Food Allergy Policy

Statement of Policy

Magdalene College, Cambridge, acknowledges the important role played by its catering services and is fully committed to complying with the Food Information for Consumers Regulations (EU FIC) No. 1169/2011.

It has been approved and ratified by the Catering Manager and the Executive Chef, who has overall responsibility for its implementation.

All managers, chefs, supervisors and staff are responsible on a day-to-day basis for its implementation.

The policy requires that all food supplied within and by The College is fully compliant with the FIC legislation and the process and procedures laid out within this policy are designed to ensure that the information supplied to all customers is accurate, consistent, and verifiable.

Magdalene College, Cambridge, has committed itself to ensuring that resources, both in staffing and finance, will be available to comply with this policy.

Mark Slater, Head of Catering
Wayne Johnson, Head Chef

1. The legislation

Food Information for Consumers Regulations (EU FIC) No. 1169/2011

Supported by UK law Food Information Regulations 2014 (SI 2014/1855)

'Sets out the general requirements for information to be provided by food business operators, so that consumers have the information they need to make informed, safe and healthy food choices’ - Food Standards Agency

Labelling rules in European Directives 2003/89/EC and 2006/142/EC ensure that all consumers are given comprehensive ingredient listing information and make it easier for people with food allergies to identify ingredients they need to avoid. However, following the implementation of the Food Information for Consumers Regulation (EU) No. 1169/2011, allergen labelling rules will be changing in December 2014.

2. Outline of the requirements

From 13th December 2014 it will be mandatory for food business operators to inform customers of the 14 key allergens that are in their food.

This policy sets out how this is to be achieved.

This is any food you sell and includes pre-packaged and homemade foods.

The labels on packaging are changing to enable you to identify the allergens more easily.

This communication can be verbal or written on the menus. However it is communicated it must be:

• Accurate
• Consistent
• Verifiable

Communication is key - ‘if in doubt, leave it out’

3. The 14 Allergens

1. Celery

Celery and products thereof. This includes celery stalks, leaves, seeds and the root called celeriac. You can find celery in celery salt, salads, some meat products, soups and stock cubes.

2. Cereals

Cereals containing gluten, namely wheat (such as spelt, Khorasan wheat, Kamut), rye, barley, oats and their hybridised strains and products thereof, except:

a. Wheat-based glucose syrups, including dextrose
b. Wheat-based maltodextrins
c. Glucose syrups based on barley
d. Cereals used for making alcoholic distillates, including ethyl alcohol of agricultural origin.

Cereals containing gluten can often be found in foods containing flour, such as some types of baking powder, batter, breadcrumbs, bread, cakes, couscous, meat products, pasta, pastry, sauces, soups, and fried foods which are dusted with flour.

3. Crustaceans

Crustaceans and products thereof (for example, prawns, lobster, crabs and crayfish, shrimp paste), often used in Thai and South East Asian curries or salads, are ingredients to look out for.

4. Eggs

Eggs and products thereof. Often found in cakes, some meat products, mayonnaise, mousses, pasta, quiche, sauces and pastries of foods brushed or glazed with egg.

5. Fish

Fish and products thereof, except:

a. Fish gelatine used as a carrier for vitamin or carotenoid preparations.
b. Fish gelatine or Isinglass used as a fining agent in beer and wine.
Fish is often found in fish sauces, pizzas, relishes, salad dressings, stock cubes and Worcestershire sauce.

6. Lupin

Lupin, which is a flower, is also found in flour. Lupin flour and seeds can be used in some types of bread, pastries and in some pasta.

7. Milk

Milk and products thereof (including lactose) except:

a. Whey is used for alcoholic distillates, including ethyl alcohol of agricultural origin.
b. Lactitol Milk is a common ingredient in butter, cheese, cream, milk powders and yoghurt. It can also be found in foods brushed or glazed with milk, and in powdered soups and sauces.

8. Molluscs

Molluscs, including mussels, land snails, squid and whelks, can also be commonly found in oyster sauce or as an ingredient in fish stews.

9. Mustard

Mustard and products thereof including liquid mustard, mustard powder and mustard seeds. This ingredient can also be found in breads, curries, marinades, meat products, salad dressings, sauces and soups.

10. Nuts

Nuts, not to be mistaken with peanuts (which are actually a legume and grow underground). This ingredient refers to nuts which grow on trees, such as hazelnuts, cashew nuts, almonds, walnuts, Brazil nuts, pistachios, and macadamia nuts (Queensland nuts). Except for nuts used in alcoholic distillates, including ethyl alcohol of agricultural origin.

11. Peanuts

Peanuts and products thereof. Often used as an ingredient in biscuits, cakes, curries, desserts, sauces (such as satay sauce), as well as in groundnut oil and peanut flour.

