FOOD ALLERGEN GUIDANCE PACK

FOOD ALLERGEN GUIDANCE PACK

SECTIONS 1. What is the legislation regarding food allergens? 2. Who will enforce this legislation? 3. Where do we start? 4. What is Food Intolerance? 5. What is Coeliac Disease? 6. What is a Food Allergy? 7. What is a major food allergen? 8. What are the rules for Pre- Packed Food? 9. What are the rules for loose foods? This guide is designed to inform and help you comply with the requirements of the Food Allergen aspect of the new Food Information Regulations 2014 (FIR) and to give guidance on other relevant legislation, ensuring that you keep customers with health related special diets safe. The guide includes; details of legislative requirements, key action points and practical advice for you to consider. These guidance notes can be used in conjunction with the TUCO Food Allergen presentation and the TUCO food allergen labelling guide to provide all of the key information to your colleagues. 10. How should we provide this information to our customers? 11. Managing the risk of cross- contamination of allergens? 12. The importance of communication 13. Key Action Point Summary

1. WHAT IS THE LEGISLATION REGARDING FOOD ALLERGENS? The Food Information Regulations 2014 (FIR) are the UK s domestic regulations that establish the enforcement measures for Regulation (EU) No 1169/2011 on the provision of food information to consumers (EU FIC) Since 13th December 2014, all caterers (known as Mass Caterers in the regulation guidance) have the mandatory responsibility under these regulations, of providing information on the 14 major allergens to their customers. You will find more information about this in Section 9 of this guide.

Continued... 1. WHAT IS THE LEGISLATION REGARDING FOOD ALLERGENS? This regulation has also made mandatory changes to the labelling of pre- packed foods from food manufacturers, including: The introduction a minimum font size on labels The need for any of the 14 major food allergens to be emphasised in the ingredients list The abolition of allergy advice boxes on food labels in order to avoid confusion You will find more information on this in Section 8 of this guide. You should also be aware that as of July 2016 this legislation also regulates the use of the term Gluten Free. The level of gluten allowed in gluten- free foods is still 20 parts per million or less, but there have been recent changes to the way that the statement no gluten- containing ingredients (NGCI) and other factual statements can be used. Since 20 July 2016 you cannot use NGCI against individual products or dishes. E.g. Descriptions such as Fish Pie: this dish has no gluten containing ingredients should not be used. However, food businesses can use NGCI in menus when listing a group of products/ dishes or in menu titles, to indicate that all the items in question do not have gluten- containing ingredients. E.g. No gluten containing ingredients menu or statements such as All dishes on this menu do not use gluten containing ingredients. Food businesses are expected to bring their menus into compliance by 20th February 2018. A good further source of information for gluten free terms is the Coeliac UK website: www.coeliac.org.uk that gives advice to food industry professionals. Caterers also have duties under The Food Safety Act 1990 to ensure that: Nothing is added to or removed from food or food is not treated in any way, which means it would be damaging to the health of people eating it Food served or sold is of the nature, substance or quality, which consumers would expect Food is labelled, advertised and presented in a way that is not false or misleading

2. WHO WILL ENFORCE THIS LEGISLATION? The Food Standards Agency has responsibility for food allergen policy. They work with local authority enforcement officers in trading standards and environmental health departments. 3. WHERE DO WE START? A good place to start is to gain an understanding of the impact of health related restricted diets on our customers. It is important that we understand the difference between Food Intolerances, Food Allergies and Coeliac disease and the consequences of accidental food allergen contamination for those people with these conditions. KEY ACTION POINT 1: Make sure that you understand your customer s condition and the consequences of accidental food allergen contamination for their health. The following section will help you:

4. WHAT IS FOOD INTOLERANCE? Food intolerance occurs when a person s gastrointestinal system is unable to digest certain foods. Unlike Food Allergies it is not an immune response that is triggered by food proteins. People can be intolerant to many different foods but most common food intolerances are lactose, wheat, eggs, alcohol, food additives and it is not unusual for sufferers to be intolerant to more than one food. Interestingly, in people of Chinese decent there is a much higher incidence of lactose intolerance than in those with a Northern European decent. Food intolerance sufferers have a slower reaction than food allergy sufferers; symptoms may appear several hours after eating the offending food, even into the next day. So you may not be informed that a customer has reacted until well after they have left your dining area. Although Food Intolerances are not life threatening, they can be very uncomfortable for the sufferer and result several days off of work or university. FOOD INTOLERANCE Symptoms Asthma Bloating Diarrhoea Fatigue Joint Pain Rashes Vomiting

