Food allergen management, control and communication 

Where can I get  advice for my business about food allergens?

The council is committed to helping food businesses by providing links to the main guidance for food labelling and allergen information.

A good starting point is to refer to our food services sign-posting guidance document:

Focus on Food Labelling - Food Ingredients and Allergen Requirements (v1) (pdf 603kb)

This also covers links to labelling guidance for foods which are categorised as ‘Prepacked for Direct Sale’ (PPDS).

There is additional advice and guidance on implementing, promoting and complying with the allergen legislation on the Food Standards Agency Website:

Food Standards Agency - Allergens information and guidance (external website)

Find out more about other sector and product specific food labelling requirements which may affect your business.

What are the key concerns I should have as a caterer about food allergens?

As a food business, under food hygiene regulations you must take steps to avoid food allergen ingredient contamination and inadvertent cross-contamination that would make your food unsafe for an allergic customer. You must also follow the allergen information rules set out in food information regulations. This means that you must:

• handle and manage food allergens adequately
• provide allergen information to the customer for both pre-packed and non-prepacked food or drink.

You also need to make sure that your staff are trained about allergens.

14 main food allergens:

You need to tell your customers if any food products you sell or provide contain any of the main 14 allergens as an ingredient. 

These are:

• celery
• cereals containing gluten - including wheat (such as spelt and Khorasan), rye, barley and oats
• crustaceans - such as prawns, crabs and lobsters
• eggs
• fish
• lupin
• milk
• molluscs - such as mussels and oysters
• mustard
• tree nuts - including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts
• peanuts
• sesame seeds
• soybeans
• sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million).

The letter below was sent to all East Riding Caterers in August 2019, in regard to food allergen management, control and communication in catering premises.

Allergens Letter to Caterers (pdf 68kb)

What do I need to do to protect my customers from a food allergy or intolerance?

Some useful reference links to further advice and guidance include:

Food Standards Agency - Allergen advice for food businesses (external website)

Foods Standards Agency - Food allergy online training (external website)

Business Companion - Food allergens and intolerance (external website)

Allergen Information for Loose Foods (external website)

BRC Guidance on “Free-From” Allergen Claims (external website)

Can I get a copy of East Riding's allergen management supplement? 

East Riding Food Services has developed an allergens management supplement to the Food Standards Agency's (FSA) Safer Food Better Business (SFBB) caterers' pack to help businesses establish and document the management procedures. 

Such procedures underpin the 'Confidence-in-Management' component of the premises risk rating score, by aiding businesses in setting out the 'Safe Methods'  they implement to control food allergen hazards. 

Food business operators can download and print a copy of the Allergen Management SFBB supplement here:

Allergen Management SFBB Supplement (pdf 755kb)

As a caterer what allergen training do I need to give my staff?

Your staff should:

• be able to ensure that customers who are declared food allergy sufferers are provided safe food
  
• know the procedures and policies when asked to provide allergen information
• have training and instructions on handling allergy information requests
  
• be able to respond appropriately to requests for an ‘allergen-free’ meals request and understand why in most catering situations this cannot usually be achieved
  
• know the risks of allergen cross-contamination when handling and preparing foods and how to prevent this.

The Food Standards Agency (FSA) provides free of charge food allergy online training where you and your staff can learn more about food allergies and the allergen information rules. 

What practical steps can I take in my kitchen to avoid food allergen cross-contamination?

Typically, there may be numerous different ingredients being stored and handled, and several different dishes being prepared at similar times in a typical cafe or restaurant kitchen. However, there are some technically simple controls that can be adopted to help reduce the chances of cross-contamination as far as reasonably practicable, these might include:

• storing ingredients and prepared foods separately in closed and labelled containers
• keeping ingredients that contain allergens separate from other ingredients
• cleaning utensils before each usage, especially if they were used to prepare meals containing allergens
• washing hands thoroughly between preparing dishes with and without certain allergens
• having separate work surfaces, chopping boards and utensils for foods prepared without certain specified allergens.

It is accepted that a kitchen is not like a food factory, which is why it's usually NOT advisable to suggest you can produce a meal that is guaranteed allergen-free or described as 'free from 'x' allergen'.  

If you cannot avoid cross-contamination, tell your customers that you can't provide an 'allergen-free' dish. 

What information do caterers need to provide about allergens?

Under food information regulations caterers must provide information about the intentional presence of 14 specified allergenic ingredients in the food they supply, this can be orally or in writing. Where they elect to provide this information orally, there must at least be appropriately placed notices advising customers of this (see below.)

Making customers aware that due to the nature and dynamics of catering operations, foods may be at risk of unavoidable cross-contamination by allergenic ingredients is also advised. 

Menu descriptions may say that an item is 'made with 'x' allergen-free ingredients', but by default should NOT normally be stating that a menu item is 'x-allergen-free', since the inherent potential for cross-contamination will usually preclude this.

An example notice, specifically required by food information regulations and implied by Hazard Analysis Critical Control Point (HACCP) assessments under food hygiene regulations, might be as given below:

The fact that a business makes a declaration such as above that foods may contain allergen cross-contaminants, does not negate the need to also take all reasonable precautions and exercise all due diligence identify and control potential allergen contamination hazards. 

What are the FAQs about food allergens?

Using the link below you can access and download a document with answers to some of the questions we are asked about food allergen management, control and communication: 

Allergens Management, Control and Communication Frequently Asked Questions (pdf 566kb)

How does food allergens management affect a premise's risk rating and Food Hygiene Rating Scheme score?

To answer this question requires some understanding of how the Food Hygiene Rating Scheme (FHRS) score is generated from the general Food Standards Agency (FSA) food hygiene rating compiled following a premises hygiene inspection. 

There are three components of the general FSA food hygiene rating taken into account to generate the FHRS score; these are: 

• Premises Hygiene - the condition of the structure of your premises - its layout/design, cleanliness, lighting, ventilation, and other facilities
• Practice Hygiene - how hygienically food is handled - safe food preparation, cooking, re-heating, cooling and storage
• Confidence in Management (CIM) - how you manage and document food safety - implementing systems such as 'Safer food better business', record keeping, staff training, and your compliance history.

With regard to food allergen management, control and communication requirements, if there are shortfalls in measures taken to avoid unintended contamination and/or cross-contamination of menu items with allergenic food ingredients that have not been declared to the customer, these will impact as follows:

Supplying food products/menu items containing allergenic foods as ingredients that have not been declared to the customer or which the customer has specifically been assured are not ingredients in the food is a serious failing. Any systematic failure to put in place, implement and maintain adequate procedures to avoid such an occurrence, such as a lack of staff supervision, instruction or training will impact directly on the CIM score. The fact of any such contamination at an ingredient level may also be reflected in a lower Practice Hygiene rating. 

Evident or significant risk of food allergen cross-contamination will usually result in a lower premises or practice hygiene score, dependent on the circumstances. If this is also due to systematic lack or failure in management procedures then this may also be reflected in a lower CIM score.

For more information about the FHRS scoring processes, please follow this link to the Food Standards Agency FHRS webpages: 

Food Hygiene Rating Scheme (external website) 

How will the new rules for prepacked for direct sale food (Natasha’s Law) which comes into force on 1st October 2021 affect the way I provide allergen information?

Food labelling requirements for prepacked for direct sale food (PPDS) changed in 1 October 2021

East Riding Food Services has produced a sign-posting guidance document, Focus on Food Labelling - Food Ingredients and Allergen Requirements. Within this document there is a link to the FSA food labelling decision tool which will help you to identify the type of food your business provides and the allergen labelling requirements.

Any Prepacked for Direct Sale food that you supply must be provided with the following mandatory food information:

• The name of the food

• List of ingredients

• Allergen information (emphasised within the ingredient list)

• Quantitative ingredient declaration (QUID) for meat ingredients (except for mass caterers preparing food ready for consumption by the final consumer).

The name of the food, list of ingredients and allergen information must be provided directly on the packaging or on a label attached to the packaging.

Please refer to Focus on Food Labelling - Food Ingredients and Allergen Requirements for further details.