How I Use the Allergen Management Template with Customers in Pilla

Scientific research has shown that the incidence of food allergies, food intolerances and coeliac disease has been increasing significantly over a number of recent years and it is predicted that within the next twenty years the prevalence of these conditions will affect great numbers of people. These people are our potential customers and the company has got a duty of care to protect these potential customers from harm.

In December 2014 new European legislation came into play, the food information regulations 2014.

Looking at the bigger picture over the whole of the European union, it was decided that the 14 foods/ingredients that cause 95% of all problems in the whole of the European union would be contained within the list.

*For the purposes of ease and not creating confusion, the following section will refer to all foods/ingredients that can cause harm i.e. Allergies, intolerances, sensitivities and coeliac disease as "allergens".*

It has become a legal requirement that food businesses declare specific allergens when they are used as ingredients in food that is sold. The purpose of the new legislation is to provide clear and accurate information about allergens in products so that it is easier for people affected by food allergies to make informed choices. This will include all meals that are served from your location and not just prepacked foods that are brought in by your company.

*Please note in regard to this section, that all other foods must be considered including bar and other food service areas, therefore all types of drinks including beers, wines, spirits, liquors, cocktails, also anything else served from the bar including complimentary snacks, crisps, biscuits etc.*

In addition to the need to declare allergens it is the responsibility of the food business to proactively signpost and encourage customers to declare their food allergies making us aware of their needs.

Secondly as part of hazard analysis, risk management and this FSMS it is the duty of the company to provide suitable and sufficient systems to control allergens at all stages including through the purchasing process, delivery and storage, preparation and service, customer information, staff information, training and supervision of all food handlers.

All food handlers including bar and service staff must follow the following safety points to ensure a consistent level of safety is achieved.

Supplier and specification

• In many cases a large company can specify supply and delivery of manufactured foods in order to avoid major and common allergens such as peanuts and tree-nuts, milk, eggs, crustaceans, gluten etc.
• All consideration should be taken at this stage as to whether some allergens can be avoided in order to avoid problems but also to make the menu more acceptable to more potential customers
• One example could be sauces and gravies that avoid gluten
• Suppliers must have a system in place where the food business can get quick accessible written information about the ingredients within the products including information regarding products that "may contain" an ingredient
• Suppliers must have agreements in place that when branded products have had changes to the recipe / ingredients list made to a supplied product then they have a robust system in place to inform the food business of these changes, these must be written and not verbal
• If a supplier supplies an alternative product to the one ordered, there must be a robust system in place to inform the food business that this is the case, new information given regarding recipe / ingredients must be written, not verbal

*Written consent includes email that has been confirmed as received by the food business.*

Delivery

• For many staff the first potential point of contact with foods that contain allergens is at the point of delivery. Staff must ensure that the delivery corresponds with the order that was placed ensuring that brands ordered have not been replaced with other brands without written consent
• Staff must ensure that contamination has not taken place within the delivery process by checking that packaging is intact and that no spillages have taken place onto other products, if this is the case inform a responsible person as the whole delivery may need to be rejected, especially if allergen contamination with major allergens has taken place
• Staff must ensure that all delivery items have correct and intact labelling. Items with missing labels must be rejected
• Staff must exercise diligence when moving delivered stock to the point of storage that no potential contamination can take place

Unboxing, decanting and storage

• Care must be taken during the unboxing process that product primary packaging is kept intact and that the product or the packaging does not act as a source of contamination
• Management and staff should consider where within the storage area that any of the 14 main allergens should be stored in relation to other products for the purposes of avoiding potential cross contamination
• If any of the 14 allergens are decanted into other containers, then all original information must be retained
• Containers that contain major allergens must not be washed then used for other foods / ingredients as the risk of cross contamination is too high. Dedicated containers must be used if decanted and disposed of if no longer required
• Every effort should be made that when storing major allergens such as nuts for example that they are stored on lower shelves to avoid risks from spillages
• Please consider some people are so sensitive to peanuts/tree nuts that even dust and microscopic particles have been known to trigger anaphylaxis. Some people are so sensitive to shellfish that vapours emanating from them have been known to set off an anaphylactic reaction
• Extreme care should be taken if a spillage occurs with any kind of major allergen. Wet cleaning is advised using disposable cloths which should be carefully discarded after a robust clean has taken place. Sweeping should be avoided to avoid making small particles airborne and thus cross contaminating further products

Allergen matrix

A requirement of the food information regulations 2014 is that the food business should compile a file or matrix detailing the ingredients within their menus and recipes, specifically detailing the presence of any of the main 14 allergens including the presence of items that "may contain" an allergen.

