Preparatory Work on ImprovingInformation in Catering Outlets and for

Foods Sold Loose(LSA 13/258)

Final Report Commissioned by the FSA

Ms Brigid McKevithMs Claire MacEvillyDr Michele SadlerDr Judy Buttriss

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CONTENTS

EXECUTIVE SUMMARY 3

1. BACKGROUND INFORMATION 71.1 CURRENT SITUATION1.2 STRUCTURE OF SECTOR1.3 TERMS OF REFERENCE

2. REVIEW OF NATIONAL PRACTICE 132.1 INTRODUCTION2.2 METHODS2.3 RESULTS OF SELF COMPLETED QUESTIONNAIRES2.4 REVIEW OF CURRENT GUIDELINES AND RECOMMENDATIONS2.5 IN DEPTH DISCUSSIONS

3. REVIEW OF INTERNATIONAL PRACTICE 563.1 INTRODUCTION3.2 METHODS3.3 RESULTS

4. RESEARCH IDENTIFIED 64

5. RECOMMENDATIONS 665.1 PROCESS USED TO DEVELOP RECOMMENDATIONS5.2 RECOMMENDATIONS: ALLERGY AWARENESS5.3 RECOMMENDATIONS: OTHER INFORMATION

6. CONCLUSIONS 75

REFERENCES 76

APPENDIX 78A. STEERING GROUP MEMBERSB. QUESTIONNAIRESC. FOOD ALLERGY LABELLING GUIDELINESD. UDEX AND OFSCIE. DETAILS OF RESEARCH IDENTIFIEDF. TRAINING RESOURCES

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EXECUTIVE SUMMARY

INTRODUCTIONConsumers have identified a number of different information issues with regard to non-prepacked foods including allergens, date marks, logos and nutrition information.Allergens, the use of healthy eating information, logos and origin labelling are alsoimportant issues in relation to catering establishments. In late 2001, the British NutritionFoundation was charged with investigating the provision of information on these topics(see section 1.3 for details) and making recommendations on the way forward, which arepractical and realistic but also meet consumer needs. The object of the project was to:

1. establish what research had been conducted in the past on the issues,2. establish the current national and international practice,3. explore the issues in-depth with stakeholders, and4. make suggestions and recommendations as to how the key issues identified could be

taken forward.

METHODSA Steering Group was assembled including members from the different stakeholdergroups (see Appendix A for membership). Five questionnaires for self-completion weredrafted to obtain information on current national practice, barriers and opportunities, andexamples of good practice from the different stakeholders. Detailed questionnaires forcaterers and caterers working with schools, manufacturers and retailers were also draftedto be used as the basis for in-depth interviews (see Appendix B for copies of thequestionnaires). The self-completion questionnaires were distributed by post/email viamembers of the Steering Group and by the British Nutrition Foundation to a collated listof contacts within the different stakeholder groups. Simultaneously, 40 in-depthinterviews were conducted covering the stakeholder groups and guidelines andrecommendations from UK organisations were reviewed. Self-completion questionnaireswith an international focus were sent to some internationally-based organisations andinformation was also gathered via in-depth research with companies with internationaloperations. Information on international initiatives was gathered and the Food LabellingStandards of Codex Alimentarius and relevant EU legislation were also referred to forany information on these issues.

The recommendations in this report are based on the information collected via thequestionnaires and in-depth interviews, and take account of advice and informationprovided by the Steering Group. Reviewing existing national and international practicesand guidelines has also influenced the recommendations.

OUTCOMESIt was apparent throughout the project that, of the many factors being investigated,concerns about allergy were considered by far the most important. For this reason, therecommendations focus on allergy and allergen awareness. It was agreed by the SteeringGroup that the priority should be identification of measures aimed at tackling concerns

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about peanuts, tree nuts and seeds, as these are causes of particularly serious allergicreactions. However, consideration has also been given to the other matters included in theremit for the project (see Sections 5.3).

Summaries of the main areas covered in the project are given below:

1. Research identified (see section 4)Some research was identified but there is a need for further research on these issues,including identification of the type of information consumers want on foods sold loose orthrough catering outlets and the type of information they need to be able to make healthyand safe choices about the food they eat.

2. Current national and international practice (sections 2 and 3)There is a diverse range of players involved in the provision of foods sold loose andthrough catering outlets, some of whom are managing the flow of information morecompetently than others. Different guidelines have been developed by national andinternational organisations and these share some common themes.

3. Issues identified by stakeholders (sections 2 and 3)The different stakeholders highlighted allergy as a priority. A need for sharedresponsibility by those in the food chain and by consumers, especially allergy sufferers,was expressed, as well as a need for agreement on commonly used phrases andterminology to increase effective sharing of information.

4. Recommendations (section 5)The overall aims of the recommendations are: (i) to enable the consumer to make aninformed choice by provision of accurate information and (ii) to enable the food supplier(including caterers and retailers selling non-prepacked foods) to provide accurateinformation to their customers and ultimately to the consumer.

With regard to allergy awarenessRecommendation 1:The FSA should lend its support to approaches which help establish good operatingpractices with regard to allergens, particularly with regard to nuts, peanuts and seeds.

Recommendation 2:The FSA should work with interested parties to develop an agreed list of commonallergen-containing foods or food groups.

Recommendation 3:The FSA should work with interested parties to develop a definitive list of tree nuts, asthese, along with peanuts and seeds, are recognised sources of allergens associated withparticularly severe reactions.

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Recommendation 4The FSA should work with interested parties to develop agreed definitions for terms suchas ‘free from’ and ‘may contain’, and agreed processes for declaring the presence ofallergens.

Recommendation 5With regard to transfer of information about food ingredients (e.g. allergen status or otheraspects of labelling information) as foods move within catering establishments (e.g. whenpackaging is removed or products decanted for storage), the FSA may wish to considerworking with interested parties to develop guidance on the transfer and retention of suchinformation.

Recommendation 6:The FSA should work with interested parties to define minimum training requirements inrelation to allergy awareness for food sector staff. The aim would be to minimise crosscontamination and to facilitate provision of accurate information to the consumer.

Recommendation 7:The FSA may wish to consider supporting an allergy awareness scheme that could beconstructed along similar lines to the Heart Beat Award Scheme.

With regard to provision of other informationRecommendation 8:The FSA may wish to consider working with interested parties to develop ‘food based’guidelines for defining ‘healthy eating’ options in catering establishments. These couldbe based on existing materials such as Catering for Health and the Heartbeat AwardScheme.

Recommendation 9:With regard to foods sold non-prepacked that require cooking, the FSA may wish toconsider actively encouraging the provision of information on cooking method byretailers by providing guidance on the methods and formats that are already in use, e.g.printing information onto price labels, use of leaflets, verbal communication. This mightalso be extended to cover storage and durability information for foods that do not requirecooking.

Recommendation 10:The FSA may wish to consider actively encouraging retailers to provide information oncountry of origin by offering guidance on the methods and formats that could be used,e.g. printing information onto price labels, use of leaflets, verbal communication.

Recommendation 11:The FSA should work with interested parties to develop an agreed list of commondefinitions for terms such as vegetarian and vegan.

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Recommendation 12:The FSA may wish to consider working with interested parties to develop guidance onthe transfer of information about ingredients as they move within catering establishments(see recommendation 5).

Recommendation 13:The FSA may wish to consider working with interested parties to define minimumtraining requirements in relation to healthy eating options. The aim would be to facilitateprovision of accurate information to the consumer.

Recommendation 14:The FSA may wish to consider supporting a scheme such as the Heart Beat AwardScheme to give support and recognition to those companies addressing issues such ashealthy eating options.

CONCLUSIONMany consumers would like further information on the foods they purchase non-prepacked and from catering outlets. The priority for this information should be forallergens because of the danger allergen-containing foods present to susceptibleindividuals. However, by also addressing other areas such as healthy eating options,country of origin and vegetarian and vegan foods, the FSA can increase awareness andclarity of these issues, help the food industry to improve its current practice and helpconsumers to make informed choices about the food they buy.

Foods sold loose and through catering outlets are managed by many diverse players,some of whom are managing the flow of information more competently than others.Recommendations outlined in this report are relevant to all players but aim to giveguidance specifically to those organisations not currently addressing these issues.

British Nutrition FoundationJune 2002

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1. BACKGROUND INFORMATION

1.1 CURRENT SITUATION

In recent years there has been a significant increase in the number of meals eaten outsidethe home, with people eating on average around three meals per week, for example inrestaurants, pubs and other catering establishments (Buttriss, 2002a; FSA, 2002). Inaddition, a large variety of foods and meals are now sold non-prepacked from many retailoutlets.

Table 1. Examples of non-prepacked products and outlets in the UK

Examples of products sold non-prepacked:• Products available at delicatessen counters• Home meal replacements• Bakery and cakes• Fruit and vegetables• Confectionery• Fish and meatExamples of outlets:• Multiple and independent food retailers• Delicatessens• Butchers• Fishmongers• Greengrocers• Bakers

In order for consumers to make informed decisions when purchasing such products andwhen eating out, there is a need for greater provision of information about these foodsand dishes. This is particularly important for consumers with food allergy.

However, such foods are currently not subject to much of the food labelling legislation.The Codex Food Labelling Standards (1985) do not include foods sold non-prepacked orin catering situations. In the UK, many of the food labelling regulations do not apply tothese situations either, although this is likely to change in the future.

Even without legislative changes, improvements can be made in the provision ofinformation in catering establishments and for non-prepacked foods. Issues regardinghealthy eating and food allergy are becoming more relevant to caterers and retailers.However, alternative methods to labelling are needed for communicating suchinformation.

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Recommendations for dietary intakes of population groups have been made by COMA(Department of Health, 1991) and include a recommendation that no more than 35% oftotal energy should come from fat and no more than 11% of total energy from saturatedfatty acids. Salt intake should be about 6 grams per day. Data from the most recentlypublished National Diet and Nutrition Survey of adults were collected in the late 1980s;(Gregory et al. 1990) results from the latest adult survey are due in 2002/2003. However,using the annual National Food Surveys, several positive trends can be identified. Therehas been a decrease in energy intake and in the amount of fat and saturated fatty acidsconsumed. Although these trends are encouraging, further reductions are needed to meetthe recommendations.

Figure 1. Trends in energy, fat and saturated fatty acid intakes 1980 – 2000(Department for Environment, Food & Rural Affairs and National Statistics, 2001)

The Balance of Good Health (FSA, 2001) is the model used to communicate theserecommendations and enable consumers to put them into practice. It describes thedifferent food groups and the proportion each component should contribute to our dailyintake. There are also eight accompanying guidelines:1. enjoy your food2. eat a variety of different foods3. eat the right amount to be a healthy weight4. eat plenty of foods rich in starch and fibre5. don’t eat too many foods that contain a lot of fat6. don’t have sugary foods and drinks too often7. look after the vitamins and minerals in your food8. if you drink alcohol, drink sensibly

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The prevalence of proven food allergy (involving the immune system) in children isestimated to be 1-2% of the population and in adults less than 1%. Food allergy can belife threatening and it has been identified as a major consumer and public health concern(Buttriss, 2002b). Food allergy and food intolerance (the umbrella term used to describe arange of adverse responses to food) are often confused; the overall prevalence ofintolerance is estimated to be no more than 5-8% of children and less than 1-2% of adults(Buttriss, 2002b). It is estimated that at least 76% of deaths from anaphylaxis occur fromconsumption of food prepared away from home (Gowland, 2002). Furthermore peanutsand tree nuts seem to account for the largest proportion of anaphylaxis (Bock et al. 2001,Anaphylaxis website, 2002). Traditionally, allergy has not always been covered in thetraining for people working in catering. However in 2001 Catering for Health (FSA &Department of Health, 2001), developed by the British Nutrition Foundation, waslaunched. This resource provides guidelines and practical tips for teaching about healthiercatering practices as well as allergy. In May 2002, versions directly applicable for use inWales and Scotland, also developed by the British Nutrition Foundation, were launched.

The prevalence of clinically proven coeliac disease is 1 to 3 cases per 1000 people(Buttriss, 2002b). The only treatment for this condition is a gluten-free diet and if this isnot followed, there may be serious negative consequences such as increased risk of smallbowel lymphoma (Buttriss, 2002b).

The Food Labelling Forum Summary Report (FSA, 2000) identified some issues causingconcern to consumers, such as lack of fully comprehensive ingredient listing. The need tobe able to identify all ingredients used in the production of a food or drink is seen bysome as essential to enable consumers to identify ingredients that they either need orwant to avoid. This was emphasised by both vegetarians, of whom there is an estimated 4million in the UK (Mintel, 2001), and allergy sufferers who need to avoid certainingredients for ethical or medical reasons. This type of information is likely to also beimportant to the estimated 250,000 vegans in the UK. The importance of clear country oforigin labelling was also highlighted in the report. This information may be important forsome consumers who, for example, want to buy or avoid products from a specificcountry. The need for clearer definitions of terms such as ‘produced in’ was also raised,on the grounds that current usage did not actually give consumers the information theyrequired. (FSA, 2000). Marketing terms such as ‘fresh’ and ‘traditional’ were viewed asbeing occasionally misleading. The Food Advisory Committee has since developedguidance on best practice in the use of these potentially misleading terms (FAC, 2001a).

Quantitative research of about 1000 adults conducted for the FSA investigated whatinformation consumers wanted regarding non-prepacked food (FSA, 2000). It was foundthat:• About ¾ of the sample shopped for non-prepacked foods.• For such foods a wide range of information was relevant to consumers, but no

specific type of information was cited by over a third of the adults surveyed.• Consumers were most likely to look for the following information:

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Basic ingredients usedUse of GM ingredientsPresence of additivesSize of portionsCountry of originNutritional contentPresence of allergensMethod of cookingOrganic statusAnimal welfare informationVegetarian or vegan status

34%32%32%29%27%24%23%21%19%16%13%

A stakeholder meeting organised by the FSA in 2001 identified a number of issuesneeding consideration in relation to the sale of non-prepacked foods:

• allergens• healthy eating options• country of origin• logos• date marking• use of terms such as ‘fresh’ and ‘home-made’

In late 2001, the British Nutrition Foundation was charged with investigating withstakeholders the provision of information on these topics (see section 1.3 for details) andmaking recommendations on the way forward, which are practical and realistic but alsomeet consumer needs.

1.2 STRUCTURE OF SECTOR

The business sector involved in the provision and sale of foods sold loose and in cateringestablishments is wide ranging. The industry has many members, from single person,home-based enterprises to large, multinational companies employing thousands.However, all are dependent on others in the chain to ensure the success of theirbusinesses (MAFF, 1999).

Figure 2 attempts to give an overview of the different parts of the food chain and howthey are interconnected. Manufacturers, retailers and caterers may source raw ingredientsdirectly (e.g. from market gardeners and local fishermen) or they may procure goods viaa wholesaler. Some manufacturers produce goods specifically for retail or cateringcustomers, while other products are manufactured then sold and distributed viawholesalers. Some smaller catering outlets may not buy their supplies from wholesalersbut may rely on local retailers. Members of enforcement agencies (such as TradingStandards Officers and Environmental Health Officers) may be involved in any numberof the various stages along the food chain.

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Figure 2. Structure of Sector

Members of enforcement agencies may be involved at every stage

RAW INGREDIENT SUPPLIERS

WHOLESALERS

MANUFACTURERS

RETAILERS CATERERS

CONSUMERS

WHOLESALERS

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1.3 TERMS OF REFERENCE

The project described in this report focuses specifically on foods sold loose through avariety of outlets and foods available via catering establishments. Pre-packed foodsavailable directly to the public are not considered. The aims of the project were to:• establish what research had been conducted in the past on the issues (listed in section

4),• establish the current national and international practice (sections 2 and 3),• explore the issues in depth with industry, enforcement bodies and consumers, and• make suggestions and recommendations as to how the key issues identified can be

taken forward (section 5).

It was not the aim of this project to obtain statistical information about the provision ofinformation for foods sold non-prepacked and in catering establishments. Rather, the aimwas to establish the breadth of current practice, what barriers and opportunities areperceived by the different parts of the food chain, and to identify examples of goodpractice.

This report summarises the findings of an industry-wide survey of current national andinternational practice; past research conducted is identified. The report also summarisesthe findings of in-depth discussions with industry representatives, enforcement bodiesand consumers and makes recommendations as to how the key issues identified can betaken forward.

Abbreviations:EHO Environmental Health OfficerFAC Food Advisory CommitteeFSA Food Standards AgencyGMP Good Manufacturing PracticeHACCP Hazard Analysis Critical Control PointIFST Institute of Food Science and TechnologyOFSCI Optimum Food Service Supply Chain InitiativeBRC British Retail ConsortiumTSO Trading Standards OfficerUDEX Universal Descriptor Exchange - a commercial database operator

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2. REVIEW OF NATIONAL PRACTICE

2.1 INTRODUCTION

This section of the research project aimed to establish the breadth of practice within theindustry and identify issues of concern across the sector.

2.2 METHODS

A Steering Group was assembled including members from most of the different sectors(see Appendix A for membership). Five questionnaires for self-completion were draftedto obtain information on current national practice, barriers and opportunities, andexamples of good practice from the different stakeholders:

• Caterers• Consumer and Support Groups• Enforcement Agencies• Manufacturers• Retailers

Detailed questionnaires for caterers and caterers working with schools, manufacturers andretailers were also drafted to be used as the basis for in-depth interviews (see Appendix Bfor copies of the questionnaires).

The drafting process involved feedback from the Steering Group at several stages toensure appropriate wording, a clear and concise format, and adequate coverage of theissues pertinent to the different sectors. The questionnaires for self-completion weredistributed via members of the Steering Group and also directly by the British NutritionFoundation to a collated list of contacts within the different sectors. Questionnaires werereturned and information collated and analysed. Much of this information was qualitativerather than quantitative. Because the primary intention was to identify good practice,there was no attempt to identify a truly representative sample, although efforts were madeto contact companies based in different areas of Britain and in particular to reflect thebroad nature and size of such operations. This process took place during February andMarch to avoid the busy Christmas period.

Simultaneously, 40 in-depth interviews were conducted covering a wide range of foodchain sectors and stakeholders. Detailed questionnaires were used for caterers andcaterers working with schools, manufacturers and retailers, while for consumer groupsand enforcement agencies the basic questionnaire was used. Questionnaires formed thebasis for discussion (either face-to-face or by telephone) or were completed and returnedby post. All Steering Group members were also involved in the in-depth survey.

Guidelines and recommendations from UK organisations were reviewed to provideexamples of good practice.

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2.3 RESULTS OF SELF-COMPLETED QUESTIONNAIRES

Table 2 shows the breakdown of completed questionnaires that were returned.Distribution of the questionnaires, in itself, will have resulted in an increased awarenessof healthy eating and allergy issues, one of the project’s aims.

Table 2. Summary of Completed Questionnaires

Stakeholder Group NumberCaterers 187Consumer/Support Groups 20Enforcement 6Manufacturers 26Retailers 9

2.3.1 CATERERSOver 180 completed questionnaires were received from a range of cateringestablishments including sandwich shops, teashops, pubs, restaurants, staff restaurantsand contract caterers serving schools and hospitals. Feedback is presented under twoheadings: food allergy and consumer choice, the latter including healthy eating options,cooking method, vegetarian, vegan, country of origin, portion size and use of descriptorssuch as ‘home-made’.

(a) Food AllergensAll of the responding caterers were aware of the concerns regarding food allergy andalmost all are asked about specific ingredients by their customers. Caterers are mostcommonly asked about the following ingredients or foods:

• nuts/treenuts (identified by ~90% of caterers)• gluten/wheat (identified by ~59% of caterers)• dairy (identified by ~44% of caterers)• eggs (identified by ~8% of caterers)• shellfish (identified by ~8% of caterers).

About 60% of caterers identify the use of nuts/peanuts when their presence is not obviouswithin the title of the dish e.g. chicken satay; while only about 26% identify othercommon allergens in dishes they sell. Customers are informed about the use ofingredients by a variety of methods. Over 50% of caterers rely on their staff providingdetails when asked by customers but other methods used include signs, labels and noticesinforming customers to ask for help. However, 3 out of every 10 caterers surveyed do notmake their staff aware of the precise contents of such dishes or update staff whenchanges, such as the addition of nuts, are made.

Of the foods and ingredients that are bought in, a third of caterers surveyed do not keepthe labels or take a note of label information, even though over 80% of caterers think the

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label is a useful tool for providing information about allergens. Nuts/peanuts are notallowed or used in about a third of the catering establishments who responded. Of thosewho do use them, over half (57%) do not store or label them differently from otheringredients and over three-quarters do not have any special procedures in place whenpreparing dishes containing nuts. Over 50% of responding caterers had receivedinformation about food allergies from sources such as Research Associations, companyinformation, trade journals, other media sources, the Anaphylaxis Campaign and EHOs.About 70% of caterers have regular staff training sessions, with allergies included as atopic in over half of the catering operations responding to the questionnaire. About 50%of respondents have standard advice for customers with food allergy, ranging fromnotices advising customers to inform them if they have allergies to signs warningcustomers that dishes can not be guaranteed to be nut free.

“We need more information about contents of food and why and what causes allergies”(comment from one of the responding caterers)

(b) Consumer ChoiceAside from the issue of allergy, it appears from the responses that customers ask caterersmainly about cooking methods and specific ingredients, suggesting perhaps a need forspecific information rather than just general ‘healthy eating’ information. Over 80% ofcaterers claim to provide ‘healthy eating choices’. Dishes for those looking for healthyeating choices may include:• low fat• vegetarian, and• low sodium options,with salads, pasta and baked potatoes given as examples by respondents. However, thesuitability of all the options promoted as ‘healthy eating’ is not known. There seems to besome confusion about the meaning of terms, with some of the responses from theenforcement agencies highlighting this.

Those caterers who do provide the above options also use a wide variety of methods toinform their customers of availability, although ‘staff providing details when asked’ wasthe most commonly given response. About one-third of responding caterers do notreceive nutritional information from their suppliers or wholesalers; half who do get thistype of information receive it from some suppliers/wholesalers and less than 10% get thisinformation from all suppliers/wholesalers. Labels and product specifications are themain ways of communicating this information.

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Figure 3. Types of Healthy Eating Information Asked About by Customers

Almost all caterers (94%) who responded offer vegetarian choices some or all of the time.Vegan dishes are offered less frequently, with 50% of caterers offering vegan optionssome or all of the time. However, it is unclear what definitions caterers are using withrespect to these terms. These options are mainly communicated to customers via themenu. Most caterers provide information about portion size and the cooking method usedand often use descriptions like ‘fresh’, ‘home-made’ and ‘traditional’ (although onecaterer noted they were removing these in line with a recent FAC report). Fewer catererswho responded provide information about country of origin. About 40% of caterers whoresponded to the questionnaire are asked by their customers for information regardingportion size. Fewer customers ask for information about country of origin and about 60%of caterers are asked whether the food is ‘fresh’ or ‘home-made’ and for informationabout cooking method. Most caterers do not use the internet for sales or delivery tocustomers but 50% use the telephone, with some providing information to customers viatheir menus or information leaflets.

Comments from responding caterers included:“We could give more choices for vegetarians but often forget”“Restaurants should provide more choice for healthy options which are heart friendly”.

Catering: Do customers ask for information about healthy eating choices

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2.3.2 CONSUMER AND SUPPORT GROUPSTwenty completed questionnaires were received plus comments from severalorganisations. Feedback is given under the two headings used in the questionnaires –firstly issues when eating out and secondly issues when buying non-prepacked foods. Itwas indicated in the questionnaires that personal opinion (as opposed to consumerresearch or enquiries) was the basis of many of the responses from this sector.

(a) When eating outMost respondents in this sector identify nuts/peanuts as the most important allergens,although many other allergens also rate highly, such as shellfish. A number of otherallergens were identified by respondents within this stakeholder group that were not listedon the questionnaire (grouped together as ‘other’) including latex, wheat and sugar.Interestingly, whilst allergy to wheat gluten and to latex are well established, sugar isgenerally not regarded as a source of allergic reaction.

Figure 4. Importance of Common Food Allergens as Ingredients When Eating Out

With respect to ‘healthy eating choices’, most of the consumer and support grouprespondents felt information on the ingredients used is very important for ensuringconsumer choice and safety. Gluten-free logos or statements are rated as very important,followed by similar information about vegetarian items. Over 50% of respondentsthought information on country of origin and portion size moderately important, givingthem a score of 3 or 4 on the scale of importance (1 being not important and 5 being veryimportant).

Consumer & Support Groups: Importance of common food allergens as ingredients when eating out

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(b) When buying non-prepacked foodsRespondents were asked to rate the importance of information on common food allergensas ingredients. A number of common food allergens are deemed important, withinformation on the use of nuts/peanuts and shellfish being viewed as most important.

