Caterers’ responsibilities

Your basic responsibility is to provide food that is safe to eat.

By law, you must:

Give information about allergens in the food you provide, and
Have in place a food safety management system based on HACCP principles.

HACCP stands for hazard analysis and critical control points. It’s a system that helps you assess risks and control food safety hazards. These hazards include food allergens.

How to provide information
for loose foods

Loose (unpackaged) foods are not prepacked before sale. for example;

Ice-cream on display at an ice-cream counter
Sandwiches made to order
Meals cooked and served at a restaurant.

If you sell or provide loose food to customers, you must supply information for every item on your menu that contains any of the 14 allergenic foods as ingredients.

This information can be provided either:

in writing on a menu, chalkboard or in an information pack
Or
orally, with a written notice placed in a clearly visible position explaining how customers can get the information.

When allergen information is provided orally, you can also back this up in writing if you wish to do so. This is a good idea, as it's a great way for the information to be checked for accuracy and consistency.

Prepacked and prepacked for direct sale foods

Information on any of the 14 allergenic foods used as ingredients in prepacked and prepacked for direct sale (PPDS) foods must be provided on the label. PPDS means the food is packaged and sold in this packaging to customers at the same place.

Examples include:

Sandwiches that you make, pack and sell at your premises.
Pies that you make and pack at your bakery and sell at your market stall.
Boxed salads.

All prepacked and PPDS foods must be labelled with:

the name of the food, and
an ingredients list including allergenic ingredients. The allergenic ingredients within the food must be emphasised on the ingredients list, for example, in bold, in capital letters, in contrasting colours, or underlined.

For instructional videos that clarify what PPDS is, and how to create
an ingredients list and label for PPDS food products, go to https://www.safefood.net/allergens/natashas-law

Further information on allergen labelling can be found at https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses

Other ways of selling

If you sell food at a distance, such as a telephone order for a takeaway or online, the allergen information should be provided twice.

Before the food is purchased
When the food is delivered or collected.

On both occasions this information can be given in writing (such as webpage, menu, label) or orally (for example over the phone).

Buffets

If you offer food in the form of a buffet, you need to provide allergen information for each food item separately. You should not provide it for the buffet as a whole.

You can provide this information by labelling individual dishes with their allergenic ingredients, or by displaying a sign directing customers to ask staff for allergen information.

How to manage food allergens

Follow these 5 steps:

Identify allergenic ingredients.
Have a food allergen management system to avoid cross-contamination when storing, labelling, preparing and serving food.
Train all staff.
Act with due diligence.
Communicate fully, openly and tactfully with customers about their needs.

Identifying allergenic ingredients

Be aware of the 14 allergenic foods on the UK/EU list* and where they may be found. Identify them clearly on menus, recipes and storage labels.
If a customer tells you they need to avoid allergens that are not on the list, check recipes and labels. Ensure you can avoid, remove or replace these foods for them.
Keep information on ingredients up to date and easily accessible. You could keep it for example, on a computer or manual file or on store-room notices. You can then check at a glance whether or not a foodstuff contains allergens.
Ask your suppliers to tell you of any changes in ingredients or recipes.

*Identifying the 14 allergens: Annex 2 to Regulation No. 1169/2011

2. Food allergen management system

Allergen management is key to keeping your customers safe when they have food allergies or intolerances. Take the following actions to make your system effective:

Train all staff to be aware of the importance of food allergen control and your in-house system. Provide regular refresher training.
Keep up to date information on the allergen ingredients in your recipes.
Ask suppliers to tell you about any changes in ingredients.
Check that items delivered match exactly those you ordered.
Store allergens, such as nuts, peanuts and gluten containing foods separately in lidded containers. Mark or colour code the containers.
Alert your staff to cross-contamination risk and how to control them.

Prepare and serve non-allergenic food separately from allergenic food if asked to do so.
Train all staff how to properly clean utensils and equipment to avoid cross-contamination.
Make sure information about allergenic ingredients is clear, up to date and easy for all staff to find.
Encourage customers to consult with your staff so they can make an informed choice about what foods are safe for them to eat.

How to avoid cross-contamination

Look out for the risks of cross-contamination in storing, labeling, preparing and presenting food. It an occur in 4 main ways:

Food-to-food contact — Food allergens can easily pass from one food to another (for example, in a dusting of flour or a display of fish next to shellfish).
Food-to-equipment contact — Thoroughly clean all equipment, utensils and worktops before preparing allergen-free food, or use dedicated equipment.
Food-to-hand contact — Always wash your hands thoroughly before preparing allergen-free food.
Food-to-clothing contact — Change clothes that may be contaminated with an allergen (such as flour) if you need to prepare food without that allergen.

After preparing an allergen-free meal, keep it covered, keep it labelled and deliver it separately to the customer.

3. Train all staff

Consider making one member of staff responsible for handling all queries about allergens. Make sure all staff know who this is. Nominate a deputy in case that person is absent.
For your food allergen management system to be effective, all staff should get basic training in food allergen management before they first start work so they are aware that any allergen requests must be taken seriously.
Free allergy training is available online:

Safefood training

Food Standards Agency training

4. Act with due diligence

Food allergy issues can sometimes lead to legal cases against a food business. It can strengthen your defence if you can show you “took all reasonable precautions and exercised due diligence”. In general terms this means;

Keeping written records of the checks carried out as part of your food safety management system.
Providing accurate information on allergens for each menu item.
Demonstrating how you avoid allergen cross-contamination.
Ensuring all staff training on food allergen management is up to date and added to their training records.

5. Communicate with customers

You and your staff must ensure you give customers with food allergy or food intolerance accurate information about allergens in the food you offer. They use this information to decide whether or not to buy and eat the food.

You will need to think carefully about how you handle their queries and provide information.

To make sure you and
your staff have the right
information at hand

You must state clearly if any of the food you serve contains any of the 14 listed allergenic foods. This applies whether or not the food is loose or prepacked. Remember, food allergy is not limited to the 14 allergenic foods on the UK/EU list. Let customers know they are welcome to discuss any food allergy or intolerance issues with you or your nominated staff member(s).
Look out for precautionary allergen labels. These state, for example, ‘may contain nuts' or ‘packaged in a factory that also handles cereals containing gluten’. They are not compulsory; food laws does not require food manufacturers to provide ‘may contain’ statements. A customer may want to know if such warnings apply to any food you are preparing for them. You should always tell them of any ingredient with a ‘may contain’ label for the allergen they are trying to avoid so they can make an informed decision about buying the food.

If asked, tell your customer
what steps you take to avoid cross-contamination.

On gluten, you should:

Follow the guidance ‘Gluten-free food’
Discuss the customer's needs with them, particularly if they are worried about cross-contamination.
Remember cross-contamination of foods with gluten or other allergens are a risk during delivery, storage, preparation and service.
For more information on managing gluten and gluten declarations click here.
Use tact and discretion, as some customers may feel uncomfortable or embarrassed about discussing their dietary needs in public, especially if these are due to a medical condition.

Remember, if you are unsure of any of the ingredients, or if there is any doubt about cross-contamination, you must tell the customer. The final decision to buy rests with them.