The safety of food products is of critical importance to all businesses within their supply chain. It is also a topic that is fast-moving, complex and one of the most challenging aspects of manufacturing food or food ingredients.
By Mike Adams, Product Innovation Lead, Campden BRI
This article will consider some of the major food safety risks that the bakery industry is dealing with, and discuss some emerging risks and threats, which it is vital to be aware of. Each section will consider the risk, its root cause and the status of any mitigation strategies.
Acrylamide, 3-MCPD and GE
Acrylamide is produced by a particular reaction pathway within the Maillard reaction, which occurs between amino acids and reducing sugars within food when it reaches temperatures of 120oC – 165oC. It is an important reaction responsible for significant physical changes, such as the browning of foods, as well as the generation of a large number of different molecules responsible for flavor and aroma.
Whilst many of the resultant molecules are incredibly important, imparting the characteristic flavors to many bakery products, especially bread and cake crusts, biscuits and crackers, one molecule has been identified as particularly problematic.
Acrylamide is formed from the reaction of reducing sugars (such as glucose, fructose, lactose) and the amino acid asparagine. Acrylamide has been identified as a potential carcinogen and therefore steps to limit human exposure to it have been implemented across many territories.
In 2018, the EU Regulation (EU) 2017/2158 came into force that set a Benchmark Level (BML) of 350 parts per billion (ppb) of acrylamide in biscuits and cookies, with manufacturers required to apply practical steps during processing to achieve acrylamide levels that are ‘As Low As Reasonably Achievable’ (ALARA). The Regulation has been retained in the UK, however any further changes made on an EU level will not be automatically introduced in the UK.
Currently, products are still allowed to be marketed that have an acrylamide level above the BML, as long as they are using the ALARA principle to ensure the level is as low as possible, as well as reviewing mitigation strategies and demonstrating they are working to reduce the level.
Similar restrictions are in place in other territories, with Proposition 65 in California using a ‘No Significant Risk Level’ (NSRL) and a ‘Maximum Allowable Dose Level’ (MADL). In order to avoid a mandatory warning being printed on the product packaging, Proposition 65 states that the NSRL for acrylamide is 0.2 micrograms per day, so manufacturers are required to understand the typical consumption rates of their products, as well as the acrylamide level in their foods. At a national level in the US, the Food and Drug Administration (FDA) has released guidance for manufacturers on reducing acrylamide levels in foods.
There are several strategies to reduce acrylamide to ALARA and they are primarily a combination of reformulation and processing changes to reduce exposure to elevated temperatures for prolonged periods. Other strategies include the use of enzymes, as well as longer-term approaches involving changes to agricultural practices for key raw materials. Some of the most common mitigation strategies in the bakery are listed in Table 1.
One of the newest strategies on the market is the use of acrylamide-reducing yeast. Several manufacturers now offer a type of yeast that produces a significant level of asparaginase. This enzyme breaks down asparagine, which is the key amino acid in the Maillard reaction pathway that leads to acrylamide. While a number of enzyme preparations have been on the market since the 2000s, this recent innovation of utilizing yeast to produce the enzyme in-situ has the benefit of reducing the number of ingredients required, as well as potentially removing the need to include enzymes on ingredient declarations in territories where this is required.
3-MCPD (3-monochloropropane diol) is part of a group of related substances called 3-MCPD esters that are formed in foods and oils during both the production and refining of oils, as well as processing during food manufacturing.
GEs (glycidyl fatty acid esters) are formed in a similar way and a large proportion of these contaminants are produced during the refining process of oils. There are a number of actions that oil refiners have implemented, between 2010 and 2015, that have led to significant 50% reductions in GE, demonstrating that supply chain management plays a key role in mitigation strategies.
However, several products that contain fats or other lipids, or are fried as part of their manufacture, can generate 3-MCPD during processing. GEs tend to be generated at temperatures >200oC, so are not typically generated in significant levels during manufacture.
3-MCPD is considered potentially carcinogenic and has a tolerable daily intake (TDI) of 2 µg per kilogram of body weight per day. There is no legislation on levels in individual products, so manufacturers must assess the typical consumption of their product and whether levels of 3-MCPD are in line with this. Once the product is consumed, GEs are broken down by the digestive system and glycidol is released. Glycidol is considered carcinogenic and mutagenic, therefore intake via food should be as low as possible.
There are mandatory limits on the levels of 3-MCPD esters and GEs for some foodstuffs, such as soy sauce, hydrolyzed vegetable protein and infant foods, contained within Regulation (EC) No 1881/2006 (introduced via Regulation (EU) 2020/1322).
Mitigation of the formation of 3-MCPD varies considerably depending on the product and process. The focus for baked products such as biscuits is primarily on formulation, while fried product mitigations use a combination of reformulation and process adaptions. Chloride has been identified as a significant cause of elevated 3-MCPD levels, so the reduction or elimination of chloride from recipes can have a major impact. Oil temperature management when frying foods has a significant effect, with elevated temperatures (such as during temporary downtime) causing notable elevations in 3-MCPD levels.
It is worth undertaking a risk-based approach to both 3-MCPD and GEs, encompassing supply chain, formulation and manufacturing practices, with a comprehensive analysis of suppliers, ingredients, formulations and processes. You must ensure levels are known, risk factors are understood and mitigation strategies can be implemented if required.