• This matrix will serve as a reference when customers ask about the presence of allergens in a meal/recipe. This must be maintained diligently by the senior chef and/or the executive chef in regard to any changes made to the recipe, the original ingredients or changes to products by suppliers
• Chefs must consider items that have been cooked in the same oil as another product as this item would now potentially contain allergens for other products cooked in the same oil. For example, a gluten free customer asking for some chips, which subsequently are cooked in the same oil as some fish with a batter having previously been cooked in the same fryer, the chips would now contain gluten
• For the above example, now the chips being offered would have to indicate the presence of gluten within the menu, the recipe and the allergen matrix
• If any condiments, sauces or sundries are provided on the table to the customer, the customer must be made aware of the presence of any of the 14 main allergens present within them, these should be indicated on the menu as well as within the allergen matrix
• An allergen matrix has been provided in your food safety compliance diary. If you choose to use another system, then ensure it covers all of the above points

Preparation

Note: Food preparation staff must understand that people can be allergic to almost any kind of food / ingredient as well as the main 14 allergens. All the following safety measures will need to be considered if we are informed by a customer that they have an allergy to something which is not one of the main 14 allergens.

• Chefs should consider making recipe sheets detailing all individual ingredients for the purposes of preparation of a meal involving an allergen which is not one of the main 14 allergens in order to avoid future problems
• Before preparation of an allergen free meal, all consideration should be given to where this will take place, it is advised that a dedicated worktop be allocated for this process. If a work surface cannot be dedicated permanently then a robust clean of a temporary surface must take place
• It should be noted that when cleaning a surface for allergen purposes, then the surface should undergo preliminary cleaning with a food grade degreaser/hard surface cleaner first before the use of the sanitizer. The most important issue being that food residues including proteins, oils, fats, starches, sugars are removed diligently, the risk coming from the food residue, of course the disinfection stage must also take place after this to ensure that pathogens are removed
• All equipment and utensils intended for use as part of the preparation must be considered, suitable and sufficient cleaning and disinfection must take place by the use of a well-maintained industrial grade dishwasher
• Persons involved in the preparation of the food must consider their clothing and whether it could be source of cross contamination, it is recommended that disposable aprons are worn to avoid contamination
• Staff should also consider what they may have eaten themselves at breaks in regard to major allergens e.g. Eating a snicker bar at lunchtime, then preparing a peanut free meal later
• Staff involved in the preparation of an allergen free food must wash their hands robustly before and after the handling of these foods/ingredients. Note: alcohol gel will not work as food residues must be removed from the skin by soap and water
• Consideration should be given to any cloths used whilst preparing allergen free food, these should be single use and throw away
• Consideration must be given to where the waste products from allergen free preparation will go, it is advised that waste bins are dedicated and that they are close to where the preparation is taking place and that they are emptied regularly
• Food preparation staff must not deviate from fixed recipes, adding in extra ingredients that are not contained within the information in the allergen matrix

Service

• All service staff including bar staff must undergo allergen awareness training, also managers and supervisors should undergo allergen management training to ensure control measures are being maintained and adhered to diligently
• Food service staff should ensure that allergen free meals are served separately from other meals
• Service staff taking food orders must ensure that any allergen information is communicated clearly to food preparation staff, as many mistakes have occurred in the past during this stage. If a member of service staff is unsure about anything, they must refer the query to a manager or supervisor who has the required levels of knowledge to deal with the query
• Staff must never tell or promise a customer anything that they do not understand properly, they must get assistance from a manager or supervisor who has the relevant knowledge to deal with the customer
• Communication between service staff and kitchen staff is absolutely critical, it must be robust and clear at all times. It is an offence under food hygiene laws to give inaccurate or incomplete information to a customer and can lead to prosecution
• If any condiments, sauces or sundries are provided on the table to the customer, the customer must be made aware of the presence of any of the 14 main allergens present within them, these should be indicated on the menu as well as within the allergen matrix
• Service staff must be trained and made aware that sundry items can sometimes contain allergens. For example, a gluten free customer being served a complimentary chocolate or biscuit with a coffee after the main meal has been consumed

