Any food has the potential to cause an allergic reaction, but by law, food businesses must inform customers if any food they provide contains one or more of the 14 allergens that are named in the legislation. These 14 are those that most commonly cause allergies.

The list includes:

• Celery

• Cereals containing gluten, like wheat, spelt, rye, barley, and oats

• Crustaceans such as prawns and lobster

• Eggs

• Fish

• Lupin

• Milk

• Molluscs like mussels and clams

• Mustard

• Peanuts

• Sesame

• Soybeans

• Sulphur dioxide and sulphites (if present at more than 10 parts per million)

• Tree nuts such as walnuts, almonds, cashews, hazelnuts, pecans, Brazil nuts, and macadamia nuts.

Important reminder: just because the word nut appears in the name of a food, it doesn’t mean it’s a tree nut. For example; pine nuts, coconut and nutmeg are not tree nuts.

Additives, processing aids, or other substances

These rules also apply when allergens are used as additives, processing aids, or other substances, when they are present in the final product.

Additives and processing aids are substances that aren’t consumed as foods themselves but are used in production for a specific purpose, like preserving, stabilising, colouring or helping ingredients mix together. For example, soya lecithin is commonly used as an emulsifier. It helps oil and water blend smoothly and can be found in products like chocolate, margarine, and salad dressings.

It’s worth noting that most people with a soya allergy can tolerate highly processed products such as soya lecithin. However, clear labelling and providing clear and accurate information to a customer is essential so that that they can make an informed decision.

Some substances are used during processing and treatment but may still leave traces in the final product. For example, egg white, or albumen, is sometimes used as a processing aid in wine or fruit juice. Even though it’s not added as an ingredient, traces of egg protein can remain, and because egg is one of the 14 named allergens, it must be declared if present in the final product.

A final example is dried fruit preserved with sulphites. If that dried fruit is used to make chutney (for example), the sulphites may still be in the final product, even if no sulphites were added during preparation.

Allergens can be easy to overlook and can be found in some unexpected places. Let’s take a closer look at each of the 14 named allergens.

• Celery includes the leaves, stalks, seeds, celeriac, and celery salt. It can also be found in some meat products, soups, powdered soups, and stock cubes.

• Cereals containing gluten include wheat, rye, barley, oats, spelt and Kamut. They’re often found in bread, pasta, cakes, pastries, batter, and soups or sauces thickened with flour, sausages due to rusk or breadcrumbs used as binders, foods that have been dusted with flour before cooking, some spice mixes, stock cubes, and even flavoured crisps.

• Crustaceans such as prawns, lobster, langostine, crab, scampi and any pastes (i.e. shrimp paste) make from these. Note: if you use eco straws, they may contain chitosan. It’s often extracted from crab or prawn shells. This means eco straws containing chitosan could trigger an allergic reaction in people with a crustacean allergy.

• Eggs are commonly found in pasta, quiche, cakes, mousses, and mayonnaise. They may also be used to glaze pastries or pies, in sauces such as Hollandaise, or to bind items like burgers. Egg white is also used in royal icing.

• Fish can turn up in more places than you might expect. Fish sauce is often used in sauces, stir fries, and marinades. Fish can be found in some salad dressings. For example, Caesar dressing may contain anchovies. Worcestershire sauce also contains fish, and occasionally, so does soy sauce. And don’t forget pizza toppings.

• Lupin may be labelled as lupin, lupine, lupin flour, lupin seed, or lupin bean. It’s a legume, just like peanuts, lentils, and soybeans. The seeds, known as lupin beans, are ground into a flour that’s used in a range of products. It’s used more often in European foods like bread, pastries, and the batter for onion rings or fried chicken. It’s also becoming more common in gluten-free, high-protein, or low-carb products.

• Milk is found in obvious products like cheese, butter, cream, and yoghurt. It may be brushed onto pies, pasties, and pastries before baking. Milk powder is used in a wide range of products, including baked goods, desserts, ice cream, and cereal bars. Watch out for whey powder, which is derived from milk, and don’t forget items coated in or containing chocolate or even some mayonnaise, which can include milk-based ingredients.

• Molluscs include clams, mussels, oysters, squid and snails. Oyster sauce is a common ingredient in marinades and stir fries.

• Mustard includes the seeds, mustard and cress, mustard powder, and liquid mustard. Mustard is often found in pickled foods such as gherkins and onions, piccalilli, sauces such as mayonnaise, barbecue sauce, and ketchup, marinades, salad dressings, curries, soups, and stock cubes.

• Peanuts can appear under different names including monkey nuts, groundnuts, or even arachis. For example, arachis oil, is another name for peanut oil and so is groundnut oil. Other forms include peanut flour and groundnut flour. Peanuts are found in a range of products, including Asian and Indian dishes, cakes, desserts, and sauces.

• Sesame includes the seeds and sesame oil. Sesame is often found in breads, breadsticks, hummus, tahini, and sprinkled over dishes or used in Asian foods and stir fries.

• Soybeans include the beans themselves, as well as edamame, which are the young, green soya beans. They’re used to make a wide range of products like soya protein, soya flour, soy sauce, miso paste, tofu, and tempeh. Cooking oil can also contain soya. You’ll often find soya in chocolate too, usually as soya lecithin, which helps bind ingredients like cocoa solids and cocoa butter. Soya flour is used to improve the texture of bread, and it can be found in cakes, biscuits, and even burgers. You may be interested to know that roughly 60% of manufactured products contain soya!

• Sulphur dioxide and sulphites are used to preserve dried fruits, vegetables, and meat products like sausages and frozen prawns. They’re also used in wine, beer, and fruit juice. They must be declared when present above 10 parts per million.

• Tree nuts include walnuts, almonds, cashews, hazelnuts, pecans, macadamia and pistachios. They’re used in all sorts of products including bread, crackers, baked goods and desserts. It’s also important to watch out for nut oils and any products made with them, as well as ingredients like marzipan and ground nuts, such as ground almonds. While not directly related to food, be aware of hand creams and toilet tissues that can contain tree nuts. In hand creams and cosmetics, these may sometimes be found under the Latin name e.g. Prunus Amygdalus dulcis.

When checking for allergens, check product labels and ingredient lists thoroughly. UK law requires allergens to be clearly listed, usually in bold, so that they’re easy to spot.

Myth busting

Is coconut a tree nut? No. Coconut is a fruit.

Are pine nuts tree nuts? No. Pine nuts are the edible seeds of the pine tree.

Are peanuts tree nuts? No. Peanuts are legumes which is why they are separate in the 14 named allergens list.

Is nutmeg a tree nut? No. Nutmeg is a spice.

Remember: Not all foods containing the word “nut” are tree nuts. If a customer says “I have a nut allergy”. Make sure you clarify with them exactly what they’re allergic to.

