Allergen Information and Control of Cross-Contamination - www.nwleics.gov.uk
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www.nwleics.gov.uk
Allergen Information
Click to add text and Control
of Cross-Contamination
Food Information Regulations 2014
Food Information Regulations 2014
Since December 2014 all food businesses have been required to provide
Food Safety Act 1990
information about the allergenic ingredients used in food sold or provided by them.
Food Safety and Hygiene (England) Regulations 2013
There are 14 major allergens which need to be declared:
Cereals containing gluten Molluscs
Crustaceans Celery
Eggs Mustard
Fish Sesame
Peanuts Sulphur Dioxide ( >10mg/kg of product)
Soyabeans Lupin
Milk Nuts (almonds, hazelnuts, walnuts, pecans,
brazil, pistachio, cashew, macadamia)
Why is it important that Food Businesses
control allergenic ingredients?
2% of adults and 5-8% of children have a food allergy = 2 million people.
Anaphylaxis can be fatal.
An allergic reaction can be can be produced by a tiny amount of a food ingredient
that a person is sensitive to.
Around 10 people die each year.
1,500 per year die from asthma attacks – some of which are initially caused by a
food allergy.
Recent Cases May 2016, Paul Wilson, 38, who had a nut allergy, died after consuming a curry containing peanut. January 2017, Megan Lee, 15, who had a severe nut allergy died after eating a meal from an Indian restaurant that contained nuts. June 2017, Chole Gilbert, 15 who had a sever dairy allergy died after consuming a kebab containing yogurt. September 2018 Natasha Ednan-Laperouse, 15, died after eating a Pret Baguette containing sesame seeds – ongoing.
Food Standards / Food Hygiene
Food Information Regulations 2014
Food Inspections Areas to consider to carrying out Food Hygiene Inspections: • Storage • Preparation • Cooking • Equipment • Cleaning • Management • Training
Storage of Allergenic Ingredients
• How and where are allergenic ingredients and foods containing allergenic
ingredients stored?
- Secure?
- Evidence of cross-contamination?
- Packaging intact?
• Can allergens contaminate other products or become contaminated themselves?
• Are there cross-contamination issues?
• Are all allergens marked/labelled where required?
• Original packaging kept?
• If there is there a colour code system in place, is it adhered to? Does it work? Is
cleaning effective?
Preparation and Cooking • What are the set procedures when preparing food for a customer with a food allergy? - Designated areas - Clean down procedure • What controls do they have in place to prevent cross contamination? • Are all allergens marked/labelled where required? • If there is there a colour code system in place, is it adhered to? Does it work? • Consider use of oils and fats. -Peanut oil -Sesame oil -Butter
Use of Equipment • Equipment must be effectively cleaned to ensure allergen residues are removed. • Complex equipment must be dismantled and manually cleaned to ensure hard to clean areas area are free from allergen residue i.e. vac pac example • Are items such as woks cleaned between uses? • Dual use of equipment presents a risk of cross-contamination
Cleaning and Handwashing • Is cleaning effective? • Is there a risk of cross contamination? • Could cleaning cloths be contaminated with allergenic material and become a source of contamination? • Are there good hand-washing practices in place and observed? • Are there any circumstances where gloves are used? • Are gloves changed as required? • Sanitiser/anti-bac gel is not sufficient to remove allergenic proteins. Physical agitation and removal is required.
Management
• Information on allergenic ingredients must be either:
- Written up front (e.g. on a menu or menu board) without the customer having
to ask for information;
- Sign-posted to where written information can be found or obtained;
- Sign-posted to say that oral information can be obtained from a member of
staff;
- If information on allergenic ingredients is provided orally, this must be
consistent and verifiable and backed up by ingredient labels etc.
• Has allergen control been looked at in the Food Safety Management System
(SFBB or HACCP based) or as a general control by the FBO?
- How often is it reviewed?