5. WHAT IS COELIAC DISEASE? Coeliac disease is a disease of the autoimmune system, not a food intolerance or a food allergy. It is a hereditary condition in which the body s immune system reacts and makes antibodies when gluten is consumed. These antibodies then attack the healthy tissue lining the gut causing it to become inflamed; this causes some uncomfortable symptoms to appear within one to two hours and these may last for several days. Inside the gut are tiny villi whose job it is to absorb nutrients in food. In people with coeliac disease the villi become damaged as a result of eating gluten and eventually become flattened, meaning nutrients are not absorbed. Consequently, many of the symptoms associated with Coeliac disease are a result of malnutrition. This can have long- term effects, leading to other health issues such as anaemia, infertility and osteoporosis. Coeliacs also have an increased risk of developing bowel cancer. Gluten is found in wheat, barley and rye. Oats contain a very similar protein to gluten and some coeliacs cannot tolerate them. Gluten Appears as a hidden ingredient in many processed foods. Because of the many symptoms associated with Coeliac Disease, it can be difficult to diagnose, here are just a few of them: COELIAC DISEASE Symptoms Anxiety & Depression Bloating Constipation Diarrhoea Fatigue Infertility Mouth Ulcers Pain Skin Problems

6. WHAT IS A FOOD ALLERGY? Food allergy is caused when the sufferers body mistakenly identifies a food protein as a threat and makes an antibody to fight off the food. When the food is eaten again or sometimes when it comes into contact with the skin, it triggers an immune response where mast cells release chemicals into the blood stream, which include histamine. This causes various symptoms depending on where in the body they are released: IgE MAST CELL ANTIGEN HISTAMINE GASTRIC ACID SECRETION: abdominal pain, nausea, vomiting and diarrhoea BLOOD VESSELS TO DILATE: Light-headedness and fainting CONTRACTIOPN OF RESPIRATORY WAYS: Runny nose, wheezing, watering eyes, sneezing, coughing SKIN: Redness, swelling, irritation, rashes

The symptoms vary in degree and can occur very rapidly, appearing within seconds and only a tiny particle of the allergen is required to cause symptoms. In severe cases the reaction will lead to life threatening anaphylactic shock. Anaphylaxis can include symptoms appearing in different parts of the body at the same time, such as: Rashes Severe swelling of the lips, tongue and throat Wheeziness Loss of consciousness The most common food allergies in the UK are nuts and peanuts. Teenagers and young adults are at the greatest risk of death as a result of a food allergy as they are more likely to take risks and are becoming more independent. Often they don t remember how severe their last reaction was, as they have been kept safe within their family and away for the food allergen. As you can imagine, living with a food allergy is difficult and eating out can be very stressful. People with food allergies will need reassurance that the food you provide will be safe for them to eat. If you suspect that someone is suffering life threatening anaphylactic shock you must treat the situation as an emergency and call the emergency services immediately by dialling 999 or 112. In the UK around 10 people per year die as a result of eating a food allergen and there are around 1500 asthma deaths a year, some of which will have been triggered by a food allergen.

7. WHAT IS A MAJOR FOOD ALLERGEN? There are hundreds of ingredients that your customers could be allergic to, however the Food Information Regulations identify 14 Major allergens that are the most common ones found in Europe and these are the ones that must be identified on both pre- packed and loose foods. They are: CELERY CEREALS CONT. GLUTEN CRUSTACEANS EGGS FISH LUPIN MILK MOLLUSCS MUSTARD NUTS PEANUTS SESAME SEEDS SOYA SULPHUR DIOXIDE

As you can see the Food Standards Agency have devloped a symbol for each of the 14 major allergens which can be downloaded and used on your allergen management records, this provides an extra measure of clarity. Here is an example of how you might use them. KEY ACTION POINT 2: Know the 14 Major allergens and find out which of your pre-packed and loose foods contain them.

8. WHAT ARE THE RULES FOR PRE- PACKED FOOD? The term Pre- Packed Food refers to any food put into packaging before being offered for sale, for example a packet of biscuits, a sealed packed of crisps, a jar of sauce, a cereal bar or a can of soup. Under the food information regulations, food manufacturers must emphasise, on the ingredients label, any of the 14 major allergens or their derivatives that are used as an ingredient or in the processing of that product. You should also be able to find the information on any product specifications from your supplier. The allergen may appear on the label in bold type or CAPITAL LETTERS or in a different colour, as long as it stands out from the rest of the ingredients on the ingredients list. Allergy advice boxes have been eliminated, but you may see a box that explains where to find the allergy information, like this one: It is really important that all of our team members are aware of how to identify the allergens on pre- packed foods and you must consider the implications of those foods that are removed from their original packaging and stored for later use. How will you make sure that the major allergens are still labelled?