Other allergens

While legislation focuses on the 14 named allergens, people can be allergic or intolerant to other ingredients too. Allergies to lentils, fenugreek, cumin, peas, chickpeas and kiwis are becoming more and more common. These allergens probably won’t be highlighted on menus or packaging. If a customer asks about a specific ingredient, you should check the full ingredients list, where possible, and refer to packaging or supplier information.

If it’s not possible to provide accurate information for allergens outside of the 14 named in the legislation, for example, when using unlabelled non-prepacked ingredients from another business, the customer must be informed of this, so they can make an informed decision.

In the UK, making a ‘free-from’ claim is voluntary but if a food business chooses to make one, it must be absolute. That means the allergen must be completely absent from the product. Any ‘free-from’ claim must be backed by a thorough risk assessment, with strict controls in place so there is no chance of cross-contamination with the allergen. More detailed guidance on free-from claims is available from the Food and Drink Federation.

‘Gluten-free’ and ‘very low gluten’ claims

Under the law, there are only two allowed claims or statements when it comes to gluten:

‘Gluten-free’ means the food contains 20 parts per million (ppm) or less of gluten.

‘Very low gluten’ means the food contains 100 ppm or less of gluten. The ‘very low gluten’ claim can only be made in manufactured foods where the cereal ingredients have been specially processed to remove the gluten. E.g. use of codex wheat where gluten is removed.

Any other wording, like “low gluten” or “gluten-friendly”, isn’t permitted.

If a business wants to label a manufactured product as gluten-free or very low gluten, they must be able to prove the claim through testing.

Even if a product is labelled as ‘gluten-free’ or ‘very low gluten’, the original cereal (i.e. wheat) will still be present and as such must still be declared as an allergen for those with a wheat allergy (for example), because it’s one of the 14 allergens.

This is where it becomes crucial to understand the difference. A gluten-free product may be safe for someone with coeliac disease or gluten intolerance, but not for someone with an allergy to a cereal containing gluten, such as a wheat allergy or barley allergy. That’s because food allergies can be triggered by even the tiniest trace of the allergen.

For example; barley malt vinegar in a pickle may contain less than 20 parts per million (ppm) of gluten, potentially making it safe for someone with coeliac disease or gluten intolerance, but it could still cause a reaction in someone with a barley allergy. As always, the context matters, and team members need to be confident in checking labels and giving accurate information to customers.

Vegan food and allergens

Just because a food is labelled vegan, that doesn’t mean it’s free from animal-based allergens. Traces of milk, egg, fish, crustaceans, or molluscs can still be present, especially if the product was made in a factory that handles non-vegan food. That’s why you’ll often see ‘may contain’ warnings on vegan products. This is really important for customers with food allergies or food intolerances.

Remember: ‘Vegan’ does not mean allergen-free. Always check the label, even if the product is plant-based.

In this video, we explore the key legal requirements that apply to allergens, starting with the general food safety legislation, and then the laws that relate specifically to allergen information.

General food safety legislation

Food Safety Act 1990

Section 7: it’s an offence to render food injurious to health by adding any article or substance to the food. For example; adding milk powder to a dish labelled as “dairy-free” or “milk-free” without declaring it. This could make the food harmful if it’s consumed by someone with a milk allergy.

Section 14: it’s an offence to sell food which is not of the nature, substance, or quality that a customer would expect. In relation to allergens, an example could be if a customer orders food without a specific allergen, and it still contains that allergen. For example, a customer has an allergy to egg and asks for an egg-free chicken burger, but they are served a burger where the mayonnaise used contains egg. That would not meet the customer’s expectations, and it could be dangerous.

Section 15: it’s an offence to provide food that’s labelled, advertised, or presented in a way that is false or misleading. Mis-leading verbal communication and menu descriptions could also be included here.

Regulation (EC) No. 178/2002 (retained in UK law post-Brexit)

Article 14: food must not be placed on the market if it is unsafe. That includes food that could be harmful to a specific group such as people with food allergies, where the food is intended for them. For example, if a product is sold as “mustard-free” but actually contains mustard, that food would be considered unsafe.

Regulation (EC) No. 852/2004 (retained in UK law post-Brexit)

Article 5: food businesses must identify hazards and implement effective control measures as part of their food safety management system or HACCP system. This includes the specific risks posed to food hypersensitive customers and the risks of allergen cross-contamination.

Allergen- specific legislation

Regulation (EU) No. 1169/2011 on the Provision of Food Information to Consumers (often referred to as FIC).

This regulation has been carried into UK law through the Food Information Regulations 2014, and it’s enforced by local authorities. It requires food businesses to highlight the presence of any of the 14 named allergens and to ensure allergen information is accessible and accurate. The way allergen information must be provided depends on which category the food falls into.

The Food Information (Amendment) (England) Regulations 2019 (known as Natasha’s Law)

Natasha’s Law applies specifically to prepacked for direct sale (PPDS) foods. PPDS food must have a label on the packaging, or attached to it, that includes: the name of the food, and a full ingredients list, with any of the 14 named allergens emphasised, usually in bold, capitals, or a different colour. We’ll go into more detail on PPDS requirements, along with the other food categories in the videos that follow.

Allergen information on the named 14 allergens is always required, the only thing that changes is how the information must be communicated, depending on the type of food.

In this series of videos, we’ll look at the four categories:

• prepacked food

• prepacked for direct sale (PPDS)

• non-prepacked (loose) food

• distance selling.

For each one, we’ll look at:

• what it means

• some examples

• how allergen information must be communicated to customers.

Prepacked food

Let’s start with prepacked food.

Prepacked food is food that is normally manufactured and:

• Placed into packaging before being offered for sale, and

• Is fully or partly enclosed by the packaging,

• Cannot be altered without opening or changing the packaging, and

• Is ready for sale to the final consumer or a mass caterer.

If it’s sealed up and ready to go, that’s prepacked.

Examples of prepacked food

Most prepacked foods are sold in retail settings, such as supermarkets and convenience stores or supplied by your food service wholesalers. Examples include dried foods, frozen foods, tinned foods, ready meals, prepacked sandwiches, packaged snacks such as crisps, biscuits, sweets, and chocolate bars.

How must allergen information be provided?

For prepacked food, allergen information must be included in the ingredients list. That ingredients list must:

• Be clearly titled, usually with the word ‘ingredients’

• List the foods in order of weight.

• If one or more of the 14 named allergens are present in the food, they should each be emphasised in a way that makes them stand out from the rest of the text. That might be bold type, CAPITAL LETTERS, italics, underlining, or a different colour.

• If an allergen appears more than once, it must be emphasised every time it appears in the list. For example, if a product contains milk in two separate ingredients, both mentions must be highlighted clearly.

• May contain statements for any of the 14 named allergens is voluntary and can/ will appear in a separate statement or box on the packaging.