- How is it being implemented?Food Safety Management System • Allergen Management must form part of the businesses HACCP • The SFBB insert is adequate but the other “Safe Methods” must be updated to include Allergen Management - Cross contamination - Cleaning - Separation of food • Encourage businesses to have a written procedure from notification to service (advisory) in addition to SFBB • Can only enforce Allergen Matrix if it is stated that this method is being used in SFBB
Staff Training • Formal and/or in-house? • Do staff understand allergen control? • Can they tell you the allergens that must be listed on packaging or know where to go for assistance? • Do staff understand the severity of allergies and the issue surrounding cross contamination? • Do staff understand product substitution i.e. peanuts for almonds in curries? • What would they do in practice if a customer asked for a product free from an ingredient? • Includes front of house staff, managers and chefs.
FHRS Scoring Food Law Practice Guidance (England) 2017
Enforcement • Food Information Regulations 2014: Improvement Notice • Food Safety and Hygiene (England) Regulations 2013: Hygiene Improvement Notices • Food Safety and Hygiene (England) Regulations 2013: Hygiene Emergency Prohibition Notices • Case Study • Offences • Prosecution
Enforcement Examples of non-compliance: • Staff unaware of 14 prescribed allergens • Staff unable to accurately advise of allergenic ingredients in foods served – verbal or written (Officers should be testing and challenging FBOs on this) • Incorrect information being given regarding allergens (verbal or written) • Cross-contamination: -storage -preparation -equipment • Inadequate cleaning / cleaning procedure • Insufficient FSMS • Lack of training in Allergen Management
Enforcement Notices Improvement Notice: Allergens Food Information Regulations 2014 Regulation 5(5) Hygiene Improvement Notice: Cross-contamination risks during storage Article 4(2), Annex II, Chapter IX, paragraph 2 Regulation (EC) 852/2004 Hygiene Improvement Notice: Cross-contamination risks during preparation and cooking Article 4(2), Annex II, Chapter IX, paragraph 3 Regulation (EC) 852/2004 Hygiene Improvement Notice: HACCP Article 5(1), Regulation (EC) 852/2004 Hygiene Improvement Notice: Training Article 4(2), Annex II, Chapter XII, paragraph 1, Regulation (EC) 852/2004 Hygiene Emergency Prohibition Notice Food Safety and Hygiene (England) Regulations: Regulation 8
Improvement Notice: Allergens Food Information Regulations 2014 Regulation 5(5): “In relation to a relevant food to which this regulation applies, the Article 9(1)(c) particulars made available by a food business operator must be made available with a clear reference to the name of the substance or product listed in Annex II where— (a) the relevant ingredient or processing aid is derived from a substance or product listed in Annex II, and (b) the particulars are made available otherwise than by means provided for in FIC”
Hygiene Improvement Notice: Cross-
Contamination
Article 4(2), Annex II, Chapter IX, paragraph 2 Regulation (EC)
852/2004
“Raw materials and all ingredients stored in a food business are to
be kept in appropriate conditions designed to prevent harmful
deterioration and protect them from contamination”
Article 4(2), Annex II, Chapter IX, paragraph 3 Regulation (EC)
852/2004
“At all stages of production, processing and distribution food is to
be protected against any contamination likely to render the food
unfit for human consumption, injurious to health or
contaminated in such a way that it would be unreasonable to
expect it to be consumed in that state”Hygiene Improvement Notice: HACCP Article 5(1), Regulation (EC) 852/2004 “Food Business Operators shall put in place, implement and maintain a permanent procedure or procedures based on the principles of HACCP (Hazard Analysis and Critical Control Points)”
Hygiene Improvement Notice: Training
Article 4(2), Annex II, Chapter XII, paragraph 1, Regulation (EC)
852/2004
“Food Business Operators are to ensure:
1. That food handlers are supervised and instructed and/or trained in
food hygiene matters commensurate with their work activity;
2. That those responsible for the development and maintenance of the
procedure referred to in Article 5(1 of this Regulation or for the
operation of relevant guides have received adequate training in the