Figure 5. Importance of Common Food Allergens When Buying Non-prepackedFoods

Information on ingredients used is again thought to be the most important information tobe provided. Gluten free symbols were also deemed important, followed by vegetarianlogos/statements. Most people thought use by dates are also important. Information onthe quantity of ingredients and country of origin scored towards the higher end of thescale and, therefore, information on these issues appears to be moderately important.Most thought cooking instructions for raw or uncooked foods sold loose would be useful.

“Introduce a labelling option which indicates where allergens are used on site althoughnot in the product, thereby allowing the consumer to make realistic risk assessments”(one consumer’s comment)

Consumer & Support Groups: Importance of common food allergens as ingredients when buying non-prepacked foods

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2.3.3 ENFORCEMENT AGENCIESOnly 6 questionnaire responses from enforcement agencies were obtained. However, 3additional in-depth interviews also took place (see section 2.4.3). Feedback is given underthe two headings used in the questionnaires – firstly about eating out and secondly aboutnon-prepacked foods.

(a) Eating outConcern about the food allergens in nuts/peanuts, sesame seeds and milk in an eating outcontext were topics enforcement officers have experience of, with these concerns beingraised several times a year in this setting. Concerns about healthy eating,vegetarian/vegan dishes and products, and the use of descriptions arise 4-5 times per year.One respondent reported an increase in complaints from the public regarding businessespromoting misleading ‘healthy eating’, vegetarian and vegan dishes. The complaintsoften related to the promotion of menu items as vegetarian or low fat and suggest theremay be some confusion with the interpretation of these terms by some businesses. Thiswas highlighted by the following examples:

• a bought-in low fat dish having grated cheese added to it yet still being described aslow fat

• fish dishes being given as examples of vegetarian dishes.

(b) Non-prepacked foodsWith regard to the sale of non-prepacked foods, enforcement authorities have experiencewith many different allergens, with each responding enforcement officer dealing withconcerns about nuts/peanuts occurring up to 10 times a year. They also deal with otherissues including country of origin (about 6 times per year), vegetarian/vegan (about twicea year) and the use of descriptions such as ‘fresh’ and ‘home-made’ (also about twice ayear).

“Legally define claims so that the consumer/enforcement agency has an unambiguousunderstanding of their meaning and the assurance that wherever they are used they meanthe same thing” (recommendation from an enforcement officer).

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2.3.4 MANUFACTURERS

Feedback is presented under two headings: food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’.

(a) Food AllergensMost companies who responded to the questionnaire request information from theirsuppliers about nuts/peanuts, as well as other ingredients including soya, egg, fish,shellfish and seeds. Some manufacturers also collect information on a range of otheringredients such as the antioxidants BHA and BHT, and food colours. Information of thiskind is mainly supplied in the form of a company specification or questionnaire and keptwithin the specification system. This information is then used in various ways, includingthe final product specification and ingredient labelling. Most manufacturers requestspecial operational procedures from all their suppliers with regards to nuts/peanuts (someuse audits and questionnaires while others refer to the HACCP systems in place). Fewermanufacturers require this type of information for other allergens, even though manyimmediate clients ask about a number of allergens i.e. not just nuts/peanuts.

Of those manufacturers who use nuts/peanuts, most store them in a separate area withdistinctive labelling. Special procedures are often in place e.g. separate containers used totransport ingredients on site; segregation procedures which are audited; dedicatedline/plant; clean down procedures following production. Most staff receive training aboutfood allergy (mainly at induction) and are briefed on the contents and changes toproducts.

“Provide criteria for what ‘free from’ means” (recommendation from a respondingmanufacturer).

(b) Consumer ChoiceOver half the manufacturers provide products (to be sold as loose foods or via cateringoutlets) that represent healthy eating choices. They often form part of a healthy eatingrange, with claims also being made on the label. A similar number of manufacturersproduce vegetarian products and about 30% produce vegan products. Some but not all ofthese products carry a logo or statement. Where applicable, about half the manufacturersprovide cooking instructions for raw/uncooked foods.

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2.3.5 RETAILERS

Feedback is presented under two headings: food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’.

(a) AllergensMost of the retailers who responded sell a variety of non-prepacked products (see Figure6). All respondents were aware of concerns about food allergy and claimed awareness ofingredients used for all of their non-prepacked products. Some have special procedures inplace for the display and service of products containing nuts/peanuts, such as notices onservice counters. Most, however, have no special procedures in place for products thatmay contain other allergens. Most responding retailers do not sell non-prepackednuts/peanuts but one retailer sells them at Christmas in their shells. Another respondentwho sells non-prepacked nuts/peanuts has a notice on the counter warning customers ofthe unsuitability for allergy sufferers of food items.

If customers require information, respondents rely mainly on informed staff to answercustomers’ questions and/or the use of display tickets. Most retailers are asked aboutnuts/peanuts in products and other allergen-containing foods such as wheat, egg and milk.Tomato was also mentioned by one responding retailer as a allergen-containing food thatcustomers enquire about, although this is not a common cause of allergic reaction. Onlyabout half of retailers who responded to the questionnaire brief their staff on the contentsand changes to dishes being served.

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Figure 6. Range of Products Sold Non-prepacked by Retailers

(b) Consumer ChoiceConsumers often ask about healthy choices, including the use of specific ingredients andcooking methods. Most retailers have some items which are promoted as healthy choices,mainly through display tickets. Examples of such items include:• the salad bar• half fat cheese• ‘no salt added’ turkey breast.

All of the responding retailers provide vegetarian options and over half also providevegan options. Customers are informed about these either by staff when asked and/orthrough use of a display ticket. All retailers provide information about use-by dates/shelflife. Some use descriptions such as ‘fresh’ and ‘home-made’, or provide details oncountry of origin. Customers most often ask for information on use by dates and thecountry of origin. For those retailers with internet or telephone services for orderingand/or delivery of food to consumers, the above information is still available to customers- either via a website icon or via the call centre. Most responding retailers providecooking instructions for raw/uncooked foods.

“We provide information by a number of means including display tickets, ‘free from’listings, website information and a series of fact sheets” (examples from one respondingretailer of different ways information is provided).

Retailers: Types of Products Sold Non-prepacked by Retailers

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2.3.6 SUMMARY OF KEY POINTS

Many different comments where received from the questionnaires. However, somepractical steps were suggested by all of the groups. These include:

• Better labelling of foods, possibly abolishing the 25% rule as “allergic people needfull, clear ingredient lists”. (Many manufacturers already voluntarily ignore the 25%rule, particularly for nuts and peanuts).

• Further training would be useful for all. This could include introduction of key issuesto vocational courses at catering colleges.

• Guidelines on allergens would be beneficial including guidance on which allergensshould be identified, how they should be identified (e.g. common name), the levels ofallergens which cause sensitivity.

• Set phrases and criteria for what is meant by the terms vegetarian and vegan.• Concerns regarding legibility and readability were raised in relation to labels and/or

written information. The use of symbols, logos or colour-coded panels weresuggested as alternatives.

A number of barriers were perceived by the respondents. These are summarised below:

• Cost implications were seen as a major barrier by most groups.• Consumer groups perceived a reluctance on the part of manufacturers and caterers to

respond to concerns. This perception was not echoed by those respondents fromindustry.

• Some respondents believe legislation may be needed in this area to ensure adequateattention is given to the issues across the food chain. However, many caterers did notthink legislation would be helpful, as many smaller operations already struggle withmeeting their business and legal responsibilities. On the other hand, moresophisticated businesses already have a range of policies in place.

• Some responding retailers regarded keeping relevant information with products thatare to be sold loose a difficult task because of the large number of products stocked.

• As different manufacturing sites and different suppliers may be used for rawmaterials, manufacturers highlighted the need for flexibility with regard to provisionof information e.g. overtly prescriptive legislation would be restraining.

• It was also noted that the range of food products and their composition are constantlybeing updated and evolving – how are these concerns to be addressed andcommunicated?

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2.4 REVIEW OF CURRENT GUIDELINES AND RECOMMENDATIONS

Over the years, a number of guidelines have been drafted and disseminated to try andaddress some of the issues covered in this project, especially allergens. These include:

• the FSA’s Be Allergy Aware,• the British Retail Consortium’s Technical standard and protocol for companies

supplying retailer branded food products,• the British Retail Consortium’s Guidelines for the Handling of ‘Nuts’,• the Food and Drink Federation’s Food Allergens Advice Notes,• the Institute of Grocery Distribution’s Voluntary Guidelines for Food Allergens and

Gluten,• the Anaphylaxis Campaign’s Severe food allergies: guidance for caterers,• the FSA and Department of Health’s Catering for Health,• the FSA’s Dine out, Eat well,• the Vegetarian Society’s Catering pages,• the Heartbeat Award Scheme,• the FAC Committee’s Review of Food Labelling and Review of the use of the terms

Fresh, Pure, Natural, etc in Food Labelling, and• guidelines and information from Coeliac UK.

These resources have been reviewed and components of the guidelines have beenincorporated in the recommendations of this report.

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2.5 RESULTS OF IN-DEPTH DISCUSSIONS

Table 3. Summary of the Completed In-depth Discussions

Stakeholder NumberCaterers 14Consumer/Support Groups 3Enforcement 3International 4Manufacturers 7Wholesalers 2Retailers 7

2.5.1 CATERING

Feedback is presented under the headings food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’. Examples of barriers andopportunities given by the respondents are also shown.

(i) Large Group Caterers (n = 4)(a) Allergens• All were aware of the issue of food allergy.• All had experience of customers asking about the use of nuts/peanuts and other

potential allergen-containing foods such as eggs, milk, fish, shellfish, additives andsesame seeds.

Caterer 1The company instigated a project on allergens, which is now into its third year. The aimis to develop a common framework across all the group’s branded restaurants and hotels.

SUPPLIER INFORMATION: The company policy requests all suppliers to have a GMPand HACCP-based strategy for use, handling and declaration of nuts and theirderivatives. The company requests information from suppliers in the form of product datasheets, and these are filed centrally by the technical services department. Difficulties aresometimes encountered in getting such information from suppliers. For example somesmall suppliers do not understand what is being asked, and large companies do notalways want to divulge brand information. The information is used to develop allergydata sheets for menu items, and to enable staff to respond to customer enquiries. Labelson locally purchased supplies are seen as a useful means of providing information, butthey would be more useful if all the main allergen-containing foods and ingredients weredeclared. International suppliers have to provide the same level of information as UKsuppliers.

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STORAGE AND PREPARATION: HACCP and Standard Operating Procedures are inplace across the company. For allergy sufferers, special procedures are in place that relateto taking an order, preparing and serving the meal.

TRAINING: Food allergy is covered in staff training. Staff are informed about theingredients used in dishes as the menus change.

DIALOGUE: The menu highlights the use of main ingredients, such as fish and shellfish.Logos are not used to highlight nuts or other main allergen-containing foods. The menushave a statement that allergic customers should ask for the duty manager who willexplain the company’s policy, and share with the customer the precautions that thecompany is able and is not able to take. Information provision to customers is takenseriously in order for allergy sufferers to be able to choose dishes with confidence.

Caterer 2SUPPLIER INFORMATION: Most suppliers provide information about the use of nutsand other allergen-containing foods, in the form of specification sheets, which are filed toretain the information. A manual is prepared for communication of this informationwithin the company. ‘May contain’ labelling for nuts is assumed to reflect well-controlledsystems and notice is taken of the information. Some suppliers are requested to havespecial procedures e.g. biscuits are used as a bar snack, rather than nuts, and the biscuitsupplier must ensure that nut lines are not run next to biscuit lines. The company does notrely on product labels, which are not considered a useful method of communication.

STORAGE AND PREPARATION: Nuts present in kitchens are not stored differently toany other ambient ingredient, and dishes containing nuts are not prepared any differentlyto other dishes.

TRAINING: Staff induction training includes anaphylaxis. Further training covers otheraspects of food allergies. Staff are informed about menu changes.

DIALOGUE: The use in dishes of nuts or other foods containing potential allergens is notpointed out on the menu. There is a general menu declaration, advising people withspecial dietary requirements or allergies to ask for the manager. The company has anadvice and instruction document, relating to communication with the customer, thatensures the hotel is prepared if a customer with food allergy asks for information. Thispolicy relates only to communication with the customer. At corporate events clients areasked in advance about special dietary requirements.

• The company had 3 cases of anaphylaxis last year. In one case, a wedding, they knewin advance that a boy was allergic to nuts. Everything was carefully controlled andchecked. When the boy went to bed, chocolates for the adults were brought out, whichhad almonds on top. Unexpectedly the boy came back into the room and ate one ofthe chocolates with a big visible almond on the top.

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In the other 2 cases the customers did not tell staff that they were allergic andpresumably assumed there were no ingredients that would cause them a problem.

Caterer 3SUPPLIER INFORMATION: As a company supplying products to the rail industry,additives and ingredients are discussed with clients at menu presentations, and thisdialogue includes nut derivatives and seeds. The company’s own suppliers are requestedto provide information about the presence of nuts and peanuts and possible cross-contamination during production and storage. Product labels are not considered useful forthis purpose and all ingredients and additives must be listed on the product specificationsheet, including the major allergens. Though information is requested from suppliers it isnot always forthcoming from international suppliers. The information is retained on adatabase, and copies of the specification sheets are passed onto the train operatingcompanies. Books containing menu information are given to members of the on-boardcatering staff. These state whether the products contain nuts, but not other major allergen-containing foods.

STORAGE AND PREPARATION: For nut-containing products, suppliers are requested tohave a separate production line and storage area, or to use the last production run prior tocleaning.

TRAINING: The company has received information from The Anaphylaxis Campaign.On-board catering staff have training on the subject of food allergy.

DIALOGUE: The company does not have a policy or advice for consumers with foodallergy. However, on-board catering staff have information on ingredients, and menusinclude the statement that ‘some items may contain nuts’. Other allergen-containingfoods are not highlighted. Staff are briefed as menus change.

Caterer 4SUPPLIER INFORMATION: Information is requested from suppliers about all uses ofnuts and peanuts and about the use of the other main allergen-containing foods. ‘Maycontain nuts’ labelling is interpreted by the company to mean a risk of extraneouscontamination and customers are warned accordingly. Ingredient information, received inthe form of a product specification sheet, is retained as a manual copy and is also storedelectronically. In addition, the label is considered a useful means of providinginformation.

STORAGE AND PREPARATION: Suppliers are not requested to follow any specialoperational procedures. Nuts are not stored differently to other ambient ingredients. Thereare no differences in the preparation of dishes containing these.

TRAINING: Information has been received from The Anaphylaxis Campaign. Thecompany has regular staff training that varies between the branded restaurants, but foodallergies are generally not included.

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DIALOGUE: On average 1 request per month is received about nuts/peanuts on theguest-care help line (company serves 1.5 million meals each week). There is a similarfrequency of requests for information about gluten, milk and shellfish. Customers aremainly informed about the presence of nuts/peanuts only where their presence contributesto the character or flavour of the dish. However, in some of the company’s brandedoutlets where there is more demand for information, the presence of nuts, milk andshellfish is highlighted. Staff are briefed as menus change and they can provide moredetails to customers if asked. Most restaurants in the chain have nuts on the premises andthe policy is to make customers aware that there is a risk of contamination in any product.

(b) Consumer ChoiceCaterer 1• Customers ask about healthy choices, the use of particular ingredients and how dishes

are cooked. Some menus show Weight Watchers points, and there is a programme ofsalt reduction for recipe dishes. Otherwise healthy eating is not a primary focus.

• Customers ask for vegetarian and vegan options. All menus show choices that aresuitable for vegetarians and staff can provide further details.

• Portion size (uncooked weight) is shown for steaks and gammons. Marketing terms(such as ‘fresh’ and ‘home-made’) reflect advice from the FAC. Country of originmay be used as a quality designation such as Scottish salmon, Spanish chorizosausage. Cooking methods are extensively indicated on menus.

Caterer 2• Healthy eating choices are indicated as ‘Lighter’ or ‘Healthier’ options on some

menus, or as ‘ticked’ products. Examples are grilled chicken, cottage cheese andpineapple.

• Healthy eating options not usually requested for events with a pre-set menu, e.g.weddings.

• Vegetarian dishes are available and are requested more frequently than vegan dishes.Staff are informed which dishes fall into these categories, and these choices are alsoindicated on the menu.

• The company undertakes a lot of corporate business and asks in advance forinformation about special dietary requirements.

• Menus indicate portion sizes. Marketing terms (such as ‘fresh’ and ‘home-made’) areused but the company is aware of legality issues. Menus also indicate country oforigin and cooking method.

Caterer 3• Customers do not ask for healthy choices. However, the company provides salads,

fish dishes, low-fat and low calorie products and low calorie beverages. Thisinformation is printed on menus. The company requests nutritional information fromall suppliers.

• The company provides vegetarian but not vegan options, and customers are informedabout the status of these dishes on the menu. Hence customers do not generally askfor information about vegetarian or vegan choices.

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• The uncooked weight of steaks is provided but not of other items. Marketingdescriptions are generally avoided. Regional labelling is used on the menu e.g. Welshlamb, but not country of origin labelling. The cooking method is generally indicated.Customers ask very occasionally about cooking methods, but not about portion size,fresh/home-made, or country of origin.

Caterer 4• Menus are generally moving more towards fresh steamed vegetables, char-grilling

and salads. Customers rarely ask for information about healthy eating choices.• Some suppliers provide nutritional information to the company. The menu is the main

source of information for customers.• Customers rarely ask for information about vegan choices, but there are generally 2

requests per month to the central guest careline about vegetarian choices. Vegetariandishes include broccoli bake, lasagne and various pies; there are no vegan dishes.Information about vegetarian dishes is printed on the menu.

• Use of marketing terms such as ‘fresh’ and ‘home-made’ are challenged internallywithin the company and there has to be filed evidence to support use of the claim.

• ‘British’ is sometimes used where traceability supports use of the term.• The cooking method is indicated in virtually all menu descriptors. Customers ask for

information about portion size, but not about country of origin or cooking method.

(c) Barriers and opportunities identified by the above caterers• Consumers with known allergies must be made more aware of the need to ask, and

not be made to feel a nuisance.• The challenge of obtaining accurate allergy information and presenting it as

consumer-friendly, meal-based information is practically impossible for small single-unit businesses, particularly as the 25% rule makes is difficult to assimilate allergendata.

• Staff need to have detailed product knowledge or easy access to it, and not just relyon discarded packaging.

• The onus should be on food suppliers to provide information in an easily accessibleformat.

• The main focus should not be on menu information/labelling, but on the requirementto maintain comprehensive reference guides ready for when the consumer asks.

• However, the retail and catering trades perceive the provision of information asdifficult and expensive, particularly the need for training in a sector with atraditionally high turnover of staff.

• Most emphasis from consumers is on allergens – there are more requests than forhealthy eating information and it is therefore important to prioritise allergens overhealthy eating.

• There is a danger that if it becomes practice for the more common allergens to beselectively listed on menus that a caterer could be liable to legal action if a lesscommon or unrecognised allergen produced a reaction.

• Web based solutions have a key role to play in the better provision of allergen andintolerance data to both restaurants and customers. In the near future all allergen and

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intolerance data will be supplied electronically and automatically downloaded ontothe product database via a Website. This will be a much more efficient means ofgathering allergen and intolerance data than the present method of using manualspecifications. The process of producing product data sheets and supplyinginformation to restaurants, customers and the care helpline can be automated, givingthe opportunity to have complete information available.

• However, two barriers remain that do not make extra controls commercially viable -the risk of contamination in the kitchen and the small size of the market.

(iii) Contract Caterer (n = 1)The company has different arms that include (1) Contract Catering e.g. for companies,hospitals and schools, (2) Retail Outlets e.g. at stations and airports, (3) MotorwayServices and (4) Leisure e.g. for one-off catering situations such as large events.Discussion with the audit department across the whole group is summarised below.

(a) AllergensSituations vary across the company, but there is an overall policy for food allergens andfood intolerance.SUPPLIER INFORMATION: Suppliers are asked for technical specifications includingwhether the products are free from a range of allergens. The only two possible answersare (1) ‘yes’ and (2) ‘no’. Suppliers are also asked for information about the productionfacility – i.e. are nuts present? Again the two possible answers are (1) ‘yes’ and (2) ‘no’.If yes, suppliers are asked what preventive measures are taken to avoid crosscontamination. International suppliers have to provide the same specifications as UKsuppliers. If a supplier says a product ‘may contain nuts’ the company wants to know‘yes’ or ‘no’. The company would investigate the factory, check their controls and askquestions.

STORAGE AND PREPARATION: In some catering units, the company has no nuts or nutoils on site. In others the indiscriminate use of nuts is avoided. However, where nuts andnut products are used they are not stored separately as there are limitations on space.Also, it would be very difficult to implement special operational procedures and checkthat these are being rigorously followed.

TRAINING: The company has its own training department and induction trainingincludes food allergy topics.

DIALOGUE: Customers ask about nuts, lactose and occasionally about gluten. Schoolsare the main clients that request information about nuts. Retail outlets display a statementabout the presence of allergens, advising customers to ask staff on display. Staff haveaccess to an operating manual in which they can check the product specification.Alternatively they can contact the audit department. The issue is more difficult to dealwith in the retail situation, as the customer wants to buy immediately. In a canteensituation, the customer is seen regularly and there is time to find out information and giveadvice. In catering units, staff are told daily what dishes are available and whatingredients they contain. In schools with allergic children, the schools would be told

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about the use of specific ingredients. However, there is never a guarantee that a productor dish is nut free, and so it is very difficult to give absolute information. For the brandedproducts that the company sells e.g. salads, the manufacturers state ‘may contain traces ofnuts’. In order to be more helpful to the nut allergic customer the company’s ownbranded products provide more information. For example, if the products are made in afactory with nuts but nuts are segregated, they state ‘made in an environment where nutsare present but every precaution has been taken to avoid their presence’.

(b) Consumer Choice• Healthy eating is a big topic in schools because of government guidelines. Product

specifications are requested and are checked for every product. A nutrition consultantis employed to deal with this.

• Other than for schools, it is up to the catering unit manager to source low fat andhealthy eating products depending on customer requests. Some in-house units havesandwich ranges that are less than 300 calories. The sandwiches have a healthy eatingstatement about being based on recommendations by BNF and government reportsaimed at reducing fat, sugar, salt etc.

• The company has healthy recipes to which all catering units have access.• Canteens offer vegetarian choices, indicated by shelf talkers. The dishes are

categorised as vegetarian according to the supplier’s definitions. Productspecifications are checked carefully to ensure cheese is vegetarian. The company’sown vegetarian logo is used on branded products where appropriate.

• Country of origin – when the dioxin problem and the animal-feeding problem inFrance arose, customers asked particularly about meat origin. With contract catering,these matters can be attended to individually, e.g. if a client asks for English applesthese can be provided, depending on the economics of the situation. Country of originis not flagged up on shelf talkers or labels. The company has the information andcould provide this detail if requested. However, the buying arrangements areconstantly changing, and thus country of origin may change.

(c) Barriers and opportunities identified by the above Contract Caterer• These issues are being discussed across the food service sector. One of the key issues

is supplies coming into catering establishments where there is no requirement toprovide on-pack information, as there is for retailers. For their own-label productssome wholesalers do an excellent job in providing information on the outer pack, butthis is not always available from branded suppliers. Smaller suppliers/wholesalers donot even know what a product specification is.

• A standard specification is needed with a legal requirement to provide a minimumlevel of information that has to be passed to caterers with the products. It should becommunicated on outer packs as a prerequisite.

• OFSCI (Appendix C) is one initiative that is discussing what information needs to beprovided. Manufacturers are putting their on-pack information on the UDEXdatabase. For food service they are deciding what allergen information should beincluded as a mandatory requirement. It can easily be accessed, making informationflow easier for everybody. Already 60-70 manufacturers are signed up, which

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accounts for 80% of the group’s suppliers. Niche suppliers e.g. patisserie bakers donot have the resources or back-up to comply.

• There needs to be legislation as there was for genetically modified (GM) foods. Untillabelling of GM ingredients became a legal requirement, suppliers would not providethe information when requested, saying there was no legal requirement to do so.However, once this became legal, the company was flooded with information.

• During discussion with the Government Services arm of the group it was explainedthat if a customer with food allergy informs staff, the catering unit manager will dotheir best to ensure that appropriate meals/dishes are provided. The companynutritionist checks the product specifications for suitability.

• The company has nominated suppliers for particular types of ingredients e.g. chickennuggets, but some dishes are home-made such as shepherd’s pie.

• In schools, parents let staff know that their child has an allergy to nuts or to otheringredients. The kitchen has a photograph of the child pinned up for recognition, andthere is a notice of what to do if the child has an anaphylactic reaction. Thenutritionist determines what the children can and cannot have, and special dishes canbe provided if necessary. Parents can see the product specifications if they wish.Sometimes parents provide dishes themselves.

• There seem to be more children coming through with allergies, especially to nuts.Recently two headmasters called in one day concerning children with nut allergies – itis unusual to have two such calls in one day.