Agency staff and outside caterers

• Management must ensure that outside caterers can prove that they have suitable and sufficient control measures in place in regard to allergen control and management
• Risk assessments must be provided by outside catering operations detailing all measures taken to prevent, control and mitigate risks from allergens. They must also be able to prove that their staff have undergone robust allergen management and awareness training and can provide an allergen matrix detailing all potential food allergens contained within their offering
• Temporary and agency staff must be able to prove that they have adequate knowledge and have undergone allergen training before handling food

Record keeping

• Record any rejected deliveries or items rejected because of allergen controls not adequate
• Allergen matrix must be kept up to date and amended or edited when required
• Any amendments/edits to allergen matrix has been communicated to all staff, record this
• Allergen training records for all staff recorded including any retraining
• Any allergen incidents regarding customers recorded
• Recipe sheets/menus recorded, any changes communicated and recorded
• Record any food discarded because of cross contamination or breach of allergen controls

Corrective actions

• Reject deliveries or items that breach allergen controls
• Discard foods that have been cross contaminated with allergens
• Retrain staff if allergen controls are breached and provide extra supervision until competency is shown

Allergen information

Cereals that contain gluten - The reason why this has been included in the 14 "allergens" is mainly for the purpose of protecting people who have coeliac disease, which is an auto immune disease, where the gastrointestinal tract is damaged by the presence of gluten. Wheat allergy itself is relatively rare. Although wheat itself contains the protein gluten, other common grains also contain gluten. The following grains, barley, rye, triticale, oats and all wheat varieties, some of which are hybrid and ancient varieties of wheat all contain gluten such as spelt, kamut, khorasan, farro, durum, bulgar, couscous and semolina. Oats in the UK mainly contain gluten, because of the fact that they are heavily cross contaminated from the factories where they are milled that also mill wheat and barley. Certified gluten free oats can be found from accredited sources. However, oats must still be classified as an allergen due to the fact that they contain a very similar protein to gluten called avenin that has been shown to affect a high percentage of coeliac sufferers in the same way as gluten. Symptoms associated with coeliac disease include bloating, cramping, diarrhoea and in the longer-term malnutrition through malabsorption of vitamins and minerals, anaemia, muscle pain, aching joints, severe fatigue, depression and cancers due to long term cell damage.

Crustaceans - Crustaceans are one of the big five allergens around the world. Shellfish within this category include lobster, crab, langoustine, prawn, shrimp and crayfish as well as any derivatives of these for example shrimp paste. Crustaceans can elicit true allergic reactions, the worst being full anaphylaxis. Symptoms range from: gastrointestinal problems such as nausea, sickness, stomach cramping, bloating and diarrhoea; skin problems such as severe swelling especially around the face, lips, mouth and the mucous membranes in the mouth, severe itching, severe rashes and urticaria; problems with the pulmonary system, severe constriction of the trachea, bronchii and bronchioles, severely limiting the ability to breath; severe problems with the circulatory system as blood vessels dilate massively leading to a life threatening drop in blood pressure that severely affects the hearts ability to function, potentially leading to a cardiac arrest if untreated. Extremely sensitive individuals have been known to react to vapours from shellfish. Note: spoiled shellfish of all types and spoiled fish can produce histamine this can lead to a condition called scombrotoxic poisoning. Symptoms can be the same as per an allergic reaction.

Molluscs - Molluscs include all bivalves such as oyster, clam, muscles, cockles but also whelks, periwinkles, snails (including all land snails), cuttlefish, squid and octopus amongst others and also any derivative substances from these creatures for example oyster sauce and squid ink used in pasta. Allergic reactions can be the same as per crustaceans.

Eggs - All egg products and derivatives must be considered including eggs from other birds for example, goose, duck, pigeon and quail. All types of allergic reaction are possible.

Fish - All types of fish must be considered, although reactions are more prevalent in certain species such as cod, hake, haddock, mackerel, whiting, salmon, trout, herrings, bass, swordfish, halibut and tuna. Also consider all derivatives and oils of fish as potential allergens, not forgetting that allergens can be hidden within common products such as Worcester sauce i.e. Anchovies. All types of allergic reactions are possible, some people even react to the smell of fish.

Peanuts - Some people mistakenly think that all types of nuts are the same, actually peanuts are unrelated to common tree nuts such as hazelnuts, they are actually legumes. Caution must be taken as peanuts have many other names including groundnuts, the oils derived from them sometimes being referred to as groundnut or arachis oil. Peanuts are also commonly ground into a flour, so be aware of peanut and groundnut flour. Peanuts are classified as one of the big five allergens around the world. Sensitivity can be extreme, even microscopic particles and odour from peanuts have caused severe anaphylactic reactions. Cross-reactivity is another potential problem with peanuts, as sufferers have occasionally reacted badly to other legumes that contain similar proteins for example soya, green and kidney beans, lupin and pea proteins used extensively in manufactured products.

