As explained in the Allergy Awareness online course, the Big 8 allergens in the United States account for approximately 90% of all food allergies. The Big 8 are: eggs, fish, milk, peanuts, shellfish, soybeans, tree nuts, and wheat.
If you manage foodservice operations, you know that the FDA Food Code requires awareness of the Big 8 in any foodservice operation. In addition, you bear responsibility for managing the food allergen risk to protect foodservice guests from allergic reactions.
This course will equip you with an understanding of the principles of allergen risk management in foodservice, as well as sources of allergen exposure, how to address signs of allergic reaction, and best practices in foodservice that can help keep your guests safe.
Allergen awareness is a two-fold mission. For your foodservice operation to be successful, there needs to be a clear understanding of what an allergen is and how it must be labeled and handled.
The risk that is imposed by undeclared allergens has received dramatic attention since the Food Labeling and Consumer Protection Act (FALCPA) was established. Furthermore, we have a greater understanding of the complexity of the problem and how it has increased.
An idea to keep in mind is that consumer awareness drives business awareness. In other words, allergy awareness is a two-way street. The more the public knows, the greater skill set a business must have to compete for their trust and loyalty. A foodservice administrator needs to be aware of FALCPA, which is discussed on the next slide.
Employees are essential to an allergen control program, too. You can reduce liability with education and awareness.
What happens if there is an allergic crisis? Emergency protocols ensure you and your team are ready to respond. When it comes to allergen risk management, the stakes are high. The old adage applies: An ounce of prevention is worth a pound of cure.
The Food Labeling and Consumer Protection Act of 2004 (FALCPA) was passed to help consumers identify allergens from food labels. It applies to both domestic and imported foods that are regulated by the FDA. Prior to FALCPA, it was up to the consumer to decipher ingredient names and know which might contain an allergen. Now, common allergens are more clearly identified. This labeling is a valuable tool for foodservice menu planners, too.
Note that FALCPA does not require foodservice establishments to label foods that may contain allergens. The FDA explains, "FALCPA only applies to packaged FDA-regulated foods. However, FDA advises consumers who are allergic to particular foods to ask questions about ingredients and preparation when eating at restaurants or any place outside the consumer's home."
The FDA explains the labeling rules as follows: "The law requires that food labels identify the food source names of all major food allergens used to make the food. This requirement is met if the common or usual name of an ingredient (e.g., buttermilk) that is a major food allergen already identifies that allergen's food source name (i.e., milk). Otherwise, the allergen's food source name must be declared at least once on the food label in one of two ways. The name of the food source of a major food allergen must appear either: 1) in parentheses following the name of the ingredient, or 2) immediately after or next to the list of ingredients in a "contains" statement.
FALCPA addresses the Big 8. Keep in mind that if there is another allergen of concern, you will still need to do your research with suppliers and manufacturers. A rule of thumb: If in doubt, call the manufacturer.
Despite the regulatory controls in place, food processors can make mistakes. An allergen present in food but not declared on the label is called an undeclared allergen.
The FDA explains it this way: "Some labels may not be as reliable as they should be." In fact, undeclared allergens were cause for 43% of food recalls during a 60-day period in 2017, reports Food Safety News.
This may happen for a variety of reasons, says the FDA—using the wrong ingredient, or misuse of automated label-printing technology, for example.
Explains the FDA, "A food product with a label that omits required allergen information is misbranded and can be seized by FDA."
The FDA explains that it is "working on three fronts to reduce the number of such recalls: by researching the causes of these errors; working with industry on best practices; and developing new ways to test for the presence of allergens."
What can you do? Use recall alerts, such as those available from recalls.gov, to stay on top of recalls from undeclared allergens. And of course, work with trusted suppliers who have their own allergen control plans in place. It pays to have an open dialogue and ask questions, just as you do for other aspects of food safety in your food procurement process.
Risk management is a proactive endeavor. Part of developing a risk management program is to establish objectives and metrics up front.
Understanding your limitations as an establishment is one of the most important factors in allergy awareness. It should never be expected that every item on a menu can be or will be allergen-free. However, given the correct tools and skillset, properly trained staff may inform your foodservice guests about which products you may offer safely based upon their stated concerns.
Some organizations establish a zero-allergen-tolerance policy, meaning they will not allow any level of an allergen within a product. That means including a warning on any product, even if the risk is not meaningful. Large numbers of products may end up with warnings.
Some operators establish a 1% threshold. When using the 1% rule, it applies to the ELISA Method reading, for 1% of allergic substances threshold. This means that if there is less than 1% of a potential allergen in a product, then they will not provide an allergen warning. The problem here is that less than 1% could still signify hundreds of parts per million of allergen in the finished product. This could still lead to exposures to allergens and possible responses.
There is no easy answer to this question. The actual amounts of an allergen that can trigger a response vary from person to person. Stefano Luccioli, MD comments in Food Safety Magazine, "It is my observation that some companies employ a zero-allergen-tolerance policy and thus tend to place an allergen label or warning on any product, even when the risk is negligible or possibly nonexistent. This may reduce risk but may not be beneficial to consumers, as it limits the number of potentially nutritious products available to them. Other companies use risk management strategies that may underestimate the hazard. These companies argue that they are doing a good job by keeping allergens at less than 1% in the finished product. Less than 1% could still signify hundreds of ppm of allergen in the finished product. This could easily lead to exposures to allergens in the mg protein range per serving—doses shown to cause reactions in allergic consumers and to be associated with severe reactions."
You will want to use a team approach to allergen management. Risks need to be controlled at every step in the flow of food. Thus, many people play a role. Including managers from all affected areas is critical. You will need to define policies and Standard Operating Procedures (SOPs). You will also need to define a flow of communications that keeps guests or clients safe.
As explained in the online course, Allergy Awareness, the principle of cross contact or cross contamination with allergens occurs when one food comes into contact with another food and the allergen is transferred.
Enforcing strict cleaning policies and procedures is essential for preventing cross contamination. Furthermore, foodservice teams must clean and sanitize work areas before and after food preparation. If they are working with a peanut-free item, then they must use a separate peanut-free sanitizer bucket.
Be aware that food can become cross contaminated not only through direct contact with peanuts and peanut-containing ingredients for example, but from food garnishes as well.
Food Allergy Research & Education (FARE) recommends, "Clean and sanitize with soap and water or all-purpose cleaning agents and sanitizers that meet state and local food safety regulations, all surfaces that come into contact with food in kitchens, classrooms, and other locations where food is prepared or eaten."
To confirm product selection and effectiveness, it's a good idea to consult your supplier.
FARE recommends using "handwashing procedures that emphasize the use of soap and water." They note, "Plain water and hand sanitizers are not effective in removing food allergens." Research behind this reveals that:
Cooking oil can become a source of cross contamination within a foodservice kitchen. Cooking foods in a fryer can transfer allergens from one food to another if the same cooking oil is used for different foods.
For example, if popcorn shrimp or a fish product is fried with the same oil as other fried foods, this should be disclosed. Both shrimp and (fin) fish are among the Big 8 allergens.
Needless to say, grills can be a source of cross contamination.
Oils can also seep through wax paper, according to FARE. Thus, even if you use wax paper on a baking sheet, you would still want to clean and sanitize the baking sheet before using it to bake a new food.
Research published in the Journal of Allergy and Clinical Immunology examined peanut and/or tree nut allergic reactions occurring in foodservice establishments. Among 156 episodes of allergic reactions, most involved peanuts (67%) or tree nuts (24%). Interesting findings include:
These findings underscore the importance of establishing ways to manage the risk throughout the flow of food in your foodservice operation. Areas to watch include the following:
Ingredients: Many ingredients are visible such as, cheese, wheat bread, or a wheat pizza crust. Some foods may contain a hidden ingredient, such as onion powder in ketchup, milk in non-dairy creamer, gluten or sulfites in balsamic vinegar, soybean oil and eggs in mayonnaise, or casein (milk protein) in popcorn.
Baked goods: Allergens can be hidden, such as almond flavoring in a cookie mix. Peanut butter chips in cookies may not be clearly obvious to customers. When serving cookies, be alert to cross contamination in a "help-yourself" cookie jar.
When labeling menu items, be specific. Instead of listing a special cake as apple cake, be specific that it is an apple walnut spice cake. For a pasta special, mention ingredients, e.g., pasta special with a walnut pesto sauce.
Food allergens can spread through the air. For example, smelling peanut butter could trigger an allergic reaction for a sensitive person. Sitting next to someone who is eating a cheese sandwich, however, will not create an allergic dairy reaction.
Restaurants that allows guests to shell peanuts will generate an airborne allergen exposure. Other situations that can generate airborne exposure are:
It's crucial to recognize the symptoms of an allergic reaction to food. Keep in mind that an allergic reaction may be mild, or it may be life-threatening, depending on the individual. A guest may say something like:
The onset of a dangerous allergic reaction could occur in minutes or hours. Symptoms could include:
In a serious anaphylactic reaction, multiple organ failure could occur, and the final result could be fatal.
An individual who begins having an anaphylactic response needs emergency medical treatment. Your protocol needs to include a response that fits with your organization's resources and policies.
It's estimated that one in every 13 children under the age of 18 has some form of an allergy. That's almost two children in every classroom throughout the country. It's no surprise that food allergen management affects every foodservice establishment throughout the nation.
As these children grow up and go to college, they assume responsibility for managing their own food choices, and colleges and universities need to be ready to accommodate them.
Serving 26,000 students daily at Loyola University in Baltimore, MD, Food Management reports on Parkhurt Dining's allergen control program:
The same article in Food Management describes the approach at North Carolina State University, Raleigh, NC, where the foodservice team participated in the FARE allergy pilot program. More than 200 staff members took a class on allergen management and had to complete a test.
Virginia Tech in Blacksburg, VA, publishes menus online and allows website visitors to filter and explore options based on their own needs.
A case study from Lesley University in Cambridge, MA, tells us that accommodating food allergies for foodservice patrons is crucial from a legal standpoint. Failing to do so may be in violation of Title III of the Americans with Disabilities Act (ADA).
As reported in FoodService Director magazine, students filed a complaint with the Department of Justice, "alleging that the university did not provide adequate foodservice for students who suffer from celiac disease or food allergies, even though students living on campus are required to purchase a meal plan."
Is a food allergy a disability? The Department of Justice issued this statement: "Some individuals with food allergies have a disability as defined by the ADA—particularly those with more significant or severe responses to certain food. This would include individuals with celiac disease."
Some of the remedies ordered included: a $50,000 settlement; working with individual students to develop customized plans; allowing certain students to be exempt from the meal plan; and creating a designated food prep area to prevent cross contamination.
The article goes on to analyze the ADA impact on other foodservice operations. The article reports another Department of Justice statement: "The ADA does not require that every place of public accommodation that serves food to the public provide gluten-free or allergen-free food." However, "reasonable steps," such as disclosing ingredients used in menu offerings, would be expected.
As you devise your own food allergen control plan, consider points of risk that may be unique to your type of foodservice operation. Here are some best practices relative to various types of foodservice.
An industry survey reported by Food Safety Magazine in 2015 indicated there is much room for growth in allergy awareness education in the foodservice industry. Auburn University research involving managerial employees in restaurants revealed that:
The FDA Food Code calls upon the person in charge of a foodservice establishment not only to know about the Big 8—but also to ensure that foodservice employees know, too.
It is important to establish policies and SOPs for allergen risk management in your foodservice operation. Staff training is essential and may cover topics such as:
For food allergy training resources, see the Sources & Further Reading page in this course.
Food allergy is widespread, and thus affects every foodservice establishment. A comprehensive risk management approach can help prevent potentially life-threatening allergic reactions. To accomplish this, a foodservice manager must take a team approach.
Examining risks in the flow of food, establishing controls, working closely with suppliers, reading food labels, and identifying menu offerings clearly are important. Establishing and enforcing procedures that eliminate the potential for cross contamination can prevent foods from becoming contaminated with allergens.
Finally, communication is valuable. A successful foodservice establishment will communicate clearly with guests, and devote attention to staff training.
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Michael Foods, Inc.