza degli Alimenti

Consulente Aziendale

Co-founder ISQAlimenti.it

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