In recent weeks, we have seen a worryingly high spike in allergen related client cases. These being both near misses and confirmed allergic reactions experienced by customers. Since the introduction of the Food Information Regulations in 2014, allergens have remained a hot topic and a major concern within the hospitality industry. Taking into consideration the ever-changing challenges and guest requests, it has never more important to ensure allergens are dealt with correctly following strict procedures.

At Food Alert, we want our clients to feel comfortable when dealing with allergen requests and know that they have taken every duty of care for their customers. This guidance has been written to ensure that you safely deal with allergy requests over the festive period and into the new year and beyond.

Understanding the Law around Allergens

The Food Information Regulations 2014 control how food businesses must legally give information to their customers about the food they produce, sell, and serve and the way this information is provided.

Furthermore, Important changes to allergy labelling of “prepacked for direct sale” (PPDS) food from 1 October 2021. Under ‘Natasha Law’ all food outlets in Great Britain have the duty to provide full ingredient lists on labelling PPDS food.

PPDS food is food that is packed by a food business, before being offered for sale by the same food business to the final consumer. Common foods are sandwiches, cakes, pies, and salads.

Staff issues and Temporary staff

Post COVID, the hospitality sector has seen a major shift in the availability and retention of staff. We are also in a period of seasonal work in which we see casual employees work through the holidays with a real possibility of not returning post new year. However, all the team must be aware of how to deal with allergens and requests, and this must from part of day one induction training.

New and inexperienced team members however are not best placed to deal with allergy requests, and we recommend that you create in house allergy experts that may be known as allergen advocates or champions, for both front and back of house who are dedicated to day-to-day allergen enquiries. These employees may be managers or other experienced staff who are fully conversant with the in-house allergy procedures and who receive additional or more frequent training and have an in depth understanding of the business allergens matrices. New, casual or seasonal staff can report to the advocates/champions who can deal with the orders rather than taking on the request themselves. Even though casual staff should have a basic understanding, they should not be left with the responsibility of dealing with requests. Remember just sharing the allergen matrix is not enough, you should go through the allergy request with the allergic person to make sure that they only order foods that are safe for them and the allergy champion should be responsible for communication with the back of house team and ensure that the correct order goes out to the customer.

Training

Training has always remained a key fundamental when ensuring due diligence, no matter the topic. It is vital that staff of all levels have some form of allergen awareness and understand the basic principles of what the legislation covers. Businesses can follow the below steps to create a more robust training policy –

• Ensure allergen awareness is part of your induction process for new starters
• Refresh training frequently and when menu’s change
• Create on the job allergen training which can be built into an employees’ job progression
• Ensure that all team members complete the FSA free allergen training
• Food Alert offer allergy training via their training partner https://www.foodalert.com/ihasco-referrals/
• Bespoke training to the operation of the business and how you manage allergen requests

Check, check and check again!

The way in which businesses provide allergen information to customers can vary. Some may ask at the beginning of service if they have allergy requests even prior to ordering, whereas other may put the onus back on the customer to advise them of their allergies via sign posting on their menus and menu boards etc. Whatever the method, it is important that the in-house procedures are followed, and orders are checked and verified to ensure the ingredient in question is not present. A conversation with the customer is always important and as above it is recommended that a manager or ‘allergy champion’ is involved in the order.

It should also be taken into consideration that not all customers are tech savvy or understand how an allergen matrix works. This may affect their ability when ordering a dish. Even though a business may demonstrate due diligence by providing accurate information, there is always a duty of care involved. Showing additional consideration will help with building confidence with the guest but also prevent allergy incidents.

Online orders

Special care needs to be considered when orders are done online or via apps. You must provide allergen information to customers when taking an order. This can be done orally (by phone) or in writing (through your website or a printed menu).

You should have a statement on your website to advise customers where they can obtain allergen information before they place their order. If you provide food via an external online ordering website, they may have their own requirements for providing allergen information to customers. Many businesses and delivery platforms recommend that where an allergy order is required that the customer should always call if they have an allergy.  It is important that the team know how to deal with such phone calls and always refer to the allergen matrices (even if they think they know the menu well).  Staff should be aware of how to communicate with the kitchen when specific allergy requirements are taken over the phone or online. Staff should have clear written allergen information to refer to, so that they can respond to allergy requests accurately.