12. Sesame Seeds

Sesame Seeds and products thereof. These seeds can often be found in bread sprinkled on hamburger buns, for example, breadsticks, hummus, sesame oil and tahini. They are sometimes toasted and used in salads.

13. Soya

Soya, often found in bean curd, edamame beans, miso paste, textured soya protein, soya flour, or tofu. Soya is a staple ingredient in oriental food. It can also be found in desserts, ice cream, meat products, sauces and vegetarian products. All soybeans except:

a. Fully refined soybean oil and fat
b. Natural mixed tocopherols (E306), natural D-Alpha tocopherols, natural D-Alpha tocopherol acetate, and natural D-Alpha tocopherol succinate from soybean sources.
c. Vegetable oils derived phytosterol and phytosterol esters from soybean sources.
d. Plant stanol ester produced from vegetable oil sterols from soybean sources.

14. Sulphur Dioxide

Sulphur Dioxide (sometimes known as sulphites) -This is an ingredient often used in dried fruit such as raisins, dried apricots and prunes. You might also find it in meat products, soft drinks, vegetables, as well as in wine and beer.

4. The Processes

The following management process has been introduced to ensure that customers are given accurate, consistent, and verifiable information.

4.1 Procurement

Suppliers

The College have written to all suppliers to clarify what they are doing in preparation for the change in legislation. Appendix 1 details the letter.

The College uses reputable suppliers. Please refer to the College’s Food Safety Policy. All suppliers are required to comply with the legislation.

Change in ingredients/supplier

If any of the ingredients change (not available, replaced) or a supplier is changed, then the menus and production sheets must be updated to reflect any changes.

4.2 Deliveries

All deliveries are checked to ensure that they are labelled with the contents and required allergy information.

Manufacturers are required to highlight any of the key allergens that appear in their food.

This may be by highlighting the allergen in bold, underlined or in other ways that make these easy to identify.

The allergen information must also be in one place only, i.e., in the main ingredients, list and no longer in an allergen ‘box’.

Accepting or rejecting deliveries of produce

If the labelling information is not available, the person taking delivery will:

• Reject and inform one of the chefs in charge on duty
  or
• If the delivery is required, speak to the chef in charge on duty, who must contact the supplier and ask them to email through the missing information.

Products can only be used if they have the correct labelling. It is a criminal offence for a supplier not to supply this information.

Decanting

Where possible all ingredients should remain in their original packaging with allergen information attached.

If this is not possible, it is important that the decanted goods must be labelled to ensure they can be identified with a new handwritten allergen label with a date on.

4.3 Preparation

All chefs and new staff members have had external Allergen training and must be aware of every ingredient they put into a dish for the presence of the 14 allergens, as well as the allergens in premade foods they are serving.

Chefs and serving staff must be sure they check thoroughly and if in any doubt, they must check with the chef in charge on duty before serving to a customer if asked.

Customers, staff and fellows are encouraged to ask a member of staff if they have an allergy to any food source at the time they attend any of the food offerings around the college. That member of staff will double check with the kitchen before serving, and an alternative can be offered if the first is not favourable by the customer.

If either is any doubt, the answer is ‘NO’ and the food should not be served or an alternative is offered.

Voluntary information – may contain

There are a number of products that have ‘may contain’ in their ingredients list. This information is voluntary. If these ingredients are used we will pass this information on to customers.

Avoiding allergens

Where possible if an allergen is not vital to a dish and its omission will not affect the integrity of the dish then it will not be used- i.e. Worcestershire sauce, mustard, etc. The executive chef will consider this when producing the standard recipes.

Single Ingredients Items

Where the product is a single ingredient product- such as eggs, milk, cheese, etc and the title of the product is obvious and indicates the allergen, these do not need to be labelled as the item is a sufficient description.

However, if this is unclear with items such as latte/ cappuccino (milk), tahini (sesame), edamame beans (soya), etc., these should be labelled.

Cross Contamination during Preparation and Service

Cross-contamination of products is not covered in legislation, as the legislation only covers foods that are ‘intentionally’ added to a dish. However, the college has carried out a risk assessment to reduce risk where possible by following the HACCAP guidelines in good hygiene practises.

Customer information will explain the extent of the law and exemptions and that the College is taking the necessary measures to avoid cross-contamination and provide the information when required.

There are areas where cross contamination of food is very difficult for the College to control. This is particularly evident in the self-service salad counter.

Servery notices will be displayed explaining that there is a risk of cross-contamination in this area and to avoid it if you have a particular allergy.

Preparation for future service and re-use

Where food is prepared for future service, or there is food to be kept following service for future re-use, it is vital that it is labelled to ensure it can be identified at a later time. This is vital for the identification of allergens. If there is no identification label, then the item of food must not be used.