Titanium Dioxide
Titanium dioxide was first approved for use as a food additive by the European Union in 1969. Its many technical attributes and benefits make it a versatile ingredient for the food industry:
+ Gives products, such as glitter, icing, dressings, white chocolate, panned confectionery and sauces, a brilliant white sheen that makes food look more appealing to consumers
+ Inert in the presence of other ingredients
+ Resistant to pH and temperature fluctuation
+ Capable of acting as an anti-caking agent
+ Can improve texture
The European Food Safety Authority (EFSA) undertook a review of the safety of titanium dioxide in 2016 and identified the need for new safety studies due to gaps in the understanding of the risks associated with its use.
In 2021, following additional research, EFSA updated its safety assessment of titanium dioxide to reflect that it can no longer be considered safe as a food additive. Following the publication of this report, the Commission Regulation (EU) 2022/63 was drafted and formally adopted, coming into force in the EU on 7 February 2022. The ban included a six-month transition period, meaning that foods produced containing titanium dioxide, in accordance with the rules applicable before this date, could continue to be produced and placed on the market until August 7, 2022, and sold through until the end of their shelf-life.
Mike Adams, Product Innovation Lead, Campden BRI
In the UK, the Committee on Toxicity published an Interim Position Paper which did not support EFSA’s opinion on titanium dioxide therefore at present the additive continues to be permitted in Great Britain while a further review is undertaken. Under the provisions of the Northern Ireland Protocol, however, the EU ban applies in Northern Ireland.
As previously discussed, titanium dioxide is a highly functional ingredient, used widely across bakery applications. Unfortunately, there are few solutions that offer similar levels of functionality, both in terms of quantity required and cost. In some applications, there are no solutions at all that offer similar functionality.
The method for replacing titanium dioxide depends on the matrix it is being used in, with very different methods required for each matrix. Table 2 lists some of the replacements and technologies that have been applied.
The starch and mineral-based solutions are widely available, with a number of proprietary toolboxes being developed by colorant suppliers, such as ADM and Sensient, as well as the availability of bulk commodity materials for use by manufacturers. Color management solutions exploit the physics of color and light, using blue or purple colors to ‘neutralize’ yellow shades and make products appear whiter or brighter. This is not the most effective strategy; but, it forms part of the toolbox for manufacturers.
Processing changes can also be used to help improve whiteness, especially in liquid and semi-solid products. Homogenized fat droplets within a water phase, such as milk or mayonnaise, are responsible for the white appearance of these products, due to fat micelles causing light to refract and scatter, therefore reflecting all light and appearing white. This phenomenon can be utilized to improve the whiteness of fat-containing products and the addition of a homogenization step during processing can help improve the whiteness of products. In addition, helpful new materials are constantly coming to market, such as ‘Bright White’ chocolate, which is a white chocolate that claims to be significantly less yellow than conventional white chocolate. This could possibly help reduce the reliance on titanium dioxide in product categories that use white chocolate.
Emerging risks
PFAS – polyfluoroalkyl substances
Governments around the world are currently trying to remove PFAS (polyfluoroalkyl substances) from the food supply, as well as the environment. A patchwork of new legislations in recent years has banned packaging products with PFAS and increased pressure on manufacturers to provide safe alternatives. In Europe, Denmark became the first country to ban PFAS in packaging, in July 2020. Together with four other European nations, they are proposing a joint REACH restriction to limit their manufacture and placing on the market, and around the world, non-governmental organizations are asking for a prohibition on PFAS in food packaging.
PFAS, also called per- and polyfluoroalkyl chemicals, are part of a class of about 9,000 fluorinated compounds. Due to their structure and properties, PFAS are widely used as they provide a non-stick barrier to fat and water. The compounds are therefore found in takeaway food packaging, microwavable bags, kitchen utensils and cookware.
Linked to a range of serious health problems, they are dubbed ‘forever chemicals’ because they don’t break down naturally and consequently toxic exposures continue even after the packaging is disposed of.
Consumers and some researchers fear that PFAS in food packaging can leach into food, which then provides an easy ingestion source for consumers.
The demand to ban PFAS from food packaging increases pressure on food packaging companies that need to quickly adapt in response. Under constrained timelines, companies must look for substitutes, undertake PFAS testing and R&D, and conduct due diligence in order to ensure that substitutes marketed as ‘PFAS-free’ are as described and are free from the thousands of compounds that make up the PFAS class of chemicals.
Food fraud
The risk of food fraud, although not emerging, is expected to see a resurgence due to supply chain issues and inflation. There have been a number of high-profile incidents in the past decade:
+ Substitution of horse meat into the beef supply chain
+ The use of melamine to increase the apparent protein content of milk
+ Multiple issues, both historical and ongoing, with olive oil and honey authenticity
+ Illegal dyes in spices
Not all of these present an immediate food safety risk. However, the very fact that a manufacturer may not know what is in the material they are purchasing presents a significant risk. While lab-based tests are available for many of the most common and well-known issues, such as illegal dyes, animal speciation and authenticity of olive oil and honey, there is huge scope for adulteration and substitution across the entire food supply chain which would be impossible to test for.
This risk, therefore, requires a combined mitigation approach, with the primary step being the development of Vulnerability Assessment and Critical Control Points (VACCP) and Threat Assessment and Critical Control Points (TACCP) plans, to consider vulnerabilities and threats respectively. These assessments will help identify where the most critical risks are and will assist in the development of procedures, tools, audits and testing regimes to identify and mitigate as many risks as is reasonably practicable.
As this article has shown, there are a wide variety of food safety hazards faced by the bakery industry, requiring a concerted effort to ensure that consumers’ health is protected. Government regulation has been shown to move quickly to legislate around levels and use of risk-linked substances, so it is more important than ever to ensure that manufacturers are aware of the risks and have mitigation strategies in place.