Since the pandemic, almost 40% of the population order takeaway food through an app or online. Some 170,000 food businesses are registered on three of the biggest online platforms, Just Eat, Uber Eats and Deliveroo. These three online platforms, supported by the FSA, have developed a new Food Safety Charter which commits them to make sure businesses selling food through their platforms are registered with their Local Authority and meet a minimum standard under the Food Hygiene Rating Scheme (FHRS). The Charter also commits them to use their communication channels to businesses and customers to share FSA hygiene and safety information and support those with food hypersensitivities.

Substitutions

Due to ongoing global events, many food and drink supply chains have been affected resulting in businesses experiencing difficulties when trying to procure certain ingredients. Product substitutions, where a similar ingredient is changed for another has become the norm. This can have a detrimental effect on allergen control.

It may be that allergenic containing ingredients were not present in the offering before but are now with the substitution in place. Therefore, extra precaution should be taken, and all eventualities considered. How can you combat substitutions?

• Create an approved and trusted supply chain and ensure you have agreement with them on how to manage substitutions and allergens
• Strive to request ingredient substitutions are only made with products containing the same allergens as the original product
• If a substitution does contain an allergen, make sure that they are aware of the need to highlight this to you and how they will do this and then in turn ensure an amendment to your allergen matrices either as a temporary measure or as a permanent change
• Communicate the substitution with all staff both front and back of house before the start or the shift and ensure that managers and allergy advocates/champions know what ingredients have been substituted.
• Ensure the correct information is communicated with your guest when taking an order
• Remember having the correct certification is not a one-off exercise. You must make sure certificates are maintained and in date.  If suppliers fall short of your expectations, then you should act and delist them

Sauces and Dressing

Although dishes may be allergen free, additions such as sauces and dressings at the point of service may alter the requirement to includes the allergen in your matrices. It is important that all aspects of a dish and the process are scrutinised to identify a possible allergen entry. Recipes and specification should be rigorously followed and not altered at any stage. For example, dressing should not be applied as a ‘finishing touch’ unless this has been agreed as part of the menu.

Allergen Matrices

When creating an allergen matrix, it is important that the matrix is kept up to date and amended as and when required. All dishes as well as sauces and garnishes must be taken into consideration. A version number and revision date should be applied to the matrices, with the most up to date version being kept onsite. A copy should be accessible at all times, whether this be online or a printed version. Older versions should be removed from circulation to prevent confusion with staff and customers.

Finally, items which may contain allergens due to the manufacturing process or in house contamination when preparing foods should be clearly highlighted as they may still pose a risk depending on the severity of the guest’s allergy.

Free from’ foods

Free from’ foods are manufactured for a particular market of people who need to avoid certain foods to protect their health, or who to choose to do as part of a personal dietary regime.  They tend to use substitute ingredients, such as tapioca, rice or potato instead of gluten-containing flour (e.g., wheat), or soya, rice or coconut instead of milk

The assurance of ‘free from’ claims require a combination of strict supply standards to ensure all raw materials are free from the claimed allergen and on site, the strictest storage, handling, production and packing controls, to ensure complete segregation, with no risk of any cross-contact.

You must not rely on a ‘vegan’ logo and assume it will be free from milk, fish, crustacean, mollusc and/or egg food allergies – always check with manufacturers that the products are allergen free before making any claim.

The Food and Drink Federation Guidance advises that “the (potential) presence of inadvertent traces of non-vegan or non-vegetarian substances should not be an obstacle to labelling a product as vegan or vegetarian…as long as reasonable measures are taken to prevent contamination. The Vegan Society’s Vegan Trademark can also be applied to foods carrying a ‘may contain’ statement providing that there is robust evidence to show the risk of cross-contact has been effectively managed.”  It is essential that you ensure that customers are aware that vegan does not necessarily mean allergy free.

