THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED

Transcription

1 DRAFT 2006 THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Voluntary Best Practice Guidance Key Considerations Date of Publication

2 FOREWORD We wish to acknowledge the valuable contributions made to this guidance by:- Anaphylaxis Campaign British Beer and Pub Association British Retail Consortium Coeliac UK Compass The Craft Guild of Chefs Gloucestershire Trading Standards Trading Standards Institute Whitbread 3663 (Catering Suppliers)

3 CONTENTS Page/s PART 1 INTRODUCTION Why is guidance needed? 3 Food Allergies and Food Intolerance What is the purpose of this guidance? 4 3. Who is the guidance aimed at? Where can I obtain further copies of this guidance? 5 PART 2 COMMON ADVICE FOR ALL BUSINESSES SELLING FOOD NON-PREPACKED Introduction 6 2. Effective Communication 6 10 What Practical Steps to be taken 7-9 Key messages Basic Training Allergen messages to be conveyed to new staff 11 Key messages Ingredient Information How do you sell your product 13 Making a food from a recipe 14 Bought in foods Accessing ingredient information Key messages Summary of Key Messages 19 PART 3 WORKED EXAMPLES FOR DIFFERENT TYPES OF FOOD BUSINESSES Sandwich Bars Bakery Restaurant (Carvery) Fast Food/Fixed Menus

4 5. Function Catering Different Cuisine Techniques APPENDICES APPENDIX I Contacts for further information about this Guidance 35 APPENDIX II Other Sources of Information

5 PART 1: INTRODUCTION 1. Why is this guidance needed? 1.1 Consumers with food allergy and coeliac disease need to know which foods they can safely consume. To help them do this, there are statutory labelling requirements for prepacked foods, requiring allergenic ingredients to be declared on the label. However, foods sold not prepacked, for example in restaurants, bakeries, deli counters or salad bars and foods that are sold prepacked for direct sale (foods that are generally wrapped on the same premises as they are sold, such as meat pies or sandwiches packed on site) are exempt from these requirements. It is therefore difficult for allergic consumers to know which allergenic ingredients are used in foods sold in these ways. 1.2 In these situations allergic consumers typically have to ask for information about these foods at the point of sale, or rely on any written information provided voluntarily by businesses. If the allergic consumer is given the wrong information, the consequences could be serious as they could become ill or could potentially die. 1.3 This guidance focuses on ingredients rather than cross-contamination, as most allergic reactions occur after someone has eaten a food that contains a deliberately added allergenic ingredient that they did not know was there. The Agency has produced guidance on allergen management aimed primarily at prepacked foods [link to guidance]. The principles set out in that guidance could also be used when preparing foods that are not prepacked. However, further examples of when cross-contamination should be considered are given in Parts 2 and 3. Food Allergies and Food Intolerance 1.4 It is important for all food businesses to be aware of food allergy and to take it seriously. This is because when someone eats a food they are allergic to, even the tiniest amount could potentially cause a very severe reaction, called anaphylaxis. In the UK about 10 people die every year from allergic reactions to food and many more end up in hospital. In most cases, the foods causing these reactions are those sold without a label, where declaration is not required by law. 1.5 Severe allergic reactions are relatively rare and most commonly caused by only a handful of foods. The following food allergens have been identified as public health concerns across Europe, however, some people may ask about other foods to which they are allergic and these should be treated with equal importance and in the same manner:- Peanuts (also called Ground nuts) 3

6 Nuts (almond, hazelnut, walnut, cashew, pecan nut, Brazil nut, pistachio nut, macadamia nut and Queensland nut) Fish Eggs Crustaceans Sesame seeds Milk Soybeans Celery Mustard Sulphur dioxide and Sulphites 1.6 Some people need to avoid certain foods because of coeliac disease, a life-long auto-immune disease caused by an intolerance to gluten. At least 1 in 100 people need to avoid gluten, a type of protein found in cereals. People with this disease need to avoid:- Cereals containing gluten - Wheat - Rye - Barley - Oats - Spelt - Kamut 2. What is the purpose of this guidance? The purpose of this guidance is to help establishments selling or providing non-prepacked food or food which is prepacked for direct sale to customers, become aware of the potential problems associated with food allergy and intolerance, and to provide best practice advice for them so that they can provide sufficient and accurate information to allergic customers should they be asked. This will help food allergic consumers by reducing the risk of them having a reaction and enable businesses to ensure that consumers can make fully informed choices about the foods they eat. 3. Who is the guidance aimed at? This voluntary guidance is relevant to all situations in which foods are being sold non-prepacked (un-wrapped) or prepacked for direct sale, whether in catering establishments or through retail outlets. The phrase food that is not prepacked will be used in this guidance to cover both these categories. The guidance is also relevant to businesses providing food in institutional catering operations, such as schools, hospitals, prisons, as well as where food is provided at corporate events, or conferences. It will also be a helpful guidance tool for enforcement authorities when advising all sizes of food businesses providing food that is not prepacked. However, the guidance should not be used as an enforcement tool. 4

