On 13 December 2014 the EU Food Allergen Regulations (Food Information Regulations EU1169/2011) came into force. For many, this new legislation has caused extra work, incurred unwelcome costs and been perceived as confusing. The bottom line is, however, this is now law and failure to comply could be very costly. Liz Allan, director of Allergy Aware Kitchen, offers step-by-step advice to operators who may still be struggling with the new regulations
If you prepare and serve food for customers to eat straight away (this means restaurants, hotels, pubs, deli’s and catering companies, from the smallest chip van to the largest restaurant chain) the new regulations stipulate that you have to be able to provide your customer with information about the EU Top 14 allergens if they ask for it.
You are allowed to provide the information verbally, but because the regulations state that it has to be “verifiable”, it means that your information has to be “backed up” in writing somehow. It is crucial to be consistent; if different members of staff are asked the same question about the allergens in your dishes, everyone should each be able to answer the question with exactly the same information. This information needs to be sufficient to enable your customers to make an informed decision as to whether they want to eat in your outlet.
Dispelling the myth
Unfortunately we still have a long way to go before the vast majority of people fully understand what living with intolerances or allergies entails. Many perceive people with food allergies and intolerances in the way the vegetarians of the 1990s were perceived – a bit hippy and somewhat bizarre.
Please bear in mind that, unlike vegetarians (unless it’s for religious reasons), people with food allergies do not have a choice about eating certain foods. It is for them that these regulations have been introduced and for them that you need to be compliant.
Take your head out of the sand
Make sure that you read up on the regulations as much as you can. Just because your Environmental Health Officer wasn’t banging on your door on 14 December, this does not mean that they aren’t thinking about their next visit. Make sure you start learning about what you need to-do. It is even worth a phone call to speak to your EHO tomake sure that you are aware of anything specific they will want from you during their next visit.
Increase your knowledge
There is plenty of free information available on the Food Standards Agency website. The FSA also has a basic on-line Food Allergen Module, which gives you a few pointers towards what you need to know. I suggest that you expand on the FSA’s information in order to get a full knowledge base.
Learn about the EU Top 14 allergens
You need to know what the Top 14 allergens are (see page 24) and what their alternative names are; for example, Peanuts are also known as Groundnuts, Monkey Nuts and Goober Nuts while Sesame is also known as Anjoli.
Look at your menu
Start by using an Allergen Matrix (you can either download one from the FSA website or we can supply you with our own version) to help you build a picture of the allergens you use in your business on a daily basis. This will also give you a chance to highlight which allergens you do not use, for example would you use Lupin in any dishes? Lupin is unlikely to occur in the UK as it is used mostly in Eastern Europe, but do not rule it out until you have checked thoroughly.
Contact your suppliers
Suppliers have a duty of care to supply allergen information to you. All manufacturers, whether in the UK or overseas, have to abide by our laws. They have had to supply allergen information for a number of years. Since December 2014 they now have to supply it in bold font sothat it is easily recognisable.
Once you’ve checked all of your dishes for allergens, make sure that you write up your dishes and the allergens they contain. You do not need to give away your secrets, just the allergen information.
Keep your records updated
Make sure that your suppliers know to inform you about allergen changes in ingredients. A necessary action, but you also still need to check ingredients yourself to ensure nothing slips past you unnoticed.
Food Allergy Awareness training for all staff is key and this takes time.
Alarmingly, some training organisations are offering training that takes a mere 10 minutes. While this may sound attractive, it will be doing you no favours. It takes longer than 10 minutes to learn about Food Allergy, Food Intolerance, Coeliac Disease, Anaphylaxis and the Food Information Regulations. Do not be tempted to take the quick route to what you believe is compliance. If anything were to happen in your establishment and a quick scratch on the surface were to reveal non-compliance, you could probably have landed yourself in hot water.
Honesty is the only policy
You have to be honest with an allergic customer. If you do not know the answer to their question, make sure you find someone who does. Never tell anyone that something is safe when you don’t know, always find the person who knows the answer, whether that is a manager, chef or supervisor.
Tragically, only last month (January) an 18-year-old student in her first year at Manchester University died when she was given the wrong information about what her food contained. It is alleged that the young woman explained about her allergy and was incorrectly assured that the food was safe to eat – with tragic consequences.
Know Your Allergens
There are 14 major allergens that need to be declared when they are used as ingredients in a food. Any service provider should be able to provide information on which foods contain these allergenic ingredients. If a member of staff is unsure of the answer to a customer’s question, they must ask somebody who knows. This information must be accurate and verifiable.
|Cereals containing gluten namely wheat (such as spelt and Khorasan wheat), barley, rye and oats - these can be found in some types of baking powder, couscous, meat products, pasta, pastry, sauces, soups and fried foods that are dusted with flour||Nuts not to be mistaken with peanuts (which are actually a legume and grow underground), this ingredient refers to nuts that grow on trees such as almonds, hazelnuts, walnuts, pecan nuts, Brazil nuts, pistachio, Macadamia and cashew|
|Crustaceans such as crabs, lobster, prawns and scampi - watch out for shrimp paste that is often used in Thai and south-east Asian curries or salads||Celery this includes celery stalks, leaves, seeds and the root called celeriac. You can find celery in celery salt, salads, some meat products, soups and stock cubes|
|Eggs found in cakes, some meat products, mayonnaise, sauces, pastries and foods brushed or glazed with egg||Mustard found in breads, curries, marinades, meat products, salad dressings, sauces and soups|
|Fish found in some fish sauces, pizzas, relishes, salad dressings, stock cubes and Worcestershire sauce||Sesame often found in bread, houmous, tahini and always in sesame oil|
|Peanuts found in items such as biscuits, cakes, curries, desserts, sauces and groundnut oil||Sulphur dioxide or sulphites often used in dried fruit such as raisins, dried apricots and prunes. Can also be found in meat products, soft drinks, vegetables, wine and beer. People with asthma have a higher risk of developing a reaction to sulphur dioxide|
|Soya a staple ingredient in oriental food, soya is often found in bean curd, edamame beans, miso paste, textured soya protein, tofu, desserts, meat products, sauces and vegetarian products||Lupin found in some types of bread, pastries and pasta|
|Milk watch out for milk in powdered soups and sauces||Molluscs including mussels, land snails, squid and whelks, but can also be commonly found in oyster sauce and as an ingredient in fish stews|
Icons courtesy of the Food Standards Agency.
Further information and resources including chef cards, can be found on the Food Standard Agency’s website.
The British Hospitality Association’s website also contains useful information.