The requirements for Prepacked for Direct Sale food, also known as PPDS were introduced in the UK in 2021, through Natasha’s Law. Natasha’s Law requires that all prepacked for direct sale (PPDS) foods carry a full ingredients list with emphasised allergens so that food hypersensitive customers have clear and accurate information to make safe food choices.

This was following the tragic death of 15-year-old Natasha Ednan-Laperouse, who suffered a fatal allergic reaction in 2016 after eating a baguette that contained undeclared sesame seeds. The food had been prepared and packaged on-site at a Pret a Manager outlet and was not required at the time to carry full ingredient and allergen labelling.

What is Prepacked for direct sale (PPDS)?

PPDS food is food that is:

• Packed before being offered for sale

• Packed by the same food business* that is selling it

• And sold to the final consumer

For it to count as PPDS, the food must be completely or partially enclosed in packaging, and that packaging must prevent the food from being changed without opening or altering it.

If a food business packs food on-site, in advance of a customer placing an order, that food is likely to be PPDS.

*Same food business means:

• On the same premises

• On the same site (i.e. a building complex such as shopping centre, exhibition centre or airport terminal where the same food business operates from more than one unit in the building complex).

• On other premises if the food is offered from sale from a moveable and/or temporary premises (i.e. market stall, mobile food truck etc) and the food is offered for sale by the same food business who packed it.

Examples of what is and isn’t PPDS:

Let’s explore a couple of scenarios:

1. A hospitality business called ‘Top Hospitality’ is the hospitality provider in a large events venue.

PPDS: They prep sandwiches in a central kitchen, pack them in sealed boxes, and deliver them to their own smaller units around the venue, where the sandwiches go into display fridges where customers can help themselves. That’s PPDS, because the food was packaged in advance, on-site, and by the same food business.

Not PPDS: Top Hospitality bakes fresh cinnamon buns and delivers them on trays to those same units within the exhibition centre. The buns are left unpackaged until a customer walks up, orders one, and a team member bags it up. That’s not PPDS because the food wasn’t prepacked in anticipation of an order.

1. A cake maker, called ‘Cake Me Home’.

On a Friday, they slice and pack cakes into sealed packaging or containers at their production kitchen, ready to take to sell at their Saturday market stall. That’s PPDS, the cakes were packed before sale, by the same business, even though the food is sold somewhere else. But if the same cake maker brings unpackaged cakes to the market stall and only bags them up when the customer places an order, that’s not PPDS.

Some more examples of PPDS foods

• Sandwiches, bakery products, cakes, salad pots, pasta pots, packed on-site and sold from the same location.

• Packaged food samples given away by a bakery that made them on the premises.

• A butcher who pre-packs sausages or burgers for sale in their own shop.

How must allergen information be provided?

PPDS food must be labelled just like prepacked food. The packaging must include (or have a label attached to it) that includes:

• The name / description of the food.

• A full ingredients list, in weight order, with any of the 14 named allergens clearly emphasised in a way stands out clearly from the rest of the ingredients. For example, bold text, CAPITAL LETTERS, a different colour, or underlining.

• If an allergen appears more than once in the list, it must be highlighted each time.

• ‘May contain’ statements of the 14 named allergens can be listed in a separate statement but there should not be ‘contains’ statements.

Still not sure if it’s PPDS?

Ask these 3 questions:

1. Is the food packaged when the customer sees it? This means a single item (the food and its packaging) presented to the consumer and the food is completely or partially enclosed and cannot be altered without opening or changing the packaging. If yes, it’s prepacked. If no, it’s non-prepacked.

2. Was it packed before the customer ordered it? If yes, it’s prepacked. If no, it’s non-prepacked.

3. Was it packed by the same business that is selling it, either on-site, or from a mobile unit or stall? If yes, it’s PPDS.

If the answer to all three is yes, the food is Prepacked for Direct Sale.

What are non-prepacked foods?

Non-prepacked foods are foods that aren’t packaged before being offered for sale.

They include:

• Foods sold loose in retail settings, like supermarkets and deli counters.

• Foods that are prepared and served on request such as meals in a restaurant or from a takeaway.

• Foods that are packed on the premises at the customer’s request, such as a sandwich made to order.

How must allergen information be provided?

For non-prepacked foods, allergen information must be available for each food item that contains any of the 14 named allergens.

The law allows this information to be given in any format, in writing or verbally, but the customer must be clearly signposted to where they can get it. If allergen information isn’t printed directly on a menu or display board, there should be a clear notice telling customers to speak to a team member for allergen information.

While giving allergen information verbally is legally acceptable, the Food Standards Agency’s best practice guidance recommends that allergen information is available in writing and backed up with a conversation.

What is Distance selling?

Distance selling is when food is sold without any face-to-face contact with the customer.

Examples include:

• Takeaway meals ordered online or by phone

• Recipe boxes

• Click-and-collect services

• Food sold through online marketplaces, like Instagram, Facebook, or eBay.

How must allergen information be provided?

For distance selling, allergen information must be provided at two key stages:

1. It must be available to a customer before the order is completed. That might be on a website or app, an online menu or in a printed catalogue, or given verbally, for example, during a telephone order.

2. At the point of delivery. The moment the food is delivered, allergen information must be provided again. This could be in writing such as on allergen labels or stickers, as part of the menu or receipt, or verbally (i.e. a follow-up phone call to confirm allergen details).

It is considered best practice to provide allergen information in writing at some point in the process and ideally both before the order is placed and when it’s delivered.

Any dishes that have been prepared to be free of a particular allergen(s) must be clearly identified i.e. through the use of a sticker on the container.

Product specs, delivery notes, labels and recipes can help when it comes to collating allergen information and providing it to customers.

Product Specifications (Specs)

Product specs are like a food’s CV, they tell you what’s in the product, how to store it, and most importantly for us, which allergens it contains. Specs often come from the supplier or manufacturer and are vital when you’re building allergen-safe recipes, updating your allergen matrix or verifying ingredient changes. For example, a spec sheet for mayonnaise might list milk and mustard as allergens, which are not necessarily expected and details you wouldn’t necessarily know just from the product name.

If you’re responsible for managing allergens, make sure you have up-to-date specs for every ingredient you use. Don’t forget suppliers can and do change ingredients, often without big red warnings. So, review product specs regularly.

Product labels

In terms of product labels, every pre-packed item should have a clear ingredient list, and any of the 14 named allergens must be highlighted, usually in bold. Suppliers may update ingredients, sometimes without obvious notice. Always double-check labels and ingredient lists when new stock arrives, even if it’s something you’ve ordered many times before.

Delivery notes

Always confirm that what was delivered matches what was ordered. If your supplier has sent a substitute, that product might contain different allergens. For example, you might usually use a gravy mix with no milk or celery. But the substituted version from another brand could contain one or both.