7 4. Where can I obtain further copies of this guidance? This document is available from the Food Standards Agency website at [? ] and can also be obtained from [mailing house]. 5

8 PART 2: COMMON ADVICE FOR ALL BUSINESSES SELLING FOOD THAT IS NOT PREPACKED 1. Introduction 1.1 There are three key messages that apply to all businesses who sell or provide food that is not prepacked, in relation to the provision of information on allergens. These are:- Effective Communication (with the consumer, suppliers and between staff) Basic Training for staff Ingredient Information 2. Effective Communication 2.1 Effective communication between staff within a business, between staff and the consumer and between staff and their suppliers, is of paramount importance in ensuring that food allergic customers have accurate information. However, the consumer also has a responsibility to ask for information and relay their dietary needs themselves. Then they should make the ultimate decision on whether or not to purchase and consume a food based on the information they receive. 2.2 In the absence of food labels (i.e. food that is sold not prepacked), the allergic consumer is reliant on verbal communication with staff at the point of sale, or voluntary written information provided (for example on menus, display tickets or information boards), to find out about the ingredients of a food. Effective communication in these situations is therefore vital and could help to ensure that a consumer does not eat something that could potentially risk their life. 2.3 Businesses need to think carefully about how to handle such requests for information from a food allergic customer and how to ensure that their staff have access to the requested information if asked. It is therefore essential that if a member of staff is asked about the ingredients of a food by a food allergic consumer, they ensure that any information they choose to provide is full and accurate, or that if the information is not available they say so. If in doubt, staff should be advised to seek advice from another (more senior) member of staff before a response to the consumer is given. Where possible, some businesses may be able to appoint allergy experts among their staff (who ideally are available) at all times when the establishment is open) to whom requests for allergen information could be 6

9 directed. However, it would be necessary to ensure contingency plans are in place for when these members of staff are not available. 2.4 Where it is decided that adequate information about the allergen content of a food cannot be reliably obtained, staff must never guess as to the allergen content of foods. Instead they should advise the customer that they are unable to provide the information requested and cannot be sure that the food in question is free of the ingredient concerned. In such situations it may be possible for a special meal not containing that allergen to be prepared, particularly if the customer gives the business prior warning, e.g. it may be relatively easy for a restaurant to provide a salad without nut oil dressing (for someone who has advised they are allergic to nuts), or gluten free pasta with sauce, for someone who has coeliac disease. In these cases the business will need to consider any possibility of cross-contamination as well as ingredients used. 2.5 Customers may ask about the ingredient content of different food for all sorts of different reasons. For example:- to avoid certain ingredients for religious reasons; personal (dislike of a food); dietary or medical reasons; food intolerance or food allergy. The potential health consequences of a consumer eating a food they are allergic to are much greater than if someone just dislikes a food. Therefore, if staff are unsure, they should seek clarification from the customer as to the severity of their need to avoid a food ingredient. 2.6 It should be recognised that some customers may find it difficult to tell staff that they have a food allergy, and may feel awkward, not wanting to make a fuss. Businesses could therefore look at ways in which they could make it easier for customers to feel more comfortable about asking for information. This could be in the form of a poster, or a statement put on the menu, letting customers know that the establishment is happy to help with any specific request in relation to food allergies. What practical steps can be taken? 2.7 The following practical steps should be taken into consideration by a business when responding to customers with food allergies who ask about the ingredients in a food:- 7

10 Communication with the customer who asks for ingredients information If a customer asks about the ingredients of a food, the member of staff dealing with the query will need to decide who is the most appropriate person within the business to deal with it. - Does the business have a designated person to deal with allergy related requests? - If the member of staff approached is at all unsure how to deal with the query, then they should be advised to seek advice from another (more senior) member of staff who may be specifically trained in this area. - Staff should never guess about the ingredient content of foods. They need to know where to get the most accurate information. - If they are unable to give the information to the customer, they should say so. - If unable to provide the information, is there an alternative or could an allergen free food be specially prepared? The person dealing with the query/request will need to find out: - Whether the food in question contains the ingredient the customer asked about? - Is the member of staff able to speak to the person who prepared the food (e.g. the Chef) to ask them what ingredients they used? - Is full ingredient information of each product your business sells recorded and retained somewhere by the business that the customer could be referred to? Any information given to the customer should be accurate, but if in doubt, the customer should be advised accordingly. Staff should never guess and never advise that a product does not contain a particular ingredient, unless they are sure it does not. Staff preparing the food should advise the staff serving it of any recipe changes or substituted/new products. For example, in restaurants this could be done as part of pre-service meetings between the food preparation area and serving staff. Once a customer has indicated a food allergy, this information should be clearly communicated to the food preparation area and other members of staff in the restaurant/shop/canteen/food preparation area. - If the business provides seating areas for customers, these should be thoroughly clean and free from food residues. 8