9. WHAT ARE THE RULES FOR LOOSE FOODS? It is mandatory for caterers to provide information on the presence of any of the 14 major allergens on all loose foods, also known as non-prepacked foods or foods that are prepacked for direct sale: NON- PREPACKED FOODS In a retail environment, this is likely to apply to foods which are sold loose from a delicatessen counter (e.g. cooked meats, cheeses, cooked sausage rolls, cooked samosas, pies and dips), fresh pizza, salad bars, bread sold in bakery shops, meat from butchers, pick and mix confectionery (including individually wrapped sweets and chocolates), etc. In a catering environment, this is likely to apply to foods that are not sold pre- packed but loose, for example meals served from a counter, served on a buffet or served in a restaurant, also foods that are packed on the sales premises at the consumer s request. For example: food from a takeaway outlet. PRE- PACKED FOODS FOR DIRECT SALE These are foods that have been packed on the same premises from which they are being sold. For a product to be considered pre- packed for direct sale it is expected that the customer is able to speak with the person who made or packed the product to ask about ingredients. Foods that could fall under this category could include; prepared salads, meat pies made on site and sandwiches made and packaged, perhaps in a central production unit and sold from the premises in which they are made.

10. HOW SHOULD WE PROVIDE THIS INFORMATION TO OUR CUSTOMERS? Under the Food Information Regulations caterers can provide the allergen information orally (verbally). If you are relying on this method there are some important points to consider: 1. It must be made very clear to the customer where they can find the information, or who speak to. Many caterers are using the sign template below, provided by the Food Standards Agency, to invite their customers to ask about ingredients of dishes. This could be placed in dining areas, on menus or websites and is available, along with lots of other useful food allergen resources here: https://www.food.gov.uk/business-industry/allergyguide/allergen- resources#toc- 3 KEY ACTION POINT 3: Decide which would be the best way for your operation to provide food allergen information to customers and ensure that it is accurate by regularly reviewing it. 2. Any allergen information given by catering staff must be accurate, consistent and verifiable upon challenge. So you must consider how you are going to ensure that this verbal information is correct: Is there a process in place to enable consistent information to be provided? Or refer queries to the nominated person(s) and/or Is verifiable ingredients information available to team members on a chart, recipe book, and ingredient information sheets or from a chef onsite? You could also present written food allergen information to your customer, e.g. via: Symbols on menus A chalkboard Allergen charts Separate allergen menus The information must be kept up to date especially if any changes are made to recipes.

11. MANAGING THE RISK OF CROSS- CONTAMINATION OF ALLERGENS Food Allergens are classed as a food safety Hazard along with physical, chemical and microbiological hazards and as such, the risk from them should be carefully considered in your HACCP process. Many of the cross-contamination control measures will involve the same processes as with other hazards e.g. handwashing. There are some key steps at which control measures should be implemented:

SUPPLY AND DELIVERY STORAGE GOODS MUST BE PURCHASED FROM REPUTABLE SUPPLIERS Your suppliers play an important part in making sure that you are giving the correct food allergen information to your customers and should be keeping you up to date with any changes in ingredients in the goods you are purchasing. CHECKS ON DELIVERY You will need to ensure that the goods delivered are exactly the brands that you have ordered. A different brand of the same product may contain different food allergens. (The same consideration needs to be made when making cash purchases, perhaps from local supermarkets, when you have run out of an item in your store room.) You should also check that all goods are fully labelled, that the packaging is intact and that there are no signs of spillage. SEPARATE THE MAJOR FOOD ALLERGENS Allergenic ingredients must not come into contact with non- allergenic ingredients so they should be stored separately and clearly labelled. KEEP THE ORIGINAL PACKAGE OF PRODUCTS so that the ingredients list can be read and any food allergens identified. TAKE CARE WITH LOOSE INGREDIENTS Keep unpacked allergenic foods in clearly labelled containers with tight fitting lids. TRAIN TEAM MEMBERS TO READ THE LABELS make sure everyone understands where to find the allergen information on labels and especially where hidden allergens may be found in processed foods.