Recipes

Recipes must be, accurate, up to date and most importantly, followed. That means no guessing, no freestyling because even a small tweak, like switching sauces or adding a garnish, can introduce a new allergen and put someone at risk. Remember to document specials recipes too, for future use or if you need to check after an issue has occurred.

How do you check a recipe?

Start with the written recipe or spec sheet. Ideally, these should be stored in a shared folder, recipe binder or a digital kitchen system. Then check each ingredient against your allergen matrix or product specs to confirm that what you’re using matches what’s listed. If a recipe changes, whether it’s a planned update or a last-minute change, the allergen info must be updated too. Then, make sure that information is shared with everyone who needs to know including the kitchen, front-of-house and anyone else handling allergen enquiries.

Precautionary allergen labelling (PAL)

Precautionary allergen labelling is when a food business adds a statement to a product label such as, “May contain…”, “Produced in a kitchen that also handles…” or “Not suitable for…”. PAL is used to warn customers about the unintentional presence of allergens, this is usually from cross-contamination or cross-contact as it’s also referred to, during production. Essentially, the allergen wasn’t added deliberately, but there’s still a chance it could be in the product or dish.

When should PAL be used?

Precautionary allergen labelling must not be used just to “cover” the business, in other words, “just in case”. If PAL is used where there’s no real risk, it can confuse customers and cause them to unnecessarily avoid certain foods. Instead, PAL should only be used when a thorough risk assessment shows that there’s a real risk of cross-contamination and therefore a potential risk to a food hypersensitive consumer. If that risk is present and can’t be fully controlled, then a precautionary label is appropriate.

When preparing and serving non-prepacked food, businesses are legally required to provide accurate allergen information and communicate any known risks of cross-contamination. While it’s good practice to accommodate different dietary needs, you are not legally required to cater for every dietary requirement, but you must be transparent.

For example; if a pizza restaurant makes fresh dough using wheat flour and prepares other dishes in the same area, the risk of gluten cross-contamination is high. In this case, serving someone with coeliac disease or gluten intolerance safely may not be possible. It’s the food business’s responsibility to assess the risk and clearly inform the customer, verbally or in writing, so the customer can make an informed decision. Where appropriate, a precautionary allergen statement such as “may contain gluten due to preparation methods” should be used to protect both the customer and the business.

Let’s look at some practical ways and best practice to provide clear, reliable allergen information.

Make allergen information available in writing: This isn’t a legal requirement, but it’s best practice and recommended by the Food Standards Agency. In writing could be, on the menu, in an allergen folder, or digitally such as on a tablet. Whatever the format, it’s essential that the information is up to date, easy to find, and that all team members know where it is and how to access it quickly. If there’s a physical folder or allergen pack, everyone needs to know exactly where it’s kept and how to use it.

When creating this information, it’s a good idea to have a two-person approach. One person producing the information and the second person verifying it through checking ingredients against standard recipes. Standard recipes are advisable to ensure all team members are aware of ingredients. Specials can also have a standard recipe.

Clearly emphasise allergens on menus: It’s good practice that allergens are clearly highlighted within the dish description on menus, so customers can spot them easily at a glance. This helps to prevent confusion and makes the ordering process more transparent.

Where appropriate, it’s helpful to provide allergen information online whether that’s on your website, through an app, or as part of a digital ordering platform. This is helpful for food hypersensitive guests to be able to see the information in advance.

For distance selling, allergen information must be provided twice: At the point of ordering and again at the point of delivery. Any dishes that have been prepared to be free of a particular allergen(s) must be clearly identifiable. For example, through the use of a sticker on the container. Remember it’s best practice to provide written allergen information both at the point of ordering and again at the point of delivery.

Train the team to talk about allergens: Every team member should be trained in your process for handling allergen requests. That includes knowing where to find correct information, understanding the serious consequences of getting it wrong and knowing what to do if they’re unsure, such as finding someone in the business who may be known as the ‘allergen expert’ or ‘allergen champion’ who can advise.

Decide who in the team is best placed to have these conversations: Is everyone trained to the same level, or should allergen enquiries be handled by someone specific, like a manager or head chef who may be referred to as the ‘allergen expert’ or ‘allergen champion’ in the business?

Know the process from start to finish: If a team member takes an order involving an allergen requirement, they must know the full process; from taking the order, to communicating it clearly to the kitchen, to ensuring the meal is prepared and delivered safely.

Keep the packaging from bought-in food items when stored after decanting: This allows you to check ingredient lists directly and show the label to a customer if needed.

Let’s look at what happens if things go wrong and the consequences of not complying with allergen legislation.

Who enforces the law?

Allergen legislation is enforced by local authorities. Most local authorities take a graduated approach to enforcement. If something isn’t right, they may start by giving verbal or written advice, often in the form of an inspection report or letter. If that advice isn’t followed, or if the issue is serious enough, they may issue an Improvement Notice. This is a legal document that tells the business what needs to be done and the deadline for doing it. Do not ignore it. Failing to comply with an Improvement Notice can result in prosecution.

For breaches of food safety law relating to allergens, an officer may issue a Hygiene Improvement Notice, this also sets out specific steps and deadlines to fix breaches of food safety law. For example, requiring food handlers to be adequately trained in allergens or ensuring allergens are covered in a HACCP system. In extreme cases, an officer may issue a Hygiene Emergency Prohibition Notice. This notice is used when there is a real and imminent risk to public health. It can stop the use of a food premises, a specific area or piece of equipment, or an activity that poses a serious risk.

If this notice is issued, the officer must apply to the courts within 3 days to have it turned into an order. The premises or equipment can’t be used again until the local authority confirms that it’s safe and issues a certificate. Sometimes, a business may be allowed to close voluntarily to put things right, but that’s at the officer’s discretion.

Scotland: Remedial Action Notices

In Scotland, officers have the option to serve a Remedial Action Notice, or RAN. This can be used in any type of food premises. It immediately stops the use of a space, piece of equipment, or process until compliance is achieved.

Prosecution and penalties

If a food business fails to comply with a notice, or if an officer finds serious breaches of food safety law, they can recommend prosecution. Penalties include, unlimited fines, up to 6 months in prison if convicted in a Magistrates’ court and up to 2 years in prison if convicted in the Crown Court or Scottish Sheriff Court. Under the Food Information to Consumers regulations a single offence could incur a fine of up to £5,000.

The Due Diligence Defence

If a business is taken to court, they may be able to defend themselves by proving they took all reasonable steps to produce safe food. This is known as ‘the Defence of Due Diligence’. Accurate and complete records are key to a strong due diligence defence.

If procedures and records are missing, out of date, or incorrect, that defence is gone. No paperwork, no protection.

Keep your allergen policies, food diaries, procedures, and food safety systems up to date and make sure they’re followed in practice.

It’s good to be able to show that when incidents or near misses have occurred, they were documented and then processes reviewed, updated and improved as appropriate. Also, you may consider keeping a diary of customers who state they have an allergy and then eat the allergen. For example; if a customer says they have an extreme shellfish allergy but their partner orders shellfish and perhaps you even see the customer trying some.

n.b. In relation to allergens, a near miss is an incident where something goes wrong i.e. in handling, preparing, or serving food containing allergens, but the mistake is caught before the customer consumes the food and suffers an allergic reaction. For example, a meal containing peanuts is accidentally plated for a customer who requested “no peanuts,” but the error is spotted before it reaches the table.

Other consequences

There are other consequences to getting it wrong, which include civil action by the affected customer or their family, negative press coverage, damage to the business’s reputation and customer trust and the need for product recalls, which can be extremely disruptive and costly.

Allergen cross-contamination or cross-contact, as it’s also known, happens when traces of an allergen accidentally make their way into a product or dish that wasn’t meant to contain them. Preventing cross-contamination or cross-contact is absolutely essential if a food business wants to serve safe food to food hypersensitive customers.

How does allergen cross-contamination happen?

There’s a few common ways:

1. Food to food: such as when different foods are stored too closely and end up touching, for example, fish and shellfish stored in the same container. Or when one food spills or drips onto another.

2. Human contact: i.e. from food to hands, such as if someone handles different ingredients without washing their hands in between, or uses the same gloves to handle multiple items, then allergens can easily transfer. For example, preparing pizza toppings or assembling sandwiches without changing gloves or washing hands.

3. Via equipment, utensils or surfaces: here’s some examples:

   • Using a whisk to make a sauce containing milk, and then again for a dairy-free or milk-free version, without being properly cleaned in between.

   • Chopping fish and shellfish on the same board without thorough cleaning in between.

   • Using the same wok for different stir fries, such as one that contains soy sauce and another that doesn’t, without thorough cleaning in between.

4. Through shared cooking liquids: For example, using the same fryer for battered chicken and gluten-free chips, or boiling egg pasta or noodles in the same water used later for egg-free pasta or noodles. That shared liquid becomes a vehicle for allergens.

Spotting the hazards

To prevent cross-contamination, every food business should take a close look at the operation and ask a few key questions:

• Which ingredients do we use that are known to contain allergens?

• Could any of our ingredients unintentionally contain allergens?

• Are there any other sources of allergens on site?

Then, think about how cross-contamination could happen from those sources. What are the routes or vehicles those allergens could take? A good way to do this is to walk through the full food journey, from purchasing, receiving deliveries, to storage, preparation, equipment, cooking, cleaning, waste management and service.

The form of the allergen

It’s also important to think about the form of the ingredient. Powders, like flour, can be especially risky as they can spread easily in the air and land on other surfaces and food. Liquids may be less mobile, but they still carry a risk of spreading through spills. Larger particles, like nuts or seeds can create what’s called a “hot spot”, where the allergen isn’t evenly spread and a customer might get a concentrated dose in a single bite.

In some situations, it may not be possible to prevent cross-contamination completely. If that’s the case, the customer must be clearly informed so they can make a safe, informed decision.

Having a clear allergen policy is a proactive step for any food business. It may form part of the food safety management system, or HACCP plan, or it may be a separate document, dependent on the nature and size of the business.

What is an allergen policy?

An allergen policy is a formal document that outlines a business’s commitment to managing allergens and serving safe food to food hypersensitive customers. It explains how allergens are stored, handled, prepared and served safely throughout the operation. It shows that you’ve considered the hazards, assessed the risks, and put control measures in place. It’s really a reflection of a business’s standards, values, and commitment to doing the right thing.

A well-written allergen policy should be a living framework that’s continually reviewed and updated to meet new challenges and ensure ongoing safety. When it’s implemented effectively, it supports team members, protects customers, and builds trust with enforcement officers and customers. Where possible, a business may consider having an internal allergen policy, which would be more detailed, and an external allergen policy, which contains the key points a business wants to communicate to customers. The external policy can provide contact details should the customer wish to obtain more information.

What should an allergen policy cover?

• An introduction that sets out the purpose of the policy.

• A statement of the organisation’s commitment to managing allergens.

• A breakdown of roles and responsibilities, from senior managers and supervisors to chefs and front of house.

• An overview of food hypersensitivity including food allergies, intolerances, coeliac disease and common symptoms.

• A list of the 14 named allergens.

• Any food bans that apply on site, for example, no peanuts.

• How ‘May Contain’ statements are managed and communicated.

• What team members need to know about allergen legislation and a commitment to ensuring that all team members receive appropriate and ongoing training in allergens.

• A summary of the controls the business has in place to manage allergens at every stage, from deliveries to buffets, takeaways, online orders etc.

• How allergen information is gathered and provided to customers including for PPDS foods and including suppliers ‘May contain’ information.

• How allergen requests from customers will be handled, including allergens outside of the 14 named allergens.

• What to do in an emergency situation, such as a customer experiencing anaphylaxis.

• How allergen issues and near misses are managed, reported and communicated back to the customer if necessary.

• Details of the product recall procedure.

• Details on how the policy will be monitored, reviewed and improved, including annual reviews, or updates after any significant changes or incidents.

Writing the policy is the first step. The key is making sure it’s followed in practice across the business. Every team member should understand the parts relevant to their role and senior staff must lead by example. It’s important to engage with your team when producing the policy as they will know how their department or section works, and what is and is not possible. Don’t forget to review and improve your allergen policy.

Let’s walk through each stage of a typical catering operation and look at practical steps or controls that a business can take to prevent allergen cross-contamination and also to manage allergens effectively.

Many of these controls apply to back of house, but it’s just as important for front of house teams to understand them too, especially when handling allergen requests from customers.

1. Purchasing ingredients:

• Choose reputable suppliers who understand allergen risks and controls.

• Have an agreement where your suppliers commit to notifying you of any substitutions or ingredient changes.

• Ensure all products and ingredients are clearly and accurately labelled.

• Have a robust product recall procedure which is clearly outlined in the allergen policy and/or food safety management system. This will help to ensure that in the event of a product recall, items can be easily identified, removed from use and either disposed of or returned to the supplier.

1. Deliveries:

• Cross-check all deliveries against your order.

• Look out for unannounced product substitutions.

• Review ingredients lists and other supplier information to spot any changes. Also, check supplier paperwork for notifications of changes.

• Reject products with unclear, damaged, unreadable labels or non-English labels or where the packaging is split or contaminated.

• Keep ingredient information accessible. For example, cut out labels and store in a folder or upload to a shared digital record.

• Record any ingredient changes and substitutions and communicate these throughout the business.

1. Food storage:

• Store all ingredients, prepared foods and items prepped in house, in sealed, clearly labelled containers/ packaging, ideally in their original packaging.