11 If the customer has advised of their food allergy prior to visiting the establishment, then steps should be in place to ensure that front office staff relay this information to both restaurant and kitchen/food preparation staff. - Ensure the chef/person preparing the food has been told which allergens the customer needs to avoid. - The member of staff who will be serving the customer should be made aware that a specially prepared meal is to be served. If a customer has indicated a food allergy the food should not have been displayed with foods that contain ingredients to which they are allergic, due to the possibility of cross-contamination. - Also utensils and preparation surfaces should be clean. Things to be aware of Customers may not always make it clear that that they have a food allergy and staff may not always understand what the customer is asking for. - Ensure staff seek clarification in these situations and check whether the customer has an allergy or intolerance. Businesses need to ensure that staff understand the seriousness of food allergy and the importance of giving accurate information about the allergen content of food ingredients. Before responding to a customer request, serving staff must check with the staff preparing the food every time they are asked whether a dish contains a particular ingredient. The ingredients might have changed because of a new or altered recipe, changed suppliers, substituted products etc. Menu descriptions should be accurate, descriptive and kept up to date. - Where possible, allergens could be mentioned in the menu description e.g. coffee gateau with hazelnuts or risotto with cheese and breadcrumb topping. There needs to be an agreed procedure for dealing with food allergy related requests so that front-line staff know how to handle these and don t give wrong or incomplete information to the customer. - Could the customer be offered an alternative? 9

12 Key Messages from this Section If a customer asks you about the ingredients in a food:- - Never guess - If you don t know, try to find out - If you are unable to provide the information, say so - Can you provide an alternative food? Always ensure staff are advised of any recipe changes 10

13 3. Basic Training for Staff 3.1 All businesses will have different mechanisms and levels of resources for training their staff, depending on their size and nature. Larger businesses may have in-house training or the facility to send staff on external training courses to learn about food allergies and intolerances. These should be encouraged where possible. Medium sized and small businesses may rely predominantly on on-the-job training and training materials that are available free of charge from local councils or other providers (such as this guidance). 3.2 No matter what size of business you operate or what training support mechanisms you have adopted, it is important to ensure that, from their first day in the job, all staff receive sufficient training in relation to the issues of food allergy so that they know how to handle queries from food allergic customers should these arise. This should apply equally to permanent staff, as well as to contracted or temporary staff. 3.3 All staff, no matter how junior they are, should be made aware that food allergy issues must be taken seriously and they will, at the very least, need to know what they should do if they are approached for information by an allergic customer. Remember to be aware-: it is normally the front of house staff that will be most likely to have direct contact with food allergic customers and they will need adequate training; other staff such as those clearing tables may also come into contact with customers and should know how to help a food allergic customer; chefs and all those involved in preparing foods will also need to understand the importance of knowing what ingredients have been used in each food, so that they can make this information available to the consumer if asked. 3.4 There are three key allergen messages that should be conveyed to all staff from the first day of work. Allergy messages to be conveyed to new staff Food allergy issues must be taken seriously - The consequences of giving the wrong information to the consumer could make them ill or even kill them. Everyone will need to know the agreed practice for dealing with allergy information requests when received. - Some businesses may have a designated allergy trained member of staff and this is encouraged, where possible. 11

14 Members of staff should be urged to seek clarification from the consumer if they start asking about the ingredients in foods. Is it because they are food allergic? - Don t be afraid to check why the information is being sought. If not able to give the required information, say so. Never guess about the ingredient content of foods. Key Messages from this Section All staff should receive training on handling allergy requests from their first day in the job There should be an agreed practice for dealing with allergy information requests and all staff should know about this. 12

15 4. Ingredient Information 4.1 The important message here is that businesses need to ensure that information on the ingredient content of the foods they are selling is obtained, held and retained or is otherwise available so it can be relayed to a consumer who asks. Put simply, it is about knowing exactly what ingredients have gone into which foods. 4.2 Although foods that are sold not prepacked are exempt from providing most of the general labelling requirements, in many cases foods being supplied to businesses will be accompanied by full labelling information, including ingredients information. This could be on the packaging itself or on the documentation delivered alongside the goods. Retention of this information for foods you buy in is therefore a good way of making the information available to customers. 4.3 There are many different ways of retaining ingredient information about the foods you sell, and it is up to individual businesses to determine what approach is best for the size of business and their level of resources. The following list of questions should be considered for each of the foods you sell. This initial step will help to start the process of identifying ways of managing allergen ingredient information. How do you sell your product? Do you buy in the product already packed and sell in original wrapping e.g. packets of crisps? Do you buy the product and remove the packing and possibly process (i.e. cut up/slice into portions, reheat or cook) before offering for sale to the consumer e.g. ready made desserts or quiches, meat pies? Do you make it from your own recipe e.g. cakes, sandwiches, meals etc? Allergen information is required by law on the packaging Point the customer to this information. Allergen information will be on the packaging or on the documentation delivered with the food - Ensure this information is accessible. You should ensure that you have ingredients information for each component of the food. Ensure this information is accessible. 4.4 Having considered this initial step, you will then need to consider how you access your ingredient information. The following may help you with this:- 13

