Food Safety Standard

Guidance for the catering industry

Responsibilities of Caterer:

Your basic responsibility is to provide food that is safe to eat. By law, you must have in place a food safety management system based on HACCP (hazard analysis and critical control points) principles to assess risks and control food safety hazards.

Food allergens are also a hazard and, while generally not included in HACCP systems, should nonetheless be considered and handled in the same systematic way.

Identifying allergenic ingredients:

Be aware of the 14 allergens on the EU list * and of 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 EU list, check recipes and labels to ensure you can avoid, remove or replace these foods for them.
Keep information on ingredients up to date and accessible, for example on a computer or manual file or on storeroom notices. You can then check at a glance whether a foodstuff carries a warning about potential allergens.
Ask your suppliers to notify you of any changes in ingredients or recipes.

Food allergen management system:

Allergen management is key to ensuring the safety of customers with food allergies or intolerances. Your system should have the following controls in place:
Train all staff from day one, with regular refresher courses, to be aware of the importance of food allergen control and your in-house system.
Appoint a responsible member of staff to handle all food allergen and related queries and ensure that all staff know who this is. Nominate a deputy in case that person is absent.
Keep up-to-date information on the allergen ingredients in your recipes and show this information at the point of sale if required to do so.
Ask suppliers to notify you of any changes in ingredients.
Check that items delivered match exactly those that were ordered.
Store major allergens such as gluten, nuts and peanuts separately and in lidded containers. These should be marked or colour coded if possible.
Alert your staff to cross-contamination risks and how to control them (see the box ‘How to avoid cross-contamination’ below).
Prepare and serve non-allergenic food separately from allergenic (see the box ‘Preparing allergen-free food’ below).
Train all staff how to properly clean utensils and equipment to avoid cross-contamination.
Ensure the allergen information for customers on menus or notices is clear and easy to read.
Encourage customers to consult with your staff so they can make an informed choice about what foods are safe for them to eat.

Train all staff

Appoint a responsible member of staff and deputy to deal with all allergy/intolerancerelated requests.
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 related requests must be taken seriously.

Act with due diligence

Food allergy issues can sometimes lead to legal cases. And while every legal case is unique, it’s considered best practice to always act with what’s called ‘due diligence.’ This means that if someone tries to sue your business over a food allergy issue, you may by law* defend yourself if you can prove that you took ‘all reasonable precautions and exercised due diligence’ to avoid committing an offence. In general, 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
Keeping records of staff training sessions on food allergens.

Communicate with customers

You should let your customers know that you would be happy to discuss their requirements with them. You can do this by, for example, noting on the menu or chalkboard that customers should ask staff for further information if they have any concerns about allergens.
You must state clearly if any of the food you serve contains any of the 14 allergens on the EU list. This applies whether or not the food was bought loose or pre-packed. In ROI, you must provide allergen information in written form, for example by highlighting the allergenic ingredients on the menu. In Northern Ireland, you can tell the customer in person.
Remember that food allergy is not limited to the 14 allergens on the EU list. Let customers know they are welcome to discuss any food allergy or intolerance issues with you or your nominated staff member(s).
‘May contain’ statements – under EU law, it is not compulsory for food manufacturers or caterers to warn customers about the risk of cross-contamination from allergens, because the risks are difficult to quantify. However, many manufacturers do issue warnings such as ‘may contain nuts’ or ‘packaged in a factory that also handles cereals containing gluten’. Your customers may want to know if these warnings apply to any food you are preparing for them. You should always tell them of any ingredient with a ‘may contain’ advisory so they can make an informed decision.
If asked, show the customer your recipes or packet labels and to tell them what steps you take to avoid cross-contamination.
When discussing gluten, you should:
- Provide information for menu items that have any of the cereals containing gluten as ingredients
- Only use the terms ‘gluten free’ or ‘very low gluten’ if you know the exact amount of gluten in the product.
- In ROI, you must not use the term ‘no gluten-containing ingredients’.
- Only use statements such as ‘suitable for people intolerant to gluten’ or ‘suitable for coeliacs’ if you know the amount of gluten in the product.
Use tact and discretion, as some customers may feel uncomfortable or embarrassed about discussing their dietary needs in public, especially if they have an underlying 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 the customer.