Natasha’s Law is due to be implemented in October 2021. An important development in helping prevent the serious effects of food allergies, this law deals with labelling products that have been packed on premises ready for sale.
Who does it affect?
Any business that is
preparing, packing and selling food from the same premises, or food that is
packed centrally and sold from a mobile stall or vehicle
When does it come
October 2021 in
England, but other UK nations are expected to follow shortly after
What foods are
covered by the new law?
Any food which is
Pre-Packed for Direct Sale (PPDS); that means made by staff in-house, wrapped
or placed in packaging and then put on display. This could include products
like sandwiches, salads, snacks and cakes.
What must we do?
All PPDS products
will need to clearly display the name of the food and a full list of all
ingredients. Any named allergens (from the 14 named allergens list) must be
highlighted within the ingredients list, for example by printing them in bold
or a different colour.
What are the
penalties for non compliance?
to follow the new rules could face a fine of up to £5,000 per offence.
Any business who is selling or planning to sell pre-packed foods would be sensible to consider their operations and processes now, in order to allow all required changes to be in place and tested before October 2021. As well as considering the physical labelling requirements, food businesses will also need to think about staff training implications. Whilst the new law makes information more readily available and therefore easier for staff to communicate accurate information, a key message for all staff in food preparation is the importance of consistency in and clear communication of ingredients and recipes.
Every food business in the UK has a legal responsibility to:
make sure food is safe to eat
make sure it doesn’t add, remove or treat food in a way that makes it harmful to eat
A very important part of fulfilling this legal duty is creating a Food Safety Management system, using the principles of Hazard analysis and Critical control points (HACCP). HACCP is a system that helps you identify potential food hazards and introduce procedures to make sure those hazards are removed or reduced to an acceptable level.
These procedures will help you produce and sell food that is safe to eat, providing you:
keep up-to-date documents and records relating to your procedures
regularly review your procedures to ensure they reflect what you produce or how you work
Creating a HACCP Food Safety Management System
To create a comprehensive food safety management system, you will need to consider the entire journey of the food you produce, starting with the source of your ingredients and covering areas such as food handling, storage, cooking, cleaning and staff training.
A great resource to help you with this is the Safer Food, Better Business resource provided by the Food Standards Agency. This book walks you through each area of your business and tells you what you need to look out for, what records you need to keep, and how often you need to review your processes.
Safer Food, Better Business highlights the importance of good record keeping when producing food that is safe to eat. Good records will instil a culture of diligence within your food business and will also help prove to an EHO that you are doing things right.
The key records that most food businesses will need to keep are:
Delivery Schedule, showing that temperature, dates, packaging and labels are checked for all food deliveries
Ingredients listings, including the 14 listed allergens
For more information, The Safer Food Group offer a Level 2 HACCP awareness course that looks into each area of Food Management in closer detail, explaining how to get it right – and what can happen when you don’t!
You might think that getting your food business allergy safe is a hassle – but think about the consequences of being careless with ingredients that have the potential to kill. If you put the right processes and procedures in place and everyone follows them, you can be sure you are doing your best to keep your customers, your kitchen and your reputation safe.
Ensure that you have adequate food allergy training to fully understand the risks of allergenic ingredients and the best practice you must use to ensure a safe business. This is not as simple as just keeping peanuts out of your kitchen!
Step 2 – Ingredients Audit
Be aware of every ingredient that you use in your kitchen, whether cooked in house from individual ingredients or pre-prepared. For every element of every dish, make a list of all ingredients and highlight the 14 known allergens.
Tip: Don’t forget drinks, condiments and sauces – did you know that malt vinegar contains gluten, for instance?
Step 3 – Process walk through
Walk through the entire ‘life’ of a dish in your kitchen – from delivery, through storage, preparation, service and clean down, considering what would happen if an allergen was present in that dish. Identify points where cross contamination could occur, and how you can prevent it by measures such as:
Separated storage and prep zones for allergens
Clear identification of specially prepared meals during service
Efficient clean down and separate pot wash routines
You may decide that you cannot guarantee that allergenic ingredients can be eliminated from dishes – if that is the case, you must communicate this to your staff and customers, to allow them to make informed decisions about their food.
Step 4 – Write it down!
Once you’ve completed the walk through and decided what you will do to keep allergens isolated, you must write it down in a clear, logical way that can be followed by any team member involved in any stage of the process.
Once you have gathered all of the vital information, you have to pass it onto the relevant staff. Think about different roles in your business and their contact with allergens, as well as their contact with customers
Train your staff clearly in the processes they need to follow when working with allergenic ingredients. It is useful for front of house staff to have an understanding of food prep process, and food prep staff to understand how the front of house team operates. Create a culture in which they are happy to ask questions and seek advice if they don’t understand or have forgotten their training.
Think about how you retrain your staff when dishes, processes or legislation changes, and how often you refresh their training.
It is vital that you include allergen training in your induction programme for new and returning staff.
Consider the clearest ways in which you can communicate ingredients info to customers. It is a legal requirement to communicate the details of which dishes contain the 14 listed allergens, but some customers have allergies that are not covered by the list, and being able to inform them accurately of all ingredients in all dishes will help your reputation as a responsible business.
The key message for you and your staff when it comes to communication is NOT TO GUESS THE ANSWER TO AN ALLERGEN QUESTION. ’I don’t know’ is always an acceptable answer, if the member of staff then seeks out the correct piece of information. Teach your staff: