Cross-contact & PAL statements in Coffee Shops

This guest blog comes from Iain Ferris, Lecturer in Food Safety, Food Standards and Food Law at University of Birmingham.

You can find Iain on Linked In.

I frequently come across posts in Linkedin calling out various catering businesses about their inability to guarantee products are free from allergens, the catering equivalent of a precautionary allergen labelling (PAL) statement. This short article aims to explain why I think that these statements are valid and indeed sensible in many premises.

A student on one of our courses recently posed a question regarding a coffee shop that she had visited. It was a very thoughtful observation that highlighted the challenges faced by food business operators (FBO) when catering for people with allergies. Her e-mail stated “I was hoping you could give me some guidance, as part of my inspection I noted that the premises uses various alternative milks including soya milk and almond milk however they do not use dedicated jugs or steam wands to prevent any allergenic contamination. Is it appropriate that they should use separate labelled jugs for each type of milk and have dedicated steam wands or if they don’t have the capacity to do that to limit the amount of alternative milks they use? You could argue if they have appropriate cleaning in place that might be sufficient but I was always under the impression cleaning doesn’t necessarily remove allergens so there is still a risk for those with sensitivities.”

My response was as follows: “I think that you are correct in your considerations. The question you are deliberating is whether the cleaning of the wands and the jugs will be sufficient to remove the allergens.  From a HACCP perspective the FBO needs to have in place appropriate procedures to control the allergen hazard and the cleaning of the equipment will be an essential part of that. However, it is unlikely that the FBO would have carried out any validation study to ascertain how effective cleaning will be and the verification is visual inspection, which is not likely to be sufficient to guarantee the absence of the allergen. If you have a look at the Allergen Bureau’s VITAL research into eliciting dose levels you will see that the levels needed to cause a reaction to milk in the 1% most sensitive individuals is 0.2 mg. If you don’t have complete separation then it is quite difficult to be confident that the allergen is controlled and potentially the control is to use precautionary allergen labelling (PAL) i.e. a may contain statement. It may be possible to have separate jugs for the various milks but maybe less likely to have dedicated steamers exclusively for the milk alternatives. The motivation for the PAL in this instance is based on the inability to assure the consumer that the product is free from the allergen and driven by the lack of information on whether the cleaning control will be effective enough.”

Since then I have been curious to test the prevalence of cross contact allergens in catering premises and recently one of our masters students has been researching the effectiveness of cleaning in removing allergen residues. At 9 premises visited with our local authority colleagues we found 10 out of 16 utensils swabbed after cleaning were positive for allergen residues at a level above 0.5mg/kg (levels that potentially could trigger a reaction). Our initial findings suggest that a dishwasher alone is not always effective at removing the allergen and the use of contaminated cloths and water may also be factors. Washing utensils in running water with detergent and a clean cloth appears to be more effective than a sink-full of water. It is however debatable whether washing utensils in this manner is likely to occur or indeed whether it is practical to do this routinely although it could be done when dealing with an allergy request. There may of course be other factors such as the condition of the utensils and the initial levels of contamination that may affect this too and thus further research is necessary. It does however suggest there is a problem.

Some local authorities in England and Northern Ireland have also been carrying out sampling for allergens which has included for traces of dairy in milk alternative drinks in coffee shops. Although not published data, some authorities have reported more than 50% (n=15) of samples contained traces of dairy above the VITAL eliciting dose levels. The most likely source of this contamination appears to be the equipment and in particular the steamer. With this frequency of contamination it seems reasonable to raise awareness with the consumer that levels of allergens are likely to remain.

This research and surveys suggest that the risk of cross-contamination in catering is real and the use of statements not guaranteeing foods are free from allergens are sensible and not necessarily an excuse for poor hygiene. In addition though, more research in this area will be extremely useful in determining the risk of cross contamination and whether PAL is necessary, but also in identifying procedures that are effective in ensuring foods are safe for the allergic customer.

Food Allergy Aware has drawn up a factsheet that links to Iain’s blog, you can find it here.