16 Type of Business Examples of how information may be accessed? Large retailers and catering chains - Electronic specification. - Head Office may hold information centrally. Restaurants, canteens, pubs and small retailers - On the packaging of ingredients used. Fast Food - Head Office - Documentation delivered with the goods. Small sandwich bars, coffee shops, hot dog stalls - On the packaging. Making a food from a recipe 4.5 If you make a food from your own recipe, you will be aware of the ingredients that went into it. But it is important to remember that you will need to think about each of the ingredients used and what they themselves contain. Be aware that even ingredients present in very small quantities as part of a compound ingredient (an ingredient within an ingredient) can be enough to cause an allergic reaction in a sensitive individual e.g. a flavouring in a sauce. You would also need to consider what you use: To cook the dish To thicken a sauce As a topping or garnish In a salad dressing or marinade Bought in foods 4.6 It is very important to check the ingredients of anything you buy in ready-made, such as desserts, fillings, pies, bread, sausages and sauces. You should not rely on what you think is in these products, because foods that can cause severe allergic reactions can turn up in products where you might not expect them. Please see the table of examples: 14

17 Food Possible Allergenic Ingredient Pesto Salad dressings Cakes & Desserts Stock cubes, gravy granules & sauces Cheese cake bases Burgers, sausages, cakes pastries & biscuits (amongst others) Vegetarian products (such as vegetarian mince) Coronation chicken filling Prawns Burgers & Sausages Worcestershire sauce Soy sauce English mustard powder Beers, lagers, stouts, ales Breads & Bread Rolls Peanuts or Nuts Unrefined Nut or Seed Oils (e.g. hazelnut, walnut or sesame) & mustard which can contain wheat flour Wheat flour contains gluten. Marzipan/frangipane are both made from almond Praline is made from hazelnuts Can contain a thickener containing gluten and also contain milk Contains gluten and can contain nuts to make them crunchier Can contain Soya flour Soya Can contain almonds or peanut Might contain sulphites Might contain gluten (in the rusk) Can contain fish or nuts & barley malt (gluten) Usually contains gluten Usually contains gluten (wheat) Usually contain gluten (barley) Normally contain gluten and can contain nuts or seed ingredients Indian Dishes Can be thickened with ground almonds or peanut flour, and may be garnished with chopped nuts. Greek & Turkish dishes such as houmous Chinese dishes often use Tofu Can contain tahini (made from sesame seeds This contains Soya 15

18 Accessing ingredient information 4.7 Businesses will need to think carefully about how to adopt their own practices for accessing ingredients information, based on their needs in terms of the size of the operation and available resources. The following list of key points may help with this process:- How to Keep and Access Allergy Information Keep a copy of the ingredient information on labels of prepacked foods e.g. sauces, desserts etc. Keep ingredients in the original containers where possible, or keep a copy of the labelling information in a central place (paper or electronic). - Remember to ensure that those who need to know are aware of where this information is stored and how it is kept. - Ensure that the information is kept up to date (for example, if recipes are changed or products substituted). - Large businesses may hold this information centrally i.e. a head office, in this instance staff will need to know who they should contact if ingredients information is required. - Suppliers can be contacted via their helplines for ingredient information. Always check deliveries to make sure what is delivered is what was ordered and ensure that the relevant labelling information is with the delivery ordered. - If it isn t, ask the supplier to provide this information. Check that the food delivered is the same brand that is normally used, as different brands might have different ingredients, and ensure that any records are updated accordingly. Look to see if the supplier has given information about any changes in ingredients of the foods delivered. If a food is delivered in bulk and then decanted into other containers, does the labelling information go with it? - Ensure these containers are clearly labelled (particularly in the case of peanuts, nuts, seeds and flour Things to be aware of Is the packaging intact? - Is the ingredients information missing, inaccurate or hard to read? Is the food which has been delivered the usual brand? 16

