What is Natasha’s Law?
Natasha’s Law was introduced following the tragic death of Natasha Ednan-Laperous who died from anaphylaxis in 2016 after consuming a Pret a Manger baguette which contained sesame. Subsequent campaigning by Natasha’s family, who set up the Natasha Allergy Research Foundation, and the outcome of the inquest into Natasha’s death led to the change in legislation. In September 2019, Natasha’s Law was passed, and catering operations were given two years to prepare to comply with the requirement to label all prepacked for direct sale (PPDS) food and drink with a full ingredients list and allergens. This approach to labelling is used across manufactured foods as part of the Food Information to Consumers (FIC) Regulation 1169/2011.
What counts as PPDS?
The Food Standards Agency defines Pre-Packed Foods for Direct Sale (PPDS) as food that is packed before being offered for sale by the same food ‘business’ to the final consumer:
- on the same premises; or
- on the same site; or
- on other premises if the food is offered for sale from a moveable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles) and the food is offered for sale by the same food business who packed it.
Food is considered prepacked when it is put into packaging before being offered for sale and:
- is either fully or partly enclosed by the packaging; and
- cannot be altered without opening or changing the packaging; and
- is ready for sale to the final consumer.
Examples of Prepacked Foods for Direct Sale (PPDS):
- Sandwiches placed into packaging by the food business and sold from the same premises
- Sandwiches placed into packaging for a school trip or sport event
- Foods packaged and then taken by the same operator to their market stall to sell
- A butcher who makes burgers or sausages which are prepacked to be sold on the same premises
- Foods packed by a food business to be sold in its retail units located within the same building complex as the premises where the food was packed such as a train station, hospital, university or holiday park.
How does this impact caterers?
The new law means caterers will need to consider how to label any foods packaged on site to ensure the information is accurate. Businesses will need to consider the implications of labelling specific allergens in situations where there is any risk of cross-contamination, such as in the ‘May Contain’ statements on labels. Current law requires businesses to manage cross-contamination risks effectively but recognises that where risk cannot be removed it is acceptable to communicate this to consumers. If stating a ‘may contain’ claim however, the possibility of a cross-contamination must be proven with a risk assessment. This is to stop businesses listing an allergen as ‘may contain’ to cover themselves.
What should caterers be doing?
- Make sure you are aware of all 14 allergens
- Educate and train your team on the legislation
- Plan an allergen and compliance audit
- Look at which foods currently served would fall into the PPDS category and therefore be included under the new law
- Consider how labelling would be done, in the most accurate but time effective way
- Consider if any of the PPDS products would have a risk of cross contamination and if a ‘May Contain’ statement is also needed in the label.
To read the full guidance, see the Food Standards Agency’s ‘Food allergen labelling and information requirements Technical Guidance’, published in June 2020.
How can allmanhall help?
- Catering controls platform – utilise a catering platform to improve analysis of ingredients in food through detailed allergen data. Combine this with a labelling supplier to print labels for your packaged foods
- Introducing sandwich suppliers
- Webinars and blogs – a variety of webinars and blogs to keep you up to date with Natasha’s Law and all other allergen legislation
- Training – our registered dietitian provides allergen training to make sure your staff are informed and up to date on the latest allergen legislation
- Resources – we supply a variety of allergen focused resources including checklists and information sheets that can support you in managing allergies
Looking to the future
The presence of allergies in our society has only increased over the years, with 1 in 4 of us now suffering from one. Therefore, it has never been more important for caterers to not only be aware of allergies but to be actively preventing allergy incidents everyday through careful practice. If you need further guidance on allergens please get in touch. Whether you are looking for allergen training for your team, support with the new labelling law or for any other support, allmanhall can help. Please call us on 01225 745520 or email us at email@example.com