Allergen information for caterers in the UK
Food allergens are an increasingly reported issue with a recent report from Food Standards Agency highlighting that the most common foods that people reported having an adverse reaction to were cows’ milk and cows’ milk products (22%), cereals containing gluten (13%) and molluscs e.g. mussels, oysters (11%). Allergen information for caterers is primarily from their suppliers. This can be supplied on labels or in documentation accompanying the deliveries.
A prosecution brought in 2016 against Mohammed Zaman, the owner of several restaurants resulted in a sentence of 6 years after a man died from anaphylactic shock. The consumer had a nut allergy and had purchased a nut free curry. The owner had substituted an almond powder as cheaper ingredient. More recently, in 2018, an inquest into the death of Natasha Ednan-Laperouse in 2016 was widely covered in the media and the coroner was outspoken about the actions that Pret a Manger had not taken. However, Pret had adhered to the regulations regarding allergens, as the food is prepared on site. There are questions over whether Pret a Manger should have implemented more stringent information given the size of the business. The BBC Watchdog programme devoted yet more of their air time to this, focusing on coffee shops and restaurant chains as recently as 28th November 2018, and promising to return to this subject again soon.
What do the regulations say?
Regulation (EU) No 1169/2011 on the provision of food information to consumers brings together rules on general food labelling and nutrition labelling into one piece of legislation. Most of the legislation is concerned with pre packed food, sold at a different site to that where it is prepared. However, there is a requirement for catering establishments to provide information to the consumer if one of the allergens listed in the legislation is incorporated into food sold by the caterer, regardless of the size or nature of the business. This has been in place since December 2014. This can be done by a variety of methods, including signposting the consumer to where the information is held or annotating the menus.
Avoid Cross Contamination
Best practise can help a business on many levels; forward planning prevents costly mistakes before they happen:
- Plan ahead and prepare foods that contain allergens at a different time to those without, scheduling allergen free first after deep cleaning.
- Ensure that all staff wash their hands regularly
- Food containing allergens should be stored in dedicated containers solely used for this purpose. The containers should be sealable and easily identifiable and stored away from other food items
- Clean and sanitise all food contact surfaces, food containers and utensils before and after use
- Avoid spills and splattering while cooking, preparing and serving food
- Use separate cooking and serving utensils for each food item
- Where possible prepare food containing allergens in separate areas, or after foods not containing allergens
- Get staff to plan out how they would do this as they then take ownership of the best practice and are more likely to comply
Potential Bad Practice to Stamp Out
- Using a utensil from one dish to another without thoroughly washing it up first
- Making gluten free products in a kitchen with standard flour being used at the same time
- Touching an allergen [e.g. nuts] and then another dish before washing hands
- Touching taps with allergens on your hands and then not hygiening the tap
Managing customer enquiries
- Ensure you understand the consumers questions and concerns
- Answer all questions accurately – train your staff not to guess, but to check your handbook. Telling the consumer that you do not know and that you will check or find someone that does know the answer is not looking foolish, it is the highest standard of customer service, but only if your information is accurate.
- If necessary check recipes and ingredient labels
Other ways of preventing allergen consumption
Use a recipe management system & never change recipes or substitute ingredients, without updating the recipe information – this will help with your general business costings too
- Ensure decanted food is labelled with allergy information, and the date of decanting or use by date.
- Ensure that service teams are briefed by the head chef or manager daily
- Make sure that menu descriptions are complete and accurate
- Ensure that any food sold off site is fully labelled. There is more information at Food and Drink Labelling – Alimenti.
Recent Questions Received
Do not think that you are alone, many owners and managers of independent and small chains of coffee shops and restaurants who do not currently employ their own full time food technical manager are needlessly losing sleep. Here are some questions, with their answers, that Louise & Ruth have been receiving:
Q When producing for a buffet party, either on site or delivered off site how do we ensure the allergen information is available?
A For onsite buffets, signposting to information is currently acceptable and any information must be accurate. For off site buffets, labelling via product labels or via the menu or as an information card would be acceptable. (See https://www.food.gov.uk/business-guidance/allergen-information-for-different-business-types)
However, this is a subject that your Environmental Health team will be able to guide you on.
Q If producing for a meeting where everyone has pre-ordered do we need to put labels on each plate or pack?
A The information needs to be available to the consumer. This can be on labelled items or on documentation accompanying the delivery to the meeting.
Q Can you refuse to serve someone because you do not feel up to managing the risk?
A If you feel that this situation may arise, because you are uncomfortable with the potential risk, it is recommended that you review your processes and procedures to remove this barrier. You cannot discriminate against someone (see Citizen’s Advice)