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New allergen rules within the EU Food Information to Consumers (FIC) food legislation came into effect on 13 December 2014. These rules effect how allergen information is provided on pre‑packed food labels and introduced a new requirement to provide allergen information for foods sold or provided loose.
Food caterers, such as hospital catering services, are now required to provide information to patients, staff and visitors about the presence or use of any of the allergens outlined in the legislation. This includes any food item served to patients at ward level and any food sold in retail outlets.
The allergens outlined in the FIC are: cereals containing gluten, wheat, oats, rye, barley, spelt, Khorasan wheat/Kamut, crustaceans (eg: prawns, crabs, lobster), eggs, fish, peanuts, soya, milk (including lactose), nuts, almonds, hazelnuts, walnuts, cashews, pecan, Brazil nuts, pistachio, macadamia, celery, mustard, sesame seeds, sulphur dioxide (where added at >10mg/kg or 10ml/L inthe finished product), lupin and molluscs (eg: clams, squid, oysters, scallops).
To meet allergen obligations, hospital caterers must be able to evidence the exact ingredients used, such as by brand name and pack size, or other information that details what is normally used or that of any replacement.
When using pre-packed foods in the preparation of meals, any ingredient containing one of these allergens must be included in the ingredient list and the name of the allergen should be emphasised within the ingredient list (eg: in bold, underlined, italics etc.). If the name of the allergen is not within the name of the ingredient, the name of the allergen should appear in brackets.
The legislation does not require full ingredient lists for loose foods – the requirement is to declare any allergens when used as an ingredient or processing aid regardless of level of use. Websites and other forms of communication should also identify the names of all the allergens contained in the product in some way, such as an allergy advice line.
Procurement and purchasing
Hospitals should ideally purchase from suppliers who provide product specifications including the full ingredient lists that include allergens. Failing that, they should use the information on the food labels and make a note of them when they are used.
All foodstuffs that are brought into the hospital, from complete meals to individual recipe ingredients, should have their ingredients checked and any allergens identified, using either their specifications or food labels.
This also applies to meals that are brought in ready made, which may not always have full details on the label. If this is the case, the information needs to be sought by other means such as specification sheets.
Safe storage and preventing cross contamination
Once the allergen contents of all ingredients are known and logged, safe storage practices must be used to avoid the cross contamination of foodstuffs: for example sugar could be contaminated by other allergens in the environment if stored near wheat flour and milk powder. Food items need to be kept in sealed containers and accessed using clean utensils to minimise the risk of cross contamination. Where possible, store allergenic ingredients, such as nuts, peanuts or sesame, on bottom shelves to prevent them falling into other foods. Larger kitchens may have quarantine rooms to separate these foodstuffs to prevent cross contamination or may keep nuts or peanuts in a special place.
The safe storage of ingredients should be included as part of the food safety management system, or Hazard Analysis Critical Control Points (HACCP) and staff should be trained accordingly.
Preparation and recipes
To be able to readily inform consumers about the presence or absence of allergens, the use of standard recipes is best practice. Each standard recipe should list each ingredient, emphasising the allergens and specifying where possible the brand name and pack size. Pack size identification is important as some brands use a different formula in different pack sizes.
If a hospital does not use standard recipes with specified ingredients, then it will need to note what ingredients and pack sizes are used each time a dish is made. When dishes are produced, especially dishes that are not served immediately, a system of batch coding, dating, and logging should be used, so that individual portions for a specific batch can be identified if necessary.
In situations where a single or bespoke meal is required, eg: for a patient with a specific diet request, the chef will need to be able to provide the allergen information on request for that particular dish. In these cases, the person placing the order, eg: the dietician or nurse, will need to be aware of any allergies that the patients may have and communicate with the staff producing the food if allergen information is going to be required.
All food service organisations must supply recipe information regarding the allergens in their dishes. Depending on the size and needs of the individual organisation the allergens in each recipe should then be listed on a file note, spreadsheet, a log, or a menu software program. This is used as a ready reference to easily show the allergens present in each of the ingredients sourced.
Software is available to support the tracking of ingredients into recipes and is used in many organisations. When this information has been put together, a rigorous system needs to be in place to update the information when it changes. This will include adding new food products into the data when they are sourced, and updating product details when their ingredients change, or when manufacturers change formulations.
Audit procedures need to be included at every step and should be a part of the HACCP and safe storage procedure.
Allergen information must be readily available, so staff members can provide the information to the consumer accurately and consistently. One method of ensuring this is through verbal communication from an appropriate member of staff, who can find the information on an electronic ordering system at ward level, from the chef, or from the food server.
A second method is through ward folders, which can include suppliers’ nutrition booklets, spreadsheets or printed recipes from a central database.
Allergy aware menus
‘Allergy aware’ menus can also be used to highlight foods that don’t use allergens outlined by the FIC.
Additionally, labels can be placed on pre packed food for direct sales from deli counters or sandwich bars. For vending machines or other food services where no staff are available, food items must be individually labelled, or a notice with all the allergy information should be placed nearby.
Hospitals cannot say they do not know whether or not a food contains major allergens, nor can they say that all food may contain allergens. Inaccurate or incomplete information would be in breach of the FIC regulation.
Consumers must be advised that the information is readily available. For patients, a statement on the standard menu outlining that food allergen information is available on request can be used. For retail or vending, a similar statement can be placed on the staff and visitor’s menu, or a conspicuous notice placed in the restaurant.
The original toolkit was co-authored by the BDA and the Hospital Caterers Association (HCA) and can be found at tinyurl.com/okpttzd
The British Dietetic Association’s website can be found at www.bda.uk.com