• On the healthy eating side, chefs are advised not to use salt and not to put salt on thetable. They dry fry and do not use oil. The same generally applies to adult provision(e.g. Prisons, Police and Ministry of Defence).

• A vegetarian and a healthy option are provided each day.

(iii) Schools Policy (1 city council and 1 county council)• The county council policy is to avoid the use of nuts as an ingredient and to avoid

supplies that may contain nut traces, but there is no policy for other allergen-containing foods. The city council’s policy is that no peanuts or by-products areallowed.

• The county council has warning notices in the schools stating that they cannot be100% sure that all traces of nuts have been avoided. The city council has anarrangement that schools contact the council over such concerns.

• In practice, in both areas, schools have a list of children with allergies. The kitchensadapt menus to suit these children, on an individual basis.

• For healthy eating, the city council does not go beyond government guidelines. Thecounty council is very strong on healthy eating and its menus are nutritionallyanalysed. It focuses on buying the right foods and cooking them in the right way.They try to direct children to make healthy choices through pricing.

• Both councils have strong policies on avoiding certain food additives. The countycouncil felt that they probably did not communicate this very well and were not surehow aware teachers and parents were of the policy.

• Non-meat options are available every day in schools and this is communicated via themenu in both areas.

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• Other topics that parents ask about include BSE, dolphin friendly tuna andaluminium.

(iv) Hospital (n = 1)(a) Allergens• The kitchen caters for patients, visitors and nurses. Nothing is made in the kitchen,

everything is bought in ready-made.• In view of nut allergies they try to avoid buying products that contain nuts. Their

supplier has worked to ensure that products are nut-free. Products labelled as ‘maycontain traces of nuts’ are avoided.

• For patients, a nut disclaimer is printed on the menu stating ‘we cannot guaranteethese products do not contain nuts. If you suspect that you have a nut allergy, pleaseask the nurse’.

• The product specification and label are a starting point for information. The kitchenwill call the supplier’s dietitian if there are any specific queries.

• The hospital previously experienced a situation where their supplier changed aproduct and did not inform them that it now contained nuts. There were allergicreactions to the product.

• Where patients have other food allergies, the nurses are told and the patient is to beput on a special diet. Menus are adjusted for these patients individually.

• For the dining room (visitors and nurses), a nut disclaimer is not displayed, and thepresence of allergen-containing foods is not flagged up. Customers must therefore askthe staff, and requests may filter down to the kitchen.

• The kitchen staff do not have training on allergens/allergies. They get theirinformation via the dietitians, trade journals such as the Caterer, and they learn byexperience

(b) Consumer Choice• For patients, healthy options are flagged up with a heart logo, which is done by the

dietitians. Visitors or nurses must ask the catering staff, or rely on their ownknowledge of what is and is not healthy.

• Vegetarian choices are provided every day, are indicated with a ‘V’ symbol on themenu. Kitchen staff are rarely asked to cater for vegans, but can buy in appropriateproducts as necessary.

• If the kitchen staff were expected to provide more information to patients, visitors andnurses, they would print up and laminate the information, and display it for those whowant or need to read it.

(v) Group of Branded Chain Restaurants (n = 1)(a) AllergensThe company is aware of food allergies. Customers occasionally ask about nuts, but notvery often. When they do ask, it is usually about nuts in general rather than specific nuts.Customers do not often ask about other potential allergens as far as the company is awarebut some queries include a customer asking about gluten, and whether a dish was trulyvegetarian.

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SUPPLIER INFORMATION: The company does not rely on the label for informationabout supplies, mainly because of the 25% rule and because the law is vague for labellingfood supplies to caterers. The purchasing department retains the specification sheets.Suppliers are asked to indicate if products contain nuts. If the company cannot be assuredthat products do not contain nuts, they put an ‘n’ on the menu beside the dish concerned.The company does not have the same controls or traceability for other allergen-containing foods.

STORAGE AND PREPARATION: Nuts in kitchens are stored in separate containers, witha dedicated spoon, and are not stored above other foods. Special precautions are taken inthe kitchens and food handlers are trained not to get nuts onto other foods even fromcontact with the spoon used to handle them.

TRAINING: Food handlers and managers are trained in allergy, but the waiting staff arenot trained. Waiting staff are told to ask the duty manager if a customer has a specificrequest. In general, the company does not get many queries.

DIALOGUE: The presence of nuts is pointed out on the menu with an ‘n’ symbol. Thereis also a disclaimer that great care has been taken, but the company cannot guarantee theabsence of traces of nuts in other dishes. Solicitors were consulted on this. They do notflag up the presence of other potential allergens. Each menu has a telephone number andthe name of a person that customers can contact. A customer with nut allergy or othersevere allergy is welcome to enter into dialogue with the company, and information canbe ascertained from suppliers about the suitability of dishes for the customer’s needsacross the range of company restaurants. The company would go out of its way to behelpful to the individual if asked the specific questions.

(b) Consumer Choice• Customers do not ask about healthy eating. The company does not flag up healthy

dishes as this is not an issue in their restaurants. Customers are out to enjoythemselves! The company could get nutritional information if it was needed.

• The company does provide vegetarian dishes and these are indicated by a ‘V’ symbolon the menu. This means dishes contain no meat or fish. They do not provide vegandishes per se, but customers can make their own vegan choices e.g. from the saladbar.

• If asked, staff can provide more details about these matters, and questions sometimesfilter through to head office. The company can go back and ask its suppliers ifnecessary.

• Menus routinely provide the portion size of steaks and burgers. Some marketingterms are used, but less so following the Food Advisory Committee advice. Menus donot generally provide country of origin labelling, unless for quality purposes e.g.Italian sausage.

• Customers sometimes ask how dishes are cooked, if the menu has not fulfilled theircuriosity. But most realise burgers are grilled.

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• The company has home delivery for some of their Italian restaurants, but customersbuy from a flyer or have seen the menu, so they have the same details as on the menuwhen ordering.

(c) Barriers and opportunities identified by the above branded chain• Customers are out to enjoy their meal, and whilst the restaurant is doing everything to

protect the health of their customers with regard to microbiological matters and nutmatters, the company does not feel, unless it is advised otherwise by the FoodStandards Agency, that it wants to go any further. If told to, it will of course takeheed.

• A balance has to be struck to provide appropriate amounts of information. Thecompany helps with enquiries and enters into dialogue with customers and withsuppliers. It always does its best to help if there is a query to which it does not alreadyknow the answer.

(vi) Multiple Retailer – In Store Café (1)(a) AllergensSUPPLIER INFORMATION: The company requests information about all uses of nutsand peanuts and other major allergens. This is provided as a specification sheet, and theinformation is retained electronically. It is used to develop free-from lists, which areprovided for customers following a range of special diets. Labels and packaging are nottherefore used. Suppliers are requested to follow British Retail Consortium guidelines.

STORAGE AND PREPARATION: Nuts and peanuts are not used as a separate ingredient,and dishes containing nuts are avoided as far as possible. However where dishes docontain nuts and peanuts they are not prepared any differently to other dishes. Themajority of food items available are bought from the shop floor, and thus vary dependingon availability.

TRAINING: Information has been received from the Anaphylaxis Campaign, MAFF andthe British Allergy Foundation. Staff have regular training but allergies are not included.As the in-store cafe is a multi-skilled area training focuses on hygiene, particularly as thestaff change regularly.

DIALOGUE: Customers ask for information about nuts, milk, eggs, fish, shellfish, soya,maize, wheat, citrus fruit and various additives. The company points out the use of nutsbut does not differentiate between different nuts. It does not point out the presence ofother allergens where this is not obvious. Customers are advised by point of saleinformation that dishes could contain nuts and it is recommended that customers with nutallergies do not use the café or that they choose prepacked items.

(b) Consumer Choice• Customers ask about healthy eating options and the canteen serves products from its

own-label healthy eating range. Customers are informed about this via the menu.Nutritional information is requested from suppliers.

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• Customers ask about both vegetarian and vegan choices, and both are routinelyprovided e.g. vegetable curry. Customers are informed via the menu.

• No information is given about portion size, fresh/home-made, country of origin orcooking method and it is not known whether customers ask for such information.

(vii) Italian Restaurant (belonging to a chain) (1)(a) AllergensSUPPLIER INFORMATION: Most supplies are basic ingredients as most dishes arefreshly cooked in-house; they only buy in desserts. For desserts, ice creams, Danishpastries and ciabatta, label information is retained as these products are stored in theiroriginal wrapping. The restaurant could get further information about the ingredients ifthey asked their suppliers.

STORAGE AND PREPARATION: Nuts/peanuts are not stored differently to otheringredients. If a customer says he/she has an allergy the kitchen staff take extra care notto cross-contaminate his/her meal.

TRAINING: During the first 4 weeks of employment there is a programme of training,and then every couple of months staff have updates. All staff are trained about the menuso they can advise customers. The restaurant has received information about allergiesinternally from the company. Staff have a statement to sign in their Health and Safety fileabout having read the information and their awareness of the issue. Staff are trained toask the manager if anything difficult arises.

DIALOGUE: Customers ask about nuts and about other ingredients such as shellfish. It isnot always clear whether this is because they are allergic or for other reasons. Therestaurant usually has 4-5 requests/questions per week. The menu highlights dishes thatcontain nuts with an ‘n’ symbol and states, ‘there is a small possibility that nut traces maybe found in any menu item’.

Staff can provide more details if customers ask. For example if a nut-allergic customerasked for advice, they would check the product labels and would advise them not to haveany products labelled as ‘may contain traces of nuts’. Training to be the general managerincludes spending 3 weeks in the kitchen learning how all the dishes are made and whatthey contain. Staff know to ask the general manager or other managers if they cannotanswer queries themselves.

(b) Consumer Choice• Staff are aware of healthier products, as there is a list in the staff manual. They know

which products can be made without cream or butter, and can accommodate anyspecial dietary requests.

• Even if suppliers provide nutritional information, this is not used at the restaurantlevel. None of the desserts provided are viewed as ‘healthy eating’.

• Vegetarian choices are flagged up on the menu with a ‘V’ symbol. Vegan choices arenot indicated, but some dishes would be suitable for vegans and staff can help with

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identifying these. Also, dishes can be altered in preparation so as to make themsuitable for vegans. The restaurant has a vegan customer who comes in regularly.

• Staff can give specific instructions to the chef about how dishes should be preparedand cooked for individual customers, as everything is prepared on the premises, and iscooked to order.

• The portion size of steaks is given. The kitchen has specifications to work to forportion size. Chicken breasts are 225g and they have to work to set weights for pasta.

• Country of origin not a concern.• The menu in most cases states the cooking method used (e.g. grilled or oven-baked),

so the information is given up front.• The restaurant provides take-aways and telephone ordering. There is a take-away

menu from which customers can order and if any concerns arise, such as allergies, thestaff can deal with this in the same way as if the customers were in the restaurant. Thetake-away menu goes into as much detail as the restaurant menu.

(c) Barriers and opportunities identified by the above Italian restaurant• The general manager, in a previous job, had a customer with an anaphylactic reaction.

She had asked for no kiwi fruit without saying why. The chef had therefore removedthe kiwi fruit rather than making up a fresh dish and she had a reaction. He feltresponsibility for this incident was 50:50. Had she explained the seriousness of herrequest, a fresh dish would have been made.

• The restaurant feels that it would be good if people with allergies stopped thinkingthey are a problem, and are causing too many problems. There is a need tocommunicate to the public that allergy sufferers or people with specific requests arenot a problem and that they can be catered for. If they ask for advice they will havemore choice as dishes can be altered specifically to suit their needs.

(viii) Small and Ethnic Restaurants (n = 3)• Discussions with a single unit fish restaurant highlighted awareness of food allergies

and willingness to cater for special dietary requirements, which was indicated on themenu.

(a) AllergensSUPPLIER INFORMATION: The restaurant buys in basic ingredients and cooks withthese, so the problem of ‘may contain nut’ labelling does not arise. Products with hiddeningredients are avoided.

STORAGE AND PREPARATION: Nuts are stored separately, away from flour to avoidcross-contamination. Special procedures would be used to ensure no cross contaminationif they were catering for a nut-allergic person. Nuts are added to dishes as they arecooked and none of the pre-preparation involves nuts. Hence, if a customer is nut allergicall of the nut-containing dishes could be made without nuts. The biscuits made to beserved with coffee contain nuts. A roll of biscuits without nuts is kept in case someone isnut allergic, and these are cut separately to avoid cross contamination.

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TRAINING: Staff are briefed daily about the ‘special’ dishes. There are 3 kitchen staff, 4to 5 front of house staff per shift, out of a total 6 to 7 front of house staff. Staff are briefedbefore their shift about the menu.

DIALOGUE: Major ingredients are highlighted on the menu, but if a customer has anallergy, the front of house staff know what is in the dishes and how they are cooked andcan enter a dialogue with the customer to fulfil their requirements e.g. if the customer isallergic to milk or dairy products, fish can be poached in stock instead of milk. The menuwill shortly indicate the use of nuts, which is also seen as an advantage because of thepositive aspects of flavour from nuts. Customers with allergies are encouraged to ask thestaff. The ambience of the restaurant is catering for the individual. Customers do ask fornut free, and ask whether nuts are used in the kitchen. If this is a concern staff impressupon the customer that they are very careful and are aware of the fact that of small tracesare a potential problem. Customers also ask for gluten-free dishes. The restaurant avoidsusing wheat or flour in soups and sauces, so that customers with problems have morechoice. This also makes it easier for the kitchen staff if they are busy, as they don’t haveto make special alterations to dishes.

(b) Consumer Choice• No dishes are highlighted as healthy options, as such, since fish is a healthy food and

customers are conscious of this. However, some customers are not concerned aboutthe use of butter on fish and potatoes – and still feel they have eaten healthily. Somecustomers do ask about the use of specific ingredients such as butter and cream, andthese can be removed from cooking if desired.

• The menu has vegetarian dishes, and vegans can be catered for. The menu states thatthe cheese is suitable for vegetarians.

• Portion size is given for steaks only. Terms such as fresh and home-made are usedbecause all dishes are made on the premises, freshly that day. Staff sometimes enterinto discussions with customers about the origin of the fish, more as a talking point, asthey use fresh fish from around the world. Cooking methods are stated on the menu.Specials are described verbally including cooking method.

(c) Barriers and opportunities identified by the above fish restaurants• Listing everything on the menu would be unworkable. If someone says they have an

allergy the restaurant can cater for them. But they must say so and in the ownersexperience people with life threatening allergies do make this known.

• It appears that the number of people who say they have allergies is rising veryquickly.

Discussions were undertaken with two Indian restaurants. These were chosen becauseone declared nuts on the menu, whilst the other had a Website but made no reference tonuts. In the first case, discussion with a waiter highlighted that:• Many customers ask about nuts. They may ask for dishes with no nuts at all, or

sometimes without a specific type of nut.• All staff are trained and are aware of the issue of nuts. Precautions are taken in the

kitchen.

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• Some customers ask to avoid other ingredients e.g. flours or gluten.• Staff are informed and are able to help customers choose appropriately. For example,

a customer’s child needed to avoid dairy products and the waiter advised them not tohave pilau rice as this contains milk and butter.

• The management take notice of these concerns.• When asked about ‘may contain’ labelling on supplies, the response was that all food

is freshly cooked from basic ingredients.• Some customers ask about healthy eating and some for vegetarian and vegan dishes.

Vegetarian dishes are marked with a ‘V’ symbol but there are no symbols for healthyeating. There are healthy dishes on the menu, but the customer must pick them outthemselves.

In the second restaurant,• The proprietor was aware of concerns about food allergy, particularly in relation to

nuts.• All food is freshly cooked from basic ingredients. Nuts are stored in a separate

container on a separate shelf.• Dishes with nuts are cooked separately and precautions are taken not to transfer nuts

to other dishes. There is awareness of this. If someone is known to be allergic, thekitchen staff would be told to take precautions.

• All staff are trained in health and hygiene which includes allergies.• The restaurant staff have received information about allergies, have read about it in

catering trade journals, and have bought a booklet about food and hygiene.• There was the perception that the EHO checks everything – apparently including how

they deal with nuts.• Customers sometimes ask about nuts in general, and one customer has asked

specifically about almonds. On average, they get 1 enquiry per month.• Customers do not ask about other ingredients – they can see on the menu which

dishes have e.g. fish in them.• Some of the dishes that contain nuts are indicated on the menu – i.e. the specials that

provide information about the dish and ingredients. However, regular dishes do nothave this detail. For example, Chicken Tikka Masala does not state that it containsalmonds, and the proprietor considers that people already know this. In contrast,Kashmiri Chicken Tikka Masala is a speciality of the house and the description of thisindicates that it is cooked with fresh cream, almonds, fruits and masala sauce.

• The staff can advise customers with food allergies on the best dishes for them.• On healthy eating it is felt that ‘customers know better than us.’ There are lower fat

dishes on the menu, e.g. tandoori chicken, vegetable dishes, melon, plain rice, but thisis not highlighted and it is up to the customer to be able to pick these out.

• Many customers ask about vegetarian dishes, and there is a wide choice on the menu.Some customers ask for vegan dishes. There are separate sections on the menu forvegetable main dishes, vegetable side dishes and vegetable special meals.

• Customers sometimes ask how dishes are cooked. Customers are welcome to visit thekitchen, and the staff like to show customers the tandoori oven. The menu states that

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the kitchens are always open for patrons to view the preparation of tandoori and currydishes.

2.5.2 CONSUMER AND SUPPORT GROUPS

(i) Support (n = 2) and Consumer (n = 1) Groups• Based on work with food allergic people, Support group 1 considers the availability

of information about allergens, gluten-free and vegetarian foods to be more importantthan healthy eating and country of origin information.

• At delicatessen counters it is suggested that pre-printed pot lids and stickers are usedso that allergen risk information can be transferred to the goods. This can then be readby the end consumer at the point of use.

• Barriers include the large number of independent retail outlets, language and culturalbarriers, misunderstandings through communication, delays in using up oldpackaging, the need to design new signage for counters, and education of staff. Noneof these barriers are insurmountable.

• Based on personal opinion, Support group 2 responded that availability ofinformation about nuts and peanuts when eating out is the highest priority, closelyfollowed by information about other allergens. Information about low salt choices andcooking methods was considered to be of equal importance to the latter. Othernutritional information was considered to be of slightly lower importance, withinformation about ingredients used being of least importance. Information aboutvegetarian and vegan options was also considered of very high importance, closelyfollowed by information about organic and gluten-free status. The importance ofinformation when purchasing non-prepacked foods was considered to follow abroadly similar pattern to that when eating out.

• Cooking instructions for non-prepacked foods such as burgers, chickens and sausagesis considered to be very important, along with cooking instructions for pulses.

• Perceived potential barriers to progress are unwillingness on the part of caterers andretailers to implement potentially time consuming schemes and lack of standardised,easily recognisable symbols.

• The consumer group also thought that allergies are the most important issue of thoselisted (see Appendix B), and that all of the allergens listed are important, sinceallergens are important to the individuals concerned in view of the potentialconsequences of getting it wrong.

• The problem of providing misleading or unhelpful information is just as relevant fornon-prepacked foods as it is for packed foods, e.g. disclaimers on menus are no morehelpful than ‘may contain’ labelling on packed foods.

• It is important to provide cooking instructions along with other food safety handlingmessages, e.g. saying if previously frozen, and the best before date.

• The Scottish Consumer Council has a healthy choices award scheme that was set upas part of the Scottish Diet Action Plan in 1997. It is a prestigious national healthyeating award for caterers that covers all types of outlets (www.shcas.co.uk).

• Some findings from recent National Consumer Council (NCC) research on prepackedfoods are also relevant.

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The following findings are from unpublished research by NCC for the FSA and shouldnot be quoted until the NCC’s Report is published.• Consumers do not have time to read lots of information. Logos are therefore helpful

as a short cut, provided the logo is recognisable, trusted, and understood. Logos mayalso be helpful in relation to non-prepacked foods.

• Qualitative research indicated that diabetics would like better labelling of the foodsthat are suitable for them. They feel less well catered for than other diet-restrictedgroups. They look for sugar and carbohydrate information and choose products withno added sugar, sugar-free, and low or reduced sugar. Claims are less trusted thaningredient lists. As diabetics cannot check the sugar and carbohydrate content inunwrapped breads and cakes, or products from bakeries, the contents are assumed byguesswork. Diabetics are aware of advice to eat a healthy diet, but need a confidenceboost when choosing products to confirm that they are selecting the right foods forthem.

• As there is a wide range of reasons why people are vegetarian, definitions are moreimportant to some individuals (e.g. some religions) than to others.

2.5.3 ENFORCEMENT

(i) Environmental Health Officer (n = 1)An EHO in Bath was selected for interview as the council has had 2 deaths from foodallergies in the past 5 years. The first was Ross Baillie, an athlete at Bath University, whowas 19 years old. He ate a coronation chicken sandwich not realising that it containednuts. A second death, Anthony Wong, was due to eating crisps containing powdered milkat a friend’s birthday party.

The local EHOs were made aware of these incidents and wanted to publicise the issuemore widely amongst the public and caterers in their region. They wrote a report to theirLocal Councillor Committee in November 1999, highlighting the 2 fatalities, providingbackground information about the issues, and suggesting the EHOs pursue an awarenessraising campaign. The report was approved. The Bath Chronicle latched onto thecampaign giving it front-page headlines. The EHOs wrote to the local MEP and to thetwo local MPs, who responded to say they had brought the matter to the attention of theirparliamentary colleagues.

In addition, the EHOs wrote a simple letter informing local caterers about the campaign,and enclosing the MAFF awareness guidelines and stickers. They highlighted the tworecent fatalities and stated that businesses should make their staff aware of the issue. Theplan was to follow-up 6 months later but the EHOs could not afford the time. They weregoing to ask if staff in catering establishments had seen the document, recalled what itsaid and if they would know what to do if a food allergic customer asked questions. TheEHOs are aware of leaflets and stickers in a few premises, but new staff in the cateringestablishments may be unaware of the information.

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The EHOs have a registration pack that is sent out when food businesses register withthem, and this includes allergen leaflets. When they do inspections they do not officiallyinclude allergen issues, but officers in their region are tuned into this topic.They deal with a lot of schools and nurseries, and can discuss the food allergy matterswith those in charge. Nurseries are inspected frequently and on a recent visit, 2 childrenhad nut allergies and 3 had other food allergies.

The extent to which EHOs delve into allergen issues on routine inspections essentiallydepends on the business they are inspecting. In practice if the hygiene aspects aresatisfactory there is usually time to discuss allergies. If a company is lax on hygiene thisremains the main focus of discussion. It would be progressive to ask all premises if theyhave policies about food allergens.

Some types of premises call the EHOs for advice, such as nurseries and schools. TheEHOs can send out leaflets, or can refer people to websites such as The AnaphylaxisCampaign, IFST and other specialist informants.

(iii) Public Analyst (n = 1)The role of the Public Analyst is to advise EHOs on sampling and to offer advice. Thisincludes scientific advice about levels to which traces of allergens can be detected, butalso includes advice about interpretation of the law, and practicalities of food technologyof which EHOs may not have specific knowledge. For example, EHOs may not knowwhat is feasible or what is good practice in trying to avoid contamination with allergens.The public analyst can provide a source of information about what it is reasonable toexpect or advise the trader to do.

Public analysts regularly test for minute traces of nuts and peanuts, and also for allergenssuch as eggs, and for gluten. But this is mostly in prepacked foods. Sampling efforts aredirected towards prepacked foods, as the samples are easy to take. Public analysts do notundertake much analysis of catering-derived samples.

Mechanisms are needed to ensure that reliable supporting information is available for theend seller. There needs to be strong emphasis on traceability, possibly through anaccessible electronic database.

Demand for information has to come from the consumer through the caterer, butproducers need to be required to provide the information. Supplies would then be mucheasier to audit, from the primary sources.

If a trader claims a product or dish is nut-free, with a flag, or indicates this on the menuand it is shown not to be the case, the trader is liable to prosecution.

(iii) Trading Standards (n = 1)• For allergens and consumer choice matters there is a need to look at a whole chain

solution to improving information for consumers at the point of purchase/consumption.

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• For many foods sold to catering establishments, labelling is minimal because theFood Labelling Regulations (1996) allow information to be provided by means ofaccompanying documents e.g. invoices and delivery notes. Accurately transposingthis information onto menus or to the consumer via verbal descriptions would bedesirable.

• Highlighting in colour foods/meals that contain allergens could be considered.• The use of notices and expanded menus is attractive but care must be taken to ensure

that the consumer is not overwhelmed by so much information that other importantmessages are not seen.

• Although not universally true, it is likely that the smaller the business (particularly interms of numbers of staff) the more difficult it is for them to deliver on suchinitiatives.

2.5.4 MANUFACTURERS – OF FOODS FOR CATERING AND FOODS SOLDNON-PREPACKED

Feedback is presented under the headings food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’. Examples of barriers andopportunities given by the respondents are also given.

(i) Large Manufacturers (n = 3 - 1 branded, 1 own-label, 1 ingredients/own label)(a) Allergens• All respondents were aware of food allergies as an issue.• All responded that suppliers are requested to complete a specification sheet

concerning the presence of all the main allergens, and the possibility of traces of nutsbeing present. One company asks for information about the possible presence of allthe main allergens.

• Information is retained electronically and may be used to develop ‘free from’ lists, fordeclarations on products, and for other labelling purposes.

• Ingredients suitable for nut-free products are distinguished by use of these supplierdeclarations and assessment of the risk of cross contamination.

• For nuts, suppliers are audited to understand the risk of cross contamination to otherproducts. However this is not the case for the other main allergens.

• The branded manufacturer receives many requests about the suitability of products fornut allergy sufferers, but questions about other allergens are less frequent.

• The own-label manufacturer is requested to provide information about all the majorallergens by its clients. One problem is the lack of agreement of what is a nut, as somecompanies regard coconut as a potential allergen- containing food and others do not.

• All three manufacturers have robust controls (GMP and HACCP) where nuts areused, to ensure that cross-contamination is avoided, e.g. in one case where nuts areused everything is colour coded red – red aprons, gloves, labels, sleeve guards, aseparate cooking vessel for nuts only and signs to say nuts are in use.

• All companies have staff training about allergy issues beginning with inductiontraining.

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(b) Consumer Choice• One company has no healthy eating products, another makes products tailored to their

clients’ requirements and the branded manufacturer gave low fat dressings and salt-reduced soups as examples of healthy eating options for catering establishments. Forthese products nutritional analysis is provided and claims are made on the labels.

• All of the companies manufacture vegetarian products, in some cases by defaultrather than by design, and these are marked with logos.

• Instructions are routinely provided where products require further cooking.• The own-label manufacturer provides comprehensive information, e.g. for retailer

take-away meals. The information is used in the retailers’ ‘counter book’ and coverslogos, cooking instructions, ingredients, nutritional information, storage life etc.Information is thus available to the store staff if the end consumer has questions.

(c) Barriers and opportunities identified by the above large manufacturers• Clarity is needed for the top 5 list of allergens so that these are dealt with consistently,

across the industry.• If the FSA recommends that allergens must be indicated on non-prepacked foods or

catering foods, reliance will be on companies complying with this guidance. How iscompliance monitored – who does it, how, and who pays? A counter view is thatproviding this comfort blanket for the consumer could cause a problem.

• The onus should be on the consumer to take responsibility for the foods they choose,in light of information provided by the industry.

• There is the potential for too many logos on any given pack.• In the future, Internet and carelines will provide up to the minute information. It will

also be possible to send updated ‘free from lists’ automatically to people registeredwith a company, when the lists change (this is currently done for nuts by the brandedmanufacturer but not in an electronic format).

• Food Hygiene has been accepted as a standard qualification in catering outlets. Couldthis be ‘piggybacked’ to educate staff about allergies in a more detailed andsystematic way?

• A scheme similar to the Heartbeat Scheme could be put into place in outlets that are'allergy aware'. Outlets could be assessed and recognition given to those that reach agiven standard signifying that allergy sufferers can eat there with confidence. Therecould be a formal test to pass with a certificate and sticker awarded. EHOs and localdietitians could collaborate on this, as with other schemes.

• Education will be the hardest challenge as English is not the first language of manystaff working in catering outlets.

• There is a danger of making catering establishments so wary of allergies that theyconsistently advise sufferers to avoid dishes just in case.

• Cost will be the primary restriction for many businesses.• Standards imposed must be the same internationally so that UK and European

business are not adversely penalised.

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(iii) Small Manufacturers (n = 4)• A manufacturer of desserts for the food service, retail and airline sectors

highlighted that the product information requested by their clients is pushed up thesupply chain to their suppliers.

• The manufacturer demands a specification sheet for every raw material that they use.Where multi-component ingredients are used they know the exact proportion of eachcomponent. Information is requested from suppliers about the presence of nuts andother major allergens. This information is kept as specification sheets.

• Suppliers are audited and the company only buys from approved suppliers. Belgiumand French suppliers have to provide the same level of information as UK suppliers.

• Information flow to the end consumer depends on where the product ends up – if in aretailer, communication procedures are generally in place. If in a pub via awholesaler, there is no control over retention or communication of the productinformation.

• The company is BRC accredited, and this covers HACCP and nut controls e.g. nutsare stored separately, have distinctive marking (yellow), and there are batch controls.

• Staff receive training that covers operational procedures, batch control, nut control,HACCP etc.

• As nuts are used in their factory, all products are labelled with nut warnings as it isnot possible to give a cast-iron guarantee that the products are nut free.

• There are no specific healthy eating products made. Vegetarian products carry a logoor statement.

• A manufacturer within a large manufacturing group highlighted that the companyrequests information from its suppliers about all the main allergens. The informationis retained as specification sheets. Suppliers are also requested to have specialoperational procedures in respect of allergens. The company’s clients all request thisinformation for nuts, possible traces of nuts, and for other allergens. The company hasspecial operational procedures in respect of nuts, and all staff are trained in thecompany nut policy. The company provides vegetarian dishes, but these are notlabelled as such.

• Discussion was also undertaken with a very small manufacturer of chocolates anddecorations, set up 15-16 years ago. The company buys in chocolate and melts itdown into shapes. As nuts have not been used in the factory for at least 7 years, thecompany claims to be nut-free.

• They make after dinner mints for hotels and restaurants. Labels state that theseproducts are nut free and GM free.

• However, they do not always flag up products as nut-free and believe they couldprobably make more of this in their marketing.

• Their products are mostly sold in bulk to third party distributors/wholesalers withvery few sold direct to the end retailer.

• Their customers include catering chains, retail (including mail order/in-home parties –‘once customers became aware that the products are nut-free, sales went through theroof’), ingredient suppliers and wholesalers.

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• Their large customers ask for product specifications and also audit the factory. Thecompany has its own independent external auditors, which includes the nut-freeaspect.

• Smaller customers do not ask for product specifications.

• A second manufacturer and importer of edible chocolate decorations from ECcountries said that any initiative in respect of nut-free would come from their clients.Most chocolate factories have nuts in them. It therefore cannot be assumed there areno traces of nuts in chocolate products, e.g. chocolate cakes on a dessert trolley,unless they are made in a nut-free processing environment.

• Information flow through the food service supply chain was outlined by thesecretariat to a committee of manufacturers of products for the Food Service Sector.Large catering companies, in response to customer requests, ask their wholesalers forrelevant information about the products. These questions filter down to themanufacturer, who responds to the questions asked. The information is fed back viathe same route to the end operator, such that customer questions can be answeredaccurately.

• The intention in future is to do this electronically, via UDEX. This will includeinformation about allergens, not just for food service but also for the retail chain.

2.5.5 RETAILERS - FOODS SOLD NON-PREPACKED

Feedback is presented under the headings food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’. Examples of barriers andopportunities given by the respondents are also given.

Multiple Retailers (n = 3)Non-prepacked foods include bakery, deli, fish, fruit and vegetables, hot cooked chicken,meat and meat products, pick-and-mix confectionery, pizza, take-away meals, salad bar,and customer café, which includes cakes, sandwiches and hot meals.

(a) AllergensAll are aware of the issue of food allergies.

Retailer 1SUPPLIER INFORMATION: All suppliers provide information about the presence of alluses of nuts and peanuts including potential traces, and all uses of other main allergens.‘May contain nuts’ labelling is assumed to reflect well-controlled systems and notice istaken of the information. The information is supplied via specification sheets and retainedelectronically. Hence, the presence of potentially allergenic ingredients is known for allof the non-prepacked product ranges.

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STORAGE AND PREPARATION: Special operational procedures are requested of allsuppliers in relation to nuts/peanuts and gluten.

TRAINING: The company has regular staff training that includes allergies.

DIALOGUE: Supplier information is retained as product lists and in counter guides. Itcan be made available to customers at their request. Display tickets indicate products thatcontain nuts/peanuts. Staff are also informed and can answer questions. Where there is arisk of cross-contamination, counters and shelves carry warning labels that products arenot suitable for allergy sufferers, e.g. in-store bakery products.

Retailer 2SUPPLIER INFORMATION: The company requests all suppliers of its own-labelproducts to provide information about all uses of nuts/peanuts and other main foodallergens, as part of the comprehensive product specification. If products are labelled‘may contain’, the product specification would clarify what was meant and the reason forthis. The specification is received as hard copy, but will eventually be in electronicformat. It is retained on paper and re-keyed to retain electronically. It is used to answercustomer queries, and requests from support groups.

STORAGE AND PREPARATION: Suppliers are required to carry out a HACCP for nuts,and are assisted to develop appropriate controls. They are expected to apply GMP toeliminate cross contamination of products.

TRAINING: The company has regular staff training but this does not include foodallergies. However staff are trained on the problems of nut allergies and to keep theproducts separate e.g. on the deli counter.

DIALOGUE: Customers ask if products contain nuts and also egg, milk and wheat. Thereverse of the display ticket indicates products that contain nuts and other allergens andthe server can therefore provide this information. The provision of this information isaudited regularly and it is considered a serious offence if it is not present. The staff canalso contact head office for more information. However, in most instances customerswith food allergies are advised to purchase pre-packed products. Notices at the servicecounters advise customers with nut allergy (includes sesame seeds) that all products fromthe counter are not considered suitable for them. The company does not use the phrasemay contain nuts, and prefers to state ‘not suitable for nut/sesame seed allergy sufferers’,as this is felt to have more meaning for the customer.

Retailer 3SUPPLIER INFORMATION: The company requests information from suppliers about alluses of nuts and peanuts and other major allergens. This is collected via a specificationsheet, and the information is retained electronically or as hard copy. It is used to develop‘free-from’ lists and the information is held centrally.

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STORAGE AND PREPARATION: Suppliers are requested to follow the BRC nuthandling guidelines, as for pre-packed products.

TRAINING: The company has regular staff training, which includes allergies. However,staff are not briefed on changes to products or dishes as there are too many products.

DIALOGUE: Display tickets indicate products that contain nuts and peanuts, andcustomers also ask for this information. They also ask about a wide range of otherpotential allergens. Point of sale notices advise customers to avoid the area if they havean allergy, as products containing nuts/peanuts are not displayed differently to otherproducts.

(b) Consumer ChoiceRetailer 1• Customers ask about healthy eating options, and the use of specific ingredients such

as cream and butter, but rarely ask about the cooking method.• Display tickets highlight healthy choices. Other information provided about non-

prepacked foods includes calories and fat per 100g serving, a salt indication, andadditive information.

• Customers ask about vegetarian and vegan choices. Such products are highlightedwith display tickets, and staff can provide further information.

• Shelf-life information is provided, marketing terms are used as applicable, andcountry of origin is indicated as legally required. Customers rarely ask about shelf lifebut do ask about country of origin.

• For sales and delivery via Internet ordering, customers are informed via vegetarianlogos, organic logos and healthy product indications as they order.

• Cooking instructions are provided on bags for fish, and for take-away meals.

Retailer 2• Customers ask about healthy eating options and about cooking methods. The

company provides lower-fat items on the salad bar and customers are informed aboutthese through display tickets. Staff can also provide more details if asked.

• The company provides both vegetarian and vegan options. Customers are informedvia the display tickets and staff can provide more details if asked.

• Descriptions such as ‘fresh’, ‘home-made’ etc. are used, shelf life information isprovided, and the country of origin of some ingredients is also provided.

• Customers sometimes ask about the country of origin of ingredients.• Sales by telephone and Internet are provided. There is an information icon against the

product on the Internet, which displays product details when ‘clicked’. When orderingby telephone, the call centre can access this information.

• Cooking instructions are provided on the label that is printed out at the meat counter.In other sections, the counter will have information that can be provided by staff onrequest.

Retailer 3

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• Customers ask about healthy eating options. Examples of healthy options includelow-fat cheeses. Customers are informed via display tickets, but nutritionalinformation is not provided.

• Customers ask about vegetarian and vegan choices, and are informed about the statusof these products via display tickets.

• Other information routinely provided includes use-by date and the country of origin(via display tickets). Cooking method is not indicated.

• Customers ask about shelf-life and country of origin, but not about fresh/ home-madeetc or about cooking method.

• Where customers with allergy purchase over the Internet, they are advised to choosefully labelled pre-packaged products.

• Cooking information is not routinely provided for raw or uncooked products soldnon-prepacked.

(c) Barriers and opportunities identified by the above retailers• It is felt that research is needed to ascertain consumer information priorities for

different foods so that limited space can be used for the most appropriate information.• Flexibility is important – e.g. just providing fat and calories rather than full nutrition

labelling.• The small size of the counter indicators is a potential barrier to providing a lot of

information.• Customers need to be made aware of what ‘may contain’ labelling really means.• Any proposals should be in the form of a goal-based framework, rather than

‘specifics’.• Consideration should be given to the different capabilities of large retailers and small

corner shops, as a one-size fits all approach is a potential barrier to progress.

Sandwich Retail Chain (n = 1)• Discussion with the Customer Service department at Head Office indicated a low

awareness of allergy issues. For example, pesto is added to salad dressings forflavouring and salads have only recently been labelled ‘Contains Nuts’.

• Also, a customer pointed out that where toast is offered with a choice of marmalade,marmite or peanut butter, there needs to be a separate knife to cut the peanut toast toavoid cross contamination.

• Most sandwiches/salads are made in their own central production unit and are soldpre-wrapped.

• Hot torpedoes (baguettes) and toasties are sold non-prepacked, and are preparedbehind the counter. ‘Nuts are not handled behind the counter’ – except where peanutbutter is used for toast. The expectation was that if a customer had an allergy andasked for information about these unpacked items the shop staff (most are notEnglish) would advise them to call Head Office - the telephone number is printed onall of the bags.

• There did not appear to be any formal staff training process.• Mixed sandwich platters are delivered to offices. The sandwiches are cut in the local

store. No label information is available with the platter, but specific requests for

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information could be made to the local store or preferably to customer services athead office. However, on dietary restrictions the company currently only caters forvegetarians.

• On consumer choice matters, following a lot of requests about the fat content ofsandwiches by people on weight reducing diets and requests about vegetarian options,the company is now starting to provide nutrition labelling on all sandwiches and a ‘V’logo where appropriate. They tend not to be asked about the fat content of the hottorpedoes – their customer research shows that men generally purchase the sausagetorpedoes, while women worry about fat content, and women on diets are unlikely topurchase a sausage torpedo!

• They are not asked for country of origin information.• Discussion with Operations at the Central Production Unit outlined the large

number of products (i.e. ~ 160 different sandwich fillings), and the high turnover ofproducts. They maintain a robust database of raw material data.

• The unit has recently achieved British Sandwich Association accreditation.• Because of the use of nuts in the factory, and the long run lengths, all products are

being marked with nut warnings.• If in the future other establishments were supplied (in addition to their own stores) the

same level of information would be available for the products. The information wouldbe supplied either about individual sandwiches or for trays of sandwiches, butcommunication of the information to the end consumer would be the caterers’responsibility. However, customers could always call customer services at head officewhere there is access to a database with a lot more information than can be printed onthe labels.

Small Retail Shops (n = 2)• Both are aware of food allergies.• The Craft Bakery shop has a list of products behind the counter that are not suitable

for people with special dietary requirements such as nut-free, egg-free and dairy-free.• Customers do ask for information – most requests about nuts are in relation to

children, but requests are now less frequent as nuts have been taken off someproducts. Queries about wheat tend to relate to more mature individuals. Somecustomers also ask about milk and dairy ingredients.

• Customers are not informed up front about specific ingredients and the shop relies oncustomers to ask. The only exception is that vegetarian pies are sometimes flagged upif they are on special offer.

• Staff are not trained and give advice based on their own personal experience e.g. howto reheat pies. If staff have any doubt about customer queries they telephone the mainbakery where the products are made.

• Separate discussion with the main bakery confirmed that they request technicalspecification sheets for all ingredients that they buy in. If a customer phones with anenquiry they can then provide relevant information. Customers do ask about nuts,whey powder, dairy ingredients, animal and vegetable fats and E-numbers.

• The company is a small craft bakery, they have only one set of equipment, they douse nuts and therefore they would advise those with nut allergies that their productsare not suitable.

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• Deli/butcher/bakers is also prepared if customers ask questions. Staff are trained toanswer queries (they have all undertaken mini HACCP training), and know to ask thebaker or look at the recipes and ingredients for specific dietary requests. Everything ishome-made on the premises and ingredients are kept in the original boxes so that thelabel information is retained. Staff will know the shelf life of products if asked.

• The establishment is well aware of the issue of allergies as the proprietor’s niece hasnut allergy, and they make gluten-free sausages and burgers for coeliacs. These aremade in batches to order, and the shop is on a support group list as a supplier of theseitems.

• On the healthy eating side they make low-fat sausages, and customers ask for these.They are not labelled or flagged up as low fat.

• They did make a range of vegetarian pies and pastries, but demand was not as high asexpected. They make 15 quiches of which only 3 contain meat. If customers don’tknow, it is up to them to ask which are vegetarian.

• The printed price list indicates the portion sizes of the hot and cold eating pies. It alsodetails the different types of quiches available, and the range of all the other home-made products such as desserts, gateaux and salads.

• In both shops there is no attempt to communicate the presence of nuts or otherallergens to consumers. They rely on the consumer asking for this information.

• In the Deli/butcher/bakers there are opportunities to do so e.g. home-made carrotcake is presented in a box which provides the opportunity to indicate that it containsnuts. Waldorf salad is printed on the price list, but there is no mention that it containsnuts.

• However this raises the question that if nuts or other ingredients are indicated in thesecases, will consumers then perceive that they are being told in every case. Any changein consumer expectations could have implications for them asking for information.

WI Market• Aware of the issue of food allergies.• Home-made products sold at the WI markets all have a list of ingredients, and there is

a WI market ruling that if products contain nuts they have to be labelled as ‘ContainsNuts’ or attention drawn to the nut content by underlining or ringing in red. Thisincludes coconut.

• Other potential allergens are not treated in this way.• Reheat instructions are given on pies and Christmas pudding, but not on everything.

All products are labelled with the date they were made.• There are no rules for vegetarian dishes in the WI market ‘Bible’, but in this case a

vegetarian makes the dishes so it is assumed that she knows what is appropriate.Dishes are marked as ‘Suitable for Vegetarians’.

2.5.6 WHOLESALERS

Feedback is presented under the headings food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,

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portion size and use of descriptors such as ‘home-made’. Examples of barriers andopportunities given by the respondents are also given.

Large Delivered Wholesalers (n = 2)(a) Allergens• Both are aware of the issue of food allergies• Clients purchasing products buy from a list and do not have access to the ingredients

at the decision of purchase. Hence they enquire of the wholesaler whether productsare free from certain dietary items, for both own brand and branded products.

Wholesaler 1• Receives approximately 5 requests per week about nuts, 5 about gluten, and fewer

about eggs, milk and soya. For own brand products all ingredients, including nuts andthe main allergens, are indicated via the ingredients list and via their Website.Branded product information is not available on the Website.

• There is a nut policy for own brand products - GMP procedures are to be followed,main allergens must always appear in ingredients list, and the list of nuts includescoconut. There is also a policy for gluten-free and for the other main allergens, whichis essentially to provide a list, and there is a general policy to make full ingredientsdeclaration.

• All suppliers are requested to have HACCP procedures in place for handling nuts.The company requests information about all uses of nuts and peanuts, and the othermain allergens. The company expects suppliers to only declare nuts when they areadded to the product.

• Information from suppliers is received electronically, stored on a database, and ispassed onto customers in the form of ‘allergy lists’ and advice on individual products.All foods and ingredients are traceable throughout production.

• International suppliers have to provide the same level of information and standards asUK-based suppliers

Wholesaler 2• Is currently working on its own-brand labelling and communication of the possible

presence of allergens. They want to keep the questions they ask suppliers about thepossible presence of allergens to a minimum number of allergens.

• Supplies are despatched in large boxes and there is an opportunity for informationprovision on the box. There is also the opportunity to provide information on the innerpackaging, which is usually kept when the outer packaging is discarded. However,this has cost implications, as their packaging suppliers will have to invest in newmachinery to be able to print onto the inner packaging.

• The company operates a 40-hr/week advice centre, which receives 1000 calls permonth. Approximately 700 per month are on these topics, e.g. requests for a list of nutfree products? Are particular products free of a certain ingredient? It is the exceptionrather than the rule that clients ask for this level of information, but the sizeablenumber that do ask still presents a resource challenge. If the need to have informationincreases and more companies ask, the company would not be able to handle this.

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• They are only ever asked about allergens on the EU list, but have not been askedabout sulphite.

• They obtain written confirmation from the manufacturer of branded products statingthe product is e.g. nut free, and this statement is passed on to their client.

(b) Consumer ChoiceWholesaler 1• Receives approximately 2 requests per week about healthy eating options, and

information about their healthy eating products is communicated via their help lineand Website.

• Though nutritional information is provided on own-brand products, clients alsorequest further information.

• Requests for vegan products run at about 5 per week, while vegetarian options areindicated on the price list. Further advice is available via the help line and Website.

• Portion sizes, country of origin, and cooking method are provided and the companygets requests for information about all of these matters.

• When ordering on-line or by telephone, customers have access to information via anintranet, and access to an information service.

Wholesaler 2• Some products would fit into a healthy eating category, but they do not specifically

target healthy eating. Nutrition information can be obtained from suppliers, if a clientrequests it.

• Own-brand products are labelled as suitable for vegetarians where applicable, butproducts are not labelled as suitable for vegans as this is very specialised.

• Country of origin is not really a problem. Portion size guidelines are given, marketingterms are being phased out, and packaging information gives recommended cookingmethods.

(c) Barriers and opportunities identified by the above wholesalers• Both wholesalers indicated the potential of web-based information and suggested that

the forthcoming UDEX scheme being developed by OFSCI should be furtherinvestigated.

• The need for a definitive list of nuts was highlighted – despite attempts forconsistency across industry, companies are still working to different lists e.g. there aredifferences of opinion about the inclusion of coconut and pine nuts.

• There should be a priority list of allergens.• There is a need for standardisation of information formats and requirements. It

presents a problem if large companies choose to make their own criteria and standardsthat are different to the norm.

• Because it is very difficult to get information from branded suppliers, particularly thesmaller companies, it should be made a legal requirement to provide the information.Smaller companies are unlikely to comply with a code of practice or with goodpractice guidelines. Only 50% of delivered wholesale for catering is through largewholesalers; the rest is through many small companies.

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2.5.7 SUMMARY OF KEY POINTS

The in-depth exploration enabled a detailed discussion of the issues with representativesof the different industry sectors. Many practical points were raised, and suggestions tohelp make progress included:• Clarity is needed for the top 5 list of allergens so that these are dealt with consistently,

across the industry.• The need for a definitive list of nuts to ensure a consistent approach across the

industry.• The need for a legal requirement to provide a minimum level of information that has

to be passed to caterers with the products.• Standardisation of information formats and information requirements that apply

consistently across industry.• The need to embrace the potential of web-based information in the future.• The development of standard minimum qualifications or training to ensure those in

the industry are informed about allergies in a systematic way• An allergy aware scheme for retailers and catering establishments.• Consumers with known allergies must be made more aware of the need to ask, and

not be made to feel a nuisance.• Emphasis within catering establishments on the requirement to maintain

comprehensive reference guides ready for when the consumer asks for information,rather than on menu labelling.

• Prioritise information for use on non-prepacked foods and in catering establishments -e.g. provide fat and calories rather than full nutrition labelling. Consumers’ prioritiesshould be established through research.

• Any proposals should be in the form of a goal-based framework, rather than‘specifics’.

A number of barriers were also highlighted. These are summarised below:• Recommending that allergens must be indicated on non-prepacked foods or catering

foods, will place emphasis on compliance which will be very difficult to police.• The potential for too many logos on any given pack or menu.• Education will be the hardest challenge particularly where catering staff do not have

English as their first language.• Cost implications were seen as a major barrier, particularly for smaller companies.• Standards imposed must be the same internationally so that UK and European

business are not adversely penalised.• Meeting the challenge of obtaining accurate allergy information and presenting it as

consumer-friendly meal-based information is practically impossible for small single-unit businesses, particularly as the 25% rule makes is difficult to assimilate allergensdata.

• There is also a danger that if the more common allergens are routinely listed onmenus that a caterer could be liable if a less common or unknown allergen produced areaction.

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• Consideration should be given to the different capabilities of large retailers and smallcorner shops, as a ‘one-size fits all’ approach is a potential barrier to progress.

• The perception that providing information is difficult and expensive, particularly theneed for training in a sector with a traditionally high turnover of staff.

• For non-prepacked foods, the small size of the counter indicators is a potential barrierto providing sufficient information.

