1. Allergen Control in Foodservice
Simon Flanagan Senior Consultant Food Safety and Allergens
Intro self……..28 years, proactive / reactive – numerous sectors including foodservice
I will be talking about the RA process and how you should approach structuring your risk assessment to ensure that you have robust allergen management programme able to support any allergen claims (positive or advisory) and who you should involve in that process
Taking learning's from the pre-packaged sector who have been dealing with allergen labeling regs for last 8 years
ALLERGEN CONTROL IN FOODSERVICE Simon Flanagan – Science Consultant – Food Safety & Allergens RSSL • Allergen control is cornerstone of any successful FreeFrom food operation • Basic principles on which allergen control is based • How these can be applied in food service • Where are the danger points and how to circumnavigate them

2. Overview ‘Free-from’ – key considerations
Principles of allergen risk assessment in pre-packaged food sector
Applying knowledge to the foodservice sector
Hierarchy of allergen risks in foodservice
Learning from previous research in the foodservice sector

3. Free-From - the Bar is Higher!
Invitation to purchase by potentially most at risk consumers
No such thing as zero but this is what many consumers expect!
Only currently have legal limits for ‘gluten-free’
In absence of limits many companies relying on positive release (non-detectable at LOD / LOQ)
Patchy regulation and sparse published best practice guidance
Manufacturers, retailers and foodservice setting own polices
Enforcement surveys
Before you consider moving into this sector there a number of things you need to bear in mind………
There is a real discernible difference between the absence of a precautionary for the allergen and making a positive free-from claim – it can be done but the bar is much higher
So what regulatory guidance is out there??

4. FSA Guidance
Food Standards Agency “Best Practice Guidance on Managing Allergens with Particular Reference to Avoiding Cross-Contamination” (2007)
Section Allergen-free foods
A growing number of food manufacturers and retailers are providing ranges of substitute foods made without certain common allergenic foods, such as milk, egg or cereals containing gluten. In addition, some manufacturers choose to exclude certain allergens from a site. It should not be assumed that the lack of a need to use advisory allergen warnings entitles a product to make a ‘Free From’ or ‘made in allergen X free factory’ claim.
Consumers are likely to actively seek such products if they need to avoid particular ingredients and it is essential that any such claims are based on specific, rigorous controls to ensure their validity. …….An ‘allergen-free’ claim is an absolute claim, which may be interpreted by consumers to mean a complete absence, whereas the best that can be scientifically demonstrated at present is that samples of the food were shown to be below the analytical limit of detection of a testing method on one or more occasions.
Expected that any claim is based on a robust risk assessment

5. Principles Of Risk Analysis in Pre-Packaged Foods (FSA 2006)
Risk assessment - what's the risk?
Risk management - what's the risk?
Risk communication – how to warn consumers?
I am sure you are all aware of the 4 step process laid out by the orange guide………….
Condensed the 60 odd pages! Voluntary guide
Risk of cross contact – where are they?
2. Can you manage them – are the control systems robust / do you need to manage?
3. If you cannot manage, it is about communication
4. Review as in any iterative process – change in people, ingredients, processes etc.
Risk review – has the risk changed?

6. Terminology (HSE 2009)
Risk assessment – the semi-quantitative (or, in exceptional circumstances, quantitative) estimation of whether a hazard is likely to occur in practice; normally expressed as a risk factor or score by multiplying the hazard severity score by a likelihood score (unlikely (score 1), likely (score 2) or very likely (score 3)). All risk scores indicating other than low risk must be investigated and risk control/management procedures followed
Hazard – a substance etc. which has the potential to be harmful. Hazards are very varied… The severity of the hazard is determined by possible consequences; for risk assessment, the severity of hazards is scored on a simple three point scale: minor injury or effect (score 1), major injury or effect (score 2) or death (score 3).
Risk control/risk management – the means by which moderate or high risks identified through risk assessment are eliminated or reduced to acceptable levels
Risk assessment is one of those phases that means different things to different people

7. Can We Apply To Allergen Risk Assessment?
Estimation of risk – subjective
Likelihood score – subjective
Severity of hazard
Depends on the allergenic ingredient
Depends on sensitised individual
Spectrum of reaction in sensitised population from mild (1) to death (3)
Risk management
Eliminated (?) or reduced to acceptable level (?)
Cannot completely eliminate risk
What is an acceptable level (no thresholds)
Taking those definitions can we apply to allergen risk assessment?
Risk - unless you are sure that you still have traces left on the line that are visible, how can you estimate that it will go wrong?
Can we estimate risk from people / ingredients and equipment?

