Spurred on by the amazing campaign that Natasha Ednan Laperouse’s parents have fronted since the inquest’s findings into Natasha’s death, the Food Standards Agency/DEFRA have been remarkably speedy in getting out a consultation on how to move forward. The question is how feasible are any of the options – and will they work?….
The consultation is offering four which run from better training for food service operatives to full ingredients labelling for all ‘pre-packed foods for direct sale’ or PPDS – e.g. any food, like the Pret baguette that killed Natasha, that has already been packaged up before it is sold, no matter what the outlet.
With the exception of option 3, all are desirable – the question is, how feasible are they to implement – and will they work? So…
Option 1 – Better training and greater awareness
Or, as the consultation puts it, ‘promoting best practice’. This they see as:
- Best practice guidance for the catering sector to be produced by the FSA and FSS (Food Standards Scotland) and made available to all local authorities.
- Cross-stakeholder conference with businesses hosted by Defra, FSA and FSS to discuss best practice and encourage change without a legislative change.
- Public information campaign to highlight allergen knowledge and awareness for food businesses and the general public.
Yes, all totally desirable and, as they point out, relatively quick and easy to implement – well, at least to offer. If for no other reasons that they would not be regulatory so much quicker to get up and running. But….
To what extent will local authorities actually be able to make use of the guidance, given that virtually all Environmental Health and Trading Standards departments are already severely understaffed and over worked ?
And will a public information campaign actually ‘get through’ to either/both food businesses and the general public? Public information campaigns can work. I can still see the image of the girl in the pale blue silk party dress with her face all slashed with windscreen glass and the tag line ‘I did not want to crush my party dress’ that fronted the ‘use your seat belt’ campaign 30 years ago. But that was an exception. Normally public information campaigns remain well below most peoples’ radar.
So, totally desirable but efficacious? I doubt it.
Option 2 – Mandatory ‘ask the staff about allergens’ labels on all PPDS foods.
Yep – another good idea. And also relatively quick, cheap and easy to roll out.
It would certainly help to raise awareness of the problem with both food service operatives and allergy sufferers. However, you are still left with the issue of whether the staff who are asked about allergens are able to answer the question correctly – and therefore safely.
However, it does avoid the risk inherent in the last two ‘declare allergens/ingredients on pack’ options: that the outlet will get the information wrong! Given the level of ignorance within food service about allergens, this is a significant risk.
So yes, a good idea and definitely worth implementing, but only stands a chance of making a serious difference if combined with very much better allergy training of all food service operatives.
Option 3 – Any of the 14 major allergens in the food to have to be declared on an on pack label.
In theory this would be cheaper and easier for food services to implement than full ingredients labelling but it would still be expensive and confusing with a strong likelihood (again, given the level of allergen ignorance in food service) that that they will get it wrong.
Moreover, it overlooks the problem that although the 14 ‘major’ allergens are the most common, anyone can be allergic to any food so it will not help anyone who has a life threatening allergy to corn, or bananas, or capsicums or any other food not on the list of 14.
So, really not.
Option 4 – Full ingredients labelling on all PPDS foods
This would obviously be the gold standard and is what allergy sufferers are calling for. It would also have the virtue of standardising practice across the food industry as that is what is required on packaged food. However, as the consultation points out, it definitely does not come without problems.
Since labels will have to be added on the premises, as the foods are made, they will add significantly to the work and therefore the cost of offering PPDS foods – quite possibly putting some smaller operations out of business.
And of as much concern in this context and given the poor understanding of allergy in food service, what chance is there that they will get them right? Talking to nut allergy sufferer Justyn Page (of whom more anon) who was put into anaphylactic shock by cashew nuts in a milk shake because the guy making the milk shake thought ‘cashews aren’t nuts’ – who will trust an in-house generated label in a relatively small café or eatery?
But, not all of those selling PPDS food are small operators – Pret certainly aren’t! So it seems to me that there is room for a fifth option which would close the loophole which allowed Pret to serve the baguette that killed Natasha.
Option 5 – All operations OVER A CERTAIN SIZE should be required by law to include full ingredients labelling with all PPDS foods that they sell.
Although larger operators, such as Pret, may (at least sometimes) make foods on the premises, they are large enough to be able establish better training and better control systems which should ensure that the information that they provide on pack is accurate. There will be an extra cost involved, but a cost that they should be able to absorb without too much pain – especially if it enabled them to avoid the opprobrium and the reputational damage that will come their way if another Natasha episode were to occur.
Smaller operators would not be required to carry full ingredients labelling but they would be required to carry the ‘ask about allergens’ stickers and would hopefully, at least attempt to improve their training as far as allergy is concerned.
So for me, it would be ‘yes’ to options 1 & 2 plus my option 5.
Have your say – how to respond
However, not what I say, but what you have to say. DEFRA/FSA would like lots of responses and ‘encourage respondents to provide not just their opinions but also the supporting facts and reasoning to inform the evidence base for the development of final proposals’.
Respondents do not have to answer all the questions and so can choose those of specific interest. Questions which you do not wish to respond to can be left blank. The consulation is open until 29 March 2019.
Please respond through the online survey (Citizen Space).
If you cannot respond online, you can request a copy of the survey and a response form by emailing allergenlabellingreview@defra.gsi.gov.uk. Queries and completed surveys can also be sent there.
Alternatively you can respond via post at the addresses below, specifying which question(s) you are responding to:
Allergen Labelling Review Team, Defra, Room 202, Zone 2, 1-2 Peasholme Green, York YO1 7PX
Through experience I find that it is not just the Included allergens that are the problem. Cross contamination is just as big an issue as the ingredients and this needs to be addressed as well as ingredient labelling.
Interesting that nurseries can still legally sell the most allergenic trees possible. People can then buy them and plant them right on their fence-line, right next to your house. Because of cross-reactivity, many, perhaps most, food allergies are initially triggered by over-exposure to some type of allergenic pollen (probably home-grown in the landscape)..
As of yet, there are NO laws at all that say that nursery plants must be labeled per their potential to trigger allergy. This is a serious mistake….and don’t count on horticulture to do this on their own.
I learned recently that staff in a pharmacy who are behind the counter and go and get the already-made-up-by-a-pharmacist prescription and hand it to the patient need to have received special training. They are not just someone employed as a shop assistant as if in an ordinary shop.
So making each outlet have a qualified allergy adviser on the staff should be made a requirement. Maybe there should be a uniform, with a distinctive colour, like the way that staff nurses wear a different colour uniform than healthcare assistants, and sisters wear another colour. That way the public would know that the person in that colour uniform is the allergy adviser at that outlet.
Yes, it would cost money, but each outlet would need to do it, and the person could do other work as well. Yet lots of things that are done in society cost money, like having doctors and nurses and hospitals, and registering dentists, yet society does it because society thinks it worthwhile..
I remember a story from years ago. Apparently when instant mashed potato was first launched years ago there was concern that the manufacturing process destroyed (some or all?) of the vitamin C in the potatoes and that that could lead to vitamin deficiency as the product was becoming widely used as a staple food. So manufacturers all agreed to add vitamin C to the product. It cost money, but it did not distort the market as each manufacturer did it.
Likewise, having a qualified allergy adviser on the staff would cost money, yet each outlet would need to have one, or more for a big outlet. Certainly some outlets are bigger than others, but maybe there could be a government subsidy for the cost paid by a levy on all outlets according to size.
William Overington
Monday 28 January 2019