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3. REVIEW OF INTERNATIONAL PRACTICE

3.1 INTRODUCTION:

Although this project is investigating issues relating to the UK, many of these topics arerelevant to a number of countries. The food industry has become increasingly global andit is not uncommon for ingredients to be sourced in one country, a product manufacturedin another then distributed and sold in a third country. Therefore, it is important thatcompanies that function in this international environment share their perspectives in thisproject. It is equally important to learn from what other organisations have already done,in terms of developing guidelines and setting up initiatives.

3.2 METHODS:

Self-completion questionnaires with an international focus were sent to someinternationally-based companies. Information was also gathered via in-depth researchwith companies with international operations. Information on international initiatives wasgathered using an extensive web-based search and information from the self-completedquestionnaires and in-depth research. The Food Labelling Standards of CodexAlimentarius and relevant EU legislation were also referred to for any information onthese topics.

3.3 RESULTS:

3.3.1 SELF COMPLETED QUESTIONNAIRESSeveral international organisations and companies returned questionnaires. Responsesfrom the 3 international manufacturers did not differ greatly from those based in the UK:• If not routinely provided with information about nuts/peanuts and other allergens, this

information is requested• The information obtained via specification, memo or list provided by the supplier is

then incorporated into the final product specification and/or label• Only 1 of the 3 requested special operational procedures from suppliers in relation to

nuts/peanuts and none requested this for other food allergens• Some immediate clients (i.e. caterers) request information about the presence of

nuts/peanuts and other food allergens• Nuts/peanuts are often stored in a separate area, with distinct labelling, but only 1 of

the 3 respondents has special procedures in place for preparation of productscontaining these

• Staff are aware of products containing nuts/peanuts and are briefed when ingredientschange, but training does not seem to be common

• 2 of the 3 respondents produce ‘healthy eating’ choices and use claims and nutritionalanalysis to inform clients about the composition of these products

• 2 of the 3 produce vegetarian products and 1of the 3 produces vegan products. Not allof these products carry logos/statements

• Comments received from these international companies include:

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‘UK usually good – rest of Europe improving’ with regard to information provided bysuppliers on food allergies and providing nutritional information‘Educate consumers to ask questions’

Two non-UK based consumer and support groups returned questionnaires. One suggestedwarning food-allergic individuals never to eat anything unless they know all of theingredients. At restaurants, food allergy sufferers should speak directly to the manager orchef and inform them of the food allergy, its severity and what they need to know aboutthe cooking techniques and ingredients.

3.3.2 IN-DEPTH RESEARCH

Information gathered from the in-depth research about international suppliers andoperators indicates that, in most cases, international suppliers to UK companies have toprovide the same level of information as UK suppliers. Companies with internationaloperations were able to give a perspective about these issues in other countries (a hotelchain, a contract caterer, a branded manufacturer and a retailer). They generallycommented that information provision is less of a concern in other parts of Europe,particularly Southern Europe, compared with the UK, and it appears that the UK is moreadvanced in these issues compared to other countries.

Feedback is presented under the headings food allergy and consumer choice, the latterincluding healthy eating options, cooking method, vegetarian, vegan, country of origin,portion size and use of descriptors such as ‘home-made’. Examples of barriers andopportunities given by the respondents are also given.

Hotel Chain (n = 1)(a) AllergensFor operations in Europe and Africa there was awareness of concerns about food allergy.

SUPPLIER INFORMATION: Suppliers are requested to provide information about thepresence or possible presence of nuts. Note is taken of supplies labelled ‘may containtraces of nuts’. Suppliers also provide information about the other main allergens, but thisis in accordance with national and international laws, which vary from country tocountry.

STORAGE AND PREPARATION: The kitchen chef and the purchasing manager recordinformation about the presence of allergens in supplies. They review all products instorage and/or in use in the kitchen. The information is recorded in a reference book. Theinformation is passed onto customers on request. The use of nuts and peanuts in kitchensis not treated differently to other ambient ingredients, and there are no special proceduresfor preparing dishes containing nuts.

TRAINING: Staff are informed about changes to the contents of dishes as menus change.Regular staff training includes allergies - there is on-the-job coaching and training, andoff-the job training sessions. The company has received information about allergens

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through the national, regional and/or local health and sanitation organisation within eachcountry.

DIALOGUE: The menu highlights the use of main ingredients, such as fish, andcustomers ask about nuts and peanuts, seeds, gluten, but the number of requests variesbetween hotels. Main ingredients and condiments are listed on the menu. The followingstatement is printed on the menus ‘For those with special dietary requirements or allergieswho may wish to know about the food ingredients used, please ask for the manager.’

(b) Consumer ChoiceCustomers ask about healthy eating choices, the use of ingredients such as cream orbutter, and the cooking method. Healthy eating choices are provided, and this is indicatedon the menu. Staff can also provide details if asked. ‘Follow your Colour’ is a keycomponent of the recently launched breakfast concept that provides information about thenutritive value and ingredients of food items. Nutritional information is requested fromsuppliers.

Customers ask about both vegetarian and vegan choices and both are provided, althoughthis varies from one hotel to another and reflects the local/regional and seasonal foodoffered. These dishes are indicated on the menu.

Portion size is indicated for meat and shellfish such as lobster. Descriptions such as‘fresh’ and home-made’ are used, the country of origin is applicable to meat andvegetables, and the cooking method is also indicated. Customer requests for thisinformation vary between hotels.

When telephone sales are taken, staff can refer to the reference book.

(c) Barriers and opportunities identified by the above hotel chainClear labelling on all items and ingredients is needed, and international Codes of Practiceare needed.

Contract Caterer (n = 1)(a) AllergensThe Quality Manager International, based in Europe, revealed awareness of concernsabout food allergies. However, there are differences within and between differentcountries.

SUPPLIER INFORMATION: Some suppliers in some countries provide informationabout all uses of nuts/peanuts and other food allergens. The information is understood tomean different things for different suppliers, but note is taken of the information.Information is provided via packaging and product specifications and is retained in aproduct specification catalogue. In some countries labels are kept where goods aredecanted for storage. In other cases, the label is thrown away before the goods are used.Information about foods/ingredients that are suitable for nut-free products is retained as aproduct specification sheet.

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STORAGE AND PREPARATION: Special operational procedures in relation tonuts/peanuts are requested for some suppliers, particularly for hospital catering. Wherenuts/peanuts are used in kitchens they are not stored any differently to other ambientingredients, and dishes containing nuts/peanuts are not prepared any differently to otherdishes.

TRAINING: Staff are briefed on the content of dishes as menus change. The company hasreceived educational material about food allergens and it has a programme of regular stafftraining including food allergies, particularly for its dietitians.

DIALOGUE: Product information is passed on through the companies own productspecifications, and to customers through menus and blackboards. Customers ask aboutthe presence or use of nuts/peanuts in the kitchen and in dishes. They also ask about otherfood allergens. Where their presence is not obvious, the presence of nuts/peanuts ispointed out on menus, blackboards, or through information with staff, but this is not thecase for other allergens.

(b) Consumer ChoiceThe company requests information about the nutritional content of products andingredients from its suppliers. Depending on the country and restaurant type, there arerequests for information about healthy eating choices from consumers. Examples ofhealthy choices include ‘fitness meals’ (no meat), ‘whole-wheat meals’, ‘light’ meals,and diets in hospitals. The company routinely provides vegetarian choices, but not veganchoices. Requests are received for information about vegetarian choices. Consumers areinformed about both healthy eating and vegetarian choices through the menus, by staffproviding details, or through intranet sites on IT systems.

The company also routinely provides information about portion size, the country oforigin, the cooking methods and descriptions such as fresh and home-made. Customersalso ask about these. The company offers sales and delivery by Internet ordering andtelephone ordering. Their menu procedure is ISO 9000 compliant.

(c) Barriers and opportunities of the above contract catererPractical steps to ensure workable solutions should be agreed at both the European andworld-wide levels, as incompatible legislation at these levels is a barrier to progress.Currently, the UK is more ahead than other European countries because its labelling andlegislation are more advanced.

Branded Multinational Manufacturer (n = 1)(a) AllergensFrom experience of international operations, Northern European countries appear to be asaware of allergies as the UK, but some Southern European countries are less aware and itis generally necessary to verify further any information provided. However thecompany’s quality system applies world-wide and this includes storage and preparation.

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(b) Consumer ChoiceSome healthy choices and vegetarian products are provided in all countries, but more soin the USA and Northern Europe. Cooking instructions are provided on foods all over theworld. Compared to international suppliers, the UK suppliers are more aware and moreable to provide accurate information than some other countries, especially SouthernEurope. Even where it is not a legal requirement to provide nutrition information, this isstill provided on the label.

Multinational Retailer (n = 1)Information available for non-prepacked foods sold abroad varies from country tocountry, but is generally less than that provided in the UK. Staff training is focused onhygiene.

3.3.3 INTERNATIONAL GUIDELINES AND INITIATIVES

GUIDELINESAmericaOne international organisation highlighted a set of guidelines that exist in America - theFood Allergen Labelling guidelines. These were developed by the Food Allergy IssuesAlliance which includes industry and consumer groups. These guidelines can be accessedvia the following webpage – www.usii.net/sfa/allergyguides.html and also appear inAppendix B. In summary the guidelines are as follows:(i) Identify the major food allergens(ii) Advocate the use of terms commonly understood by consumers for the major foodallergens(iii) Call for manufacturers to disclose the presence of major food allergens when they arean intentional part of the food, regardless of the source(iv) Establish guidelines when the use of supplemental allergen statements is appropriate.

A code of practice on managing food allergens has also been developed in the USA bythe National Food Processors Association (NFPA). This code states that NFPA memberssubscribe to the following practices:

1. Labelling (in terms commonly understood by consumers) the major food allergens intheir ingredient declarations, including those that are part of natural and artificialflavours or other food ingredients.

2. Use good manufacturing practices (GMPs) and other allergen control strategies tomanage and minimise the potential cross-contamination of major food allergens.

3. Where GMPs and other allergen control strategies are being followed but are notreliable to sufficiently minimise the risk of allergen cross-contact, then ingredientdeclaration or supplementary information would be appropriate.

4. Take an active role in educating employees, business partners, food service customersand consumers about food allergens.

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5. Continue to develop processing, analytical and operational strategies to further reducethe risk to allergic consumers of ingesting food allergens.

CanadaThe Food and Consumer Products Manufacturers of Canada have developed an ‘AllergyBeware’ programme. This is an employee education programme and covers the four‘A’s’ in minimising cross-contact and mislabelling:1. awareness of how cross-contamination or mislabelling can potentially occur2. accuracy in ingredient listings and labelling3. correct procedures for avoidance of cross-contact or mislabelling4. recognition of how and when to take action if accidental cross-contact or mislabelling

occurs.The training programme has been running since 1993 and other organisations have used itas a model for their own communication initiatives.

Australia/New ZealandWithin Australia and New Zealand there is a new Food Standards Code which requiresthe declaration of certain substances (e.g. gluten, shellfish, nuts and soy) at all times onfood labels. There are also restrictions on the use of generic names for these substances.Several different types of food are exempt from the code, however, including foods soldloose or foods sold from catering establishments. Currently in New Zealand it is possibleto access allergen-free commercial food lists such as those compiled by the ManufacturedFoods Database (www.mfd.co.nz). However the databases depend on voluntarycontributions by food manufacturers and the printed commercial food lists are onlypublished yearly (although the website lists are updated biweekly).

InternationallyThe Institute of Food Science and Technology have a statement on food allergens. In thisthey suggest focusing on the major serious allergens (MSAs) as over 170 foods have beendocumented as causing allergic reactions. Guidance is given on dealing effectively withMSAs, labelling, the retailers’ responsibilities, the caterers’ responsibilities and novelfoods.

Codex Almentarius currently only has food labelling standards for pre-packed foods(Codex, 1985). However, within this there are guidelines regarding foods and ingredientsthat are known to cause hypersensitivity and should always be declared.

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Table 4. Foods and Ingredients that Should be Declared in Prepacked Foods(Codex, 1985)

The EU currently has a draft proposal covering the labelling of foodstuffs and ingredientsrecognised as causing hypersensitivity (Table 5).

INITIATIVESThe following initiatives addressing matters such as customer information about foodallergies and healthy eating when eating out and purchasing non prepacked foods, inother countries, were also investigated.

FinlandIn Finland there are regulations on the food labelling and the obligatory provision ofinformation about allergens. However, these regulations do not concern cateringestablishments. Restaurants and catering establishments today voluntarily give additionalinformation. This is an expanding trend for this kind of information because of consumerdemand.(AHA: marja.pohjanpalo@elintarvikevirasto.fi)

• Cereals containing gluten, i.e. wheat, rye, barley, oats, spelt or theirhybridized strains and products of these

• Crustacea and products of these• Eggs and egg products• Fish and fish products• Peanuts, soybeans and products of these• Milk and milk products (lactose included)• Tree nuts and nut products• Sulphite in concentrations of 10 mg/kg or more

Table 5. Ingredients/foods the in EU Proposal

Cereals containing gluten and products thereofCrustaceans and products thereofEggs and products thereofFish and products thereofPeanuts and products thereofSoybeans and products thereofMilk and dairy products (including lactose)Nuts and nut productsSesame seeds and products thereofSulphite at concentrations of at least 10 mg/ kg

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SwedenThe Swedish Green Keyhole labelling scheme, which highlights foods that are low in fatand high in fibre, is applicable on restaurant dishes provided their fat content is below17g/serving. The symbol is therefore occasionally found on menus in some restaurants.However, in view of the need for chefs to monitor the fat content of dishes as served, thispart of the labelling programme is fraught with difficulties.(The National Food Administration: akbr@slv.se)

Australia and New ZealandSmart Choice is run by the New Zealand Heart Foundation. The logo is used on menuitems that meet certain specified recipe criteria. This programme is not felt to be a hugesuccess, but nevertheless is thought to have potential and is therefore being re-evaluated.A group of hotels run a similar programme, which was developed by Harvard University.Strategies to extend the Pick the Tick programme in New Zealand into the ‘take-away’arena are also being developed and the major ‘take-away’ chains have expressed interest.(gareth.hughes@ghapl.com.au)

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4. RESEARCH IDENTIFIED

The questionnaires asked for details of any relevant research known by the respondents.Some sent in copies of articles and/or references to articles that were thought to berelevant. These included:• Reading, A (2000). Views on Defensive food labelling from a consumer organisation.

Food Allergy and Intolerance 1 (2): 77-82• FSA September 2000 Consumer information needs for food sold through catering

outlets and loose foods• Taylor SL & Hefle SL (2000). Good manufacturing practices for allergenic foods –

the use of shared equipment. Food Allergy and Intolerance 1 (1): 47-50• Leitch, IS, Blair IS & McDowell DA (2001). The Role of Environmental Health

officers in the Protection of Allergic Consumers. International Journal ofEnvironmental Health Research 11: 51-61 (see Appendix E)

• Unspecified research performed by the Coeliac Society• Seaton A (2001). Diet and the development of asthma. The Asthma Journal 6: 128-

130• National Asthma Campaign Fact Sheets – Diet and asthma in babies; Food reactions

and asthma• Latex allergy – list of references given from the Latex Allergy Support Group• Steenhuis IHM (2002). Feasibility and Effectiveness of Environmental Interventions

in Worksite Cafeterias and Supermarkets. PhD Thesis University of Maastricht• Steenhuis IHM, Assema P Van & Glaz K (2001). Strengthening environmental and

educational nutrition programmes in worksite cafeterias and supermarkets in theNetherlands. Health Promotion International 16: 21-33 (see Appendix E)

Several groups identified a need for further research. They suggested this research shouldinclude what information consumers want on foods sold loose or through catering outletsand what information they need to be able to make healthy and safe choices about thefood they eat.

The following research programmes were also highlighted during the course of thesurvey:

National Food Agency, Finland: monitoring allergens in bakery productsStarting in March 2002 a national project is being conducted to monitor allergens inbakery products. Bakery products have been chosen as they are most likely to have errorsin allergen labelling. Local authorities will inspect the labelling on products. The projectwill monitor breads, buns, pastries and processed bakery goods. The products will beinspected for the following allergy-causing ingredients:1) peas, fish, egg, milk, soybeans and shellfish as well as products made from these;2) peanuts, almonds and nuts; and3) oats, barley, wheat and rye.

The objective is to investigate:

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1) Whether the allergens are contained in recipes and whether these are indicated onpackages of bakery products intended institutional kitchens and consumers, as well aswholesale and transport packages, or documents for unpacked bakery productsintended for shops and institutional kitchens;

2) 2) Whether there is a possibility of cross-contamination of allergens from itemspreviously produced on the same production line and whether this is indicated onpackages or in documents (for example, the package can be labelled to indicate that it‘may contain nuts’ even if nuts are not an ingredient in the product)

3) Whether allergens and related labelling and the possibility of cross-contamination andrelated labelling have been taken into consideration in bakeries' in-house control.(National Food Agency: info@nfa.fi)

Heart Beat Limburg, HollandIn Southern Holland, within the regional community project Heart Beat Limburg, a foodintervention programme was set up to label lean meat in butchers with the fat content.This intervention programme, called ‘Lekker Gezond’ (Nice and Healthy), was in co-operation with a meat company called Van Melik Food Group. Twelve butchersparticipated, labelling lean meat products and providing advice for customers about theproducts and how to prepare them. The research found that the programme had noinfluence on various determinants of behaviour of customers towards buying lean meatproducts or the use of liquid fats when preparing meat. However, sub-analysis showedthat those exposed to the initiative had a more positive opinion about the price of leanmeat products, viewed themselves as more able to buy lean meat products and were morelikely to buy lean meat products in the future. The research also showed that not all shoppersonnel felt sufficiently prepared to fulfil their role in the programme. Though they hadundertaken training, they had low self-esteem with regard to their efficacy incommunicating information.(M. Steenbakkers: M_Steenbakkers@zzl-ggd.nl)

Australia and New ZealandThe Australian and New Zealand Heart Foundations have run intervention studies intypical fish and chip shops (no further details available).(gareth.hughes@ghapl.com.au)

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5. RECOMMENDATIONS

5.1 PROCESS USED TO DEVELOP THE RECOMMENDATIONS

The recommendations put forward in this report are based on the information collectedvia the questionnaires and in-depth interviews, and take account of advice andinformation provided by the Steering Group. Reviewing existing national andinternational practices and guidelines has also influenced the recommendations.

The overall aims of the recommendations are:• To enable the consumer to make an informed choice by provision of accurate

information

• To enable the food supplier (including caterers and retailers selling non-prepacked foods) to provide accurate information to their customers andultimately to the consumer

5.2 RECOMMENDATIONS: ALLERGY AWARENESS

It was apparent throughout the project that, of the many factors being investigated,concerns about allergy were considered by far the most important. For this reason, therecommendations focus on allergy and allergen awareness. It was agreed by the SteeringGroup that the priority should be identification of measures aimed at tackling concernsabout peanuts, tree nuts and seeds, as these are causes of particularly serious allergicreactions. However, consideration has also been given to the other matters included in theremit for the project and which influence the consumer’s ability to select food items withconfidence (see Sections 5.3).

It was also apparent that some companies have already expended considerable effort indeveloping appropriate procedures and that some excellent examples of good practiceexist in both large and smaller companies, which may help others to improve theiroperational practices and information provision. Key aspects that require urgent attentionare the conveyance of product information through the food chain to the end consumer;agreement on a definitive list of common food allergens and related terminology anddescriptions; and provision of relevant training, focusing on allergy awareness,particularly for staff who interface with the public but also those who need to understandthe importance of avoidance of cross contamination during food (and meal) production.

Furthermore, it was evident that a balance needs to be struck. Reactions to some allergensare far more serious than others (and can be life threatening) but on the other hand, thevast majority of the population is unaffected. If the blanket exclusion of allergen-containing ingredients, as has taken place in some school meal services with regard tonuts, was extended to other common allergen-containing foods (such as milk, eggs, soyaand seafood), dietary variety and nutrient provision would be seriously compromised for

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the whole population (not just the minority who react to certain foods). Furthermore, thecurrent willingness of some manufacturers, retailers, and caterers to accommodate theneed for caution with regard to nuts, peanuts and seeds might be overwhelmed if theywere required to apply these measures to a wide range of ingredients. Clearly, therefore,there is a need to prioritise and target actions.

5.2.1 GOOD OPERATING PRACTICE WITH REGARD TO ALLERGENS

Recommendation 1:The FSA should lend its support to approaches which help establish good operatingpractices with regard to allergens, particularly with regard to nuts, peanuts andseeds.

This recommendation is of particular relevance to the catering sector and other situationswhere food is sold non-prepacked, but it is also pertinent to all other situations whereallergen control could be improved.

Improvement in operating practices could be based on an approach known as the four-strand approach (provision of information; good operating practice for ‘back of house’;training; and dialogue). Details are given below. Such an approach is of particularrelevance to the catering sector but could also be applied to other sectors.

One of the major barriers to improvement concerns the flow of information about productcomposition (particularly allergen status).• The Agency may wish to consider whether there should be a legal requirement for a

minimum level of information to be passed to caterers by suppliers with products (e.g.an indication of whether the product contains any of the major allergens).

• Furthermore the Agency should support initiatives that equip staff in catering outletswith comprehensive reference guides in which they can respond to customer enquirieson the allergen status of individual dishes. This is considered a preferable approach tothe use of logos and other forms of labelling on menus.

Using the four-strand approach, examples are given below of the type of advice thatcould be included in each of the four areas for catering establishments.

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Provision of informationIt is good practice to obtain information on raw materials from suppliers.• This should include as a minimum the presence/absence of peanuts, tree nuts and sesame seeds.• Information on the other common food allergens could also be obtained.• This information needs to be accurate and up-to-date.• This could involve keeping the packaging of products that are decanted into other containers before

storage or transferring this information to a central point.• If it is not possible to obtain accurate and up-to-date information on raw materials, then customers

must not be misled or lulled into a false sense of security – allergic reactions can be life-threatening.

DialogueIt is good practice to establish a dialogue with consumers with food allergy.• There should be acknowledgement of the issue of allergy – e.g. statement on the menu.• Dialogue should be encouraged with customers – e.g. notice displayed in restaurant.• There should be interaction with allergy sufferers – e.g. staff trained to be able to identify a need for

further information and to involve supervisor/manager.• Information about dishes should be shared with customers to enable them to make an informed

decision about which meal to select – e.g. have information/packaging of different components of themeal available. If information is not complete, accurate and up-to-date, it is wrong to make guesses -this could be fatal for someone with a life-threatening food allergy. In this situation, staff should behonest with the customer, giving them any information that is available, explaining what information ismissing/inaccurate and letting the consumer decide what is appropriate under the circumstances.

Good operating practice for ‘back of house’It is good practice when preparing an allergy sufferer’s meal to:• Clean and sanitise equipment before weighing out ingredients.• Use ingredients which are known to be allergen-free based on reliable information provided by

suppliers.• Clean hands, work surfaces and utensils after handling foods containing major food allergens.• Cook the meal using thoroughly cleaned equipment and utensils.• If it is not possible to abide by these steps, then allergy sufferers should be alerted to the fact that

allergens may be present in the meals on offer.

TrainingIt is good practice to train front and back of house staff with regard to allergy:• Allergy and allergen awareness should be included in induction training.• Staff should be updated when menu/dishes change.• Management should receive further in-depth training.• If staff are untrained in allergen awareness, then allergy suffers should be alerted to the fact that

allergens may be present in the meals on offer.

5.2.2 INFORMATION PROVISION

There needs to be a focus on information provision as a starting point if progress is to bemade, whilst recognising that the value and impact of this approach is dependent on otherkey factors, e.g. what happens back up the supply chain. It is not the intention to burdenbusinesses with unrealistic demands for information and the following recommendationsaddress key areas that should be addressed.

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Recommendation 2:The FSA should work with interested parties to develop an agreed list of commonallergen-containing foods or food groups.

Recommendation 3:The FSA should work with interested parties to develop a definitive list of tree nuts,as these, along with peanuts and seeds, are recognised sources of allergensassociated with particularly severe reactions.

Recommendation 4The FSA should work with interested parties to develop agreed definitions for termssuch as ‘free from’ and ‘may contain’, and agreed processes for declaring thepresence of allergens.

Recommendation 5With regard to transfer of information about food ingredients (e.g. allergen statusor other aspects of labelling information) as foods move within cateringestablishments (e.g. when packaging is removed or products decanted for storage),the FSA may wish to consider working with interested parties to develop guidanceon the transfer and retention of such information

In relation to recommendations 2-5 above:The survey highlighted that some respondents from each of the different stakeholdergroups thought it would be useful to agree a priority list of the most common allergensfor the purpose of labelling supplies to the catering trade. It would seem logical that thepriority list should be in line with the recent proposal from the EU (Directive2000/13/EC, see Table 5). It was also considered essential, in order that progress can bemade, that a priority list of definitive list of tree nuts (see Table 6) for use throughout thefood chain be agreed. There was also recognition among the different groups of the needfor clearer definitions of terms used – for example the term nuts. Any such consensusshould take into account other definitions currently in use and those being developed.

