Allergen advice – the

Allergen

ADVICE

As of October 2021, all pre-packaged foods sold in foodservice outlets (that packed the food) will need to be labelled so that any allergens are clearly highlighted; the changing nature of the food business in recent times prompting businesses to act now.

ASSURED ADVICE FROM PAPA

A set of guidelines for labelling food to go products under the new Food Information regulations has been published by the Pizza Pasta & Italian Food Association (www.papa.org.uk - correct as of 13 May 2020).

These guidelines, which have Assured Advice status, have been designed to help member businesses comply with the regulations which in turn help operators to be able to provide more information to their consumers.

The Pizza Pasta & Italian Food Association agreed to take on a Statutory Primary Authority Role to represent its members and encourage consistent standards across the industry by providing Assured Advice on environmental health and trading standards issues.

Essentially, the Assured Advice Scheme means that issues directly aff ecting sandwich and food to go businesses can be dealt with consistently across the UK so that everyone is treated the same. By following the guidance PAPA produces under the scheme, all local enforcement offi cers (including environmental health and trading standards) must accept the procedures set out in that guidance.

On issues that aff ect the food to go industry as a whole, the Association will work with government agencies and its Primary Authority (Slough Borough Council) to produce and agree guidance for the industry which, once approved, becomes Assured Advice.

Under the Assured Advice scheme, this guidance must be respected by enforcement offi cers across the country and all members following that guidance are protected from being challenged on it. Furthermore, if members have any problems in relation to the advice, they can refer them to the Association who will take them up on their behalf.

The Labelling Guidelines that have been drawn up by the Association set out how current food labelling legislation should be applied by UK food to go businesses, and the scheme has the full backing of the Department of Business, Energy and Industrial Strategy (BEIS).

This guidance applies to the Food Information (Amendment)(England) Regulations 2019, and these guidelines apply to England only at this time (it is expected that the legislation will be replicated for the devolved nations in due course).

After 1 October 2021, all pre-packaged foods sold in foodservice outlets (that packed the food) will be required by law to be labelled with the name of the product and an ingredients list, with any allergens highlighted. This new legislation brings the foodservice sector closer in line with the requirements for packaged foods sold through retail outlets.

There are currently 14 allergens that are required by law to be listed, and these are ingredients which have been identifi ed as causing illness, allergic reactions and in some cases severe illness and occasionally death. • celery • cereals containing gluten – including wheat, rye, barley and oats • crustaceans – such as prawns, crabs and lobsters • eggs • fi sh • lupin • milk • molluscs – such as mussels and oysters • mustard • tree nuts – including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts • peanuts

• sesame seeds • soybeans • sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million)

THE REGULATIONS

The new regulations amend the Food Information Regulations 2014 (FIR) which requires food businesses to adhere to Regulation (EU) No. 1169/2011 and ensure that all mandatory food allergen information is accurate, available and easily accessible to their customers.

Currently, foodservice businesses are able to provide this information in a number of ways, including orally on request, but are not required to print it on labels. From 1 October 2021 all foods that are pre-packed (except those that are loose and packed at the request of the customer) must be labelled with the name of the product and an ingredients list with any allergens highlighted clearly – emphasised, usually in bold lettering.

DELIVERED FOOD

The new rules do not alter the requirements for food that is sold remotely, such as via deliveries. In this case, if the order is placed remotely, such as via a website or telephone, the information about allergens must be provided at the point of purchase as well as being available at the moment of delivery.

In the case of websites, customers should be provided with ingredients including allergen information at the point they make the decision and before payment is made. In this case the only information that needs to be provided is the list of allergens as there is no requirement for an ingredient list for foods sold by distant selling.

Where orders are placed over the telephone, those taking the orders should have information about allergens they can refer to and should ask every customer if they have any intolerances and inform them of any allergens that the products they are ordering may contain.

In both the above cases, if there is any risk of cross contamination, this should also be made clear to customers.

In addition, the regulations also require that information about ingredients and allergens must also be available at moment of delivery. This can be done by labelling the product, on a menu that is delivered with the product, verbally by those making the deliveries or by providing a telephone number on the packaging that customers can call for the information.

In all the above cases, care must be taken to ensure that the information provided is accurate and the allergen information must be clearly linked to the individual product it relates to.