• To minimise the risk of cross-contamination, avoid decanting flour as this can lead to spills around containers. Instead, it’s recommended to place the original flour bag directly into storage containers.

• If decanting items, label them thoroughly with the full ingredients and accurate allergen information.

• Don’t top up containers with different brands unless allergens are confirmed to be the same.

• Store allergenic ingredients separately from non-allergenic ones or on lower shelves.

• Clean up spills immediately, following a clear written procedure.

• Check packaging for damage and don’t use the product for allergen-free meals if the packaging is compromised.

• Only reuse containers if they’ve been thoroughly cleaned, but ideally have dedicated containers. Also, remember to remove all old labels to avoid confusion or misidentification.

1. Preparation and cooking:

• Thoroughly clean all utensils and surfaces before each use following the two-stage cleaning process. Especially after they’ve been used to prepare allergenic foods.

• Wash hands between each task, especially when switching between allergenic and allergen-free prep.

• Use separate equipment, utensils, and prep areas for allergenic and allergen-free foods, whenever possible. If that’s not possible, clean everything thoroughly after preparing allergenic ingredients and before preparing food for a customer with a food allergy. If using purple boards, it can be difficult to manage if they’re used for all of the 14 allergens. Some businesses chose to use them for gluten free preparation only.

• Keep surfaces clean by regularly removing visible food debris and crumbs.

• When cooking, place non-allergenic products above those containing allergens, in the oven, or wrap in foil or greaseproof paper.

• Use dedicated equipment (i.e. fryer or toaster) for allergenic and non-allergenic products. For example, gluten-free chips must not be cooked in oil that’s been used for battered foods. If this is not possible, make sure the customer is informed.

• Stick to the standard recipe.

• If ingredients or recipes change, all allergen information and all team members must be updated.

• If a mistake is made while preparing an allergen-free dish, throw it away and start again from scratch.

• Keep recipes accurate and up to date and share changes throughout the business.

• Double check garnishes, toppings, sauces and dressings and leave them off if needed.

• Remember, cooking does not destroy allergens.

• Have a clear process for preparing and serving food for the food hypersensitive customer, and make sure the meal gets to the right person.

• Always inform the customer if you can’t guarantee their meal will be free from cross-contamination so that they can make an informed decision.

1. Service/ display and buffets

Service

• Always ask at key points if there are any food hypersensitive guests i.e. when booking, on arrival, when taking the order.

• Wash hands thoroughly before handling any plates, cutlery, or food intended for customers with allergies.

• Use a clear system to ensure allergen-free meals are served to the right customer.

• When taking meals to the table, deliver allergen-free meals separately to avoid contact with other plates or food.

• Clearly label plated-up meals that are prepared in advance.

• Always prepare allergen-free meals from scratch rather than trying to adapt existing meals.

• Use clean, separate serving utensils for plating allergen-free meals.

• If a plate gets contaminated i.e. by a spill, never wipe it off and serve it, start fresh.

• You may want to consider serving food for a hypersensitive customer on a simple plate, ideally one of a different colour or shape so it can be easily identified. Avoid items such as wooden boards, slate, or baskets, as slate and wood are porous, wooden boards can split, and baskets are harder to clean.

Buffets

• For buffets and self-service areas, use separate serving utensils for each item, ideally colour-coded or otherwise easy to distinguish and display foods containing allergens separately. As an alternative, you could provide a plated meal prepared specifically to meet the dietary needs of the food hypersensitive customer.

• Provide allergen information for each item, not just the buffet as a whole. i.e. labels next to each food item or signage directing customers to ask for allergen information.

• Carry out regular checks on buffets and self-service counters to make sure cross-contamination is under control.

1. Transportation / delivery (i.e. to events):

• Ensure all items are thoroughly covered or packaged, and clearly labelled.

• Keep allergen-free products separate. Where that’s not possible, put them on top of the stack.

• Train people involved in the packing, delivery and receiving of food to understand separation requirements.

Bars and drinks

It’s important to ask customers about allergies in a bar environment too and have appropriate signage. Team members working behind the bar should be trained too including on hidden allergens, garnishes and cross-contamination risks (i.e. shared tools), also how to handle allergen requests from customers.

Here’s some things to consider:

• Keep items such as nuts in sealed containers.

• Consider cocktail ingredients. For example, some cocktails contain egg whites, Bloody Marys use Worcestershire sauce (which contains fish), and certain wines or pre-mixed cocktails may contain sulphites.

• Be aware of cross-contamination risks from shared cocktail-making equipment.

• Remember that some allergens fall outside the named 14 but can still trigger reactions. For instance, aquafaba (chickpea water) is sometimes used on the rim of a glass instead of egg white, but it can cause a reaction in people allergic to legumes, including peanuts.

• Also note that some eco straws are made from wheat or from chitosan, which is derived from crustacean shells.

Proper cleaning and hand hygiene are absolutely essential in controlling allergens.

Cleaning controls:

• Follow the two-stage cleaning process: first clean all surfaces and equipment with hot, soapy water (detergent) to remove allergens, then apply the appropriate disinfectant or sanitiser according to the manufacturer’s instructions. Remember this applies not just to food preparation areas, but also to tables and highchairs etc.

• Be aware that disinfectants, sanitisers, and antibacterial sprays generally do not deactivate allergens. Simply spraying a surface is not enough. These products are useful for killing bacteria, but allergens must be physically removed with detergent, which is why the two-stage cleaning process is essential.

• Dismantle equipment when needed to reach hidden spaces, such as places where flour or seeds may get trapped. Where possible, use a dishwasher to help ensure removal.

• Use single-use cloths where possible, as reusable cloths can spread allergens around the kitchen.

• Clean up spillages immediately. It’s also a good idea to use colour-coded cleaning equipment for allergen-free preparation areas.

Hand washing controls:

• Wash hands regularly and thoroughly.

• Remember that wearing gloves does not necessarily prevent cross-contamination, so good handwashing is key.

• Avoid soaps or hand creams containing nut oils.

• Always wash hands before handling allergen-free meals, plates, or cutlery.

  • For front-of-house teams: clearing plates that contain allergens can transfer traces to clean areas, meals, or cutlery for a food hypersensitive customer, so handwashing is especially important in these situations.

You receive an order from a customer with a food hypersensitivity. There’s a clear step-by-step process to follow and every step matters to make sure the meal is safe, and the customer gets accurate information. Taking the time to follow this process is critical. When a food hypersensitive customer places their trust in you and your kitchen, it’s a serious responsibility.

1. Recheck the labels on all the ingredients planned for the dish. That means every component, including sauces, dressings, glazes, oils, and garnishes to make sure none of the ingredients contain the allergen the customer needs to avoid. If requested, show customer the label for reassurance.