Furthermore, there was support for the requirement that major allergens should be listedin the ingredients list of all products, using the specific name (not generic) of theallergen-containing ingredient (e.g. hazel nut rather than nut), irrespective of amount (thiswould require removal of the 25% rule). The exception to this would be where thederived ingredient does not contain the causative protein, e.g. highly refined peanut oilwould not be subject to labelling. The words used for such ingredient listing should besimple, standardised, practical and helpful. However, it is important that suchterminology does not limit consumer choice. For example, use of the word ‘milk’ insteadof ‘casein’ could mean people with lactose intolerance would avoid the food even thoughit could be lactose free and hence suitable for them.

As well as appearing in the ingredients list of products supplied to caterers, it wassuggested that the presence of allergens should also be highlighted e.g. in bold text or in aseparate box/statement.

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Another priority is to reach agreement with stakeholders on terms such as ‘free from’,‘contains’ and ‘is suitable for’. Agreed terms should be used consistently as part of theproduct specification. The Steering Group’s preference is for use of the phrase ‘contains’.

Guidance is needed for caterers (in particular) on what to do when the informationprovided (on major allergens) is inaccurate or incomplete (e.g. the 25% rule has beenapplied). For example, in such situations, no judgement can or should be made to thecustomer or end consumer on the suitability of the food. Associated with this, guidance isneeded for caterers on the means of transferring product information in situations whenpackaging is removed or products decanted. One option is to transfer all information to acentral storage point.

Table 6 Tree Nuts Lists Utilised by Different Organisations

OrganisationTree Nut CODEX ILSI* FAIA CFIA* FSA BRCAlmond ! ! ! ! ! !Brazil ! ! ! ! ! !Cashew ! ! ! ! ! !Chestnut ! ! !Hazelnut/ filberts ! ! ! ! ! !Macadamia nut ! ! ! ! !Pecan ! ! ! ! !Pine Nuts ! ! ! !Pistachio ! ! ! ! ! !Walnut ! ! ! ! ! !(* ILSI – International Life Sciences Institute, CFIA – Canadian Food Inspection Agency)

5.2.3 TRAINING

Recommendation 6:The FSA should work with interested parties to define minimum trainingrequirements in relation to allergy awareness for food sector staff. The aim wouldbe to minimise cross contamination and to facilitate provision of accurateinformation to the consumer.

From the questionnaires, all the different sectors, as well as the Steering Group, identifiedtraining as being vital. Training across the food chain is an important component of manyinternational and national guidelines reviewed for this project. Therefore there is a needto look at the training needs of those working in manufacturing, retail and catering aswell as enforcement (as EHOs and TSOs appear to be key sources of information) andalso the needs of consumers (particularly those at potential risk). It is envisaged thatwithin some sectors this training component may be incorporated or linked with existingtraining (e.g. NVQ, Chartered Institute of Environmental Health and Royal Society ofHealth courses).

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Training should include elements of recommendations from this report, in particular thefour-strand approach (see section 5.2.1). The emphasis would be on practical andtransferable information and skills. Key underlying themes in relation to allergy could be:

• understanding the issues: the importance of supplying correct information to peoplewith severe food allergy; what to do in an emergency (e.g. caterers confronted withanaphylaxis);

• how to communicate this information (e.g. most retailers and caterers rely on theirstaff for sharing information with consumers, so staff who interface with the publicneed to know what questions to ask, why and the priorities);

• shared responsibility (e.g. acknowledging that allergy sufferers need to be pro-activeand involved in the communication process) and

• improved understanding of the labelling used on products and the information alreadyavailable to them (retailers, caterers and consumers in particular). Although muchinformation may already be supplied (e.g. nutritional information and ingredients onproduct specification sheets), the Steering Group felt that some sectors may not knowhow to utilise this information effectively and efficiently and these issues should beaddressed by training.

Examples of the form this training might take are outlined in Appendix F.

5.2.4 RECOGNITION SCHEME

Recommendation 7:The FSA may wish to consider supporting an allergy awareness scheme that couldbe constructed along similar lines to the Heart Beat Award Scheme.

Operations and companies which make a commitment to providing information onallergy, may want to inform potential customers of this. Several initiatives have alreadybeen developed, including one by Surrey County Council (see Appendix G for furtherdetails). Therefore a voluntary scheme could be developed that recognises these efforts.Any scheme:

• should not be part of legislation• should be based on the four-strand approach principle• should incorporate a training programme for staff• should be a nationally-run scheme• should not be overly prescriptive• should aid consumer confidence but not overtly disadvantage businesses who choose

not to be involved in such a scheme.

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5.3 RECOMMENDATIONS: OTHER INFORMATION

Issues other than allergy were also addressed in the research, namely:• healthy eating options• country of origin• logos• date marking• use of terms such as ‘fresh’ and ‘home-made’• portion size (with reference to catering establishments)

The research highlighted some areas that appeared to be of greater concern than others,such as information on healthy eating options. However, several of the above topics didnot appear to be areas requiring much attention because consumer interest was lowerand/or current practice was meeting consumer needs. The Steering Group also felt thatimportance should be given to those topics that had not previously been addressed and/orrequired further consideration. Therefore no new recommendations are made in thefollowing areas:

• Date markingThe FAC (2001a) has already recommended that durability information requirementsfor pre-packed foods also be applied to foods sold loose.

• Portion sizeConsumers think this type of information is moderately important, many caterersprovide or can provide this information if required. Therefore no specificrecommendations are made.

• Use of terms such as ‘fresh’ and ‘home-made’The FAC (2001b) extensively reviewed the use of such phrases and put forwardrecommendations. In this current research, the use of such phrases did not appear tobe a priority, and so no further recommendations are made.

5.3.1 INFORMATION PROVISION

Recommendation 8:The FSA may wish to consider working with interested parties to develop ‘foodbased’ guidelines for defining ‘healthy eating’ options in catering establishments.These could be based on existing materials such as Catering for Health and theHeartbeat Award Scheme.

Catering for Health provides guidance on the application of healthy eating advice in anumber of settings, including schools and hospitals. Clearer labelling of foods supplied tocaterers may make it easier for these sectors to pass on this type of information andtherefore help consumers wishing to choose ‘healthy’ options. Although legal definitions

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for claims exist for pre-packed foods (Food Labelling Regulations, 1996) and the FSAhas given guidance on some specific claims e.g. low fat, high fibre, use of these isgenerally not appropriate for catering situations (as caterers can not be expected tocalculate nutritional values of composite meals and dishes). However, consumers who areinterested in ‘healthy eating’ currently have few guidelines on which to judge thenutritional balance of dishes sold in catering establishments that may or may not bedescribed as ‘healthy choices’.

At this stage, we do not feel it appropriate to make recommendations on the use ofhealthy food symbols or logos. This does not mean that they may not prove useful insome settings should clearer guidelines be set.

Recommendation 9:With regard to foods sold non-prepacked that require cooking, the FSA may wish toconsider actively encouraging the provision of information on cooking method byretailers by providing guidance on the methods and formats that are already in usee.g. printing information onto price labels, use of leaflets, verbal communication.This might also be extended to cover storage and durability information for foodsthat do not require cooking.

Where appropriate, consumer and support groups responding to the survey thoughtinformation on storage and cooking for non-prepacked products should be given toincrease consumer protection. This type of information is currently provided in somesettings e.g. take-aways from retailers. However, in other instances this could beimproved. Reliance on verbal communication for this type of information may be useful,especially in specific settings, e.g. for meat purchased from a local butcher.

Information on cooking methods is often already given by many caterers so no specificrecommendations are made for catering establishments.

The Agency may also wish to move forward the FAC recommendations on durability(see above) by providing guidance on the methods already in use to communicate thistype of information, e.g. directly marking the food, providing information in writing (e.g.on the price ticket) or orally at time of purchase, and use of websites. For example,provision of information of this type for perishable foods sold on deli counters might beexpected to increase consumer protection.

Recommendation 10:The FSA may wish to consider actively encouraging retailers to provide informationon country of origin by offering guidance on the methods and formats that could beused e.g. printing information onto price labels, use of leaflets, verbalcommunication.

Research has shown that retailers are often asked about country of origin and consumersrate information on this as moderately important. As many caterers provide or canprovide this information if required, no specific recommendations are made for catering

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establishments but the provision of such information could be improved for non-prepacked foods.

Recommendation 11:The FSA should work with interested parties to develop an agreed list of commondefinitions for terms such as vegetarian and vegan.

The definitions should take into account those already in use and be acceptable tomanufacturers, retailers, caterers and consumers. Information collected during theresearch suggests that a variety of different definitions are currently being applied, someof which are very misleading.

Recommendation 12:The FSA may wish to consider working with interested parties to develop guidanceon the transfer of information about ingredients as they move within cateringestablishments (see recommendation 5).

Although this recommendation appears in the previous section in relation to allergyawareness, the transfer of other information (e.g. ingredient information, country oforigin) may also be important.

5.3.2 TRAINING

Recommendation 13:The FSA may wish to consider working with interested parties to define minimumtraining requirements in relation to healthy eating options. The aim would be tofacilitate provision of accurate information to the consumer.

Training could be based on the food-based guidelines developed (recommendation 7) andagreed definitions (recommendation 10). Catering for Health contains the basis of acurriculum.

5.3.3 RECOGNITION SCHEME

Recommendation 14:The FSA may wish to consider supporting a scheme such as the Heart Beat AwardScheme to give support and recognition to those companies addressing issues such asprovision of healthy eating options.

As the Heart Beat Award Scheme has already been successfully run, the FSA may wishconsider supporting an initiative of this type to encourage companies to recognise theimportance of providing ‘healthy eating’ options. Such a scheme could also look at theprovision of other information such as information on vegetarian and vegan choices.

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6. CONCLUSIONS

Many consumers would like further information on the foods they purchase non-prepacked and from catering outlets. The priority for this information should be forallergens because of the danger allergen-containing foods present to susceptibleindividuals. However, by also addressing other areas such as healthy eating options,country of origin and vegetarian and vegan foods, the FSA can increase awareness andclarity of these issues, help the food industry to improve its current practice and helpconsumers to make informed choices about the food they buy.

Foods sold loose and through catering outlets are managed by many diverse players,some of whom are managing the flow of information more competently than others.Recommendations outlined in this report are relevant to all players but aim to giveguidance specifically to those organisations not currently addressing these issues.

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REFERENCES

Bock SA, Munoz-Furlong A & Sampson HA (2001). Fatalities due to anaphylacticreactions to foods. Journal of Allergy and Clinical Immunology 107: 191-193.

British Retail Consortium (2001). Technical standard and protocol for companiessupplying retailer branded food products. BRC, London.

British Retail Consortium (1998). Guidelines for the Handling of ‘Nuts’. BRC, London.

Buttriss J (Ed.) (2002a). Findings of the National Food Survey for 2000. NutritionBulletin 27: 37-40.

Buttriss J (Ed.) (2002b). Adverse Reactions to Food. Blackwell Science, Oxford.

Codex Alimentarius (1985). Prepackaged Foods. Codex Standard 1-1985 (Revised 1-1995).

Department for Environment, Food & Rural Affairs and National Statistics (2001)National Food Survey 2000. The Stationery Office, London.

Department of Health (1991) Committee on Medical Aspects of Food Policy. DietaryReference Values for food energy and nutrients for the United Kingdom. Report onHealth and Social Subjects 41, HMSO London.

Food Advisory Committee (2001a) Review of Food Labelling. FSA, London.

Food Advisory Committee (2001b) Review of the use of the terms Fresh, Pure, Natural,etc in Food Labelling. FSA, London.

Food and Drink Federation (1998) Food Allergens Advice Notes. FDF, London.

Food Standard Agency (2001) The Balance of Good Health. FSA, London.

Food Standard Agency (2001) Be allergy aware. FSA, London.

Food Standard Agency (2001) Dine out, Eat well. FSA, London.

Food Standard Agency (2000) Food Labelling Forum Summary Report. FSA, London.

Food Standard Agency & Department of Health (2001). Catering for Health. FoodsStandard Agency, Middlesex.

Gowland MH (2002). Food allergen avoidance: risk assessment for life. Proceedings ofthe Nutrition Society 61: 39-43.

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Gregory J, Foster K, Tyler H & Wiseman M (1990) The dietary and nutritional survey ofadults. HMSO, London.

Institute of Grocery Distribution (2001). Voluntary Labelling Guidelines for FoodAllergens and Gluten. IGD, Watford.

Leitch, IS, Blair IS & McDowell DA (2001). The Role of Environmental Health officersin the Protection of Allergic Consumers. International Journal of Environmental HealthResearch 11: 51-61.

Ministry of Agriculture, Fisheries & Farming (1999). Working Together for The FoodChain. MAFF, London.

Mintel (2001). Meat Free Foods Report. Mintel International Group, London.

Proposal for a Directive of the European Parliament and of the Council amendingDirective 2000/13/EC Official Journal of the European Communities 27th November2001.

Reading, A (2000). Views on Defensive food labelling from a consumer organisation.Food Allergy and Intolerance 1 (2): 77-82.

Seaton A (2001). Diet and the development of asthma. The Asthma Journal 6: 128-130.

Steenhuis IHM (2002). Feasibility and Effectiveness of Environmental Interventions inWorksite Cafeterias and Supermarkets. PhD Thesis, University of Maastricht.

Steenhuis IHM, Assema P Van & Glaz K (2001). Strengthening environmental andeducational nutrition programmes in worksite cafeterias and supermarkets in theNetherlands. Health Promotion International 16: 21-33.

Taylor SL & Hefle SL (2000). Good manufacturing practices for allergenic foods – theuse of shared equipment. Food Allergy and Intolerance 1 (1): 47-50.

The Anaphylaxis Campaign (2002). Severe food allergies: guidance for caterers.http://www.anaphylaxis.org.uk/

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APPENDIX A STEERING GROUP MEMBERS

Dr Judy Buttriss (Chairman)

Les Bailey (LACORS)Jane Baynton (British Sandwich Association)Samantha Calvert (Vegetarian Society)Rod Dale (Kerry Ingredients)Dionne Davy (Food Standards Agency)*Hazel Gowland (Anaphylaxis Campaign)Johanna Hignett (Nestlé)Rosemary Hignett (Food Standards Agency)Brigid McKevith (British Nutrition Foundation)Tom Miller (Whitbread)Dr Martin Rawlings (British Beer and Pub Association)Dr Michele Sadler (MJSR Associates)Ann Savage (Geest plc)Eileen Steinbock (Brakes)Karen Tonks (Tesco)David Alexander (National Consumer Council)

Kate Deakin (Minutes Secretary)

*Observer

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APPENDIX B COPIES OF QUESTIONNAIRES

SELF-COMPLETION QUESTIONNAIRE – CATERING

There are no right or wrong answers – but honest answers will be of most help.

Please return questionnaire as soon as possible, but no later than 18th February, to: Kate DeakinThe British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQFax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk

A. Food Allergies

People with food allergy need to avoid certain foods, such as nuts/peanuts, shellfish or milk.Eating out is difficult, as they don’t always know whether these foods have been used in specificdishes. We are trying to find out about the sort of information available to consumers at themoment, so that we can make recommendations that will help people when eating out in thefuture.

1. Are you aware of concerns about food allergy?

!YesNoDon’t Know

2. In relation to food allergy, do your customers ever ask about ingredients in the food you serve?

!YesNoDon’t Know

3. If yes, which ingredients or foods do they usually want to know about?

4. Do you point out the use of nuts/peanuts where their presence is not obvious from the nameof the dish? e.g. Chicken Satay (peanuts not in name of dish).

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! If yes, which nuts:Yes

No

Don’t know

5. Do you point out the use of other ingredients to which people may be allergic - such as fish,shellfish, milk – where their presence is not obvious from the name of the dish? e.g. soupcontaining milk, where milk is not in the name of the dish.

! If yes, which ingredients?Yes

No

Don’t know

6. If yes to questions 4 or 5: how do you inform customers about the use of these particularingredients?

! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

Other means – please state in spaceprovided

Don’t know

7. In relation to the foods and ingredients that you buy in:

i) If you remove the goods from the packaging e.g. decant into storage containers/freezers/fridgesetc, do you keep the labels or a note of the label information?

!!!!Keep labelsTake a note of the label informationDon’t know

ii) Is the label a useful method of providing you with information about food allergens, or do youthrow away the packaging before the goods get into the kitchen?

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!!!!Useful means of providing informationNot useful – label thrown away before goods are usedDon’t know

8. If you use nuts/peanuts as an ingredient, how are these stored and labelled?

!!!!No differently to other ingredientsIn a separate area, with distinctive labellingDon’t knowNot relevant – don’t use nuts/peanuts

9. How do you prepare dishes containing nuts?

!!!!No differently to other dishesSpecial procedures are in place – please stateDon’t knowNot relevant – don’t use nuts/peanuts

10. Are your staff aware of the precise contents of dishes, and any changes to them e.g. additionof nuts/peanuts?

!!!!YesNoDon’t know

11. Have you ever received information telling you about food allergies?

!!!! If yes, from where:Yes

No

Don’t know

12. Do you have regular staff training sessions?

!!!! If yes, how frequently:No

Yes – but allergies notincluded

Yes – allergies included

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Don’t know

13. Do you have any standard advice for your customers who have food allergies?

!!!! If yes, please give details of advice:Yes

No

Don’t know

B Consumer Choice

Some people are interested in healthy eating or where food comes from, and may like to have thisinformation when eating out.

14. Do your customers ever ask for information about healthy eating choices?

!!!!NoYes – they ask about healthy choicesYes – they ask about use of specific ingredients such as cream/oil/ butter/saltYes – they ask about cooking method e.g. if food is fried, grilled, baked etcDon’t know

15. Do you provide any dishes for people that are looking for healthy eating choices?

!!!! If yes, please give some examples:Yes

No

Don’t know

16. How do your customers know about them?

!!!! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

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Other means – please state in spaceprovided

We don’t see a need to tell them

Don’t know

17. Do your suppliers/wholesalers tell you about fat and calories (and other nutrients) inproducts/ingredients?

!!!! If yes, how is the information provided:None of them

Somesuppliers/wholesalers

All suppliers/wholesalers

Don’t know

18. Do your customers ever ask for information about vegetarian or vegan choices?

!!!! Vegetarian !!!! VeganYes

No

Don’t know

19. Do you provide vegetarian or vegan choices?

!!!! Vegetarian !!!! Vegan If always or sometimes, please give someexamples?

Always

Sometimes

Never

Don’t know

20. How are customers informed about these dishes?

!!!! Other means:It is printed on the menuIt is chalked on the blackboardStaff provide details if asked

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Other means – please state in spaceprovidedWe don’t see a need to tell themDon’t know

21. Do you provide any of the following information about the dishes you serve?

!Yes - please give details !No

! Don’tknow

Portion size – such as the size of asteak or other item

Descriptions such as ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’ etc

The country of origin of theingredients/ foode.g. British beef, French chicken

Cooking method e.g. fried, grilled,baked, steamed

Pan fried chicken, deep fried cod

22. Do your customers ever ask for information of this type?

! Yes ! No ! Don’tknow

Portion size

If the food is ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’etc

The country of origin of theingredients/ foode.g. British beef, French chicken

Cooking method e.g. fried, grilled,baked, steamed

Anything else………………………………..

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23. Do you provide either of the following?

Yes ! No ! Don’tknow !

Sales/delivery via Internet ordering

Sales/delivery via telephone ordering

24. If yes, are any procedures in place to inform customers who may want informationabout allergens, healthy eating, vegetarian products etc?

! If yes, please give details:

Yes

No

25. To help us make recommendations on any of the above issues, can you suggest any practicalsteps that would be helpful to consumers and workable for you?

26. And do you foresee any barriers that will make progress difficult to achieve?

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27. Please add any further comments or observations

Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details will be treated in confidence and youranswers will not be attributed either to yourself or to your organisation.

BusinessName

Main functionofbusiness/operationYour Name

Address

Tel

Fax

E-mail

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SELF COMPLETION QUESTIONNAIRE – CONSUMER ANDSUPPORT GROUPS

The Food Standards Agency wishes to support consumer choice when people with foodallergy eat out or purchase non-prepacked foods. Information about other issues ofconsumer choice is also being considered. This questionnaire is designed to canvas yourexperience and your views in relation to these issues.

Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin,The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQFax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk

1. To ensure consumer choice and safety when eating out, which of the following issues do youthink it is important for consumers to have information about?

ImportanceScale of 1 (not) – 5 (very)

a) Use of common food allergens as ingredients

• Nuts/peanuts• Sesame seeds• Fish• Shellfish• Eggs• Soya• Milk• Other – please state……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

ImportanceScale of 1 (not) – 5 (very)

b) Healthy eating choices

• Ingredients used• Nutrient content• Low-fat choices• Low-calorie choices• High-fibre choices• Low salt choices• Cooking method, e.g. fried, baked• Other – please state……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

ImportanceScale of 1 (not) – 5 (very)

c) Logos or statements

• Vegetarian• Organic• Gluten-free• Other……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

d) The country of origin of the ingredients/foode.g. British beef, French chicken

1 2 3 4 5

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e) Portion size 1 2 3 4 5

f) Other – please state…………………………………………………… 1 2 3 4 5Are your responses to question 1 based on:

!!!! If based on research, please givedetails/references

Consumer researchConsumer enquiriesOther informationPersonal opinion

2. To ensure consumer choice and safety when buying non-prepacked foods, which of thefollowing issues do you think it is important to have information about?

ImportanceScale of 1 (not) – 5 (very)

a) Use of common food allergens as ingredients

• Nuts/peanuts• Sesame seeds• Fish• Shellfish• Eggs• Soya• Milk• Other – please state ……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

ImportanceScale of 1 (not) – 5 (very)

b) Healthy eating choices

• Ingredients used• Nutrient content• Low-fat choices• Low-calorie choices• High-fibre choices• Low salt choices• Cooking method, e.g. fried, baked• Other – please state ……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

ImportanceScale of 1 (not) – 5 (very)

c) Logos or statements

• Vegetarian/Vegan• Organic• Gluten free• Other – please state ……………………………………………….

Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

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d) The country of origin of the ingredients/foode.g. British beef, French chicken

1 2 3 4 5

e) Use by date 1 2 3 4 5f) Quantities of main ingredients 1 2 3 4 5g) Other – please state…………………………………………………… 1 2 3 4 5

Are your responses to question 2 based on:

!!!! If based on research, please givedetails/references

Consumer researchConsumer enquiriesOther informationPersonal opinion

3. What do you think about the usefulness for consumers of providing cooking instructions forraw or uncooked foods such as burgers, sausages and chickens that are sold non-prepacked?

4. To help us make recommendations on any of the above issues can you think of any practicalsteps that would be helpful to consumers?

5. And, do you foresee any barriers that will make progress difficult to achieve?

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6. Do you know of any research [consumer or industry practices] that has been conducted inrelation to any of these issues, either within the UK or internationally?

7. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details will be treated in confidence and youranswers will not be attributed either to yourself or to your organisation.

Organisation

Your name

Address

Tel

Fax

E-mail

91

SELF-COMPLETION QUESTIONNAIRE – MANUFACTURERS

This questionnaire relates to products sold to the catering industry, and sold non-prepacked to theend consumer.

There are no right or wrong answers – please base your answers on current practice.

Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin,The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQFax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk

A. Food Allergies

The Food Standards Agency wishes to help consumers with food allergy to select foods withconfidence when they eat out or purchase non-prepacked foods. The questions in this section aredesigned to review current manufacturing practice for products sold to the catering industry, andalso for products that are sold non-prepacked to the end consumer.

1. Do your suppliers routinely provide information about all uses of nuts/peanuts as ingredients(including very small amounts), or of the possibility of traces of nuts/peanuts being present in thegoods that you purchase? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry.

!No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know

2. Do your suppliers routinely provide information about all uses of other food allergens(including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk,soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively common cause offood intolerance. Please focus your answer on products that are to be sold non-prepacked to theend consumer or sold to the catering industry.

! If some or all, which allergens:No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know

3. Where information is received:

What format is it in?

How does your company retain it?

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How is it used by your company,and passed on to your consumers?

4. Does your company request any special operational procedures from suppliers in relation tonuts/peanuts? Please focus your answer on products that are to be sold non-prepacked to the endconsumer or sold to the catering industry.

! If some or all, please provide detailsFrom no suppliers

From some suppliers

From all suppliers

Don’t know

5. Does your company request any special operational procedures from suppliers in relation toother food allergens? Please focus your answer on products that are to be sold non-prepackedto the end consumer or sold to the catering industry.

! If some or all, please provide detailsFrom no suppliers

From some suppliers

From all suppliers

Don’t know

6. Do your immediate clients request additional or specific information about the presence ofnuts/peanuts, including traces of nuts/peanuts, in your products or about the operationalprocedures? Please focus your answer on products that are to be sold non-prepacked to the endconsumer or sold to the catering industry.