PREPARATION Although a separate preparation area would be ideal, it is not always possible. So the following will help to reduce the risks of cross contamination of allergens in your kitchen. MENU AND RECIPE PLANNING review your menus and consider whether you could make simple ingredient changes to your dishes that would remove one or some of the 14 major allergens. E.g. by using stock that is gluten free, or substituting corn flour for wheat flour, or by not using egg glaze. EQUIPMENT AND UTENSILS You may want to consider having a separate set of utensils that are used for non- allergenic foods only. Thorough cleaning of equipment and utensils should be enough to reduce the risk of transfer of food allergens but you must ensure that all equipment is in good condition so that any food residues cannot build up. FOOD SURFACES Before preparing food for a customer with a special diet, thorough cleaning with single use disposable cloths should be carried out. PREPARE NON- ALLERGENIC FOODS FIRST some caterers find it useful to prepare foods for allergic customers before carrying out all of the other food preparation in order to minimise the risk. PERSONAL HYGIENE Hand washing after handling food allergens is important and food handlers need to be aware of any allergens on their uniforms. STICK TO STANDARDISED RECIPES be aware that any deviation from a standardised recipe may result in a change in the allergen content. If you are going to deviate from a recipe or create a new dish, you must ensure that everyone in the food service process is informed

COOKING SERVICE AND DISPLAY METHODS OF COOKING consider the cooking methods that you use and whether there is a possibility of crosscontamination of allergens in ovens, toasters, fryers, grills etc. and take action to separate the processes for nonallergenic foods. HEAT WILL NOT MAKE FOOD ALLERGENS DISAPPEAR there is a common misunderstanding that heating allergens to a sufficient temperature will kill off any signs of allergens. This is not the case. SEPARATE FOODS FOR ALLERGIC CUSTOMERS display allergen free foods in separate places and make sure all foods are covered and labelled. RESTRICT SELF- SERVICE be aware of the potential contamination risk from customers who are serving themselves. TRAIN YOUR SERVICE STAFF being fully trained will help your service staff to confidently deal with customers with special diets. It is important that they know where to find accurate allergen information and that above all they NEVER GUESS the ingredients of a dish when asked by a customer. NEVER REMOVE ALLERGENS FROM A PLATE AND RE- SERVE because just a tiny particle of a food allergen left on a plate can affect the allergy sufferer. BE AWARE ALLERGENS IN GARNISHES AND ACCOMPANIMENTS such as gravies, table sauces and salad dressings. KEY ACTION POINT 4: Include the control measures, you are implementing, for food allegens as part of your HACCP process.

12. THE IMPORTANCE OF COMMUNICATION Efficient record keeping will help to ensure that the Food allergen information that you give to your customers is correct. You will need to decide the best way to create, store and use the information for your operation. Some TUCO members are using menu management software to help with this. Effective communication between everyone involved in providing food is key to keeping your customers safe. This will include: Conference booking staff Suppliers Chefs Managers Team leaders Service staff KEY ACTION POINT 5: Train your team members so that they are confident when dealing with customers with special diets. Customers with special diets need to feel confident that you can provide them with food that is safe to eat and that you are giving them the correct information about the ingredients of your dishes. If you can do this well, they will be your most loyal customers. So make sure that you let them know what is available for them.

13. KEY ACTION POINT SUMMARY Every effort has been made to ensure that these guidance notes are as helpful as possible. However, it is ultimately the responsibility of the reader to ensure that their operation complies with the law. Businesses with specific queries may wish to seek the advice of their local authority. KEY ACTION POINT 1: Make sure that you understand your customer s condition and the consequences of accidental food allergen contamination for their health. KEY ACTION POINT 2: Know the 14 Major allergens and find out which of your pre-packed and loose foods contain them. Written and compiled by: Fiona Horne, Bowthornes Ltd for TUCO Ltd

KEY ACTION POINT 3: Decide which would be the best way for your operation to provide food allergen information to customers and ensure that it is accurate by regularly reviewing it. KEY ACTION POINT 4: Include the control measures, you are implementing, for food allegens as part of your HACCP process. KEY ACTION POINT 5: Train your team members so that they are confident when dealing with customers with special diets.

The University Caterers Organisation, 20 Dale Street, Manchester M1 1EZ Tel: 0161 713 3420 Web: www.tuco.ac.uk Email: info@tuco.ac.uk Twitter: @TUCOltd