8. Best Practice – Risk Assessment
Targeted risk assessments incorporating hazard characterisation
Evolution of 2006 FSA guidelines
Three-tier allergen mapping
Assessment of risks arising from the following factors
Process flow
Environmental
Production
People
Rank risk probability against characterised hazard
Output drives allergen management or labelling
Got to be pragmatic when we conduct the risk assessment and focus on high risk activities not chasing molecules around the factory
What is the next step for industry following the 2006 guidance
Need a form of quantitative risk assessment
Result from that will be “Do we need to manage or label?”
This evolved approach was developed by RSSL and used our quantitative risk assessment toolkit & factory based allergen workshops

9. Allergen Mapping (1)
Looking at the catering sector this is ultimately about having good knowledge of allergens used as ingredients in different recipes

10. Allergen Mapping (2)
Again from a catering perspective this is about having a system to identify which recipes contain which allergens in order that this can be communicated to allergic customers

11. Allergen Mapping (3)
How does it move around the factory – one egg product in a chocolate factory What are you trying to protect from what?
Again looking at this from a catering perspective this is about understanding the areas where allergenic ingredients are handled and identify shared food contact surfaces and equipment used in preparation of the finished dish

12. Process Flow Process Flow Examples Bins for dry allergens
Ingredient weighing
Cross- contamination from non-dedicated scoops
Bins for dry allergens
Orange = allergens
2 scoops between all the bins
Control – either dedicated scoops or cleaning between use
This could well be scaled down and could consider the use of decanted ingredients as are used in commercial catering

13. Environmental Factors Examples
Warehouse
Contamination of stored products due to air extract into warehouse
Milk powder between is malt and cocoa powder
If we wanted to make relevant to catering this could relate to storage and management and hygienic practices in the kitchen and associated store

14. Production Related Activities Examples
Rework management
Rework is not clearly identified
Re-work. Pastry - with a mustard centre and one without – common rework
Catering example could be that that a common stock or base for a curry could go into several different dishes

15. People Related Activities Examples
Hygiene
Staff moving between different lines without washing hands
Chews – containing milk protein – next line was no milk containing
Catering example – could be someone prepping pastry and then moving onto prepping salads without washing hands or changing PPE / whites

16. Probable Versus Remote
Definition – probable is likely to happen under normal operating conditions
Left is part opened/ sealed packets of mixed materials
Right – go straight to line and a hose dispenses straight onto line.

17. Hazard Characterisation (1) Allergen Biochemistry
True allergens = always proteins
Most allergens incredibly stable molecular structures
Some resistant to processing
Heat treatment
Mechanical
Fermentation
Some rendered ‘more’ allergenic
Biochemistry (and matrix) influence cleaning interventions
So when we have identified the risk we start to consider hazard associated with risk there are key factors which influence this……..
Peanut – best characterized. Boiled turns in, dry roasted/fried turns out
Nut proteins are very lipophyllic – associated with fat layer

18. Hazard Characterisation
6 Key Considerations
Physical nature of contaminant
Level of processing undergone
Amount of protein (no protein = no problem)
Target consumers (vulnerable groups)
Established thresholds
Type of production environment
Characterise risk, define associated hazard and then validate existing control measures
Cleaning is significant control measure in the catering sector
So we start to pull all of these factors together we can start to get a better estimation of the relative severity of the allergenic hazard
1. Physical – air / sticky
4. free-from or children
6. Dairy versus cereals

19. Terminology Cleaning Validation Cleaning Verification:
Quantitative assessment of cleaning methods to ensure that they are sufficient to minimise allergen cross-contact
Performed once unless anything changes
Cleaning Verification:
Qualitative periodic assessments to confirm validated control measures (cleaning) are still effective
Performed periodically at predefined intervals
Monitoring of Cleaning
Qualitative ongoing assessments
Performed every time cleaning is undertaken
The exercise is performed once, but within that repeated 3x based on WHO guidelines

20. Output From Risk Assessment
Documentation is key as this forms the basis for due dillange

21. Applying Concepts To Foodservice
Allergens as ingredients – labelling
Knowledge of what allergens are in which dish and robust system to ensure that this is effectively communicated to allergic customer
Allergen mapping
Which allergens are in ingredients, which recipes do these go into and which surfaces/ equipment do these come in contact with
Risk assessment considerations
Process flow – risks associated with preparation of finished dish
Environmental – kitchen management & storage practices
Production – shared oils/ovens etc.
People – knowledge and training - front and back of house
Probability of occurrence
Similar rationale applied
Hazard characterisation
As we have illustrated the risk assessment process used in pre-packed foods can be easily transcribed into catering

22. Hierarchy Of Risks In Foodservice
Complexity & communication within the business
Wrong information given to allergic customer
Wrong ingredients used in dish
Substitution of ingredients in dish
Poor storage and segregation practices
Cross-contamination of ingredients
Ineffective cleaning and personal hygiene
Poorly cleaned food preparation surfaces
Utensils, cutlery and crockery
Poor hand washing and cross contact from PPE
Allergen containing dishes made in close proximity
Hierarchy based on the amount of allergen that could potentially be delivered to the consumer – ingredient through to trace. In pre-packaged foods cross-packing is the highest risk
In risk assessment start with the high risk activities and then work down

23. Compositions Of Risk Assessment Team
Ideally multi-disciplinary team
Depends on size of business
Could just be an individual with broad knowledge of the business
Team leader
Could be proprietor
Back of house
Kitchen team
Front of house
Waiting staff
Ingredient procurement
Shopper
Hygiene
Kitchen porter washer-upper

24. Foodservice Research: Gluten-Free
Staff training
Communication with allergic customer
Personal hygiene practices
Ingredient labelling
Ingredient storage
Preparation
Cleaning
Research commissioned by Coeliac UK in with the support of a wide range of different catering businesses - Broad cross-section of catering operations - restaurants, café’s , schools, hospitals, contract caters - Different size business - small business through to large national chains and multinational catering companies
To try to identify the procedures needed for gluten-free preparation in commercial kitchens – there are a number of parallel with the management of other allergens
Highlights of findings;
1) Training - Good training was imperative for both front and back of house teams (serving and kitchen staff) - Lots of companies had really good induction and refresher programmes covering food safety and allergens including coeliac disease
Documentation of training practices recipes and work instructions and a budding systems – lots of pictorial information for language issues
2) Effective communication key - customers – front & back of house Lots different ways of giving consumers information about choices of menu items – detailed recipe guides giving compositional information – one particularly good example – Nando’s
Other companies like Amadeus at NEC had allergy cards filled out by customers which accompanies the meal as its brought out from the kitchen
Another approach was to have an automatic system which was linked to the till to alert the kitchen about the special dietary needs of customer
3) Good hygienic practices = Good gluten / allergen management
Hygiene is obviously paramount in providing safe food of any type – good hygienic practices in all of the sites visited which also helped with their allergen control – allergen transfer by either hands or PPE
4) Clear ingredient labelling also important to distinguish be GF and Non-GF ingredients – some companies adopted additional labelling of decanted ingredients to ensure allergen visibility and traceability remained
5) Good storage also important to minimise the risk of cross-contamination with gluten – chilled, dry, bulk ingredients etc.
6) Ingredient preparation chopping /slicing – oven baking / roasting – frying (issue with shared oils), toasting – (bags dedicated toasters) boiling, grilling / girdling – established best practices for all of these different types of operation
7) Cleaning also important step to minimise risk of X-contact from shared surfaces – preparation equipment and utensils through to dishes - Manual and automatic washing – results comparable for both methods
If you want to know more about research and associated training programme – Anna Godfrey CUK here today

25. Allergen Cleaning Project – Foodservice 2006
Back in 2006 RSSL approached A. Campaign and asked if there was potential to collaborate on any ongoing studies to provide analytical support
Became clear from initial discussions that the highest risk of a reaction to an individual with severe allergy was eating away from home, especially in restaurants, takeaways
Due to a lack of substantive evidence, it is not always clear if allergic reactions experienced whilst eating in these environments had been caused by negligence on behalf of the vendor or through casual cross-contact / poor sanitation of shared implements contaminated with allergenic residues.
Also became apparent quite soon that there was a real lack of research in this area with the only published example being a study carried out in 2004 in the US looking at peanut contamination
Designed a study to understand the efficacy of different wet cleaning regimes currently employed within the catering sector on a variety of food contact surfaces by mimicking residual allergen cross contact under controlled conditions.
Applied known weight of simulants to both contact surfaces stainless-steel, polyethylene, polycarbonate etc + cooking utensils
Cleaned using a variety of both manual and automatic techniques with various commercial cleaning agents
Monitored the removal of allergens through surface swabs post cleaning
Tenacity of different allergens (Hazelnut Peanut and Milk)
Effectiveness of different cleaning methods & cleaning materials
Effect of different contact surfaces

26. Results Summary
The graphic represents the level of contamination of peanut found in the samples after a bowl detergent wash
Peanut most difficult from all surfaces
Automatic wash generally more effective
Chopping boards most difficult surface to clean
Sponges are least effective cleaning material
Detergents vs. hot water – differences but not for all surfaces
Lots of data generated but low replication

27. Learning from the Pre-Packaged Sector
Incidents by category,
Category
2006
2007
2008
2009
2010
2011
Allergens 61 86 84 79
114
Animal feed (on market) 9 10 13 8 28
Biocides 2 1
Counterfeit product 6 3 7 11
Recalls/withdrawals continued over last 7 years
Increased use of ‘may-contains’ – devaluation of warning
Common root cause – inadequate training, packaging errors and incorrect use of ingredients
Very few are a result of consumer complaint – it is industry spotting the issues
Consumers do not believe the warnings –Gemma!
Root cause – FSA information

28. FSA Allergy Incidents 2011
SO2 is the hidden allergen

29. Please Lets Try and Avoid This Approach!
Example – in a pub for a meal in a basket!
Vinegar – ingredients are malt vinegar, water, salt and barley malt extract but
May contain – nuts, peanuts, sesame seeds, mustard, celery, wheat, eggs, fish, soyabeans, milk, sulphites and cereals containing gluten
How did they manage that!!!!

30. Thanks For Your Attention
Finally like to acknowledge the following groups and individuals