! If some or all, please provide detailsNo clients request this

Some clients

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All clients

Don’t know

7. Do your immediate clients request additional or specific information about the presence ofother food allergens in your products or about the operational procedures? Please focus youranswer on products that are to be sold non-prepacked to the end consumer or sold to thecatering industry.

! If some or all, please provide detailsNo clients request this

Some clients

All clients

Don’t know

8. If your company uses nuts/peanuts as an ingredient in foods that are to be sold non-prepackedto the end consumer and in products sold to the catering industry, how are the nuts/peanutsstored and labelled?

!No differently to other ambient ingredientsIn a separate area, with distinctive labellingDon’t know

9. How are products containing nuts/peanuts prepared? Please focus your answer on productsthat are to be sold non-prepacked to the end consumer or sold to the catering industry.

! Details of special proceduresNo differently to products that do not containnuts

Special procedures are in place – please state

Don’t know

10. For products that contain nuts/peanuts, are staff briefed on the contents and on any changes tothe products being made? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry.

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! If yes, how frequently:NeverYesDon’t know

11. Does your company undertake any staff training about the issue of food allergy?

! If yes, how frequently:NoYesDon’t know

B Consumer Choice

12. Does your company provide ‘healthy eating’ choices to the catering industry or for productsthat are to be sold non-prepacked to the end consumer – e.g. products promoted as low in fat,low in calories, high in fibre, low in salt etc?

! If yes, please give some examplesYesNoDon’t know

13. If yes: how are your immediate clients informed about these products?

!Claims are made on the label

Nutritional analysis is provided

Products are part of a healthy eating range

Don’t know

14. Does your company manufacture vegetarian or vegan products (that are sold to the cateringindustry or to be sold non-prepacked to the end consumer)?

!!!! Vegetarian !!!! Vegan If yes, please give some examplesYes

No

Don’t know

15. If yes: do they carry a logo or statement?

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!YesNoDon’t know

16. Do you routinely provide any cooking instructions for the end consumer for raw oruncooked foods such as burgers, sausages and chickens that are to be sold non-prepacked to theend consumer?

! If yes, please give details of how this information is provided:

Yes

No

C The Future

17. To help us make recommendations on any of the above issues, can you suggest anypractical steps that would be helpful to consumers and workable for you?

18. And do you foresee any barriers that will make progress difficult to achieve?

19. Please add any further comments or observations

Your help in completing this questionnaire is much appreciated.

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Your contact details would be helpful should we need to clarify any of the information andto avoid us contacting your organisation again. These details will be treated in confidenceand your answers will not be attributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

97

SELF-COMPLETION QUESTIONNAIRE – RETAILERS

This questionnaire relates to products sold non-prepacked to your customers.There are no right or wrong answers – please base your answers on current practice.

Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin,The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQFax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk

1. Which types of non-prepacked products do you sell?

!Bakery products such as bread, buns, rolls etcDelicatessen products such as cold meats, pates, cheese, prepared saladsFishFruit and vegetablesHot cooked chickenMeat and meat products such as sausages and piesPick and Mix (confectionery)Ready made PizzaTake away mealsOther (please specify):………………………………………………………………………………………………..

A. Food Allergies

People with food allergy need to avoid certain foods, such as nuts/peanuts, shellfish or eggs.Buying non-prepacked foods can cause problems, as customers don’t always know whichingredients have been used. We are trying to find out about the sort of information available tocustomers at the moment, so that we can make recommendations that will help people with foodallergy in the future.

2. Are you aware of concerns about food allergy?

!YesNoDon’t Know

3. For the foods that you sell non-prepacked, are you aware of which ingredients have beenused. For example, would you know if nuts/peanuts or shellfish, milk or eggs were present in aproduct you sell?

!Not for any products

For some products

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For all products

Don’t know

4. If you sell non-prepacked products with nuts/peanuts, how are these displayed and served e.g.on delicatessen counters?

! Details of any special proceduresNo differently to other products

Special procedures are in place (please statewhat these are)Don’t know

Not relevant

5. How are non-prepacked products containing other ingredients to which some people areallergic (e.g. sesame seeds, shellfish) displayed and served e.g. on delicatessen and bakerycounters?

! Special proceduresNo differently to other products

Special procedures are in place – (pleasestate what these are)Don’t know

6. How are non-prepacked nuts/peanuts displayed and served, e.g. pick and mix counters?

! Special proceduresNo differently to similar products

Special procedures are in place - (please statewhat these are)Don’t know

Not relevant

7. If your customers need to know whether nuts/peanuts (or other ingredients that cause anallergy) are in non-prepacked products, are you able to help them?

!We can’t helpStaff are informed and can answer questionsDisplay tickets indicate products that contain nuts/peanutsWe go back and ask our supplier/wholesalerDon’t know

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8. Do your customers ever ask if nuts/peanuts are in any non-prepacked products?

!YesNoDon’t know

9. Do your customers ever ask about the use of other ingredients in non-prepacked products towhich they may be allergic e.g. fish, milk, eggs?

! If yes, which ingredients:YesNoDon’t know

10. For non-prepacked products containing nuts/peanuts, and other important food allergens, areyour staff briefed on the contents and on any changes to the ingredients of dishes served, e.g.change in the type of nut used?

! If yes, how frequently:NeverYesDon’t know

B Consumer Choice

11. Do your customers ever ask for information about healthy eating choices in relation to non-prepacked products?

!NoYes – they ask about healthy choicesYes – they ask about use of specific ingredients such as cream/oil/ butter/saltYes – they ask about the cooking method such as fried or bakedDon’t know

12. Are any of the non-prepacked products you sell promoted as ‘healthy choices’– e.g.products low in fat, low in calories, high in fibre, low in salt?

! If yes, please give examplesYesNoDon’t know

13. If yes: how do your customers know?

! Other meansThrough display tickets

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Staff provide details if askedOther means (please state)Don’t know

14. Do customers ever ask for information about vegetarian or vegan choices in relation to non-prepacked products?

!!!! Vegetarian !!!! VeganYesNoDon’t know15. Where vegetarian or vegan products are sold non-prepacked how is the customer informed?

! Other meansThrough a display ticket

Staff provide details if asked

It is communicated by other means(please state)Don’t know

We don’t sell products forvegetariansWe don’t sell products for vegans

16. Do you provide any other information about the products sold non-prepacked?

Yes ! No ! Don’t know !Descriptions such as ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’ etc

Use by date or shelf-life information

The country of origin of theingredients/foode.g. British beef, French chicken

17. Do your customers ever ask for information of this type for non-prepacked products?

Yes ! No ! Don’t know !If the food is Fresh’, ‘Home-made’,‘Farmhouse’, ‘Traditional’

Use by date or shelf-life information

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The country of origin of theingredients/foode.g. British beef, French chicken

Anything else

………………………………..

18. Do you provide either of the following?

Yes ! No ! Don’tknow !

Sales/delivery via Internet orderingSales/delivery via telephone ordering

19. If yes, are any procedures in place to inform customers who may want informationabout allergens, healthy eating, vegetarian products etc, in relation to non-prepackedproducts?

! If yes, please give details:

Yes

No

20. Do you routinely provide any cooking instructions for raw or uncooked foods such asburgers, sausages and chickens that are sold non-prepacked?

! If yes, please give details of how this is done:

Yes

No

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C The future

21. To help us make recommendations on any of the above issues, can you suggest any practicalsteps that would be helpful to consumers and workable for you?

22. And do you foresee any barriers that will make progress difficult to achieve?

23. Please add any further comments or observations:

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Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details will be treated in confidence and youranswers will not be attributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

104

DETAILED QUESTIONNAIRE – CATERING

There are no right or wrong answers – but honest answers will be of most help.

This questionnaire can either be filled out and returned by DATE to:

OR it can form the basis of a telephone interview.

A. Food Allergies

2. Are you aware of concerns about food allergy?

!YesNoDon’t Know

The Food Standards Agency has agreed a four-strand approach to help consumers with foodallergy select foods with confidence when they eat out. The questions in this section are designedto review current practice in each of these four areas.

Information for your customers

2. Do your customers ever ask whether nuts/peanuts are used in your operation/kitchen, or arepresent in any dishes?

!!!! If yes, please indicate the number of requestsfor information per week

YesNoDon’t know

3. Do your customers ever ask about other ingredients to which they may be allergic e.g. milk,fish, shellfish?

! If yes, which ingredients: If yes, indicate the number ofrequests for information per week

YesNoDon’t know

4. Do you point out the use of nuts/peanuts where their presence is not obvious from the nameof the dish? E.g. Chicken Satay (peanuts not in name of dish).

! If yes, which nuts:Yes

No

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Don’t know

5. Do you point out the use of other ingredients to which people may be allergic - such as fish,shellfish, milk – where their presence is not obvious from the name of the dish? E.g. soupcontaining milk, where milk is not in the names of the dish.

! If yes, which ingredients?Yes

No

Don’t know

6. If yes to questions 12 or 13: how do you inform customers about these particular ingredients?

! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

Other means – please state in spaceprovidedDon’t know

7. Does your company have any policy or advice for your customers who have food allergies?

! If yes, please give detailsYes

No

Don’t know

Storage and preparation

8. If your company uses nuts/peanuts as an ingredient, how are these stored and labelled?

!No differently to other ambient ingredients

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In a separate area, with distinctive labelling

Don’t know

9. How are dishes containing nuts/peanuts prepared?

! Special proceduresNo differently to other dishes

Special procedures are in place – please state

Don’t know

10. For dishes containing nuts/peanuts, are staff briefed on the contents and on any changes tothe dishes served e.g. use of different types of nut?

!NeverDailyAs menus changeDon’t know

Training

11. Has your company ever received educational information about food allergies?

! If yes, where from:Yes

No

Don’t know

12. Does your company have regular staff training?

! If yes, how frequently:NoYes – but allergies not includedYes – allergies includedDon’t know

Information received from suppliers/wholesalers

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13. Do your suppliers/wholesalers routinely provide information about all uses of nuts/peanuts asingredients (including very small amounts), or of the possibility of traces of nuts/peanuts beingpresent in the goods that you purchase?

!No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know14. When products are labelled ‘May contain traces of nuts’, what does this mean to you and how

do you use the information?

!It reflects well-controlled systems – we take note of the informationIt is a general warning that appears on many products – we don’t use the informationIt means different things for different suppliersDon’t knowOther – please specify

15. Do your suppliers/wholesalers routinely provide information about all uses of other foodallergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs,

milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively commoncause of food intolerance. For example do they flag up ‘Contains Egg’?

! If some or all, which allergens:No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know

16. When information about allergens is provided:

Please give details:

What format is it in?

How does your company retain it?

How is it used by your company, and passedon to your consumers?

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How do you distinguish betweenfoods/ingredients that are suitable for ‘nut-free’ products and those that are not?

If foods/ingredients are suitable for ‘nut-free’products, do you keep the packaging or othermeans of retaining this information?

17. Does your company request any special operational procedures from suppliers/wholesalers inrelation to nuts/peanuts?

! If some or all, please give detailsFrom no suppliers

From some suppliers

From all suppliers

Don’t know

18. In relation to the foods and ingredients that you buy in:

i) If you remove the goods from the packaging e.g. decant into storage containers/freezers/fridgesetc, do you keep the labels or a note of the label information?

!Keep labelsTake a note of the label informationDon’t know

ii) Is the label a useful method of providing you with information about food allergens, or do youthrow away the packaging before the goods get into the kitchen?

!Useful means of providing informationNot useful – label thrown away before goods are usedDon’t know

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B Consumer Choice

19. Do your customers ever ask for information about healthy eating choices – e.g. dishes thatare low in fat, low in calories, high in fibre, low in salt etc?

! If yes, how manyrequests per week

No

Yes – they ask about healthy eating choices

Yes – they ask about use of specific ingredients such ascream/oil/ butter/saltYes – they ask about the cooking method such as friedor bakedDon’t know

20. Does your company provide healthy eating choices – e.g. dishes that are low in fat, low incalories, high in fibre, low in salt etc?

! If yes, please give some examplesYes

No

Don’t know

21. How are your customers informed about the status of these dishes?

! Other means:It is printed on the menuStaff provide details if askedIt is communicated by other means –please stateWe don’t see a need to tell themDon’t know

22. Do your suppliers/wholesalers provide information about the nutritional content ofproducts/ingredients?

!No suppliers provide thisSome suppliersAll suppliersOur company requests it

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Don’t know

23. Do your customers ever ask for information about vegetarian or vegan choices?

!!!!Vegetarian

If yes, how manyrequests per week

!!!! Vegan If yes, how manyrequests per week

Yes

No

Don’t know

24. Does your company routinely provide vegetarian or vegan choices?

!!!! Vegetarian !!!! Vegan If yes, please give some examplesYes

No

Don’t know

25. How are your customers informed about the status of these dishes?

! Other means:It is printed on the menuStaff provide details if askedIt is communicated by other means –please stateWe don’t see a need to tell themDon’t know

26. Do you routinely provide any other information about the dishes you serve, on a voluntarybasis?

Yes !– please give details No!

Don’tknow !

Portion size -e.g. the size of a steak is often givenon the menu – is the portion size ofany other foods given?Descriptions such as ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’ etc

The country of origin of theingredients/ foode.g. British beef, French chicken

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Cooking method e.g. fried, grilled,baked, steamed

27. Do your customers ever ask for other information about the dishes available?

Yes – please state numberof requests per week

No ! Don’t know !

Portion size

If dishes are ‘Fresh’, ‘Home-made’,‘Farmhouse’, ‘Traditional’ etcThe country of origin of theingredients/ foode.g. British beef, French chickenCooking method e.g. fried, grilled,baked, steamedOther………………………………….

28. Do you provide either of the following?

! Yes ! No ! Don’t knowSales/delivery via Internet ordering

Sales/delivery via telephone ordering

29. If yes, are any procedures in place to inform customers who may wantinformation about allergens, healthy eating, vegetarian products etc

! If yes, please give details:

Yes

No

C International Practice

30. In relation to any international operations that you have:

Please comment on any differences between UK and international operations in the followingareas?Food Allergies CommentsStorage/preparation of dishescontaining allergens

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Staff training

Informing customers

Consumer Choice CommentsProviding healthy eating choices

Providing vegetarian or vegandishes

Indicating portion size

Providing descriptions such as‘Fresh’, ‘Home-made’,‘Farmhouse’, ‘Traditional’ etc

Providing information about thecountry of origin of ingredients/food e.g. British beef, Frenchchicken

Providing information about thecooking method e.g. fried,grilled, baked, steamed

31. In relation to your international suppliers/wholesalers:

Please comment on any difference between UK and international suppliers in the followingareas?Food Allergies CommentsInformation provided by suppliers

Consumer Choice CommentsProviding nutritional information

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Providing information aboutvegetarian and vegan products

Providing information about thecountry of origin of ingredients/foode.g. British beef, French chicken

32. Are you aware of any research [consumer or industry practices] conducted in relation to anyof these issues, either within the UK or internationally?

D The Future

33. To help us make recommendations on any of the above issues, can you suggest any practicalsteps that would be helpful to consumers and workable for you?

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34. And do you foresee any barriers that will make progress difficult to achieve?

35. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details these will be treated in confidence andyour answers will not be attributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

115

DETAILED QUESTIONNAIRE – MANUFACTURERS

Relating to products sold to the catering industry, and non-prepacked to the end consumer.

This questionnaire can either be filled out and returned by DATE to:

OR it can form the basis of a telephone interview.

There are no right or wrong answers – your answers should be based on current practice.

A. Food Allergies

The Food Standards Agency wishes to help consumers with food allergy to select foods withconfidence when they eat out or purchase non-prepacked foods. The questions in this section aredesigned to review current manufacturing practice for products sold to the catering industry, andalso for products that are sold non-prepacked to the end consumer.

1. Do your suppliers routinely provide information about all uses of nuts/peanuts as ingredients(including very small amounts), or of the possibility of traces of nuts/peanuts being present in thegoods that you purchase? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry.

!No suppliers provide this

Some suppliers

All suppliers

Our company requests it

Don’t know

2. When ingredients you buy are labelled ‘May contain traces of nuts’, what does this mean toyou and how do you use the information, particularly in relation to your products that are sold

non-prepacked to the end consumer or sold to catering establishments.

!It reflects well-controlled systems – we take note of the information

It is a general warning that appears on many products – we don’t use the information

It means different things for different suppliers

Don’t know

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Other – please specify

3. Do your suppliers routinely provide information about all uses of other food allergens(including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk,

soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively commoncause of food intolerance. For example do they flag up ‘Contains Egg’? Please focus youranswer on products that are to be sold non-prepacked to the end consumer or sold to the

catering industry. For example do they flag up ‘Contains Egg’?

! If some or all, which allergens:No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know

4. Where information about allergens is received:

What format is it in?

How does your company retain it?

How is it used by your company, and passedon to your consumers – particularly withreference to your products that are sold non-prepacked to the end consumer and sold tocatering establishments?

How do you distinguish betweenfoods/ingredients that are suitable for ‘nut-free’ products and those that are not?

If foods/ingredients are suitable for ‘nut-free’products, do you keep the packaging or othermeans of retaining this information?

5. Does your company request any special operational procedures from suppliers in relation tonuts/peanuts? Please focus your answer on products that are to be sold non-prepacked to the endconsumer or sold to the catering industry.

! If some or all, please provide details

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From no suppliers

From some suppliers

From all suppliers

Don’t know

6. Does your company request any special operational procedures from suppliers in relation toother food allergens? Please focus your answer on products that are to be sold non-prepackedto the end consumer or sold to the catering industry.

! If some or all, please provide details e.g. which allergensFrom no suppliers

From some suppliers

From all suppliers

Don’t know

7. Do your immediate clients request additional or specific information about the presenceof nuts/peanuts, including traces of nuts/peanuts, in your products or about the operationalprocedures (for foods that are to be sold non-prepacked or through catering establishments)?

! If some or all, please provide detailsNo clients request this

Some clients

All clients

Don’t know

8. Do your immediate clients request additional or specific information about the presenceof other food allergens in your products or about the operational procedures (for foods thatare to be sold non-prepacked or through catering establishments)? E.g. preparation ofmeringues within a flour environment in relation to the possible presence of gluten.

! If some or all, please provide detailsNo clients request this

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Some clients

All clients

Don’t know

9. If your company uses nuts/peanuts as an ingredient in foods that are sold non-prepacked to theend consumer and in products sold to the catering industry, how are the nuts/peanuts storedand labelled?

!No differently to other ambient ingredientsIn a separate area, with distinctive labellingDon’t know

10. How are products containing nuts/peanuts prepared? Please focus your answer on productsthat are to be sold non-prepacked to the end consumer or sold to the catering industry.

! Details of special proceduresNo differently to other productsSpecial procedures are in place – please stateDon’t know

11. Are operational staff aware which products contain nuts/peanuts, and are they briefed wheningredients change, e.g. if nuts/peanuts are added or removed from products? Please focus youranswer on products that are to be sold non-prepacked to the end consumer or sold to thecatering industry.

! If yes, how frequently:Never

Yes

Don’t know

12. Does your company undertake any staff training about the issue of food allergy?

! If yes, how frequently:No

Yes

Don’t know

B Consumer Choice

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13. Does your company provide ‘healthy eating’ choices to the catering industry or that are to besold non-prepacked to the end consumer – e.g. products promoted as low in fat, low in calories,high in fibre, low in salt etc?

! If yes, please give some examplesYes

No

Don’t know

14. If yes: how are your clients informed about the status of these products?

!Claims are made on the labelNutritional analysis is providedProducts are part of a healthy eating rangeDon’t know15. Does your company manufacture vegetarian or vegan products (that are sold to the cateringindustry or to be sold non-prepacked to the end consumer)?

! Vegetarian ! Vegan If yes, please give some examplesYes

No

Don’t know

16. If yes: do they carry a logo or statement?

!Yes

No

Don’t know

17. Do you routinely provide any cooking instructions for the end consumer for raw or uncookedfoods such as burgers, sausages and chickens that are to be sold non-prepacked?

! If yes, please give details of how this information is provided:

Yes

120

No

C International Practice

18. In relation to any international operations that you have:

In relation to foods that are to be sold non-prepacked to the end consumer please comment on anydifferences between UK and international operations in the following areas?Food Allergies Comments

Supplier information provision

Storage/preparation of dishes

Consumer Choice CommentsProviding healthy choices

Providing vegetarian/vegan dishes

Providing cooking instructions forraw or uncooked foods

19. In relation to your international suppliers:

Are you aware of any difference between UK and international suppliers in the following areas?Food Allergies Comments

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Information provided by suppliers

Consumer Choice CommentsProviding nutritional information

Providing information aboutvegetarian/vegan products

20. Are you aware of any research [consumer or industry practices] conducted in relation to anyof these issues, either within the UK or internationally?

D The Future

21. To help us make recommendations on any of the above issues, can you suggest anypractical steps that would be helpful to consumers and workable for you?

22. And do you foresee any barriers that will make progress difficult to achieve?

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23. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated.

Please provide your contact details in order that I can contact you to clarify any of theinformation. These details these will be treated in confidence and your answers will not beattributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

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DETAILED QUESTIONNAIRE – RETAILERS

Relating to products sold non-prepacked to your customers.

This questionnaire can either be filled out and returned by DATE to:

OR it can form the basis of a telephone interview.

There are no right or wrong answers – your answers should be based on current practice.

A. Food Allergies

The Food Standards Agency has agreed a four-strand approach to help consumers with foodallergy select foods with confidence when they eat out. These issues are also relevant to foodsthat are sold non-prepacked to the end consumer. The questions in this section are designed toreview current practice in each of these four areas.

I Information received from suppliers/wholesalers

1. Do your suppliers/wholesalers routinely provide information about all uses of nuts/peanuts asingredients (including very small amounts), or of the possibility of traces of nuts/peanuts beingpresent in the goods that you purchase that are sold non-prepacked to customers?

!No suppliers provide thisSome suppliersAll suppliersOur company requests itDon’t know

4. When products are labelled ‘May contain traces of nuts’, what does this mean to you and howdo you use the information?

!It reflects well-controlled systems – we take note of the informationIt is a general warning that appears on many products – we don’t use the informationIt means different things for different suppliersDon’t knowOther – please specify

3. Do your suppliers/wholesalers routinely provide information about all uses of other foodallergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs,

milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively commoncause of food intolerance. For example do they flag up ‘Contains Egg’?

! If some or all, which allergens:No suppliers provide thisinformation

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Some suppliersAll suppliersOur company requests itDon’t know4. Where information about allergens is provided:

What format is it in?

How does your company retain it?

How is it used by your company, and passedon to your consumers?

How do you distinguish between ‘nut-free’products and those that are not?

If products are ‘nut-free’, do you keep thepackaging or other means of retaining thisinformation?

5 Does your company request any special operational procedures from suppliers in relation tonuts/peanuts, for goods that are sold non-prepacked?

! If some or all, please provide details:From no suppliers

From some suppliers

From all suppliers

Don’t know

6. Does your company request any special operational procedures from suppliers in relation toother food allergens?

! If some or all, please provide details e.g. which allergensFrom no suppliers

From some suppliers

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From all suppliers

Don’t know

II Display and serving

7. How are products containing nuts/peanuts displayed and served e.g. on delicatessen counters?

! Special proceduresNo differently to other dishes

Special procedures are in place - please state

Don’t know

Not relevant

8. How are non-prepacked nuts/peanuts displayed and served, e.g. on pick and mix counters?

! Special proceduresNo differently to similar products

Special procedures are in place - please state

Don’t know

Not relevant

9. How are products containing other important food allergen sources (e.g. sesame seeds,shellfish) displayed and served e.g. on delicatessen and bakery counters.

! Special proceduresNo differently to other dishes

Special procedures are in place - please state

Don’t know

Not relevant

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10. For products containing nuts/peanuts, and other important food allergens, are your staffbriefed on the contents and on any changes to the ingredients of dishes served, e.g. change in thetype of nut used?

! If yes, how frequently:Never

Yes

Don’t know

III Training

11. Does your company have regular staff training?

! If yes, how frequently:NoYes – allergies not includedYes – allergies includedDon’t know

IV Information for the customer

12. If your customers need to know if nuts/peanuts or other ingredients are in products, how arethey informed?

! Other means:Display tickets indicateproducts that containnuts/peanutsStaff are informed and cananswer questionsA display ticket suggests thatcustomers ask staffWe go back and ask oursuppliers/wholesalersDon’t know

13. Do your customers ever ask whether nuts/peanuts are present in any non-prepackedproducts?

!!!!YesNoDon’t know

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14. Do your customers ever ask about use of other ingredients to which they may be allergic e.g.fish, milk, shellfish?

