This month’s guest blog comes from Rachel E. Kessler who is an American student currently pursuing a Master’s degree in Food and Health in Padova, Italy.
I have a unique perspective on the discussion of allergen awareness. Living with a severe tree-nut allergy and gluten intolerance, and having experienced dining out in both the United States (U.S) and Italy, I have the opportunity to delve into the distinct differences in how these countries differ in their handling of allergen safety. My journey as a student and advocate for food safety has been deeply influenced by these personal experiences.
One of these personal experiences occurred just a few months ago in New York City, when I dined out with a friend and noticed that many dishes, especially the salads, contained tree nuts. Cautious about my severe nut allergy, I inquired with the server about the salads, specifically asking if they were pre-mixed. She assured me the kitchen took allergies seriously and that it was safe to order a nut-free salad. However, when my salad arrived, I found slivers of almonds in it.
Thankfully, I inspected it before eating, which prevented a potentially life-threatening situation. I alerted the server, and later, the manager [all too] casually apologized. Unfortunately, this experience was not the first of its kind, for me, and likely many other allergic consumers in the U.S. I feel that it is important to state that I have personally never had this type of experience in Italy. Rather, I have had the opposite, where servers are extremely diligent about my allergies, at times even going so far as to recommend that I not order a particular dish because of its slight potential to contain my allergens; always redirecting me to a safer option, even without me asking them to do so. I have even had experiences in bakeries where I have been refused service out of an abundance of caution. While the possibility to have an allergic reaction while dining out certainly exists everywhere, I find it to be way less likely in a place like Italy, that will often not promise something it is not 100% certain of in terms of safety. Because of this, I find myself having a particular trust in Italian restaurants, that I do not have in the U.S.
This highlights what I believe to be the distinct difference between allergen management in the U.S and Italy- the attitudes towards it.
I believe this occurs for a few reasons, one of which being the fact that Italy is renowned for its culinary expertise, and with that comes a particular attention to detail that I don’t see too often in the U.S. Food industry workers, whether that be the chef, server, or support staff, are proud of their craft, and take great care to see that their consumer is safe and satisfied, which at times may mean telling them it is not possible to get a particular dish. This clearly juxtaposes the “customer is always right” mentality in the U.S, where servers likely feel pressure to say yes even when they aren’t entirely certain they can deliver. It is important to note here that this issue extends past that of food allergens, opening up a pivotal discussion of how restaurant workers are treated between the U.S and Italy, including differences in wages, benefits, hours, and general affect towards their jobs. However, that is a separate issue that deserves its own post.
For now, we will focus on the consequences of all these moving parts, which is a distinct difference in attitude towards allergen management. While the previous paragraphs have focused primarily on the subjective differences between cultures surrounding food and the food industries of either country, I want to shift into the regulatory component of this vital conversation, delving into the legal differences between allergen management in the U.S and Italy.
EU Regulation 1169/2011
EU Regulation 1169/2011 is commonly referred to as the Food Information to Consumers Regulation, which is a
comprehensive regulation that governs food labeling and allergen information for packaged and non-packaged food items, including those sold in restaurants.
The regulation mandates that all food businesses, including restaurants and food service providers, must provide clear and accurate information about the presence of allergenic ingredients in the food they serve. The 14 allergens included in this regulation are cereals containing gluten, crustaceans, mollusks, eggs, fish, peanuts, tree nuts, soybeans, milk, celery, mustard, sesame seeds, lupin, and sulfur dioxide/sulfites (at certain concentrations). It states that food businesses are required to provide clear and accessible allergen information to consumers, which can be achieved through menu labeling, signage, written allergen lists, or verbal communication with customers. The regulation also mandates that restaurants ensure proper staff training to eliminate the risk of allergen and cross-contamination related incidents.
In my experience in Italy, dining out in various regions of the country, most restaurants will have allergens either labeled directly on the menu (with letters or symbols correlating to the 14 major allergens), or if they don’t, they will often have a special allergen menu available upon request. In the rare but possible case that the restaurant has neither, staff will be extremely cooperative to ensure the food you order does not contain your allergen, and will often go speak to the chef directly if they are unsure about the ingredients of a dish or the possibility of cross-contamination. I have even had servers re-assure me that my plate does not contain my allergens throughout my meal, making me feel extra confident that they are taking correct measures to ensure I am safe.
Food Allergen Labeling and Consumer Protection Act (FALCPA)
In the U.S, there is no federal law equivalent to EU Regulation 1169/2011, but rather exists the Food Allergen Labeling and Consumer Protection Act (FALCPA), which requires clear labeling of the top 8 allergens in only packaged food. These 8 allergens include milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans. In 2021, an additional act was passed to include sesame to this list. However, currently, FALCPA does not mandate any type of allergen information in restaurants. While there is no federal regulation, some individual states have made local regulations regarding allergen disclosure in restaurants, however, it is always up to the individual food service providers. In my experience in the U.S, I have really only seen allergen information available directly on menus in chain-restaurants, which typically also have more information available on their websites. Of course, some individual establishments may also choose to have allergen information available, but I have found that majority of the time, this is not the case. Overall, the U.S appears to still be lacking in terms of regulations for restaurants, leaving it entirely up to the individual establishment. This allows for significant variance throughout the country, putting allergic consumers at risk. Of course, some restaurants take allergens extremely seriously, I have just not found that to be the norm.
I believe that the difference in regulations between Europe (specifically Italy), and the U.S, further facilitates the two entirely different attitudes towards allergen management- one where the consumer has security, and one where they are often left to hope for the best, but often, expect the worst. In not mandating all restaurants provide proper allergen information, the U.S leaves much more room for error than its EU counterpart does.
In the realm of dining with allergies, the contrast between the U.S and Italy (and the rest of the EU) is starkly evident. I believe that Italy’s attitude towards food, supported by the stability and security of EU Regulation 1169/2011, sets a valuable example. Adopting some of these ideals would enhance the dining experience in the U.S, ensuring a more inclusive and safer environment for all food-allergic patrons.
2 responses
Caroline,
Happy New Year.
Would you like to post this informative article on the HFSF on Linkedin?
Hi Euan
I am happy for you to share in the LinkedIn group, as unsure of the HFSF group
Caroline