Revisiting Allergen Legislation
On 13 December 2014, the EU Food Information for Consumers Regulation came into force, requiring food businesses to provide accurate information regarding the presence of 14 allergens in the foods they provide, including non pre-packed foods. Three years on from the introduction of this legislation, Fiona Sinclair, director of food safety consultancy STS, takes a look at what progress has been made, and what more still needs to be done.
Overall a huge amount of work has been carried out across the industry in terms of food businesses collating information on the allergens contained within their menus, and putting in place or refining systems for handling allergy enquiries. However, we have found some disparity between the processes large companies have in place to help them comply with the legislation and those of smaller, independent businesses.
Allergies can be life threatening; just one small mistake can prove fatal.
Small businesses v large corporations
Most medium and large organisations now often go above and beyond what is legally required when it comes to allergens and, in this very competitive industry, having customer-friendly allergen information has become a selling point for some.
Unfortunately, we often find that smaller businesses have been slower to comply with the legislation. Some are addressing the requirements well, however even now there is a significant proportion that are not complying or simply doing the bare minimum to make sure that allergen information is available for their consumers. Some even say that they are still unaware of their responsibilities, despite it having been law for over three years.
There has been a shift in terms of allergy awareness among the food industry workforce, which can only be good news. Prior to, and immediately following the introduction of the regulations, there was a flurry of activity with food businesses training up their managers and raising allergy awareness among teams. Many companies have now incorporated allergen instruction into their induction process and e-learning training courses are commonly used.
It is still very important that we do not take our foot off the gas when it comes to deepening allergen knowledge across the industry.
Accurate allergen information should always go hand in hand with new product development.
One of the most significant challenges that operators have faced has been finding the time and resources to initially collate all their allergen information and get their systems set up.
It is common for food businesses to request allergen information for products from their suppliers and use that information to work from when collating theirs. Surprisingly, one of the common complaints we hear is that, while some suppliers are forthcoming with the information, others are not, adding to the challenge for caterers.
At all times accurate information must be available for the customer. Remember: the scope for human error is huge, so it is important to double or triple check information as a matter of course.
Many food businesses now have a policy not to accept substitutions at the point of delivery as this can alter the allergen information that is available at the point of sale or service. If substitute ingredients are accepted, then the business needs to ensure that they have a failsafe system in place to update any changes to the consumer allergen information.
Recipes and daily specials
Cracks in the provision of up-to-date allergen information quite commonly arise with the introduction of new products. Daily specials are sometimes introduced or new menus launched without the accompanying allergen information. Accurate allergen information should always go hand in hand with new product development.
Another aspect to safeguard against is recipe design and making sure that all chefs are preparing dishes to the same recipe. Basing recipes on loose verbal communication holds the potential for inaccuracies in the provision of allergen information. We would recommend that all businesses formalise and document their recipes, including specials, in order to avoid any confusion.
Even if a food business has systems in place to identify the allergenic ingredients contained within the dishes they serve, they are reliant on this being correctly communicated both between staff and to the customer.
When a customer with a food allergy places an order there should be a process to follow to make sure that they select an appropriate dish, the chefs are made aware to take necessary precautions when preparing the dish and the right dish goes to the right customer.
To ensure systems are consistently followed, they need to be as simple and straightforward as possible and clearly communicated to staff. We commonly find businesses adopting a ‘call the manager’ policy for allergy enquiries and safeguarding measures in place including written and verbal communication among front and back of house staff, and clearly identifying food that has been prepared for customers with food allergies on a specific type of plate or marking it with a label or flag.
Allergies can be life threatening; just one small mistake can prove fatal. Continued education and training are vitally important, as well as continuously evolving and streamlining the systems that are already in place. Now that the FIC legislation is over three years old, food businesses would be well advised to review and refresh their training and existing systems and take the time to refine them to ensure they are second to none.
If food handlers are educated on the seriousness of allergies, they are much more likely to take stock of and follow correct procedures at all times.
Established in 1986, leading food safety and health and safety consultancy STS provides specialist services for caterers, food retailers and suppliers. STS has strong links within the food industry, working as development partners for e-learning with the Chartered Institute of Environmental Health and as industry partners for ABT.
Beyond the 14 with software
While the EU allergen regulations require operators to provide customers with information on the top 14 allergens (the Annex II list), a recent survey found that 28% of those with an allergy were affected by a substance or ingredient outside of the 14 on the regulatory list. Mike Edmunds, Managing Director, Trade Interchange, urges operators to embrace technology to ensure safety for all.
In restaurants, both front-of-house and kitchen staff may be called upon to provide information about ingredients or ensure certain allergens are excluded from dishes. However, not all allergens are instantly recognisable, especially to those who are not directly involved in the preparation.
Trigger ingredients are varied and can include kiwis, strawberries, stone fruits, bananas, coconut, garlic, peas, lentils, citrus, chicken and many more. While not required by law, it is increasingly important for caterers to monitor for these substances, given the impact they can have on the customer’s dining experience.
Supplier Information Management software
To achieve a robust allergen provision, it is important operators track compliance within their supply chains – as well as in the kitchen. This means a raft of information needs to be collected, organised, continuously updated and communicated across the business.
The industry is increasingly turning to central data monitoring solutions, such as Supplier Information Management software (SIM), which is specifically designed to improve the way risks are managed.
Innovations in technology are enabling catering professionals to have visibility of the entire supply chain in a cost and time-effective manner. When it comes to allergens, a well-maintained and easy-to-use supplier management system can not only help businesses appeal to new customers and the market, it can also help to ensure a brand’s reputation and bottom line are protected.
Trade Interchange is a leading provider of supplier management software. For details on the company’s SIM software and ARCUS platform, visit www.tradeinterchange.com
The 14 Major Allergens
- 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