! If yes, which ingredients:YesNoDon’t know

15. Does your company have any policy or advice for customers with food allergies in relation tonon-prepacked products?

! If yes, please give detailsYesNoDon’t know

B Consumer Choice

16. Do your customers ask for information about healthy eating choices?

! If yes, how manyrequests per week

NoYes – they ask about healthy eating choicesYes – they ask about use of specific ingredients such ascream/oil/ butter/saltYes – they ask about the cooking method such as friedor bakedDon’t know

17. Are any of the non-prepacked products you sell promoted as ‘healthy eating choices’– e.g.products low in fat, low in calories, high in fibre, low in salt?

! If yes, please give examples of productsYesNoDon’t know

18. If yes: how is the customer informed about these products?

!Through display ticketsStaff provide details if askedCommunicated by other means e.g. leaflets, tent cards, menusDon’t know

19. Do you provide any other nutritional information about foods sold non-prepacked e.g.calorie or fat content?

! If yes, please give some examples

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Yes

No

Don’t know

20. Do your customers ask for information about vegetarian or vegan choices?

!!!!Vegetarian

If yes, how manyrequests per week

!!!! Vegan If yes, how manyrequests per week

Yes

No

Don’t know

21. Where vegetarian or vegan products are sold non-prepacked, how are your customersinformed?

! Other meansThrough a display ticket

Staff provide details if asked

It is communicated by other means – please state

Don’t know

We don’t provide products for vegetarians

We don’t provide products for vegans

22. Do you routinely provide any other information about the products sold non-prepacked, on avoluntary basis?

Yes – please give details !!!! No!!!!

Don’tknow!!!!

Descriptions such as ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’ etc

Use by date or shelf-life information

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The country of origin of theingredients/foode.g. British beef, French chicken

Cooking method e.g. fried, grilled,baked, steamed

23. Do your customers ever ask for information of this type?

Yes - please state number ofrequests per week

No!!!!

Don’t know !!!!

If the food is ‘Fresh’, ‘Home-made’,‘Farmhouse’, ‘Traditional’ etcUse by date or shelf-life information

The country of origin of theingredients/foode.g. British beef, French chickenCooking method e.g. fried, grilled,baked, steamedOther…………………………………24. Do you provide either of the following?

Yes ! No ! Don’t know !Sales/delivery via Internet orderingSales/delivery via telephone ordering

25. If yes, are any procedures in place for non-prepacked foods to informcustomers who may want information about allergens, healthy eating, vegetarianproducts etc ?

! If yes, please give details:Yes

No

26. Do you routinely provide any cooking instructions for raw or uncooked foods such asburgers, sausages and chickens that are sold non-prepacked?

! If yes, please give details of how this is done:Yes

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No

C International Practice

27. Do you have any international operations? If yes, please answer the questions below. If no,please go to Q23.

In relation to foods sold non-prepacked please comment on any differences between UK andinternational operations in the following areas:Food Allergies CommentsDisplay and serving of non-prepacked products

Staff training

Informing customers about foods thatmay contain allergens

Consumer Choice CommentsProviding healthy options andnutrition information

Offering vegetarian or vegan dishes

Use of descriptions such as ‘Fresh’,‘Home-made’, ‘Farmhouse’,‘Traditional’ etc

Use by date or shelf-life information

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Providing information about thecountry of origin of ingredients/ foode.g. British beef, French chicken

Providing information about thecooking method e.g. fried, grilled,baked, steamed

Providing information on goodsordered by Internet or telephone forhome deliveryProviding cooking instructions forraw or uncooked foods

28. In relation to your international suppliers/wholesalers:

Please comment on any differences between UK and international suppliers/wholesalers in thefollowing areas in relation to foods sold non-prepacked:Food Allergies CommentsInformation provided bysuppliers/wholesalers

Consumer Choice CommentsProviding nutritional information

Providing information aboutvegetarian and vegan products

Providing information about thecountry of origin of ingredients/ foode.g. British beef, French chicken

Other

………………………………….

29. Are you aware of any research [consumer or industry practices] conducted in relation to anyof these issues, either within the UK or internationally?

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D The future

30. To help us make recommendations on any of the above issues, can you suggest any practicalsteps that would be helpful to consumers and workable for you?

31. And do you foresee any barriers that will make progress difficult to achieve?

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32. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details these will be treated in confidence andyour answers will not be attributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

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DETAILED QUESTIONNAIRE – SCHOOLS POLICY

There are no right or wrong answers – but honest answers will be of most help.

This questionnaire can either be filled out and returned by End Feb 2002 to:

OR it can form the basis of a telephone interview.

A. Food Allergies

1. In relation to nut allergies, does your local authority have a policy on the use of nuts inschool meals? If yes please provide details.

2. If yes, how is this policy communicated to schools, parents and caterers?

3. If there is a policy not to use nuts, is there any policy for the use of ingredients that may havecome into contact with nuts through the supply chain?

!!!! DetailsNo

The suppliers deal with thisissue

We have a policy – pleasegive details

4. Do parents ever ask whether nuts/peanuts are used, or are present in any dishes?

!!!!YesNoDon’t know

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5. Are there any policies for other ingredients to which children/teachers may be allergice.g. milk, fish, shellfish?

! If yes, which ingredients:YesNoDon’t know

6. How is the use of other ingredients to which people may be allergic - such as fish,shellfish, milk, gluten communicated, particularly – where their presence is not obvious from thename of the dish? E.g. soup containing milk, where milk is not in the names of the dish.

! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

Other means – please state in spaceprovidedDon’t know

7. Please add any further information relevant to food allergies – e.g. are children with particularallergies dealt with individually?

Further information

B Healthy Eating - nutrition

8. In relation to healthy eating, does your local authority have a policy on healthy eating inaddition to any statutory guidelines? If yes please provide details.

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9. If yes, how is this policy communicated to schools, parents and caterers?

10. Do parents ever ask about healthy eating policy?

!!!!YesNoDon’t know

11. How do children and teachers identify healthy eating options?

! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

Other means – please state in spaceprovidedDon’t know

12. Any further information – e.g. are children with particular dietary requirements dealt withindividually?

Further information

C Use of food additives

13. Does your local authority have a policy on use of food additives? If yes please providedetails.

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14. If yes, how is this policy communicated to schools, parents and caterers?

15. Do parents ever ask about food additives policy?

!!!!YesNoDon’t know

16. Please add any additional relevant information

Further information

D Vegetarian/Vegan Options

17. Does your local authority have a policy on vegetarian and/or vegan options? If yes pleaseprovide details.

18. If yes, how is this policy communicated to schools, parents and caterers?

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19. Do parents ever ask about vegetarian/vegan policy?

!!!!YesNoDon’t know

20. How do children and teachers identify vegetarian/Vegan options?

! Other means:It is printed on the menu

It is chalked on the blackboard

Staff provide details if asked

Other means – please state in spaceprovidedDon’t know

21. Please add any additional relevant information

Further information

E Other Issues

22. Does your local authority have a policy on any other issues, e.g. GM foods, Organic foods? Ifyes please provide details.

23. If yes, how is this policy communicated to schools, parents and caterers?

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24. Do parents ever ask about these or any other issues ?

!!!! Which issues?YesNoDon’t know

25. Is any other information routinely provided about dishes served?

Yes !– please give details No!

Don’tknow !

Portion size -

Descriptions such as ‘Fresh’, ‘Home-made’, ‘Farmhouse’, ‘Traditional’ etc

The country of origin of theingredients/ foode.g. British beef, French chicken

Cooking method e.g. fried, grilled,baked, steamed

26. Is such information ever asked for?

Yes No ! Don’t know !Portion size

If dishes are ‘Fresh’, ‘Home-made’,‘Farmhouse’, ‘Traditional’ etcThe country of origin of theingredients/ foode.g. British beef, French chickenCooking method e.g. fried, grilled,baked, steamedOther………………………………….

27. Are you aware of any research [consumer or industry practices] conducted in relation to anyof these issues, either within the UK or internationally?

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F The Future

28. To help us make recommendations on any of the above issues, can you suggest anypractical steps that would be helpful to consumers and workable for you?

29. And do you foresee any barriers that will make progress difficult to achieve?

30. Please add any further comments or observations:

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Your help in completing this questionnaire is much appreciated.

Your contact details would be helpful should we need to clarify any of the information and toavoid us contacting your organisation again. These details these will be treated in confidence andyour answers will not be attributed either to yourself or to your organisation.

Company

Main functionof businessYour Name

Address

Tel

Fax

E-mail

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APPENDIX C FOOD ALLERGY ISSUES ALLIANCE (FAIA) FOOD ALLERGYLABELLING GUIDELINES

(i) Major Food AllergensThe Food Allergen Labelling Guidelines focus on the Major Food Allergens, which havebeen estimated to cause more than 90% of all food allergic reactions. For the purposes ofthis programme, the Major Food Allergens are defined as the allergenic proteins from:1. Crustaceans (such as crab, crayfish, lobster, and shrimp)2. Eggs;3. Fish;4. Milk;5. Peanuts;6. Soy;7.Tree nuts (almonds, Brazil nuts, cashews, chestnuts, filberts/hazelnuts, macadamia nuts,pecans, pine nuts, pistachios, and walnuts); and,8. Wheat.Additional food allergens may be added to this list of Major Food Allergens as theirpublic health importance becomes recognised.

An ingredient that is derived from a Major Food Allergen is not subject to theseguidelines when it does not contain the causative allergenic protein. By way of example,highly refined peanut and soybean oils would not be subject to these labelling guidelinesto the extent that the allergenic proteins are not present in the oils.

(ii) Use of Ingredient Terms Commonly Understood by ConsumersIngredient terms commonly understood by consumers for the Major Food Allergens inthe product should appear within, or in immediate proximity to, the ingredient declarationof the food label. Examples of acceptable ingredient terms commonly understood byconsumers of Major Food Allergens include, ‘eggs’, ‘fish’, ‘milk’, ‘peanuts’, ‘shrimp’,‘soy’, ‘walnut’ or ‘wheat’.

(iii) Label Declaration of Major Food AllergensA food that contains a protein of a Major Food Allergen should be labelled in a mannerthat informs the consumer of the allergen’s presence, regardless of its source. Ingredientdeclarations, which appear on the information panels of food labels, are the primaryvehicle for communicating information about food allergens to the at-risk population.Information on Major Food Allergens should appear within, or in immediate proximityto, ingredient declarations. A Major Food Allergen should be disclosed even where alabelling exemption might otherwise apply (e.g., as a component of a flavour). Foodprocessors should request from their suppliers, and those suppliers should provide,information about the presence of Major Food Allergens in all food ingredients, such asflavours. Food processors should carry this information forward to the ingredientdeclarations on labels of foods that use those ingredients. The ingredient terms commonlyunderstood by consumers for Major Food Allergens should be disclosed on theinformation panel, within, or in immediate proximity to, the ingredient declaration, byusing one or more of the following methods:

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1) The use of a statement, such as ‘Contains __________,’ with the blank filled in withthe ingredient term commonly understood by consumers for Major Food Allergens(e.g., Contains soy and milk). This statement may be prefixed by an allergyinformation statement phrase (e.g., Allergy information: Contains soy and milk’).This statement should be placed at the end of, or in immediate proximity to, theingredient declaration.

2) The use of an asterisk or other reference mark next to the ingredient name or classname that refers the consumer to a statement that identifies the ingredient termcommonly understood by consumers for Major Food Allergens. This statementshould be placed at the end of, or in immediate proximity to, the ingredientdeclaration. For products that contain two or more ingredients that contain the sameMajor Food Allergen, the same asterisk or other reference mark should be placedafter each relevant ingredient in the product. For example, ‘casein*, whey*,semolina†, natural flavor†’ would appear in the ingredient declaration, referring theconsumer to a statement such as ‘*milk, †wheat’ following the ingredient declaration.

3) The use within the ingredient declaration of a parenthetical statement following theingredient name or class name that identifies allergens that are present in theingredient (e.g. natural flavour (peanuts and soy), whey (milk)).

4) The use within the ingredient declaration of a name that identifies the presence of theallergen such as ‘natural walnut flavour,’ or ‘natural peanut flavour.’

5) The use of bolding or other highlighting within the ingredient declaration or in allergyinformation statements in immediate proximity to the ingredient declaration. Foodcompanies also should follow FDA’s current guidance regarding the labelling of‘incidental additives’ that contain or are themselves a Major Food Allergen, bydeclaring the Major Food Allergen in the ingredient list of the food.

(iv) Supplemental Allergen StatementsFood processors that prepare foods potentially exposed to inadvertent contact with MajorFood Allergens acknowledge that labelling is not a substitute for good manufacturingpractices (GMP).Supplemental allergen statements should be used judiciously only when all four of thefollowing criteria are met:1) The presence of a Major Food Allergen is documented through visual examination or

analytical testing of the processing line, equipment, ingredient or product, or othermeans;

2) The risk of presence of a Major Food Allergen is unavoidable even when currentGMPs are followed;

3) A Major Food Allergen is present in some, but not all, of the product; and,4) The presence of a Major Food Allergen is potentially hazardous.5) If some, but not all, of these criteria are met, food and ingredient manufacturers

should consider food allergen control and/or labelling strategies other thansupplemental allergen statements.

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When all four of these criteria are satisfied, the supplemental allergen statement shouldbe placed in close proximity to the ingredient declaration. When using an ingredient thatutilises a supplemental allergen statement, the food processor should carry thatsupplemental allergen statement forward to the label of its food only when these fourcriteria are met. Any supplemental allergen statement should be as accurate andconspicuous as possible, to help allergic consumers make a clear decision about whetheror not the food is appropriate for them to eat. Any supplemental allergen statement shouldbe placed at the end of, or in immediate proximity to, the ingredient declaration. Foodprocessors should strive to label the same product consistently, even if it is produced indifferent locations or in different package sizes. Such label consistency would be usefulto food allergic consumers.

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APPENDIX D UDEX AND OFSCI

UDEX (Universal Descriptor Exchange) is a limited company, established in 1997. Thecompany’s main aim is establishing and maintaining a global file of complete, structured,commonly coded product descriptions (and their associated barcodes) produced tocommon global standards which would become the Industry Standard throughout thesupply chain. Advantages to this system may include a decrease in manual workload anda reduction in errors, both leading to cost savings.

UDEX is independent and non-partial and makes its product descriptions available to anyreputable organisation on a consistent commercial basis. The biggest single investor andshareholder in UDEX is 3i. UDEX has no 'trade' investors and hence no conflict ofinterest. A number of suppliers and retailers are members including Nestlé, Sainsbury’sand Tesco.

OFSCI (Optimum Foodservice Supply Chain Initiative) has been set up by TheFederation of Wholesale Distributors and the Food and Drink Federation along withleading suppliers, distributors and operators. UDEX are working with OFSCI on meeting4 key objectives:1. removing unnecessary costs from the supply chain2. shortening lead times3. the reduction of working capital in the chain4. to drive service levels

A number of definitions are currently being discussed by the group including vegetarian,vegan, lactose-free, Halal and Kosher.

It is thought that technology of this kind may be useful in sharing up-to-date and accurateinformation about ingredients and foods across the food chain.-

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APPENDIX E DETAILS OF RESEARCH IDENTIFIED

The Role of Environmental Health Officers in the Protection of Allergic Consumers.Leitch I, Blair IS, McDowell DA (2001). International Journal of Health Research 11:51-61.

Research was undertaken in Northern Ireland with 37 EHOs who regularly carried outfood hygiene inspections in a range of retail and service premises. The aim of theresearch was to establish the EHOs recognition of peanut allergy and to examine theirresponse to such risks

Just over half (19/37) of the EHOs recognised peanuts as major food allergens, and 24/37recognised nuts as major food allergens. The control of nuts/peanuts was included in 6/37EHOs’ assessment of hazard analysis systems. Only 1/6 EHOs had received hazardanalysis training in the control of nuts/peanuts during their primary professional training.

Where aspects of peanut/nut control were included within inspections, 5/6 EHOsestablished whether or not peanuts/nuts were used in the premises, 3/6 checked if theproprietor asked suppliers to ensure that all deliveries of nut/peanut containing productswere clearly labelled as such, and 2/6 established whether or not the proprietor asked forwritten information about ingredients from all food suppliers, including notification ofany changes. In relation to cross contamination, 4/6 EHOs assessed whether or not foodscontaining nuts/peanuts were clearly identified by labelling at all stages of production,3/6 assessed arrangements for the separation of peanuts/nuts from other foods duringstorage, 5/6 assessed whether or not nuts/peanuts were kept in closed, labelled containers,and 1/6 assessed whether or not food premises used colour-coded equipment whenpreparing foods containing nuts/peanuts. No respondents assessed cleaning schedules todetermine if any special instructions were given about cleaning the equipment used toprepare foods containing nuts or peanuts. Only 2/6 investigated the training of foodpreparation or serving staff in relation to food allergy.

The authors concluded that the results suggest a need for co-ordinated, formal, pre and/orin-service training of EHOs in food allergen control, and indicated the importance ofincorporating guidance on food allergen control into hazard analysis guidance documentsthat are supplied both to EHOs and to the food industry.

(Dr Ian Leitch, Omagh District Council - Tel: 02882 245321)

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Strengthening environmental and educational nutrition programmes in worksitecafeterias and supermarkets in the NetherlandsSteenhuis IM, Van Assema P, Glanz K (2001). Health Promotion International 16: 21-33.

The research objectives were to assess the feasibility and effectiveness of twoenvironmental interventions aimed at changing dietary behaviour at worksite cafeteriasand supermarkets in the Netherlands. In worksite cafeterias both interventions werestudied – (1) changes in the range of foods available i.e. increased choice of low-fat foodproducts and increased variety of fruit and vegetables, and (2) food labelling – low fatproducts labelled with a sign. In supermarkets, food labelling was studied i.e. low-fatproducts in 9 categories were labelled with a shelf label (meat, meat products, spreads,desserts, milk, cheese, sauces, sweet biscuits, and salted biscuits and snacks). Brochures,recipe cards and a self-help manual were also available with the both interventions.

Twenty semi-structured interviews were conducted with representatives of worksitecafeterias and supermarkets and the results suggested that environmental interventionsare feasible provided certain requirements for programme design and implementation aretaken into account. These included not making the educational programme too obtrusiveor dominant, that the programme should not take too much time, and it should emphasisethe positive. Appropriate materials were found to include brochures, flyers, handouts,posters, displays, self-help guides, and newsletter articles. Information provided onreceipts and audio messages were found not to be workable. The labelling programmeshould only label healthy products, labelling of a group rather than single products ispreferred, and providing too much information must be avoided. Prices should notincrease and limited changes to the range were found to be desirable.

Evaluation of the programme at 17 large worksite cafeterias (1013 respondents) showedthat respondents were generally positive about the programme. However they alsoreported that it was of low personal relevance and they did not gain more knowledge ofhealthy nutrition as a result. No effects of the interventions were found on consumptiondata of the whole study population. A short-term effect was found for labelling low-fatproducts for respondents who believed they ate a high fat diet. No convincing effects ofthe environmental interventions were found on behavioural determinants of eating less fatand more fruit and vegetables. Analysis of sales data revealed a significant effect of thelabelling programme on desserts, but not on other products.

Evaluation of the nutrition-labelling programme in 13 supermarkets (2203 customers)showed a generally positive response, with those aware of the programme indicating thatit had a positive effect on determinants for eating less fat. However the data failed toshow significant effects on fat intake, consumption of targeted products or behaviouraldeterminants of eating less fat.

Overall it was concluded that using environmental intervention components at Dutchworksite cafeterias and supermarkets is feasible. However interventions including

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labelling at worksite cafeterias and supermarkets were not successful in changing dietarybehaviour.(Ingrid Steenhuis – Ingrid.Steenhuis@ou.nl)

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APPENDIX F EXAMPLES OF TRAINING MATERIALS

Lesson Plan

AIM: To understand the importance of food allergy within a catering environment

OBJECTIVES:1. To be able to understand what allergy is and why it is important2. To know the main food allergies3. To have some knowledge of the different food allergies that affect different age

groups of the population4. To know how common food allergies are5. To know what to do in an emergency6. To understand the four-strand approach7. To understand what is meant by the following terms:

allergy, allergen, anaphylaxis, ‘free from’ and other agreed phrases8. To understand why some people need/want to avoid certain ingredients/foods

1. ALLERGYFood allergy is a specific form of food intolerance that involves the body’s immunesystem. As a result of already being sensitised to a food or food ingredient, a smallminority of people experience allergic reactions to foods that are harmless for otherpeople. These food allergies are abnormal reactions to foods. Allergic reactions to foodcan vary in severity and can be life threatening. Therefore, it is important that if you areasked about the ingredients of a dish, you take such requests seriously.

Case study – recent case study to demonstrate how food allergy can be life threatening.

2. MAJOR FOOD ALLERGENSThere are more than 270 foods that someone somewhere has had an allergic reaction to!However the main foods (and ingredients) which can cause problems because theycontain allergens (specific proteins) are:• Cereals containing gluten* (a protein) i.e. wheat, barley, rye• Shellfish*• Eggs*• Fish*• Peanuts*• Soybeans*• Milk and dairy products• Nuts*• Sesame seeds*• Sulphite (this is used as a preservative)* plus products containing these(This list is from the proposed EU Directive)

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Milk protein can cause an allergic reaction but the sugar in milk, lactose, can also resultin a form of intolerance – lactose intolerance.

Suggested ActivityIdentify the foods containing the major food allergens from the list below.(Picture cards or real foods could be used)

Mayonnaise Prawn crackersSatay sauce TomatoRice Sesame seeded rollPesto TofuIce cream BreadMarzipan HummusPotato Worcestershire sauce

3. WHO DOES ALLERGY AFFECT?The types of food people of different ages react to and whether the reaction is lifelongtends to vary. Typically it is young children who react to milk and eggs and about 8 in 10of those who react out grow their reactions by the time they go to school. Peanut and nutallergies also usually start in childhood but tend to be lifelong. Reaction to shellfish ismore often a form of allergy seen in adults.

4. HOW COMMON IS ALLERGY?Media coverage of this topic might suggest that allergy is very common, affecting a largeproportion of the population (perhaps as many as 3 in every 10). But, perhapssurprisingly, carefully conducted studies have shown that allergy affects about 1-2% ofchildren and less than 1% of adults. Food intolerance in general (which includes allergyand reactions such as lactose intolerance) affects about 5-8% of children and less than 1-2% of adults. Nevertheless, the condition can be a very serious one – even lifethreatening, and so people who handle food have an important responsibility to theircustomers.

5. IN AN EMERGENCYSymptoms of food allergy can include some or all of the following:• Swelling of throat and mouth• Difficulty swallowing or speaking• Difficulty breathing• Skin rash or flushing• Abdominal (‘stomach’) cramps, nausea, vomiting• Sudden feeling of weakness• Collapse and unconsciousness

If a customer has any of these symptoms:• Call 999 and ask for an ambulance

Say your customer could have anaphylaxis (‘anna-fill-axis’)Stay with your customer until help arrives

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6 FOUR-STRAND APPROACHAs in recommendations – focus on steps relevant to functions staff will perform.

7. STANDARDISED TERMSSome people want to avoid or reduce certain foods or ingredients for reasons other thanallergy - for example, ethical or health reasons. You need to know what the followingphrases mean:• ‘free from’• ‘may contain’

8. INFORMATION ABOUT LABELSIngredients– ingredients are listed in descending order of weight so the main ingredient when the

food was prepared is shown first– different names used for the food components responsible for reactions (e.g. for milk;

casein, whey, lactose may be used)– not all ingredients have to be labelled by law (composite products contributing less

than 25% of final product e.g. where toffee is an ingredient of an ice cream, and isless than 25% of the weight of the finished product, it could be labelled as ‘toffee(contains flavouring)’ rather than as the butter and sugar it contains; someflavourings and additives). Therefore your manager may need to check with thesupplier for full details

Role-playA waiter shows a customer to their table and hands them a menu. How can the waiterexplain that the restaurant knows about food allergy and may be able to accommodatespecial requirements? If the customer has an allergy and does not want any shellfish,what might the customer say? How should the waiter react?

Suggested dialogue:Waiter: As mentioned on our menu some of the dishes we serve contain

nuts and other allergens.

Customer: Can you please tell me which dishes don’t have shellfish in them?

W: Is that because you don’t like shellfish or because you are allergic?

C: I am allergic to shellfish.

W: I’ll get the manager to come and speak to you. She will be able tohelp you and be able to provide you with some information so you candecide if any of the dishes are appropriate for you.

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Appendix G Surrey County Council Pilot Scheme

A pilot scheme is being run by Surrey County Council from April 2002, encompassingthe issue of allergy. Entitled ‘Allergy Aware Responsible Retailer Scheme’, it aims toincrease awareness of the issues relating to food allergy and gives practical guidance.Retailers who can demonstrate they are allergy aware and are taking steps to minimiserisks, may be eligible to join the scheme.

Once the retailer has joined they receive a poster for display in their business, informationleaflets for consumers about the scheme, guidance notes and a code of good practice. Thebusiness will be audited by a TSO/EHO to ensure the required standard is being met andfood samples may be taken and analysed as part of this process.