Practical Steps for Allergen Control

1. Menus

• Where possible, choose core ingredient items which are naturally free of allergens
• Buy in specialised items where possible, rather than making them onsite. For example, gluten free bread.
• A slimmed down menu helps to control allergens and the risk of cross contact
• Display notices advising customers to ask for information on allergens or signpost them to where this information is displayed

If you are not certain that you can control cross contact in your kitchen, and addition warning such as the below is recommended:

‘Some of our menu items contain nuts, gluten, and other allergens. Due to our cooking environment, there is a risk that traces of these may be in any other dish or food that we serve. We understand the dangers to those with severe allergies, so advise you to please speak to a member of staff who may be able to help you to make an alternative choices’

2. Delivery

• Always monitor the receiving of goods to check they match the specification, and that allergens are clearly listed
• If items containing allergens are damaged or open, the delivery should be rejected as this may present as a contamination risk
• If substitutions are received, ensure allergen information is available and a system is in place to communicate this with both front and back of house

3. Storage

• Ensure foods are labelled
• Allergenic containing ingredients should be stored separately, where possible
• Once opened, decant into a clearly labelled sealed container and store below other foods
• This is particularly important for dried goods such as flour, sesame and nuts and peanuts as the risks of contamination from these products is very high.

4. Cleaning

• An effective cleaning schedule must be followed, considering all areas where allergens are prepared and processed
• You should use dishwashers to clean equipment where possible and if not use a 2-sink method for washing up
• Before preparing allergen free dishes, a two-stage clean consisting of a detergent/sanitiser followed by a disinfectant/sanitiser should be applied, following the recommended concentration and contact times

5. Personal Hygiene

• Standards of personal hygiene should be maintained at all times, particularly hand washing using soap and paper hand towels to dry
• All protective clothing that has become contaminated with allergenic containing ingredients should be changed
• Use single use disposable aprons where possible when making allergy orders

6. Preparation

• To avoid cross contact, designate a particular area for the preparation of allergen free dishes or where this is not possible, ensure adequate cleaning is carried out between the preparation
• Some businesses use colour coded equipment for the preparation of allergen free dishes. This may include knives, chopping boards etc. However, there may be other cross contamination risks so there use must be carefully considered with strict procedures in place
• To assist with planning in the kitchen, for group and advanced bookings, you should ask your customers if they suffer from any food allergies and identify any dishes that they will not be able to eat. Ensure when the party arrives you reiterate the allergies and serve the correct food to those with the allergies

7. Cooking

• Use separate oil fryers where possible for example for gluten containing products and label to reduce the risk of cross contact
• Use designated cooking utensils where possible such as frying pans, tongs, and probes
• If you have fan ovens, cook allergen free dishes separately to prevent contact.
• Foods that are sold prepacked for direct sale (PPDS) must be fully labelled with allergens highlighted emphasised on the list of ingredients

8. Service

• Garnishes, drizzling oils, dessert toppings etc. can also contain allergenic ingredients and should be on the allergy matrix
• Ensure the correct dish is served to the customer – allergy flags, different coloured or shaped plates etc can help to distinguish allergy orders

9. Buffets

• If you offer food in the form of a buffet, you need to provide allergen information for each food item separately. You should not provide it for the buffet as a whole.
• You can provide this information by labelling the allergens contained in individual dishes, or by displaying a sign directing customers to ask staff for allergen information. This information must be visible, clearly legible and easily accessible to the customer
• Foods containing no allergenic ingredients must be sufficiently separated and easily distinguishable from food containing allergenic ingredient and displayed in a way to prevent any allergenic food contaminating it.
• Provide sufficient utensils to prevent cross contact and ensure they are easily distinguishable

10. Drinks

• Remember drinks can also contain allergens such as gluten, egg white, milk and sulphites. Drinks should be included in the allergy matrix.
• Coffee counters are busy places using shared equipment to prepare, store, and handle multiple ingredients. Shared utensils and steamer arms can all increase the risk for cross contact.
• Colour coded or labelled jugs for dairy milk alternatives etc. are required
• Purging coffee machine arms and wiping between alternative milks is essential
• But remember if an allergy is severe this may not be enough, and your menu should have allergy warnings to state this.

Food Alert will be providing more information, guidance and research on allergens in the new year including a review of our Food safety and HACCP documents, but key is that you have written, robust procedures that everyone is aware of and follows.  Even tiny amounts of allergens can result in severe reactions so communication with your customers and between front and back of house is key. Designating allergy advocates/ champions both front and back of house who have an in-depth knowledge of allergens and procedures will mean that the rest of the team will know who to refer to when allergen queries are made and will provide a reassuring dialogue with customers that have allergises that their allergies will be taken seriously.

Please do contact us of you require any more information or advice on allergy issues……

Useful links

Allergen guidance for food businesses | Food Standards Agency

FDF Guidance on ‘Allergen’-Free & Vegan claims