AOAC ISPAM Food Allergen WG Meeting Book (12-15-16)

AOAC ISPAM "Food Allergen" Working Group Questions/Comments Form

Submission Date

2016-12-09 14:10:08

First & Last Name

Melanie Downs

Organization

University of Nebraska-Lincoln

E-mail Address

mdowns2@unl.edu

Date Submitted

12-09-2016

Question/Comment-1

Title, Line 3; Section 2, Line 18: With respect to the use of both the words "chicken" and "whole", a bit more clarity in the intent would be beneficial.

By inserting "chicken" to describe the source of egg, it may unintentionally disqualify ELISA methods that detect chicken egg but also react with other bird eggs (e.g. duck, turkey, etc.). While the primary purpose of the methods would be to detect and quantify chicken egg, the SMPR should perhaps address what types and/or levels of cross- reactivity with other species will be acceptable. The use of "whole" may imply that egg white and egg yolk should be detected equivalently. Most methods, however, would primarily detect egg white proteins, even when whole dried egg is use as the method calibrant. It may be beneficial to discuss and describe the extent to which methods are required to detect egg yolk and egg white fractions independently. Section 4, Lines 38-40: In the Definitions section, it would be useful to give some thought as to whether definitions for both "allergens" and "commodities" are necessary. If "allergens" are to be defined as allergenic source foods (similar to how most regulations define food allergens), then a definition for commodities may create additional confusion. Section 4, Lines 76-78: The definition given in this section seems too specific to a particular product for the purposes of this SMPR. The definition given is that of refrigerated liquid whole eggs, as defined by the USDA FSIS. Given the complicated regulatory authority for eggs in the United States (i.e. the FDA regulates in shell eggs, while the USDA FSIS regulates egg products), it may be difficult to apply a regulatory definition of whole egg for the purposes of this SMPR. (The FDA also does not have a regulatory definition for "eggs", per 21 CFR 160.100.) It would be beneficial for this working group to agree upon a simple definition for egg that suits the purposes of the SMPR.

Question/Comment-2

Question/Comment-3