In this chapter
- Understanding the challenge facing managers and supervisors
- Exploring what ‘allergen-free’ means at your premises
- Identifying the food journey in your premises
Getting the most from this course
This course is aimed at managers and supervisors of organisations or premises that produce and/or serve food to members of the public. It is particularly relevant to people tasked with managing the threat of food allergies and intolerances, and supervisory staff required to oversee the safe preparation and serving of allergen-free foods.
The course is also intended to help if required to develop a food allergy management plan, or alternatively to help you audit your existing food allergy and intolerance policy and processes. A blank planning proforma is included along with completed examples for a restaurant/takeaway and an Early Years setting. The Early Years example is also applicable to residential, health and care settings.
This is a Level 3 course aimed at Supervisors, Managers and others in responsible positions. It assumes you've already completed Level 2 (Food Allergy Awareness for Food Handlers and Servers) or have appropriate existing knowledge. We’ve included all the video content from the Level 2 course to help you refresh your knowledge; both courses follow the same chapter structure so it should be easy to recap as you study.
All information included in this course is offered as general guidance only. While significant effort has gone into making it as relevant, accurate, and as up-to-date as possible, the recommendations contained should not be applied without careful consideration and consultation with appropriate advisors, agencies and authorities. This course is audited by a Senior Environmental Health Officer.
So, what does it take to manage the issue of food allergies and intolerances in a food business/premises? The good news is it is not too complicated. At its simplest, you'll need to decide on what food products/dishes you're going to offer, document the ingredients you intend to use in each of these, and then identify any points in the food journey where your efforts to produce and serve allergen-free foods could go wrong (assuming you’re intending to offer at least one allergen-free dish). You then need to revise your processes, in other words change the way you prepare and serve food to reduce the risk of this happening, and finally communicate with customers about your use of allergenic ingredients using appropriate written and verbal communication.
Factors that should influence your plan
At this early stage in the course, we will concentrate on the type of premises and the type of food production or service you operate. The needs and characteristics of your customers will also influence your plan including whether they may be considered to be vulnerable. However, we’ll tackle this later, particularly during Chapter 7: Communication.
Factors that will influence your plan include:
The extent of your allergen-free claims
If you make claims in your policy and customer statement about the food you produce or serve being ‘allergen-free’ or ’produced in an allergen-free environment’, you'll need appropriate processes to deliver on those claims at every stage of the food journey in your premises.
The extent to which you are prepared to do more than the legal minimum.
At its simplest, the law requires you to put in place some basic communication, signage and documentation. There is no obligation to offer any allergen-free foods. You may choose to make greater efforts to accommodate allergy and intolerance sufferers in food choice, communication efforts, and safety precautions.
The way you package, sell and serve the food you produce.
The type of food business you run, for example manufacturer, restaurant or delivered takeaway, affects what you need to do to comply with the law. Whether the customer is present, and the timing of when you produce the food and package it also impact your response. The more ways you produce, serve and sell food, the more complex your food allergen management plan is likely to be, in order to keep your business legally compliant and low risk and customers safe.
A ‘simple’ example
Let’s consider the most straightforward scenario possible; you decide on a policy of NOT offering any allergen-free foods at all. Even in this scenario you may still have several practical measures you’ll need to put in place to be compliant depending on how you operate. Let’s explore these briefly.
If you're cooking food to order, you'll need a display signage requesting that customers with food allergies or intolerances speak to staff when ordering.
If you're producing food for later sale, e.g. preparing sandwiches for customers to select, you’ll need to include a full ingredients declaration on the packaging, highlighting any use of the 14 named allergenic ingredients.
If you take online orders, where the customer is not necessarily present, you'll also need to make allergen information available to the customer. We would also recommend you have a written customer statement available that describes your allergy policy. And even in this scenario staff will still need to be trained how to respond to allergy or ingredient questions and how best to explain your policy to avoid potentially dangerous miscommunication with the customer and between staff members.
During this course we’ll describe three practical business examples which you'll quickly become familiar with. These are a takeaway not offering any allergen-free foods, a restaurant and takeaway offering a few allergen-free dishes, and a cafe/deli offering an extensive range of allergen-free products sold and served in several ways.
These will help illustrate several ways of responding to and managing the threat of allergies and intolerances. They will highlight the most important considerations you’re likely to face and describe how each premises operator has interpreted the laws and the FSA (FSS) guidelines for their circumstances to arrive at their policy, processes and documentation.
Defining what ‘allergen-free’ means at your premises
If you're intending to develop a food allergy management plan for your premises during this course (see guidance and actions at the end of each chapter), it’s crucial that you fully understand the implications of defining what allergen-free means. Your food allergy policy and customer statement will need to clearly explain what allergen-free means in your business.
‘Allergen-free’ usually refers to a food product not containing a specific allergenic ingredient, rather than being free of all allergenic ingredients. Let’s consider making a claim in your customer statement that one or more of one of the foods you produce is ‘gluten-free’ and explore what this could mean and the risks involved in not accurately describing exactly what gluten-free means at your premises.
Firstly, some ingredients and food products that producers claim to be gluten-free are naturally gluten-free, while others that make this claim are actually foods that naturally contain gluten that have undergone processing to remove most (but usually not all) of the gluten they naturally contain. For this reason, you need to consider whether to label food as gluten-free when it is produced using gluten-removed ingredients. Why does this matter? Remember from the Level 2 course, for Coeliac disease sufferers even the tiniest traces of gluten can be harmful.
Secondly, claiming a product is ‘gluten-free’, and in fact any food as allergen-free should only refer to the fact that your business/premises has avoided the intentional use of that ingredient or in the case of gluten that protein. It’s possible your food products could still end up containing gluten (or other allergens) due to factors out of your control and therefore it would be unwise to claim products as categorically free of any specified allergenic ingredient with 100% certainty.
This is a really important point and it’s hopefully becoming clear that understanding and managing the details are vital to be able to communicate your policy and consistently deliver on its promises. To do this you'll need a premises food allergy management plan.
Developing your food allergy management plan
Every chapter of this course ends by considering recommended actions that will help you develop an effective food allergy management plan. The guidance that accompanies each step assumes that you're intending to offer one or more allergen-free foods.
The rules are a little complex and dependent on the way you produce and sell or serve food, but in general terms, if you're not considered to be a food manufacturer or PPDS retailer, potentially your only legal requirement may be to communicate if the food contains any of the 14 allergenic ingredients published by the Food Standards Authority.
However, many food allergies and intolerances exist that are not included in this list, and customers are still likely to suffer from, and seek information about the use of, allergenic ingredients not included in this list. For this reason, we recommend that you declare ALL ingredients used in ALL foods/dishes.
Our recommended premises plan requires the following steps:
- Step 1 - Detail the food journey in your premises
- Step 2 - Identify potential contamination events
- Step 3 - Document the use of ingredients
- Step 4 - Define food allergy policy and customer statement
- Step 5 - Design food preparation processes to prevent contamination events
- Step 6 - Identify packaging category/categories (labelling and signage)
- Step 7 - Design communication processes to prevent miscommunication events
Planning actions for this chapter
Step 1 - Describe the food journey in your premises
Every item of food you produce, sell, serve or deliver undergoes a journey in your premises. Typically, ingredients arrive from suppliers, might be decanted into appropriate containers and are placed into storage. Various food preparation tasks then take place, possibly including chilled or frozen storage in between, leading up to final cooking, reheating or assembly. Foods are then plated up, packaged or prepared for delivery, and eaten on your premises or delivered elsewhere.
In the next step (Step 2, covered at the end of Chapter 2) you’ll need to identify where or when contamination may potentially occur that results in an allergen in your allergen-free food. A complete start-to-finish view of the food journey is therefore vital in helping to ensure we can identify every potential Contamination Event (CE) in the next chapter.
Your practical actions for this step are to identify ALL the food storage, handling and processing undertaken for all foods and dishes. We’ve included a blank proforma and a completed example that features The Taj Mahal restaurant and takeaway, one of our featured case studies.
Two further completed examples are included with the blank proforma covering general food-service settings and care settings. Choose the most relevant one for your circumstances and refer to it at this stage in each chapter. Even if it is not your responsibility to develop a food allergy management plan, it's a useful learning exercise to consider the information and considerations raised in each chapter as they are applied to a documented premises plan.