19 Staff will need to be aware if the ingredients of a food product have changed, e.g. if the usual brand has changed or the recipe has changed. Does the new recipe contain different allergenic ingredients? Small amounts of a food that can cause severe allergic reactions can get into other foods for example, if containers are not securely closed or when foods are being moved from storage into the kitchen. Is there an allergy advisory statement ( May contain ) on the label? Key Messages from this Section Know the ingredients in the foods you sell Make sure ingredients information is accessible to all staff and is up to date If you use part prepared ingredients, make sure you know what s in them 17

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21 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED SUMMARY OF THE KEY MESSAGES COMMUNICATION If a customer asks you about the ingredients in a food:- - Never guess - If you don t know, try to find out - If you are unable to provide the information, say so - Can you provide an alternative food? Always ensure staff are advised of any recipe changes BASIC TRAINING OF STAFF All staff should receive training on handling allergy requests from their first day in the job There should be an agreed practice for dealing with allergy information requests and all staff should know about this. INGREDIENT INFORMATION Know the ingredients in the foods you sell Make sure ingredients information is accessible to all staff and is up to date If you use part prepared ingredients, make sure you know what s in them 19

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23 PART 3: WORKED EXAMPLES FOR DIFFERENT TYPES OF FOOD BUSINESSES This section has been designed to provide you with practical guidance on how to provide accurate information on allergens in different business sectors selling foods that are not prepacked or prepacked for direct sale, when asked. The following does not cover every single sector, but represents some of the core types of business where foods are sold in this way. You will therefore need to consider your own case individually. This advice focuses on allergenic ingredients, but also highlights some examples of where cross-contamination may occur. 21

24 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 1: Sandwich Bars As a first step to being able to provide accurate information about the allergen content of your sandwiches, your business will need to consider the following core questions:- Core Questions Do you know what is in the foods you are selling? - ensure that you look at any recipes you are using. - consider if any of the 12 allergenic ingredients have been used in the preparation of the foods (see list of allergenic ingredients on page 3 of the background document). What do you do if an allergic customer asks for information about the composition of your sandwiches (or other similar food that you sell)? Does your business have an agreed practice for retaining information about the ingredients that go into your foods? e.g. a paper folder or a computer record. - this would include foods that you buy in, as well as foods you prepare from a recipe. Does the person selling the food know where to get information about the ingredients used? If you prepare fresh sandwiches to order and are asked by an allergic customer to prepare an allergen free sandwich, are the people serving the food aware of cross-contamination issues? You will then need to consider the range of foods you sell in determining their allergen content. The following example questions for a coronation chicken sandwich may help you with this process:- Points to consider Notes Have you made the sandwich from a recipe? or have you bought the sandwich from another supplier? - If the latter applies make sure you have the ingredient information from the supplier or look at the packaging or accompanying documentation. - Ensure this information is accessible. - If you make the sandwiches from a recipe, you will then need to consider the following further 22

25 questions. Do you know where the bread has come from? e.g. local bakery shop or supplier Do you know the ingredients of the bread? - If you change suppliers or brand names change, ensure that the labelling is re-checked, e.g. nuts, sesame seeds. Have you used a spread? Do you know its ingredients e.g. milk? Did you make the filling or buy it in? Do you have the ingredients information for the filling & does it contain any of the main allergens? - You should ensure that you have a list of ingredients used, e.g. recipes for coronation chicken can vary and some may include nuts or peanuts. - You should ensure that the ingredients are checked, particularly when you change suppliers, or brands are substituted. Do you have a menu in the sandwich bar? - If so, you may wish to consider making a clear reference to allergenic ingredients in the name of the sandwich e.g. Coronation chicken with almonds. - This could also apply if you package and label your sandwiches or have signs on the displays where the sandwiches are being sold. If you are asked to prepare a sandwich specifically for an allergic customer, are you aware of the potential problems of cross contamination? - You might need to open new ingredients e.g. a new tub of spread or filling or a new loaf of bread - Ensure that the surface is clean - Ensure that utensils are clean - Or you might need to say that you can t 23

26 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 2: Bakery As a first step to being able to provide accurate information about the allergen content of the foods you are selling at your bakery, your business will need to consider the following core questions:- Core Questions Do you know what is in the foods you are selling? - ensure that you look at any recipes you are using. - Consider if any of the 12 allergenic ingredients have been used in the preparation of the food (see list of allergenic ingredients on page 3 of the background document) What do you do if an allergic customer asks for information about the composition of the food you are selling in the bakery e.g. the cakes? Does your business have an agreed practice for retaining information about the ingredients that go into your foods e.g. a paper folder or a computer record? - This would include foods that you buy in as well as foods you prepare from a recipe. Do the staff serving in the bakery know where to get information about the ingredients used? If you prepare a cake/bakery product specifically for an allergic customer, are the people preparing/serving aware of crosscontamination issues? You will then need to consider the range of foods you are serving. The following example questions for a chocolate croissant may help you with this process:- Points to consider Notes Have you made the croissant from a recipe or have you bought it in from another supplier? - If the latter applies make sure you have the information for the supplier or look at the packaging or accompanying documentation. - Ensure this information is accessible. - If you make the croissant on the premises, 24

