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Customer Focused, Science Driven, Results Led Allergen Control in Foodservice Simon Flanagan Senior Consultant Food Safety and Allergens.

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Presentation on theme: "Customer Focused, Science Driven, Results Led Allergen Control in Foodservice Simon Flanagan Senior Consultant Food Safety and Allergens."— Presentation transcript:

1 Customer Focused, Science Driven, Results Led Allergen Control in Foodservice Simon Flanagan Senior Consultant Food Safety and Allergens

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

4 FSA Guidance Food Standards Agency “Best Practice Guidance on Managing Allergens with Particular Reference to Avoiding Cross-Contamination” (2007) Section 3.3.2 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? 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

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)

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

9 Allergen Mapping (1)

10 Allergen Mapping (2)

11 Allergen Mapping (3)

12 Process Flow Process Flow Examples Ingredient weighingCross- contamination from non-dedicated scoops

13 Environmental Environmental Factors Examples WarehouseContamination of stored products due to air extract into warehouse

14 Production Production Related Activities Examples Rework managementRework is not clearly identified

15 People People Related Activities Examples HygieneStaff moving between different lines without washing hands

16 Probable Versus Remote

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

18 Hazard Characterisation 6 Key Considerations 1.Physical nature of contaminant 2.Level of processing undergone 3.Amount of protein (no protein = no problem) 4.Target consumers (vulnerable groups) 5.Established thresholds 6.Type of production environment Characterise risk, define associated hazard and then validate existing control measures Cleaning is significant control measure in the catering sector

19 Terminology Cleaning Validation – 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

20 Output From Risk Assessment

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 Similar rationale applied

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

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

25 Allergen Cleaning Project – Foodservice 2006

26 Results Summary

27 Learning from the Pre-Packaged Sector Recalls/withdrawals continued over last 7 years Increased use of ‘may-contains’ – devaluation of warning Common root cause 2008-2011 – inadequate training, packaging errors and incorrect use of ingredients Incidents by category, 2006 - 2011 Category200620072008200920102011 Allergens6186848679114 Animal feed (on market)9101310828 Biocides201220 Counterfeit product636711

28 FSA Allergy Incidents 2011

29 Please Lets Try and Avoid This Approach!

30 Thanks For Your Attention


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