2. If the allergen is present (or possibly present), stop and inform. If any of the ingredients contain the allergen, say they may contain it, or aren’t suitable for people with food allergies, then the customer must be informed, either directly or via the front of house team. They need that information to make an informed decision about whether to continue with the order. Never guess. Never make assumptions.

3. Clean the preparation area thoroughly. If the customer decides to go ahead, and the meal is safe to prepare, the next step is to thoroughly clean the prep area using the two-stage cleaning process. That includes all work surfaces, utensils and equipment you’ll be using. You’re removing every trace of the allergen, not just what’s visible.

4. Wash your hands. Before you start, wash your hands thoroughly, even if you’ve just washed them recently. This is one of the simplest but most important steps.

5. Use separate or cleaned equipment. Where possible, use dedicated ‘allergen-free’ boards, utensils, and equipment. If that’s not possible, make sure everything is cleaned thoroughly before use. Some kitchens also have separate preparation areas for certain allergens. Especially for ingredients like flour, which can spread easily to surrounding surfaces and food.

6. Wear a clean or disposable apron over your work clothes to reduce the risk of allergen particles being transferred to the meal during preparation.

Why is communication important?

There are two big reasons why good communication matters:

1. It ensures the customer receives accurate allergen information.

2. It helps the customer make a safe and informed choice about what to eat.

One mistake, one moment of miscommunication, could cost someone their life. Beyond the safety risk, the way a food business handles these conversations can also determine whether a customer ever returns.

Young people aged 15 to 25 are particularly at-risk when it comes to managing food allergies. Many avoid asking questions or disclosing their needs for fear of standing out. It’s important to take the time to speak with them, sometimes privately and always sensitively, to understand and support their requirements.

Put yourself in the customer’s shoes

Food plays a huge role in our lives and social activities: meals out with friends and family, birthday parties, and other celebrations. A food hypersensitive customer may have to miss out on many of these events, or feel anxious about joining in.

Think about what might be going through their mind when they visit your business:

• Am I welcome here?

• Can I trust them?

• Are all team members trained?

• Will my food be safe?

• Do they have an allergen policy?

A customer with a food hypersensitivity isn’t asking for a special meal to be awkward, to follow a trend, or because they’re fussy. It’s a medical necessity. For some, the wrong meal could be life-threatening. For others, it could mean becoming seriously ill afterwards.

Some people with food allergies may avoid eating out altogether. Others may eat out but feel very anxious. They might ask a lot of questions in advance, by email or in person. This isn’t to be difficult, it’s because they’re worried. Some may stick to one dish they trust, or only visit the same restaurant each time. How you respond can either help reduce that anxiety or make it worse. Handle the interaction well, and they’re likely to come back regularly, which is good for business.

Certain comments can increase anxiety and damage trust, such as:

“Is it actually an allergy or just a preference?”

“Your allergy’s just mild, right?”

“We’ve never had an issue before”

Even if meant kindly, comments like these can make customers feel dismissed or doubt whether your business takes allergens seriously. Instead, show empathy and compassion, both through your words and your body language.

Every team member needs to understand their role in keeping customers safe. While the details may vary depending on your business, there are key areas that should always be covered. Everyone should know:

• Who has overall responsibility for allergen management?

• How to confidently handle allergen requests from customers?

• How to prevent cross-contamination at all times including during storage, preparation, service, and cleaning?

By law, allergen information can be provided verbally, but the Food Standards Agency say that best practice is to make it available in writing, and then support that with a conversation.

Providing written allergen information

When creating written allergen information, here are some key things to get right:

Easy to use: It should be obvious which dishes are safe for the customer. If it’s a folder or pack, it’s a good idea to have it in sections so it’s easy to cross-reference against the menu.

Clear: It must show exactly which allergens are present in each dish or product.

Comprehensive: It must cover all 14 named allergens, not just the most common ones.

Accurate: The information must be regularly reviewed and kept up to date. If a recipe or ingredient changes, the allergen information must change too.

How should it be presented?

Written statements: Allergen information can be presented in written statement on a menu, a label, or a ticket beside displayed food. For groups of allergens like tree nuts and cereals containing gluten, it’s important to specify the type.

Symbols: Symbols can be used to represent allergens. For allergen groups, such as cereals containing gluten or tree nuts, a single symbol can be used, but you must still be able to explain exactly which tree nut or cereal is involved if a customer asks.

Dish breakdown: You can provide a breakdown of each component in a dish, especially for things like burgers, sandwiches, or salads. This may allow your customers to ask for dishes to be tailored with components omitted from their final dish, providing this can be done safely. You must take cross-contamination risks into account before offering modifications.

Where should the allergen information be?

There should be signage indicating the availability of written allergen information. Ideally, written allergen information should be ‘readily available’, without customers having to ask for it. This could be on the main menu (paper or digital), in an allergen folder or printed matrix behind the counter, displayed on a wall, or board in a space customers can access.

If your menu or specials change often, and you need more flexibility, you can store allergen information in a separate document, but it still needs to be available on request. In that case, you must have a clear message on your menu or display, such as: “We have a menu with allergen information. Please ask a member of staff who will be happy to provide it.”

If you don’t use a menu, display this message clearly next to your food, on signage or menu boards. In addition to displaying signs, you could also ask customers if they require allergen information when you take their order.

If you provide the allergen information in a digital format, i.e. through a website, app or QR code, it’s advisable to have an accurate backup in case of tech issues or for customers who can’t access it easily. Make sure all team members know where to find this backup information!

If you run specials or limited-time dishes, these must be included in your allergen information too. The allergen information must be kept up to date for every item on offer. Also, if any ingredients or products come with “may contain” statements from the manufacturer, these must be passed on to the customer. They should also be clearly noted in your written allergen information.

Foods outside the 14 named allergens

A food business is not legally obliged to provide information outside of the 14 named allergens, but it is helpful to the customer if you can. For example, pea protein allergy is becoming common and can be found in a large proportion of vegan products and some potato products.

This may require you to check full ingredients lists, refer to packaging and supplier information, where possible. Standard recipes should contain full ingredients and having this either in digital or paper format will act as additional resource for you to help these customers. If it’s not possible to provide accurate information, for example, when using unlabelled non-prepacked ingredients from another business, the customer must be informed, so they can make an informed decision as to whether they want to place an order.

Handling allergy queries from customers

Every front of house team member should know what to do when a customer asks about allergens. In some businesses, depending on their procedure, that may simply mean knowing who to refer the request to. In other cases, a team member will handle the query directly and be able to have the conversation confidently and in an understanding way. What they’ll need to know includes:

• where to find the written allergen information

• how to get further information about a dish, such as whether it can be modified safely

• who to speak to if they’re unsure.

Here’s a checklist for front of house teams to get started:

• What is the process in the business for handling allergen requests? For example, are all team members required to handle allergen requests or are they required to refer customers to someone such as the on-site ‘allergen expert’ or ‘allergen champion’ (i.e. a manager or supervisor)? The same applies for delivery and takeaway orders i.e. over the phone or online.