27 you will need to consider the following further questions. Do you know what ingredients are in the croissant pastry e.g. the pastry will contain butter (milk) and wheat flour (gluten); the pastry could also contain Soya flour? - You should ensure that you have a list of ingredients used. - You should also ensure that you keep any labelling information on the ingredients which are bought in and that these are regularly updated, particularly when you change suppliers, or brands are substituted. Do you know the ingredients of the chocolate filling e.g. does it contain hazelnuts or soya? - You should ensure that you have a list of ingredients used. - You should ensure that you keep any labelling information on the ingredients which are bought in and that these are regularly updated, particularly when you change suppliers, or brands are substituted. Is a glaze used and do you know the ingredients e.g. an egg glaze? - You should ensure that you have a list of ingredients used. - You should also need to ensure that you keep any labelling information on the ingredients which are bought in and that these are regularly updated, particularly when you change suppliers, or brands are substituted. Do you have the name of the chocolate croissant displayed? - If so, you may wish to consider making a clear reference to allergenic ingredients in the name of the croissant e.g. chocolate croissant with hazelnuts. Is the person selling the chocolate croissant aware of possible allergy crosscontamination issues? - If the croissant is served to the customer ensure that clean utensils are used (i.e. tongs. 25

28 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 3: Restaurant (Carvery) As a first step to being able to provide accurate information about the allergen content of the foods you are selling at your carvery, your business will need to consider the following core questions: Core Questions Do you know what is in the foods you are selling? - Ensure that you look at any recipes you are using. - Consider if any of the 12 allergenic ingredients have been used in the preparation of the foods (see list of allergenic ingredients on page 3 of the background document) What do you do if an allergic customer asks for information about the composition of the foods you are serving at the carvery e.g. the stuffing in a turkey roast? Does your business have an agreed practice for retaining information about the ingredients that go into your foods e.g. a paper folder or a computer record? - This would include foods that you buy in as well as foods you prepare from a recipe. Do the staff serving the foods from the carvery know where to get information about the ingredients used? If you prepare a meal specifically for an allergic customer, are the people preparing/serving the meal aware of cross-contamination issues? You will then need to consider the range of foods you are serving. The following example questions for a traditional Christmas turkey meal served from a carvery may help you with this process:- Points to consider Have you made all the foods making up the Christmas meal from a recipe or have they been bought from another supplier? - If the latter applies, make sure you have the ingredient information from the supplier or look at the packaging or accompanying documentation. - Ensure that this information is accessible. - If you make the foods on the premises, you should then need to consider the following further questions. How did you prepare the roast potatoes? Notes 26

29 - Were the roast potatoes bought in and do they have a coating? You should check the ingredients. - Ensure that you check what the potatoes were cooked in e.g. oil was it a nut oil and if so, was it refined nut oil (unrefined oils may cause allergic reactions) - Is flour used to coat the potatoes? This could be a problem for customers with coeliac disease. - Were the roast potatoes re-heated by deep frying them in oil and had the oil been previously used to cook battered foods, such as scampi or fish? How was the meat cooked? - Ensure that you check whether anything was added to the meat during the cooking process (e.g. spices, stuffing, basting, marinades) or whether any garnish was added after cooking. If a marinade was used for the meat, does this contain any allergenic ingredients? What ingredients are used to make the stuffing? - Does it contain breadcrumbs? - Does it contain nuts? What ingredients are used in the gravy or any sauces? - Were these thickened with flour? - Did you use stock cubes or gravy granules? How were the vegetables cooked? - If roasted, what oil were they cooked in? - Was any garnish added e.g. butter glaze, breadcrumbs, croutons or sauces (thickened with wheat flour)? Do you have the names of the foods you are serving at the carvery displayed or in a menu? - If so, you may wish to consider making a clear reference to allergenic ingredients in the name of the foods, e.g. roast turkey with a nut stuffing and buttered vegetables. Is the person serving at the carvery aware of possible allergen cross-contamination issues? - Ensure that a different serving implement is used for the stuffing (if nuts are used) and for 27

30 the meat. Display warning to allergic customers if some parts of the meal are self-service e.g. the vegetables. 28

