It is hard to believe that it is almost 10 years since the Food Information Regulations were introduced in December 2014. The laws introduced a new requirement for the labelling of foods, where all pre-packed foods must have clear allergen information emphasised on the ingredient list and non-packaged foods must have all the allergen information available for consumers.
Three years ago in October 2021, Natasha’s Law was introduced and all pre-packed food made on any catering businesses premises must have full ingredient and allergen information clearly emphasised.
Despite the introduction of laws, there is still a lack of understanding, misconceptions and myths surrounding allergies:
- “A little bit won’t harm you.”
- “If you are Gluten free, do you want the Vegan Menu.”
- “Chef said there is only a little bit of cheese on that dish, so you should be ok.”
- “The chips are cooked in very hot oil in the fryer, so everything is safe.”
The training across the industry is inconsistent and there is no legal requirement for a minimal level of training, whereas, for Food Hygiene training a minimum of Level 2 every three years is a requirement to work within the hospitality sector. Online training is easily accessible, but also easily forgotten. Allergen training is much more effective when staff attend a face-to-face training session, as in this situation they can ask questions, scenarios are explained, and practical exercises make the training memorable.
After 10 years we are sadly still reading about tragic deaths due to severe anaphylactic reactions and in most cases the reactions could have been avoided if communication between the staff member and the customer had been effective. Never assume and always check with the customer exactly which food they need to avoid.
In addition, communication between staff is vital. FOH staff must be confident to ask the Chefs about the suitability of the dishes on the menu and Chefs should discuss directly with the customer if there is any doubt. Sadly, in a busy restaurant situation conversation can be mis-interpreted and the wrong dish is served.
Owens Law is currently under review and may be introduced as another law to manage allergens within the hospitality sector. Following the tragic death of Owen Carey following an anaphylactic reaction to a buttermilk chicken burger, his family want Owens Law to ensure that more information is provided on restaurant menus. The grilled chicken breast that was a menu option on the Byron Burger menu failed to declare that the chicken was marinated in buttermilk.
By introducing Owens Law this would ensure that all ingredients are provided for each dish on the menu. From a practical perspective, this will be an onerous task for the restaurant but using QR codes and Apps would help to make this work in practice. Larger restaurants and restaurant chains will have the resources and budget to introduce this type of system, and some restaurants already do this, while smaller independent restaurants may find this difficult, and mistakes may be made.
Another issue that may arise if that customers may look through the detail on the QR code or app and make decisions about their choice of meal, they may not tell the restaurant staff that they have an allergy. The impact of this is that the chef will not be aware and therefore will not follow procedures of preparing the dish separately, using different knives and utensils and there is a substantial risk of cross contamination during the process.
It will be particularly important to continue with the dialogue with customers which is customary practice. The staff member will usually ask if anyone has any allergies, this will prompt the customer to state they have chosen a dish because they need to avoid a certain allergen.
It is difficult to think of any other laws which have been introduced which have caused so much discussion and confusion. The understanding of the law and food allergen management continues to cause Near Miss Incidents, Allergy reactions, Hospital admissions and Tragic Deaths.
Jacqui McPeake, JACS LTD on behalf of Allergen Accreditation