Details of PAPA’s full Assured Advice on Allergen Labelling (revised May 2020) can be found at https://www.papa.org.uk/ index.php/assured-advice/701-assuredadvice-on-allergen-labelling

A NEW WAY OF OPERATING

Even before the re-opening date for the hospitality industry had been confirmed in the wake of Covid-19, food businesses up and down the country had been trying to prepare themselves for a new way of operating.

No-contact dining, pre-order, click and collect, and social distancing are all concepts that were almost unheard of just a few months ago, but these are fast becoming the new normal for many hospitality businesses now.

More and more food operators are either starting, or expanding, their takeaway offerings, making the ‘food to go’ market one of the success stories of lockdown. The adoption of technology has played a vital role in how a business communicates and interacts with its community and customers, allowing them to set themselves apart and thrive in the current landscape.

TRUST AND TRANSPARENCY

Many businesses have been quick to adopt new technologies to support social distancing, whether it’s using click and collect software to reduce queues at busy times or communicating allergen information with their customers.

If customers with food allergies can see allergy information with the touch of a button, they can make safer and better informed choices and will be more likely to purchase something. Trust and transparency are key to getting this right.

Even the largest food companies face challenges with complying consistently with existing legislation and providing the right level of information that customers want and that keeps them safe. Small operators with limited time and resource find this even more challenging. However, this will only get more challenging as legislation and enforcement tightens, and consumer expectations and the level of allergy sufferers rise.

Whilst most businesses have been quick to adapt with regards to social distancing, the underlying issues have not gone away. Legislation and enforcement tighten, and consumer expectations and level of allergy sufferers rise, and for the most part, it is still difficult for foodservice businesses to obtain and maintain complete and accurate food data (some still work from printed Excel sheets).

Food operators now have a huge choice of digital solutions to choose from to enable them to operate with minimal or no-contact, but many do not consider the level of detailed allergen and ingredient information required to meet existing and future legal obligations with regards to allergen communication, i.e. at point of order, and point of delivery or collection.

FOOD SAFETY

Despite some of the focus shifting onto social distancing and keeping Covid-19 at bay, food safety is just as important now as it has ever been. And although many new businesses may have pivoted to a takeaway model, they still need to follow the FSA’s guidelines with regards to communicating allergens.

The FSA’s guidance states that if food is sold online or over the phone, allergen information must be provided at two stages of the ordering process: • before the purchase of the food is completed - this could be on a website, or on a digital or printed menu or over the phone. • when the food is delivered - this can be an allergen sticker on the box or an enclosed copy of a menu containing allergens, or over the phone.

Alongside current legislation, from 1 October 2021 ‘Natasha’s Law’ will come into effect, requiring food businesses that sell pre-packed directly for sale (PPDS) foods to have to include product labels providing the full ingredients contained, with allergenic ingredients emphasised within it. This will certainly be a challenge for many operators who struggle to meet existing legislation.

SINGLE SOURCE SOLUTION

Helping to meet these challenges is Kafoodle - a full kitchen management system as well as a robust click and collect system providing foodservice businesses with an integrated single source solution that is invaluable now, but essential for the future, feel its creators.

Recipes are created using supplier ingredient data, and then the ‘brain’ behind Kafoodle Kitchen does all the hard work by calculating the nutritional values, assigning allergens, and generating compliance labels. It can even work out per-serving costs allowing the businesses to improve compliance and operational policies, whilst still keeping an eye on costs, say the company.

Have a change to a recipe or an updated ingredient? Then simply enter the new details into Kafoodle, and it will recalculate the nutritional values, update allergen information and have updated labels ready to print at the click of a button. The digital menus that customers see will also automatically update in real time, making sure that they are always getting the correct information at the point of purchase, point out Kafoodle.

As well as ‘does contain’ allergy warnings, food outlets should also be able to inform customers of any risks of cross-contamination, feel Kafoodle’s creators - i.e. where a menu item ‘may contain’ an allergen as a result of operational processes.

Kafoodle enables food businesses to track and communicate ‘may contains’ as well as ‘does contains’, allowing customers to make a more informed decision about what they eat depending on their specific sensitivity.

TAILORED

The powerful food preference filtering within Kafoodle’s digital menus also helps to reinforce the customer’s trust by allowing them to filter the menus based on their individual needs and requirements. By selecting an allergen to avoid, or dietary preference, or even down to individual nutritional values (calories, fat, salt etc), for example, the customer can fine-tune the menu to only show what is appropriate for a truly personal and safe customer experience.