31 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 4: Fast Food/Fixed Menus As a first step to being able to provide accurate information about the allergen content of the food you are selling at your establishment, your business will need to consider the following core questions:- Core Questions Do you know what is in the foods you are selling? - Ensure that you look at any recipes you are using. - Consider if any of the 12 allergenic ingredients have been used in the preparation of the food (see list of allergenic ingredients on page 3 of the background document). What do you do if an allergic customer asks for information about the composition of the foods you are selling e.g. a burger meal? Does your business have an agreed practice for retaining information about the ingredients that go into your foods e.g. a paper folder or a computer record? - This would include foods that you buy in as well as for any foods you prepare from a recipe. Do the staff serving the foods know where to get information about the ingredients used? If you prepare a meal specifically for an allergic customer, are the people preparing/serving the meal aware of cross-contamination issues? You will then need to consider the range of foods you are selling. The following example questions for a burger meal with fries may help you with this process: Questions to consider Have you made any of the foods which make up the burger meal from a recipe? or have you bought these foods in from another supplier e.g. the burger? - If the latter applies, make sure you have the information from the supplier or look at the packaging or accompanying documentation - Ensure this information is accessible. Do you know where the bun has come from e.g. local bakery shop or supplier? Do you know the ingredients of the bun e.g. does the bun have sesame seeds Notes 29

32 on it? Do you know the ingredients of the burger? - Note that burgers may contain wheat and rusk. - Eggs may be used to bind ingredients. Do you know the ingredients of the fried chicken? - Note that fried chicken may be coated with batter or breadcrumbs. - Eggs may be used to bind ingredients. Do you have a fixed supplier? Is there a possibility of product substitution? - Ensure that the ingredients of foods are checked, particularly when suppliers are changed, or brands are substituted, as new products may contain different ingredients. Does the meal contain mayonnaise, tomato sauce, relish, salad/garnish? Do you know the ingredients of the mayonnaise? Do you know the ingredients of the tomato sauce or relish? Is the salad coated in a dressing and do you know its ingredients? How do you cook the fries? - Are the fries coated with any allergenic ingredients e.g. wheat flour or milk? - Has the fat which is used to cook the fries, been used to cook anything else e.g. fish or foods coated in breadcrumbs (wheat flour) or a batter (egg, milk) e.g. scampi? Do you have a menu displayed in the restaurant? - If so, you may wish to consider making a clear reference to allergenic ingredients in the name of the food e.g. beef burger with salad in a sesame bun. Does the person selling the burger meal know where to get ingredients information should they be asked by a food allergic customer? - Some businesses may hold this information centrally (i.e. at a head office). 30

33 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 5: Function Catering As a first step to being able to provide accurate information about the allergen content of the foods you are providing/selling, your business will need to consider the following core questions: Core Questions Do you know what is in the foods your are providing? - Ensure that you look at any recipes you are using. - Consider if any of the 12 allergenic ingredients have been used in the preparation of the foods (see list of allergenic ingredients on page 3 of the Background document). What do you do if a food allergic customer asks for information about the composition of the foods you are providing/selling e.g. quiches on a buffet? Does your business have an agreed practice for retaining information about the ingredients that go into your foods e.g. a paper folder or a computer record? - This would include foods that you buy in as well as foods you prepare from a recipe. Do the staff serving the foods know where to get information about the ingredients used? If you prepare a meal specifically for an allergic customer, are the people preparing/serving the meal made aware of this and do they know about cross-contamination issues? You will then need to consider the range of foods you are serving. The following example questions relate to a Wedding reception buffet, which may help you with this process:- Points to consider Notes Have you made the foods you serve at Wedding receptions from a recipe or have you bought in the foods from another supplier? - If the latter applies, make sure you have the information from the supplier or look at the Packaging or accompanying documentation. - Ensure this information is accessible. 31

34 Do you have regular suppliers? Is it the usual brand? Have they supplied the foods you expected e.g. product substitution? - Ensure that the ingredients are checked, particularly when suppliers are changed, or brands are substituted. If you make the foods from a recipe, do you know what ingredients are used and do they contain any of the main allergens? - Ensure that you keep any labelling information for the ingredients used and ensure that this is kept up to date. Do the people serving the food at the Wedding Reception know where to get ingredients information if asked. - You could set up systems to ensure that you are aware of any food allergic guests prior to the Wedding, for example you could encourage the Wedding organiser to seek this information when sending out invitations. - Separate plates of selected foods could be prepared in advance for people with a particular allergy. You should ensure that these are clearly labelled and covered to prevent contamination. Are the people serving the food at the reception aware of possible crosscontamination? - Ensure that serving implements are cleaned or different serving implements are used for each type of food. 32

