Presentation on theme: "Allergen Control in Foodservice"— Presentation transcript:
1Allergen Control in Foodservice Simon Flanagan Senior Consultant Food Safety and AllergensIntro self……..28 years, proactive / reactive – numerous sectors including foodserviceI 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 processTaking learning's from the pre-packaged sector who have been dealing with allergen labeling regs for last 8 yearsALLERGEN 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
2Overview ‘Free-from’ – key considerations Principles of allergen risk assessment in pre-packaged food sectorApplying knowledge to the foodservice sectorHierarchy of allergen risks in foodserviceLearning from previous research in the foodservice sector
3Free-From - the Bar is Higher! Invitation to purchase by potentially most at risk consumersNo 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 guidanceManufacturers, retailers and foodservice setting own policesEnforcement surveysBefore 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 higherSo what regulatory guidance is out there??
4FSA GuidanceFood Standards Agency “Best Practice Guidance on Managing Allergens with Particular Reference to Avoiding Cross-Contamination” (2007)Section Allergen-free foodsA 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
5Principles 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 guideRisk 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 communication4. Review as in any iterative process – change in people, ingredients, processes etc.Risk review – has the risk changed?
6Terminology (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 followedHazard – 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 levelsRisk assessment is one of those phases that means different things to different people
7Can We Apply To Allergen Risk Assessment? Estimation of risk – subjectiveLikelihood score – subjectiveSeverity of hazardDepends on the allergenic ingredientDepends on sensitised individualSpectrum of reaction in sensitised population from mild (1) to death (3)Risk managementEliminated (?) or reduced to acceptable level (?)Cannot completely eliminate riskWhat 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?
8Best Practice – Risk Assessment Targeted risk assessments incorporating hazard characterisationEvolution of 2006 FSA guidelinesThree-tier allergen mappingAssessment of risks arising from the following factorsProcess flowEnvironmentalProductionPeopleRank risk probability against characterised hazardOutput drives allergen management or labellingGot to be pragmatic when we conduct the risk assessment and focus on high risk activities not chasing molecules around the factoryWhat is the next step for industry following the 2006 guidanceNeed a form of quantitative risk assessmentResult 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
9Allergen Mapping (1)Looking at the catering sector this is ultimately about having good knowledge of allergens used as ingredients in different recipes
10Allergen 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
11Allergen 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
12Process Flow Process Flow Examples Bins for dry allergens Ingredient weighingCross- contamination from non-dedicated scoopsBins for dry allergensOrange = allergens2 scoops between all the binsControl – either dedicated scoops or cleaning between useThis could well be scaled down and could consider the use of decanted ingredients as are used in commercial catering
13Environmental Factors Examples WarehouseContamination of stored products due to air extract into warehouseMilk powder between is malt and cocoa powderIf we wanted to make relevant to catering this could relate to storage and management and hygienic practices in the kitchen and associated store
14Production Related Activities Examples Rework managementRework is not clearly identifiedRe-work. Pastry - with a mustard centre and one without – common reworkCatering example could be that that a common stock or base for a curry could go into several different dishes
15People Related Activities Examples HygieneStaff moving between different lines without washing handsChews – containing milk protein – next line was no milk containingCatering example – could be someone prepping pastry and then moving onto prepping salads without washing hands or changing PPE / whites
16Probable Versus Remote Definition – probable is likely to happen under normal operating conditionsLeft is part opened/ sealed packets of mixed materialsRight – go straight to line and a hose dispenses straight onto line.