Kafoodle works with a wide range of operators, including Pizza Pilgrims.

Kafoodle worked with the Metropolitan Pub Company (a division of Greene King) for the launch of their much anticipated click and collect service. Launched on 22 May (a Bank Holiday weekend), they saw an influx of orders over the first week which the Kafoodle system and the pubs themselves were able to handle expertly. The launch exceeded expectation and the planned roll-out to their wider estate has been brought forward; the chain is also expanding on their pub meals selection to also offer a grocery click and collect service for their local communities.

Kafoodle works with a wide range of customers, from small independent restaurants to national contract caterers and across hospitality, healthcare, education and corporate catering, supporting OCS, Havering Catering Service, Pizza Pilgrims, Kurbside Kitchen, Kalimera and The Vurger Co with all aspects of digital kitchen management and allergen control.

As a modular system, Kafoodle can be as streamlined or powerful as a business needs it to be. Starting with its Essentials package, for example, it can be set up in just a few hours and offers overnight payments (rather than weekly) so that the revenue can get to the business when it’s needed.

RENEWED FOCUS

Bureau Veritas says that it has been pressing food organisations to pay closer attention to accurate allergen labelling, especially as the coronavirus pandemic continues to impact the industry.

Jointly established by the International Accreditation Forum (IAF) and the International Laboratory Accreditation Cooperation (ILAC), World Accreditation Day (held on the 9 June this year) is a global initiative to raise awareness of the importance of accreditation. This year’s theme focused on how accreditation supports food safety, highlighting how it ensures competent and impartial inspection, certification and testing services in every part of local, national, and international food chains.

Accurate food allergen labelling has never been more important to ensuring food safety, feel Bureau Veritas, particularly as producers, takeaway restaurants and delivery services have seen a surge in demand during the recent coronavirus lockdown.

“This year’s World Accreditation Day and its focus on food safety came during a very challenging time for the food industry due to the ongoing coronavirus pandemic,” says Tracy Wain, food safety technical manager at Bureau Veritas.

“Hospitality closures forced many outlets to offer takeaway-only services for the first time during the lockdown, and they have also had to quickly develop new contact-free and cashless delivery and takeaway collection methods. As such, the way in which allergen information is given to customers may have had to change too.

“Meanwhile, food manufacturers are not only having to deal with supplychain disruptions, they are perhaps having to operate in a different way to ensure that social distancing can take place throughout the workplace.

“Amid these urgent priorities, not to be overlooked is the need for businesses to still ensure they are correctly labelling the 14 allergens set out by the Food Standard Agency’s (FSA) guidance, and as required by law. This is vital to bolstering the confidence of consumers, suppliers, purchasers, and specifiers in the quality and safety of food as well as maintaining accreditation.”

According to Bureau Veritas, the food industry has in any case been under increased pressure in recent years to provide accurate food allergen and ingredients labelling, and the coronavirus pandemic has only heightened this requirement.

“Consumers, the FSA and the government will expect this as the standard going forward. The good news is, with much of the industry already overhauling their operations and introducing new ways of working, now is the perfect time create, review and implement robust systems for food labelling, as ultimately, it could help to save lives,” adds Tracy Wain.

Bureau Veritas (www.bureauveritas. co.uk) offers a wide range of robust certification and compliance services aimed at the food sector, its health and safety team having recently released its ‘Restart Your Business’ service to help provide a voluntary, independent assessment of a firm’s Covid-19 readiness to re-open their business premises.

LABELLING SOLUTIONS

Early June saw the launch of a new comprehensive food labelling system – Allergen Checker - to help catering and hospitality businesses protect their customers who have food allergies.

Allergen Checker has been created by catering-industry experts based in York, and is an easy to use, online system which enables restaurants, cafés, pubs and other food outlets to easily identify and display all allergens and ingredients in their food products, say the company (www.allergenchecker.co.uk).

The launch is particularly aimed at the UK’s burgeoning takeaway industry, which is experiencing huge growth in the current Covid-19 crisis, with many food outlets having been forced to close during the pandemic and find new ways of reaching their customers.

Many thousands of takeaway food products are potentially being delivered to customers without full ingredient labels, potentially putting customers who suffer from food allergies at risk, claim Allergen Checker (in the UK, an

estimated 2 million people are living with a diagnosed food allergy, and 600,000 with coeliac disease, they also point out).

After signing up for the online tool, users can create their own virtual store cupboard, input ingredients, identify allergens and print customised full ingredient labels to attach to takeaway items, so customers know exactly what’s in the food they’ve ordered.

“As businesses emerge from the current Covid-19 lockdown, hundreds of new takeaway services are starting up. However, many businesses simply don’t have a system in place to display full ingredients lists on their food products. It’s just not something they have necessarily needed to think about until now,” says founder of Allergen Checker, Mark Morgan-Huntley.

“As someone who has worked in catering for many years, I wanted to find a solution to this challenge for businesses in the industry. We have specifically designed Allergen Checker to help conscientious caterers protect their customers who have food allergies and intolerances.”

Allergen Checker is a subscriptionbased service, costing less than £1 per day for unlimited ingredients labelling. The company says that it is also donating £10 per subscription to the Natasha Allergy Research Foundation, which funds vital research into food allergies.

NEVER MORE IMPORTANT

With changes in delivery and collection methods introduced as a result of Covid-19 and the increased requirement for a contact-free, socially distanced experience, the need for accurate allergen labelling has become even more important, stress labelling solution provider, Tri-Label.

“Until now food-to-go retailers have been required to hold a list of allergens behind the point of sale, but the foods themselves have not been required to carry labels and information on allergens, as it is assumed that the customer can speak with the person who made or packed the product for this information,” explains Tri-Label’s Alan Bryson.

“This led to people mistakenly thinking that the food does not contain any allergens. Face to face communication has no longer been an option as orders for home delivery or collection are being taken via websites or by phone. While there is plenty of advice out there for food businesses to ensure customers with allergies are identified, the failsafe remains accurate labelling.”

The importance of accurate allergen labelling came into sharp focus with the death of Natasha Ednan-Laperouse, on a flight in July 2016, following an allergic reaction to a baguette purchased shortly before at Heathrow Airport, and it was that tragedy which led to the introduction of stricter labelling regulations for prepackaged food, introduced in September 2019, and known as ‘Natasha’s Law’.

The new legislation, which applies to England, Wales and Northern Ireland, mandates full ingredient and allergen labelling on foods which are pre-packed for direct sale and comes into effect from October 2021. Before the Coronavirus crisis developed, the Food Standards Agency (FSA) was developing a working interpretation of the types of food to which the legislation applies, giving food businesses 18 months to prepare for the new requirements.

With the topic now reaching a larger audience through the national media, point out Tri-Label, and the recent anaphylactic shock storyline on popular soap opera Emmerdale which is watched by millions, the subject remains one of significant importance both to customers and the foodservice businesses and their employees.

The Chartered Institute of Environmental Health (CIEH) advises that for website and phone ordering, businesses must clearly communicate with customers and highlight any allergies or intolerances. These should then be communicated to kitchen staff to ensure the specific allergenic ingredient is avoided as well as ensuring food is prepared safely by avoiding cross contact. Allergy sufferer’s meals require clear labelling, identifying individual food items to avoid mistakes on delivery and unpacking by the customer.

“Not only does this mean that business owners or managers and their staff need training to ensure they are familiar with the full list of 14 allergens, but also that any recipe or menu change must result in a labelling review,” adds Alan Bryson. “CIEH also advises that during delivery, food prepared for allergenic customers should be stored separately to avoid any cross contact, but only accurate labelling can provide a failsafe on delivery and truly give consumers confidence.”

Tri-Label Online is a flexible, secure, easy-to-use, low-cost cloud-based software package which is updated every time there is a change in legislation; it can be accessed through a PC or Mac, using any internet browser, has unlimited capacity, and automatically backs-up data. The user is given unique login credentials to access their account, which can be linked to other users within the same organisation or setup in standalone mode.

The user inputs their ingredient constituent parts and nutritional information (Bloomer Bread – Wheat, Salt, Yeast, Water etc; Calories 100, Carbs 130 etc.) based on a 100g measurement (this information is sourced from the ingredient supplier). The user then inputs their recipe for each product by weight (Bloomer Bread 180g, Cheese 60g, Butter 5g). Tri-Label Online then automatically