35 GUIDANCE ON THE PROVISION OF ALLERGEN INFORMATION FOR FOODS THAT ARE NOT PREPACKED Section 6: Different Cuisine Techniques It is recognised that there are many different cuisine techniques used when cooking foods. It is therefore important that in addition to looking at the composition of foods, you carefully look at the techniques you use to produce them. This will ensure that you are in the best position to be able to give the customer accurate information should you be asked. The following list of points may help you with this process:- Do you cook your foods in oil? - Could the oil itself present a risk to allergic customers? Most oils are refined, but some speciality oils may be unrefined and may cause allergic reactions e.g. sesame oil, walnut oil. - You should ensure that if you are asked to prepare a meal that does not contain a certain food, it is not cooked in the same oil that has already been used to cook other foods. For example, if the food is cooked in oil used to cook prawns, this could cause a reaction in someone who is allergic to shellfish or if the oil is used to cook foods with batter, the oil would be contaminated with gluten. - If you prepare a meal especially for a food allergic customer, ensure that the equipment used to cook the food e.g. the grill or frying pan is thoroughly cleaned. This is because very small particles of an allergen can cause a reaction in a sensitive person. Do you use peanut oil? - This could cause a severe reaction in a customer who is nut allergic. - You will need to ensure that if an allergic customer asks about the ingredients of a food, that you remember to advise them that the food was cooked in peanut oil. - If you prepare a meal especially for a nut allergic customer, ensure that you do not use peanut oil and that the equipment used to cook the food in e.g. a wok, is thoroughly cleaned. Do you use a common stockpot? - Ensure you are aware of the ingredients used in the stock are any of the 12 allergens used? - If allergenic ingredients are present, ensure you are aware of which foods the stock is used in. 33

36 Do you make sauces/gravy? - You should ensure that you know the ingredients of any sauces or gravy you make. For example peanut flour can be used for thickening and this could cause a severe reaction to a nut allergic customer. Wheat flour presents a problem for customers with coeliac disease, but cornflour or potato starch does not. - Be aware of adding water previously used to cook pasta or stock cubes containing gluten. - Make sure that if asked about the ingredients of foods, you advise the customer if peanut flour or wheat flour has been used to thicken a sauce. Do you use toppings or decorate the foods you sell? - You should ensure that you know the ingredients which are used in the toppings, for example cream could be used in a topping or nuts could be used to decorate a cheesecake do you know which types of nuts they are? - Croutons served in soup will contain wheat and may have been cooked in oil or deep-fried. Do you use salad dressings? - Make sure you know what allergenic ingredients have been used e.g. walnut oil, mayonnaise containing egg, mustard powder or soy sauce etc. Further points to consider when preparing and serving food:- If you have been asked to prepare a meal that does not contain a certain food:- - You might need to open new ingredients e.g. new jar of sauce. - You should ensure that worktops and all equipment used is thoroughly cleaned, including chopping boards, knives, food mixers, bowls, pans and utensils used for stirring and serving. - Ensure you don t cook the food in oil which has previously been used to cook other foods, for example fish. - Ensure that you do not use unrefined peanut oil for frying or peanut flour for thickening, when specifically preparing a meal for a nut allergic customer. If foods are displayed in self service areas:- - Ensure that when serving foods, different utensils are used for the allergenic foods and the non-allergenic foods. If a dish has already been prepared:- - Do not remove the allergenic ingredient from the food and re-serve the meal to the customer e.g. nut decoration from a gateau, as there could still be small amounts of the food in the dish and these are enough to trigger a severe allergic reaction in sensitive individuals. 34

37 APPENDIX I: Contacts for further information about this Guidance The address for all correspondence relating to the issues set out in this advice is: In England: In Wales: In Scotland: In Northern Ireland: Consumer Choice, Food Standards & Special Projects Division Food Standards Agency Aviation House 125 Kingsway London WC2B 6NH Tel: Fax: Food Standards Agency Wales 11 th Floor, Southgate House Wood Street Cardiff CF10 1EW Tel: Fax: / Food Standards Agency Scotland St Magnus House 6 th Floor 25 Guild Street Aberdeen AB11 6NJ Tel: Fax: Food Standards Agency Northern Ireland 10C Clarendon Road Belfast BT1 3BG Tel: Fax:

38 APPENDIX II: Other Sources of Information More detailed background information on Food Allergy & Intolerance and the legislative context & definitions is available at: [weblink to: FSA Voluntary Best Practice Guidance] A Summary document is also available at: [weblink to : FSA Introduction to Voluntary Best Practice Guidance] Food Standards Agency Safer Food Better Business Food Standards Agency Scotland CookSafe Food Safety Assurance System Food Standards Agency Northern Ireland Safe Catering Your Guide to HACCP Anaphylaxis Campaign PO Box 275 Farnborough Hampshire GU14 6SX Tel: Coeliac UK Suites A-D, Octagon Court, High Wycombe, Bucks HP11 2HS Tel : Fax : Helpline :

39 Institute of Food Science and Technology 5 Cambridge Court 210 Shepherd s Bush Road London W6 7NJ Tel: Fax: LACORS 10 Albert Embankment London SE1 7SP Tel: Fax: