Following on from our last blog from Sally Trice, this blog looks at the implications of Natasha’s Law on caterers and the implementation of the PPDS labelling on 1st October 2021.
What is pre-packed for direct sale?
PPDS food is food that is packed before being offered for sale by the same food business to the final consumer.
This could be on the same premises, on the same site such as an airport terminal with multiple outlets, or on other premises if the food is offered for sale from a moveable or temporary premises but offered for sale by the same business who packed it.
There is some very helpful information available for caterers on the FSA website: www.food.gov.uk/ppds.
All PPDS foods must have on the package the name of the food and an ingredients list within which any of the 14 major allergens present are highlighted. All the ingredients of the food must be stated in descending order of weight as recorded at the time of their use in the manufacture of the product.
The allergens within the food must be emphasised every time they appear in the ingredients list and all component parts of the food product e.g. the bread, the filling and the spread must also be detailed.
The information must appear on the package or on a label attached to the package and be easily visible and clearly legible. There are many software labelling options which are available, but labels can also be handwritten as long as they meet the requirement.
Risk factors
There is no doubt that the new legislation will be a challenge to many businesses. A recent study revealed that only 64% of businesses selling PPDS foods were aware of Natasha’s Law. Although the industry has had almost 2 years to prepare, many businesses have only just reopened, and the emphasis has been to make sure that premises are covid-secure so some businesses may have lost sight of the deadline.
Many small catering outlets will not have a central database from which to draw recipes and will be buying ingredients from their local cash and carry or supermarket. They may even change the menu weekly which will mean completely different labels are required. Each food business will need to stay on top of ingredient changes and will be reliant on good communication with suppliers. If the usual brand of mayonnaise is not available and another is sent or chosen from a supplier, the allergen content of the product can be altered significantly.
The recommendation is to produce labels on the day of production and not in advance otherwise there is a risk of an ingredient change making the label incorrect. This will involve cross-checking and verification of ingredients which will add to the preparation time. The whole point of the regulations is to provide accurate and verifiable information for the consumer and to facilitate safe and informed food choices for the Food Hypersensitive customer.
Although you will need to ensure you have a contingency plan in place in case of malfunctions with your labelling software if appropriate.
In addition to mandatory allergen information, voluntary information about the unintentional presence of allergens, “may contains, “usually from unavoidable cross-contamination can also be provided. This information does not need to be included on the label and it can be given verbally or be displayed on signs or notices on the premises. This information should only be provided after a thorough risk-assessment has been carried out to ascertain the level of risk of allergenic cross contamination which cannot be reduced by cleaning or segregation. The use of precautionary allergen labelling when there is no real risk, could be considered misleading food information.
Enforcement of the new regulations will be carried out by a mixture of Trading Standards Officers and Environmental Health Practitioners. Many EHPs have been focused on the COVID response and may not have had the time or resources to help local businesses prepare for the changes but do acknowledge that food businesses have had a very tough time.
The general consensus seems to be that if an operator is making an effort to comply with the regulations they will be supported and helped by their local authority. Natasha’s law ties in with the normal HACCP-based checks on preparation, cross contamination, storage, and training but there is likely to be increased emphasis on allergen management in the light of the new regulations.
All staff must have basic Food Allergy Training and the FSA offer a free “Food Allergen and Intolerance e-learning programme” which should be taken as a minimum.
Other useful websites:
Food Allergy Aware is running a series of bite-sized on-line workshops in August & September in collaboration with Jacqui McPeake. Caroline & Jacqui are working together as “Hospitality Allergen Support UK” to help raise awareness of the importance of near miss reporting and staff training and to answer any specific business-related questions in regard to Natasha’s law.
Please register your interest at https://foodallergyaware.co.uk/events/
To find our more about how we can help you please email Marketing@fatc.co.uk or call 07732637292 for a FREE 20 minute call to discuss your site.
Sally Trice
Consultant/Trainer – Food Allergy Aware
