Natasha’s Law in health and care settings

What does your setting need to do?

The UK Food Information Amendment – Natasha’s Law – came into force in October 2021. An important development in helping prevent the serious effects of food allergies, this law amendment deals with labelling products that have been packed on premises ready for sale. It was brought into force to strengthen the 2014 Food Information to Consumers legislation, and followed a period of dedicated campaigning by the parents of Natasha Ednan-Laperouse, who tragically lost her life after eating a sandwich containing the allergen sesame. At the time, foods prepared in house and packaged for later sale were not required to be labelled individually.

What is Natasha’s Law and who does it affect?

Natasha’s law applies to any business or food operation that is preparing, packing and then later selling food from the same premises, or from a mobile stall or vehicle. This includes: cafes and coffee shops, takeaway and fish & chip restaurants, sandwich shops, farm shops, as well as work, school and hospital canteens. Voluntary and charity organisations who undertake fundraising events such as bake sales will also need to consider how they package their goods and whether they need to apply the new rules.

How does Natasha’s Law apply in a care or health setting?

Within care and health settings many foods are prepared and served directly to residents and patients – the new rules do not apply to these foods, although they will be covered by existing food safety regulations, including those relating to allergens. Some settings prepare, sell and distribute meals to customers off-site (e.g. ‘Meals-on-wheels’ services); these will typically be covered by regulations for distance selling of food. Where settings prepare and pre-package food for sale to customers – for instance to visitors to their café or restaurant – they will need consider Natasha’s Law and how to apply the correct labelling to those foods.

When does it come into force?

Natasha’s law was created in September 2019, and came into force in October 2021 throughout the UK.

What foods are covered by Natasha’s law?

Any food which is Pre-Packed for Direct Sale (PPDS); that means prepared in-house, wrapped or placed in packaging, ready for the customer. This includes food that customers select themselves, as well as pre-wrapped items that are kept behind a counter.

What are PPDS foods?

Examples of PPDS items include:

  • Sandwiches, pies, burgers, ready meals or cakes/baked goods prepared and packaged by a food business before the consumer selects them
  • Foods prepared and packaged and sold at a market stall
  • Wrapped deli counter goods such as cheese and meats, and boxed salads placed on a refrigerated shelf prior to sale
  • Freshly made pizza or boxed salads from a supermarket deli counter which are packed on site and refrigerated prior to sale
  • Mixed bags of sweets which are made up, packaged and sold on the same premises or from a mobile unit such as an ice cream van.

For further help, use this tool created by the FSA.

What must we do?

All PPDS products will need to be clearly labelled with 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, italics or a different colour. An exception to this rules is products with a surface area of less than 10cm2 – if this applies to your products, have a look at the FSA website to understand your responsibilties.

What are the penalties for non compliance?

Businesses failing to follow the new rules could face a fine of up to £5,000 per offence. But more importantly, the damage to the reputation of your business if a serious allergy incident occurs is almost impossible to calculate.

What else should I think about?

The death of Natasha Ednan-Laperouse highlights the importance of food allergen awareness within all food businesses and operations. As well as considering the physical labelling requirements, food businesses should also take this opportunity to think about their production process and staff training implications. It is vital that your food operation has a clear allergen policy, which allows both staff and customers to understand any risks that are present to allergy sufferers. Staff must fully understand any processes that they are expected to undertake when creating meals that fulfil any allergy-free claims you make, and those who communicate with customers must be able to do so truthfully and confidently.

All Safer Food Group training courses that contain allergy awareness advice include guidance on Natasha’s Law – and our all new Level 2 Allergy Awareness course for food handlers has been entirely updated and relaunched in September 2021, to comprehensively cover this subject.

Whilst Natasha’s law makes information more readily available and therefore easier for staff to communicate accurate ingredients information, the key message for all staff in food preparation is the importance of consistency in and clear communication of ingredients and recipes. Allergen training, whether in-house or with certified training courses, is a vital step in keeping your customers, staff and your business safe.

Preparing for Natasha’s Law

Is your business ready?

The UK Food Information Amendment – Natasha’s Law – will come into force 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. It was brought into force to strengthen the 2014 Food Information to Consumers legislation, and followed a period of dedicated campaigning by the parents of Natasha Ednan-Laperouse, who tragically lost her life after eating a sandwich containing the allergen sesame. At the time, foods prepared in house and packaged for later sale were not required to be labelled individually.

What is Natasha’s Law and who does it affect?

Natasha’s law applies to any business that is preparing, packing and then later selling food from the same premises, or food that is packed and then sold from a mobile stall or vehicle. This includes: cafes and coffee shops, takeaway and fish & chip restaurants, sandwich shops, farm shops, as well as work, school and hospital canteens. Voluntary and charity organisations who undertake fundraising events such as bake sales will also need to consider how they package their goods and whether they need to apply the new rules.

When does it come into force?

Natasha’s law was created in September 2019, and comes into force in October 2021 throughout the UK.

When will Natasha’s Law apply in Scotland, Wales and Northern Ireland?

Scotland, Wales and Northern Ireland authorities have confirmed that the law will be adopted throughout the whole of the UK from October 2021.

What foods are covered by Natasha’s law?

Any food which is Pre-Packed for Direct Sale (PPDS); that means prepared in-house, wrapped or placed in packaging, ready for the customer. This includes food that customers select themselves, as well as pre-wrapped items, kept behind a counter.

What are PPDS foods?

Examples of PPDS items include:

  • Sandwiches, pies, burgers, ready meals or cakes/baked goods prepared and packaged by a food business before the consumer selects them
  • Foods prepared and packaged and sold at a market stall
  • Wrapped deli counter goods such as cheese and meats, and boxed salads placed on a refrigerated shelf prior to sale
  • Freshly made pizza or boxed salads from a supermarket deli counter which are packed on site and refrigerated prior to sale
  • Mixed bags of sweets which are made up, packaged and sold on the same premises or from a mobile unit such as an ice cream van.

For further help, use this tool created by the FSA.

What must we do?

All PPDS products will need to be clearly labelled with 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, italics or a different colour. An exception to this rules is products with a surface area of less than 10cm2 – if this applies to your products, have a look at the FSA website to understand your responsibilties.

What are the penalties for non compliance?

Businesses failing to follow the new rules could face a fine of up to £5,000 per offence. But more importantly, the damage to the reputation of your business if a serious allergy incident occurs is almost impossible to calculate.

What else should I think about?

The death of Natasha Ednan-Laperouse highlights the importance of food allergen awareness within all food businesses. Any business that sells or is 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 their production process and staff training implications. It is vital that your business has a clear allergen policy, which allows both staff and customers to understand any risks that are present to allergy sufferers. Staff must fully understand any processes that they are expected to undertake when creating meals that fulfil any allergy-free claims you make, and those who communicate with customers must be able to do so truthfully and confidently.

All Safer Food Group training courses that contain allergy awareness advice include guidance on Natasha’s Law – and our all new Level 2 Allergy Awareness course for food handlers has been entirely updated and relaunched in September 2021, to comprehensively cover this subject.

Whilst Natasha’s law makes information more readily available and therefore easier for staff to communicate accurate ingredients information, the key message for all staff in food preparation is the importance of consistency in and clear communication of ingredients and recipes. Allergen training, whether in-house or with certified training courses, is a vital step in keeping your customers, staff and your business safe.

What is a Food Safety Management System / HACCP?

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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:

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!

Important Links

Free 14 allergens poster

How do I keep my restaurant allergy-safe?

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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.

So, what are the steps you need to follow to make your kitchen allergen safe? This list is not a comprehensive guide – you must ensure that you are properly trained to implement a successful allergen policy in your business – but it is written to show you that making your business allergen proof is logical and achievable, and shouldn’t be intimidating.

Preparation

Step 1 – Understanding

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 
  • Specific equipment 
  • 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.

Training

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.

Communication

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: