Mondeleaks-a ‘position paper‘ from the giant Mondelez, which reached our newsroom-reveals serious anomalies in the management of the contamination of wheat flour and baked goods with the mustard allergen.
Connivance emerges, between large industrial groups and the Ministry of Health, to omit dutiful alert notifications on risky foods. And the latitude of European institutions deputed to analyze risk from cross-contact with food allergens is confirmed. (1)
1) Mustard in wheat, premise.
Widespread mustard contamination of wheat, semolina, flour, and derived products (pasta, bread, baked goods) has emerged in Italy since at least summer 2021. Although its causes-use of mustard as a fungicide and in green manure, as well as its intercropping with other crops-could go back several years, as it turned out. (2)
However, the news of the contamination, long known to operators, only emerged in November 2021. Through an alert notification, in the RASFF system, with essentially no follow-up. (3) Until, in December 2021, the Ministry of Health ordered the suspension of official controls and decided to handle the alert in ‘unusual’ ways. (4)
2) The hidden alert
‘The Irish point of contact‘ for the RASFF‘ – reads the Mondeleaks document, but not also on the RASFF public website (Rapid Alert System on Food and Feed) that the European Commission manages – ‘notified that wheat from southern European countries, particularly Italy, contain high levels of mustard and soybeans.’
However, the major players in the milling and pasta, confectionery and bakery sectors-as well as the Italian Ministry of Health-have been silent about the cross contamination they had precise knowledge of, which most likely involved tens of thousands of tons of food products. Before, during and after the European alert.
3) History
The history of the affair is precisely described in Mondeleaks:
- ‘September 2021. The Italian millers’ association(Italmopa) has notified all its members of the potential mustard contamination of durum and soft wheat, in their supply chains, from fields‘,
- ‘October 2021. This information was shared with stakeholders (including Unione Italiana Food, which is the association of bakery and pasta manufacturers) and, through suppliers, with customers.
Italmopa’sfinal recommendation to wheat flour manufacturers was to label mustard in wheat flour sold at retail and to provide information to B2B customers about occasional mustard contamination of wheat.’
4) Pactum sceleris
‘In October 2021 Unione Italiana Food started conversations with the Authorities and member companies,’ Mondeleaks further reads.
‘During one of the first meetings Barilla (a manufacturer of cookies but also pasta and owner of several mills) shared the overall results of its report: more than 40 percent of durum wheat samples and 15 percent of soft wheat samples tested positive for mustard.
They shared their intention to immediately label the (durum wheat) pasta with a warning of the presence of mustard, printing the information in inkjet in the shelf-life box on the package. They also said they see no urgency for cookies and crackers (soft wheat).’
5) Mondeleaks
The Mondelez plant in Capriata d’Orba (Alessandria, Italy) uses several suppliers of products, made from Italian wheat. Some of these ‘have already declared their intention to label mustard,’ according to Mondelez International’s ‘Position PaperMustard& Agricultural Comingling. In some cases, as a result of ‘positive results’ with PCR and ELISA testing methods.
Other wheat flour suppliers, while sharing the negative results of their mustard monitoring program, were reportedly warned by their customers to ‘positive results on wheat flour delivered from their mills. In the consumer database‘, reports the Research Fellow in Food Safety area of Mondelez Europe GmBH, UK
branch, ‘no cases of mustard reaction have been reported in at least the last 3 years.’
5.1) Mondelez, the big gamble
‘The highest concentration suspected mustard reported by the supplier of Mondelez wheat flour was 56 mg/kg. If this were used in a finished product composed of 83 percent wheat flour (the main product of the Mondelez plant in Capriata is GOLD Saiwa, with 83 percent wheat flour), a concentration of 46.48 mg/kg or 4.6mg/100g would be obtained. (5)
Considering data on the dose distribution of VITAL 3.0, (6) this could trigger reactions in 20% of mustard-allergic individuals.
From data provided by wheat flour supplier MDLZ‘, on the other hand, ‘thevast majority of wheat flour samples tested gave negative results for mustard (ELISA and PCR).’
The big gamble is therefore premeditated on a scientific basis. (6)
5.2) Public health hazards
The Mondelez Science Fellow clearly recalls allergic reactions to mustard. These include.
– ‘Angioedema, airway obstruction, hives, shortness of breath, vomiting immediately after exposure, and swelling of the lips, airway obstruction. As well as anaphylaxis, which requires emergency hospital intervention‘. (7)
– ‘These symptoms are considered moderate to severe (Brown, 2004). The other Canadian report was about a single case. A 50-year-old woman had a history of anaphylactic-type reactions after exposure to mustard (Connors et al., 2006)‘.
