Preparing for Natasha’s Law
In a matter of months, the UK Food Information Amendment, more widely known as Natasha’s Law, will be introduced and it is essential that catering operations begin actively planning and preparing now. The change in allergen labelling follows the tragic death of teenager Natasha Ednan-Laperouse in 2016, after consuming a Pret A Manger baguette containing sesame. The new legislation requires that all prepacked for direct sale (PPDS) foods conform to current prepacked labelling requirements, with a full ingredient declaration, showing allergens highlighted. For more information on Natasha’s Law, visit our Natasha’s Law blog.
So how best to prepare? As food procurement experts and partners, allmanhall are supporting our clients in navigating this important legislative change. We have set out some key steps and questions to consider.
1) Do you have PPDS foods?
The first thing to identify is whether there is a need to adopt the new approach to labelling and, if so, how much of your range will be impacted. As a reminder, PPDS foods are:
- Prepared on-site.
- Individually packaged.
- Fully or partially packaged prior to selection.
- The packaging would have to be disturbed to access the food.
- Not pre-ordered.
Once PPDS requirements have been established, consider the following: could the PPDS range be reduced without increasing allergen risk to your consumers? What ingredients will be used and from which suppliers? Can they be streamlined?
2) Create PPDS recipes
To correctly label PPDS foods, the ingredients and allergens in each item need to be known, along with the quantities so that the ingredient declaration is in descending weight order. This will mean creating recipes for each PPDS item, which will also support the operational controls required to minimise risk.
3) Obtaining ingredient and nutrition information
Consider the process of obtaining information – will it be via a catering platform, the labelling system or on-pack? It is likely that it will be gathered from several sources and checking on-pack can ensure greater accuracy.
4) Labelling solution
In most cases a labelling solution is likely to be required, as the delivery of handwritten labels to the legislative standards may be quite challenging. Consider how the labelling solution works and fits into your new process. Also, what hardware is required, such as printers and where these will be located.
5) Identify risks
Allergen management is all about reducing risk to the end consumer. Walk through the journey from ordering products to a consumer selecting a PPDS item. Identify each risk point and establish an operational practice to manage those risks. For example, has a substitute product been sent in by a supplier? Has the allergen information changed on a supplier product? Has a member of the team not followed a recipe or used different products? Could members of the team confuse which labels are for which PPDS items?
6) Consider cross contamination risk – precautionary allergen labelling
Precautionary allergen labelling is where manufacturers cannot eliminate a risk of cross contamination and add a ‘may contains’ or ‘not suitable for’ statement to the label. This should now be considered in a catering environment, which is of course very different to a manufacturing site, with lots of opportunities for cross contamination. It is advisable that a thorough risk assessment is undertaken to establish cross contamination risk and this is then communicated, along with any supplier ‘may contains’. It is important to note, that ‘may contains’ should only be used if a real and genuine risk has been established.
7) Trial and train
As this is a change in operational practices, it may be wise to trial the new process so that you and your team all feel comfortable that it will be delivered effectively from October. In addition, dedicated training would be advisable to support delivery and compliance. Please do contact allmanhall if you would like us to provide you with any training. In addition to our food procurement expertise, we provide training and a number of other consultative services to support your foodservice operation.
Consider engaging with your local EHO, sharing how you will be approaching meeting the new legislation to obtain their feedback before October.
There are concerns that, through the labelling of PPDS foods, consumers may presume they are selecting a bought-in product and valuable communication with the catering team regarding allergies will therefore not take place. Consider displaying posters or adding a sticker to your PPDS foods to highlight that they are made on site and that customers should speak to the catering team regarding their allergies.
10) Ask for support!
allmanhall are supporting our clients in their preparations for Natasha’s Law. In addition to information pieces like this and our previous blog, there are a range of solutions that can be adopted. Via our client portal, The Pass, we will be providing a range of support resources over the coming months, such as checklists and toolkits. Our Natasha’s Law webinar, broadcast in April, can be viewed here. Do get in touch if there is anything you need support with or more information on.