Allergen Control in Foodservice

1. Allergen Control in Foodservice Simon FlanaganSenior 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)

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 reducedto 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

13. Environmental

14. Production

15. People

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 • 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

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

22. Hierarchy Of Risks In Foodservice

23. Compositions Of Risk Assessment Team

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

28. FSA Allergy Incidents 2011

29. Please Lets Try and Avoid This Approach!

30. Thanks For Your Attention