All dishes that are prepared in advance of service must be covered and labelled as follows:

• The name of the dish
• The date of production
• The allergen
• The use by
• The chef on duty will hand over a list of allergens in each food for that particular service for service staff to give to customers if asked.
• Each dinner, formal hall, fellows dining, the chef on duty shall go through the food with the duty manager in charge of the dining for that day.
• Customers have their own responsibility to inform us through either the college booking system or through from the conference office for dining.
• These shall be discussed one by one to ensure the smooth operation and that people do not receive food that is not suitable to their allergen needs requested. The duty manager will inform the serving staff.

4.4. Service and Customer Information

It is vital, prior to any service, that all staff are fully aware of what allergens are present in the food they are serving. The following measures have been introduced to ensure that this happens:

• Handover from kitchen to Front of House for Service
• If in any doubt, speak to the most senior chef on duty

See communication sections in this policy for further details of these methods.

4.4.1 Cafeteria and Bar Service

Pre-packaged goods

Customers are advised to check and ask if unclear.

Static Daily Menus

Cafeteria breakfast menus

The breakfast menus are static, which means the same menu is provided every day within these areas for this service.

The price lists also act as a menu and will therefore have the allergen labels added to them.

There is no need to change daily, unless products change. If any menu items do change, the whole menus/ price list will be replaced.

A note is displayed in the servery and bar saying: if item is not on the menu/price list please ask about allergen information. No information does not mean it does not contain allergens.

Bar price lists

In addition to the notice explaining the old and new labels, there is also a bar price list that categorises the drinks for sale into allergen categories- ‘these products contain gluten’, ‘these products contains sulphites’, etc.

Daily Changing Menus

Hot food

The daily menu for cafeteria lunch and dinner is produced every day following the handover of information. Each of the allergens on the menu is highlighted with the appropriate symbol and text.

The hot counters will have the menus advertised, either on the counter or on the pillar next to each counter.

The servery staff will have a daily list of each food served and the allergens they contain. If any reassurance is needed then they are encouraged to ask the chef on duty if any doubt at any time throughout the day.

Salad bar and cold desserts

The salad bar and cold dessert menus change regularly, and a sign is displayed on the salad bar informing customers to ask if they have allergies.

A notice is also displayed informing customers of the ‘high risk of cross-contamination between salads during preparation and service’.

Signposting

If there is not enough space by a counter for the menu, then a sign saying

‘Please see the menu/price list or allergy information file for allergy information’ is used.

Change in menu mid-service:

Any changes to the menu should ideally mean a new menu is prepared and displayed. if there is any delay in this taking place, a note in the servery is displayed on each counter saying ‘if the item is not on the menu please ask a member of staff for the allergen information in that dish’. No information does not mean it does not contain allergens.

4.4.2 Formal Dining including Formal Halls, Lunches and Dinners, Conferences and Events

For all meals served at the table the following action is taken:

• If menus are displayed on the table there is a notice at the bottom of each menu saying ‘Please speak to a member of waiting staff if you require allergen information’.
• If there are no menus, then notices are displayed on each table asking customers to ‘Please speak to a member of waiting staff if you require allergen information’.
• If a member of waiting staff are asked about allergens they refer this to one of the duty managers who will speak to the chef on duty and serve them any specific meal required to ensure that the customer is safe to eat each element of the menu.

4.4.4 Tea and Coffee Service

For tea and coffee service:

Biscuits served in individual packaging and customers are referred to the allergens by a notice that says – ‘please refer to the biscuit packaging for allergen information.

4.5 Communications

Advance information

There are opportunities to find out what allergies the customers of the College have in advance. The catering department is taking the following steps to communicate with its customers.

Students

Before students arrive at college, the information they are sent includes asking them whether they have any food allergies.

Formal Hall

The hall booking system allows customers to input details of their allergens. This information is printed out and given to the chefs for production and the front of house staff for service. This will be discussed at each briefing before service by the chef on duty and front of house service manager in charge.

Conference and Events

The conference and events team ask all organisers of events to provide details of guests who have allergies. These details are provided to the catering department as soon as possible so special arrangements can be made if required.

Handover for service

For every service, there will be a handover of information on allergens for all menu items produced. This includes all services- cafeteria, functions, high table and conferences.

Signposting

If the information is not available at the point of sale, then signposting is required, instructing customers where to find the information or to ask if they are unsure.

Customer information:

The servery signage will include the following information regarding allergens:

• Daily menus with specific allergy information, by dish
• Static price lists and menus with specific allergy information, by dish
• Signposting to where information about allergens is available
• Information about the 14 Allergens and a key to their symbols
• Information about the risk of cross-contamination
• Asking customers to ask a member of staff if they are unsure

In order to ensure that there are people in the department who have a greater understanding of allergens and the requirements of the legislation, the College is committed to training individuals on each shift.

This will ensure that chefs, service staff and customers have someone available during every service for assistance and advice.