5.3) Omertà and opportunity
Omertà is the common thread of Mondeleaks. In defiance of its duties to immediately notify health authorities and consumers of unsafe foods, (3) Mondelez quietly decides what approach to take:
– ‘Risk assessment, supported by a program of analysis, or
– mustard labeling (due to new information from suppliers).’
The industrial giant does not think in terms of food security but in terms of opportunity:
– ‘risk assessment will require resources to perform the analysis, add complexity in managing warehouses and releases (of materials and products) in plants and/or at suppliers,
– labeling will require specification changes and a project to change (gradually) food labels,
– intermediate positions will be needed (e.g., statements, Internet information)‘.
6) Allergen risk management, public and private malfeasance
The Ministry of Health managed the food safety risk related to systemic mustard contamination of wheat by means that are not provided for in the General Food Law, as this writer has previously reported. (4) And the European Commission-by failing to coordinate the good work of member states in crisis management (1)-has tolerated this serious wrongdoing.
The Rome and Brussels malfeasance has thus stimulated further malfeasance, and as many risks for allergic consumers. As evidenced by what was noted in Mondeleaks on 25.1.22:
– ‘Mondelez factories and their suppliers that use Italian wheat flour are affected by the problem (mainly Italian factories, but some impact is expected in other countries as well)
– we do not expect sampling by the Authorities in the near future (until the validation of the analytical method is completed, about 6 months).’
The cat is not there and the mice are dancing.
7) Allergens, the great chaos in Europe.
The European Commission stubbornly fails in its duties to coordinate the analysis and management of public health risks associated with allergen cross-contact. (1) The writer, alongside European Food Allergy, has so far urged DG SANTE and the European Ombudsman in vain that EFSA also be asked to confirm the suitability of the Vital 3.0 risk analysis system to protect the health of allergic consumers.
The shameful starvation of the European Commission can in any case be overcome by EFSA itself. To which we renew our appeal, recalling its task of ‘promoting and coordinating the establishment of uniform methods of risk assessment in areas of its competence‘ such as the one under consideration. And it is in fact the Authority ‘the recipient of messages passing through the Early Warning System, the content of which it analyzes in order to provide the Commission and Member States with all the information necessary for risk analysis.’ (8)
7.1) Food security, the asymmetries in the EU.
The asymmetries in food safety protection that result from the lack of coordination of allergen risk analysis are well represented in Mondeleaks’ further notes, about the ‘potential long-term implications’.
– ‘This problem may spread to other EU countries, and suppliers may raise the same concerns. A discussion is underway in Spain, and one of the suppliers in Viana (Navarra, Soagna) has already asked to add mustard (and soybeans) to the Mondelez specification.
– The approach of authorities in member states may differ. For example, some EU countries might accept risk assessment and set an indicative value for chemicals. How to maintain consistency of labeling across the EU?
– The issue could also impact other categories (e.g., pasta used in meals). E Suppliers could challenge MDLZ specifications for soybean labeling as well (contamination from supply chain).’
8) Interim Conclusions.
The attached document serves to demonstrate the consequences of irresponsible management of food safety at all levels, public and private. The extremes are glimpsed:
– in Italy, for the investigation of an associative crime involving Ministry of Health executives (failure to report, omission of official acts, abuse of office, and trade in harmful food substances),
– in Europe for accountability and a vibrant protest against the treasonous bread-eaters at the top of DG Sante who continue to trample on the rights of allergic consumers.
Dario Dongo
Notes
(1) Dario Dongo. Allergens and RASFF, European blackout. GIFT (Great Italian Food Trade). 13.7.22
(2) Dario Dongo, Andrea Adelmo Della Penna. Mustard. Allergy prevalence, agricultural uses, contamination risks. GIFT (Great Italian Food Trade). 19.9.21
(3) Dario Dongo. Mustard alert in wheat. The reminder is dutiful and urgent. GIFT (Great Italian Food Trade). 22.11.21
(4) Dario Dongo. Mustard allergen alert in wheat, health ministry circular. Analysis. GIFT (Great Italian Food Trade). 17.12.21
(5) Giordano Panaro. Mondelez’s new ad: “In Capriata d’Orba strategic plant for ‘healthy ‘ cookie .” https://bit.ly/3BT2Mza Ovada online. 22.7.20
(6) Dario Dongo. Allergen risk analysis. FAO, WHO and ILSI Confirm Vital 3.0. GIFT (Great Italian Food Trade). 4.7.22
(7) Morisset, M., Moneret-Vautrin, D.-A., Maadi, F., Frémont, S., Guénard, L., Croizier, A. and Kanny, G. (2003). Prospective study of mustard allergy: first study with double-blind placebo-controlled food challenge trials (24 cases). Allergy, 58: 295-299. https://doi.org/10.1034/j.1398-9995.2003.00074.x
(8) Reg. EC 178/02, Art. 23.1.b and 35
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