Milk - Milk can potentially produce two different types of reactions depending on if the sufferer is allergic or intolerant. Sufferers who are lactose intolerant can suffer sickness, diarrhoea, bloating and cramping due to their inability to digest lactose or milk sugar properly as they lack the enzyme required i.e. Lactase. Some people have a true allergy to the proteins found in milk and so can suffer varying degrees of allergic reaction including anaphylaxis, this is particularly prevalent in infants and small children in regard to cow's milk (CMA). Milk of other mammalian species is included in the legislation as many of the proteins responsible are the same or similar e.g. Goat, sheep, buffalo, yak, camel etc.

Lupin - Lupin plants are commonly known by most people in the UK as common garden plants, producing bitter tasting toxins, however, sweet lupins which are not poisonous have been commonly grown in parts of Europe for many years and eaten by both humans and used as feed for livestock. Sweet lupin seeds are being increasingly used by manufacturers as an alternative to cereal grains to bulk out many common manufactured foods. Lupin is also increasingly found in the form of flour or seeds available as a food product in itself. In some parts of Europe where the product is found more readily it is known as a common cause of allergic reactions, this is becoming more prevalent as the UK increases its usage of this product as well as many different food types appearing on supermarket shelves. The product has been of such concern that it has been included on the list of 14. The anaphylaxis campaign in the UK has advised sufferers of peanut allergies to avoid lupin as many of the proteins found in peanuts are the same ones as found in lupin.

Tree nuts - One of the big five most common allergens in the world. Commonly referred to as nuts rather than tree nuts, they include hazelnut, brazil, almond, pistachio, pecan, walnut and macadamia and cashew nuts. A nut is technically a hard, inedible shell containing a seed. Coconut, pine nuts and chestnuts are generally not classified as a tree nut, but rather a dried seed. Although not included within the 14 allergens, some people can react to all kinds of seeds and cross reactivity is common. Many sufferers of peanut allergies also occasionally cross react with tree nuts. Businesses must also consider all derivatives of tree nuts found in foods such as unrefined nut oils used as salad dressings and almonds found in marzipan and some liquors.

Soya - Soya is used extensively in food manufacturing as a high protein alternative to meat, it is also commonly used as a low-cost bulking agent in many manufactured foods. It can be used also as a flour and oil can be derived from it also. Soya bean is classified as a member of the legume family of plants, therefore cross reactivity with other common allergens such as peanut and lupin are possible in sensitive individuals. Allergic reaction can cover the full range with skin reactions being the most common, closely followed by respiratory and gastrointestinal reactions, anaphylaxis being rare but not unknown.

Sesame seeds - Sesame seed usage in the food manufacturing industry is extensive, as a result the prevalence of allergic reactions is becoming more common over time. Sesame seeds and all of its derivatives including oil must be considered. People with nut allergies may cross react with sesame seeds in some circumstances. Be aware of products where seeds are sprinkled on the surface, such as breads, biscuits, breadsticks and cakes. Sufferers can experience the full range of allergic reactions.

Celery - Celery is a common ingredient used reasonably extensively by chefs in products such as soups and sauces but also used commonly in similar foods that are manufactured. The root of the celery plant is commonly called celeriac, all parts of the plant are included in the legislation including celery powder, seeds, spice and celeriac powder. Celery allergy is most common in Switzerland, Germany and France where it is used more commonly. Quite often people suffer what is known as oral allergy syndrome, where most of the reactions are around the mouth, lips, tongue and surrounding tissues. Worst cases include full anaphylaxis.

Mustard - Mustard allergy is relatively rare in the UK but is still one of the main 14 allergens so must still be treated as such. Mustard allergy is very common in France. Mustard and all of its derivatives including mustard powder, leaves, seeds, flowers and oils will and can cause allergic reactions at all levels, oral allergy syndrome being the most common and full anaphylaxis being the rarest reaction.

Sulphites and sulphur dioxide - Sulphites and sulphur dioxide are common preservatives and antioxidants found in many manufactured foods. If they are present in greater volumes than 10mg per kilogram or 10 ml per litre then they must be declared on packaged foods as an allergen. Sulphites and sulphur dioxide can produce severe allergy like symptoms particularly asthma and particularly with individuals that already suffer from asthma or other allergies to begin with.