17Hazard Characterisation (1) Allergen Biochemistry True allergens = always proteinsMost allergens incredibly stable molecular structuresSome resistant to processingHeat treatmentMechanicalFermentationSome rendered ‘more’ allergenicBiochemistry (and matrix) influence cleaning interventionsSo 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 outNut proteins are very lipophyllic – associated with fat layer
18Hazard Characterisation 6 Key ConsiderationsPhysical nature of contaminantLevel of processing undergoneAmount of protein (no protein = no problem)Target consumers (vulnerable groups)Established thresholdsType of production environmentCharacterise risk, define associated hazard and then validate existing control measuresCleaning is significant control measure in the catering sectorSo we start to pull all of these factors together we can start to get a better estimation of the relative severity of the allergenic hazard1. Physical – air / sticky4. free-from or children6. Dairy versus cereals
19Terminology Cleaning Validation Cleaning Verification: Quantitative assessment of cleaning methods to ensure that they are sufficient to minimise allergen cross-contactPerformed once unless anything changesCleaning Verification:Qualitative periodic assessments to confirm validated control measures (cleaning) are still effectivePerformed periodically at predefined intervalsMonitoring of CleaningQualitative ongoing assessmentsPerformed every time cleaning is undertakenThe exercise is performed once, but within that repeated 3x based on WHO guidelines
20Output From Risk Assessment Documentation is key as this forms the basis for due dillange
21Applying Concepts To Foodservice Allergens as ingredients – labellingKnowledge of what allergens are in which dish and robust system to ensure that this is effectively communicated to allergic customerAllergen mappingWhich allergens are in ingredients, which recipes do these go into and which surfaces/ equipment do these come in contact withRisk assessment considerationsProcess flow – risks associated with preparation of finished dishEnvironmental – kitchen management & storage practicesProduction – shared oils/ovens etc.People – knowledge and training - front and back of houseProbability of occurrenceSimilar rationale appliedHazard characterisationAs we have illustrated the risk assessment process used in pre-packed foods can be easily transcribed into catering
22Hierarchy Of Risks In Foodservice Complexity & communication within the businessWrong information given to allergic customerWrong ingredients used in dishSubstitution of ingredients in dishPoor storage and segregation practicesCross-contamination of ingredientsIneffective cleaning and personal hygienePoorly cleaned food preparation surfacesUtensils, cutlery and crockeryPoor hand washing and cross contact from PPEAllergen containing dishes made in close proximityHierarchy 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 riskIn risk assessment start with the high risk activities and then work down
23Compositions Of Risk Assessment Team Ideally multi-disciplinary teamDepends on size of businessCould just be an individual with broad knowledge of the businessTeam leaderCould be proprietorBack of houseKitchen teamFront of houseWaiting staffIngredient procurementShopperHygieneKitchen porter washer-upper
24Foodservice Research: Gluten-Free Staff trainingCommunication with allergic customerPersonal hygiene practicesIngredient labellingIngredient storagePreparationCleaningResearch 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 companiesTo try to identify the procedures needed for gluten-free preparation in commercial kitchens – there are a number of parallel with the management of other allergensHighlights 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 diseaseDocumentation of training practices recipes and work instructions and a budding systems – lots of pictorial information for language issues2) 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’sOther companies like Amadeus at NEC had allergy cards filled out by customers which accompanies the meal as its brought out from the kitchenAnother approach was to have an automatic system which was linked to the till to alert the kitchen about the special dietary needs of customer3) Good hygienic practices = Good gluten / allergen managementHygiene 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 PPE4) 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 remained5) 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 operation7) 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 methodsIf you want to know more about research and associated training programme – Anna Godfrey CUK here today
25Allergen 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 supportBecame 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, takeawaysDue 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 contaminationDesigned 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 utensilsCleaned using a variety of both manual and automatic techniques with various commercial cleaning agentsMonitored the removal of allergens through surface swabs post cleaningTenacity of different allergens (Hazelnut Peanut and Milk)Effectiveness of different cleaning methods & cleaning materialsEffect of different contact surfaces
26Results SummaryThe graphic represents the level of contamination of peanut found in the samples after a bowl detergent washPeanut most difficult from all surfacesAutomatic wash generally more effectiveChopping boards most difficult surface to cleanSponges are least effective cleaning materialDetergents vs. hot water – differences but not for all surfacesLots of data generated but low replication
27Learning from the Pre-Packaged Sector Incidents by category,Category200620072008200920102011Allergens61868479114Animal feed (on market)91013828Biocides21Counterfeit product63711Recalls/withdrawals continued over last 7 yearsIncreased use of ‘may-contains’ – devaluation of warningCommon root cause – inadequate training, packaging errors and incorrect use of ingredientsVery few are a result of consumer complaint – it is industry spotting the issuesConsumers do not believe the warnings –Gemma!Root cause – FSA information
28FSA Allergy Incidents 2011SO2 is the hidden allergen
29Please 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 butMay contain – nuts, peanuts, sesame seeds, mustard, celery, wheat, eggs, fish, soyabeans, milk, sulphites and cereals containing glutenHow did they manage that!!!!
30Thanks For Your Attention Finally like to acknowledge the following groups and individuals