understanding the new food allergen rules

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Chun-Han Chan Food Allergen Legislation & Risk Assessment Food Allergy Branch. Understanding the new food allergen rules. The Impact of Food Allergy. The symptoms can include: rashes (usually very itchy) tingling sensation in the mouth swelling of the lips, tongue, face and throat - PowerPoint PPT Presentation



    Chun-Han ChanFood Allergen Legislation & Risk AssessmentFood Allergy Branch

  • The Impact of Food AllergyThe symptoms can include: rashes (usually very itchy) tingling sensation in the mouth swelling of the lips, tongue, face and throat difficulty breathing diarrhoea vomiting abdominal cramps and on rare occasions anaphylaxis

  • Food allergy figuresThe true burden of food allergy is estimated to be significantly higher than the hospitalisation figures might otherwise suggest

  • Food allergy~1.92m people have food allergy in the UK (based on population of 63.1m). This figure excludes food intolerance.

    There is no cure, therefore need to observe avoidanceRead ingredient labelsLook out for hidden allergens

  • Food labelling is changingMoving from General Labelling Regulation (2000/13/EC) to Food Information for Consumers Regulation (1169/2011/EC)Three year transition period from the coming into force date from 13 December 2014 new rules on allergen labelling shall applyExisting requirements for pre-packed foods are retained but new requirement to emphasize allergenic foods in the ingredients listIntroduction of new requirement to provide allergy information for unpackaged foods

  • Scope of the Regulation

    Covers business operators at all stages of food chain concerning provision of information to consumers:Food intended for the final consumerFoods delivered by mass caterersFoods intended for supply to mass caterers

    Also applies to catering services provided by transport leaving from the EU Member Statesairline cateringtrainsboats / ships

  • Annex II The big 14

  • Mandatory particulars

    Article 9(1)c - Any ingredient or processing aid listed in Annex II, or derived from a substance or product listed in Annex II causing allergies or intolerances, used in the manufacture or preparation of a food and still present in the finished product, even if in an altered formArticle 9(2) - The specified allergenic foods to be indicated with words and numbers - they may additionally be expressed by means of pictograms or symbols

  • Article 12 & 13 Clarity and Legibility For prepacked foods, mandatory information to appear directly on the package or on a label attached to itMandatory food information to be available and easily accessible for all foodsMandatory information to be marked in a conspicuous place, be easily visible, clearly legible and, where appropriate, indelible. It should not be hidden, obscured, detracted from or interrupted by other written or pictorial matter

  • Article 14 Distance sellingIn the case of foods offered for sale by means of distance communication, mandatory food information to be available before purchase is concluded and to appear on the material supporting the distance selling or be provided through other appropriate means clearly identified by the food business operatorAll mandatory information to be available at the moment of delivery

  • Article 21 Labelling of allergens

    Allergens to be indicated in list of ingredients with clear reference to name of the substance or product as listed in Annex II i.e. whey (milk)Allergenic ingredients to be emphasized through a typeset that clearly distinguishes it from the rest of the ingredients by means of the font, style or background colourIn the absence of a list of ingredients, the indication of the allergenic ingredients to comprise the word contains followed by the name of the substance or product listed in Annex IIWhere several ingredients or processing aids in a food originate from a single allergenic ingredient, the labelling shall make it clear for each ingredient or processing aid concerned

  • EU FIC Labelling

  • Article 21 continued

    Where the name of the food (i.e. box of eggs, bag of peanuts) clearly refers to the allergen concerned, there is no need for a separate declaration of the allergenic food

    Use of Allergy Boxes The voluntary use allergen advisory boxes to declare the presence of allergenic ingredients in prepacked foods are not permitted under the EU FIC

    Allergen information found in a single and consistent place

  • Article 36 Voluntary information

    The Commission has option to introduce new rules on the following voluntary information: information on the possible and unintentional presence in food of substances or products causing allergies or intolerancesPrecautionary allergen warnings (may contain) can still be used for prepacked food and non-prepacked to be applied after a thorough risk assessment and to communicate a real risk to the consumerPermits the introduction of agreed phrases or allergen reference doses for the unintentional presence of allergens in prepacked foods

  • Article 44 non-prepacked food

    A new requirement for allergen ingredients information to be provided for non-prepacked foods and food provided prepacked for direct saleFoods are offered to sale to the final consumer or to mass caterers without pre-packaging, or where foods are packed on the sales premises at the consumers request or prepacked for direct sale, the provision of the information about allergenic ingredients is mandatory

  • Article 44 non-prepacked foods cont

    Oral provision also permitted, provided the business indicates clearly that such information can be obtained upon request. Oral information must be accurate, consistent and verifiable upon challengeWhat is consistent? Is there a process in place to enable consistent information to be provided? For example to refer queries to the nominated person(s)What is verifiable? Ingredients information on a chart, recipe book, ingredients information sheets, scrap books with labels etc

  • Article 44 non-prepacked foodsCould declare allergen ingredients information through a contains statement, charts, tables etc.i.e. chicken tikka masala Contains: milk, almonds (nuts)Consider Article 12 and 13 on accessibility of mandatory information - Marked in a conspicuous place, easily visible, clearly legibleSignposting is required when information is not provided written and upfront. It should be where consumer would expect to find allergen information e.g in a folder, on menu board, at till or on the menu card

    Food Allergies & IntolerancesBefore you order your food and drinksplease speak to our staffif you have a food allergy or intolerance

  • Providing allergen information

  • Article 44 non-prepacked foodHow are dietary requests communicated from front to back of house? e.g. use of chef cards, order tickets, receiptsPreparing foods for allergic consumers- what process is in placeIs the business observing Safer Food, Better business (SFBB) Safe Method: Allergy Are they making specific claims i.e. gluten freeConsider how this claim is verified or validatedWould no gluten containing ingredients (NGCI) statement be better?

  • Regular reviews, keep it currentFood businesses need to have processes in place to ensure the information they provide is accurateRegularly review the ingredients informationWhere ingredients change, review the accuracy of the recipeDo garnishes or dressings change the allergenic profile of the meal? Check!Accuracy is dependent on the information on labelling, updating allergen information for dishes, updating staff and consumers

  • Communication is keyThink about the chain of communicationThe person buying the food The person handling the foodThe person taking the orderThe person ordering the food

  • Communication is keyEngage with serving staffRecipes changeIngredients change

  • Cross contamination with allergensThe unintentional presence of allergens is not covered under the EU FIC. This is covered under the Food Safety Act and General Food Law.Regulation No. 178/2002 General Food Law: Article 14, 2a. Food shall be deemed to be unsafe if it is considered to be injurious to healthArticle 14, 3b In determining whether any food is unsafe, regard shall be had to the information provided to the consumer, including information on the label, or other information generally available to the consumer concerning the avoidance of specific adverse health effects from a particular food or category of foods

  • E- learningAccess free training on: http://allergytraining.food.gov.uk/

  • http://multimedia.food.gov.uk/multimedia/pdfs/publication/foodallergies-sfbb-0513.pdfSFBB allergy safe method

  • Statutory InstrumentFood Information Regulations 2014 to be published by July 2014An offence has been committed for failure to comply with allergen provisionsTo outline functional working arrangements for LAs Government Guidance to support Regulation to be issued on GOV.UK ~ July 2014

    FSA allergen guidance to support SMEs to be issued on www.food.gov.uk ~ July 2014

  • Changes to enforcementBroadening responsibilityUnitary authorities and London boroughs, employ both TSOs and EHOs - up to them whether they use one or other or both to enforce the UK Food Information Regulations (FIR). This will be in most cases EHOs where there is involvement with non-prepacked food but in some cases it will be TSOs it depends on the arrangements locallyWhere responsibility is split into two tiers, to extend the responsibility of second tier (district councils) to include allergens checks under FIR in England

  • Changes to enforcement (2)FIR will introduceImprovement notices outlines necessary changes to reach compliance, timeboundFirst tier tribunals businesses to challenge / appeal INsCriminal sanctions for breaches in food allergen provisions food safetyEHOs / TSOs to help educate the food businesses and to maximise the opportunities of LAs to ta


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