application of the HACCP Principles”
All food handlers must receive appropriate allergen training
In-house / SFBB – procedures for dealing with allergy notifications
FSA online
Chefs, front of house, managersCase Study Complaint received from a member of the public - Ordered chicken tikka masala, coconut rice and garlic and coriander naan - Informed the waiter allergic to peanuts - After taking a couple of bites of the food suffered from anaphylactic shock - Ambulance was called and was treated in the ambulance - Did not have to be admitted to hospital - Customer informed on service that the meal did not contain peanuts
Investigation
Checked premises file:
- Written warning
- Allergy leaflet, matrix and warning sign provided
Inspection of premises:
- Limited knowledge of 14 allergens
- Matrix not completed
- Food exposed to a risk of contamination
- Dual use of equipment
- Staff stated: “do not use peanuts except for peanut oil”
- Warning sign not displayed
- SFBB did not include allergen specific inserts and there was no other
procedure in placeFormal Sampling 1. Pataks Tikka Masala Paste – peanuts not listed as an ingredient 2. Tikka Masala Sauce Made – Up by Chef (using Pataks Tikka Masala Paste 3. Coconut Rice 4. Garlic and Corriander Naan
Pataks Tikka Masala Paste
Chefs Tikka Masala Sauce
Chicken Tikka Masala
Coconut Rice
Garlic and Coriander Naan
Offences Food Information Regulations, Regulation 5(5): No information available regarding allergenic ingredients (verbal or written) Article 4(2), Annex II, Chapter IX, paragraph 3 Regulation (EC) 852/2004: Lack of effective cleaning of equipment after preparing dishes containing peanut oil Article 5(1), Regulation (EC) 852/2004: Lack of FSMS, risks not identified, staff not adequately trained
Article 14 of EC Regulation 178/2002 Prohibits unsafe food from being placed on the market. Food is deemed to be unsafe if it is injurious to health or unfit for human consumption. 3. In determining whether any food is unsafe, regard shall be had: c) to the particular health sensitivities of a specific category of consumers where the food is intended for that category of consumers."
Other Offences Article 16 of EC Regulation 178/2002 Requires that the labelling, advertising and presentation of food, including the information made available, should not mislead consumers. Section 14 of the Food Safety Act 1990 This provision makes it an offence for anyone to sell to the purchasers prejudice, any food which is not of the nature, substance or quality demanded by the purchaser.
Section 15 of the Food Safety Act 1990 This provision makes it an offence to falsely describe or present food. More particularly, it is an offence for food labelling to be false or likely to mislead as to the nature, substance or quality of the food. The section also applies in relation to the advertising and presentation of food. It remains widely accepted that individuals who have allergic reactions to certain foods should take care to scrutinise food labels more closely than an average consumer does.
Prosecution Wording of Offences – examples: - Food Information Regulations 2014 - Non-compliance with an Improvement Notice - Sale of food injurious to health
Food Information Regulations 2014
Regulation 5(5)
Offence Charged against:
You failed to ensure that customers could be accurately
informed which of the 14 prescribed allergenic
ingredients were in the food provided at the premises
in that staff were unaware of the 14 prescribed
allergens and could not provide any information in
relation to which food items they were in.
Contrary to the Food Information Regulations 2014
Regulation 5(5)Non-compliance with an Improvement
Notice
Offence Charged against:
You failed to comply with the requirements of
Improvement Notice reference 8472910 as there was
no written allergy information available for the food
and drink served at the premises. Furthermore, staff
were not able to verbally inform me what the 14
prescribed allergens were or which allergens were in
what products
Contrary to the Food Information Regulation 2014Sale of Unsafe Food You sold Chicken Tikka Masala and Coconut Rice intended to be eaten at the point of sale which was contaminated with peanuts, to a customer who had informed you of a peanut allergy, so as to be injurious to health. Contrary to Regulation (EC) 178/2002 Article 14(1)
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