• Is there a clear and accurate way of providing customers with allergen information?

• Is there written allergen information available to refer to?

• Is there a risk of cross-contamination between allergens and if so, is this risk communicated to the customer?

• How are allergen-specific orders recorded and clearly communicated to the kitchen?

• How are incidents handled, such as a customer having an allergic reaction? (we’ll cover this in detail later).

• Is the whole team aware of the importance of reporting an allergen related issue or ‘Near Misses’ to the supervisor/manager to make them aware of what occurred (the manager/ supervisor should manage the issue and review processes to prevent reoccurrence)?

• Does the company avoid disclaimer statements such as all our food could contain ‘xxx’ allergen, unless a risk assessment has taken place? Do you instead give information on the controls in place in the kitchen and front of house and allow the customer to make an informed choice?

Delivery and takeaway orders:

The same level of care applies to food sold via delivery or takeaway.

• Is there a process in the business for handling allergen requests over the phone or online?

• Does your website clearly state that allergen information is available before an order is placed?

• Is your online allergen information clear, accurate, and easy to access at the time of ordering?

• If you use a third-party platform, like a delivery app or website, are you following their allergen info requirements? N.B. Some businesses state that allergen orders can only be made directly over the phone and not through the app.

Communication is key

As we’ve already learnt, written allergen information should be provided and underpinned with a conversation. This conversation isn’t a legal requirement but it’s definitely best practice. That means don’t just hand over a folder or point at a QR code; take the time to ask follow-up questions and make sure you understand the customer’s requirements so you can pass that information on correctly to the kitchen.

Why is this conversation so important?

It:

• Allows a business to gather all the necessary details from the customer so a safe meal can be prepared.

• Enables the customer to make a safe and informed choice about what to eat.

• Makes sure the customer is aware of any potential cross-contamination risks.

• Allows a discussion about whether it is possible to modify or adapt a meal to suit the needs of the customer.

• Allows a business to let the customer know of any last minute changes to products, ingredients etc. so that the customer has the most up to date information to make an informed choice.

Encouraging customers to speak up

Customers need to feel comfortable telling team members about their allergen needs and sometimes they need a little encouragement. It’s good practice to ask every customer directly and also display a clear sign in a prominent place letting customers know they should speak to a team member about allergens. If it’s not possible to ask every customer directly, then at the very least, a sign should be displayed and visible.

Decide who will handle allergen conversations

Every business should be clear on who is responsible for having these conversations with customers. If all team members are expected to handle allergen requests, then everyone must be trained to the same level. If only certain team members are to handle these conversations (i.e. a manager or supervisor), make sure the rest of the team still knows how to ask about allergens, who to refer the customer to and how to pass that information on quickly and clearly.

What should be covered in the conversation?

The conversation with the customer should as a minimum include:

• What food the customer needs to avoid.

• Whether the customer has received written allergen information.

• Any risk of allergen cross-contamination.

• Whether the customer feels they have enough information to make an informed choice.

• Whether any safe adaptations to a dish can be made, if this is possible.

Be professional and reassuring

Keep in mind, for the customer this isn’t just a conversation. Essentially, they’re revealing personal medical information, which can feel awkward or uncomfortable. The way the interaction is handled matters. Be professional, respectful and make sure the customer feels heard, supported and safe. You may say something such as “thank you for letting us know. We understand how important this is”.

Always provide accurate information

It’s critical that accurate information is given to the customer. Refer to the written allergen information, use supporting information where necessary, such as recipes, ingredient spec sheets, product labels etc. Be honest and specific. For example, if you can’t guarantee there will be no cross-contamination due to your kitchen set up, tell this to the customer. If you can offer solutions or modifications, again let the customer know what you can and cannot do.

How allergen communication might work in practice

1. Ask early. Encourage customers to let you know about allergen requirements. For example, through messaging or asking directly “are there any food allergies, intolerances or coeliac disease that we need to be aware of?”. (Note: A front of house team member may respond “Thank you for letting me know, I’ll get the allergen folder and ask my manager to come over to take your order”.)

2. Provide written allergen information. Whether it’s on the menu, in a booklet, or digitally, make sure the customer can access it.

3. Discuss the details. Have a conversation with the customer. Ask what they need to avoid, check if the dish can be modified and clarify anything you’re not sure about. This will be in person or via telephone for takeaway/ delivery orders.

4. Highlight any risks. If a product has a “may contain” statement or there’s a known risk of cross-contamination, let the customer know. Avoid statements such as ‘we do not show may contain statements from our suppliers’ or ‘all our foods may contain allergens’.

5. Let the customer decide. With all of the information, the customer is able to make an informed choice about what to eat.

6. Record the allergen-free order clearly. For online orders, this might be a box or comment field that the customer completes. In person, make sure it’s recorded clearly and repeat it back to the customer.

7. Inform the kitchen. Pass the allergen information directly to the chef or person preparing the meal, so they know exactly what to do. It’s critical they receive this information so that they can prepare a safe meal.

8. Prepare the meal safely. Follow the correct procedures, control cross-contamination and where necessary leave out certain ingredients (if this is safe to do so and has been agreed with the customer).

9. Identify the meal. Make sure the front of house team know which dish is allergen-free; label it, mark it, put a flag in it or use a coloured/ different shaped plate!

10. Serve the correct meal. Deliver the allergen-free meal to the right customer and don’t let it get mixed up with anything else.

11. Confirm allergen requirements were met. This could be verbal, “Here’s your xxx (allergen)-free meal” or visual, like a label or sticker on a takeaway order.

It’s helpful to consider the various touch points you may have with a customer. If you can speak to the customer at the time of booking or follow up by phone or email prior to their arrival this can make things smoother on the day.

As we’ve learnt, an allergic reaction such as anaphylaxis is life-threatening. Knowing how to respond, and acting quickly and confidently, can save someone’s life.

Here’s what to do if a customer shows signs of a serious allergic reaction: (This advice has been kindly supplied by The Allergy Badge.)

1. Check for an adrenaline auto-injector. The customer may carry an auto-injector, such as an “EpiPen”or “Jext” pen with them. These devices contain adrenaline which can help to treat the body’s allergic reaction. Ask if the customer has one, and help them access and use it straight away. It’s worth noting that although you cannot harm someone in giving an adrenaline auto-injector, it is important it is given correctly. The instructions are on the side of the device should you need them. Although it is beneficial to have had some training first. You should administer an adrenaline auto-injector in the person’s upper outer thigh without hesitation. The device is single use and can be administered through clothing, just avoid any seams.

2. Call 999. Call for an ambulance immediately stating “We think the customer has anaphylaxis”. That’s pronounced “ana-phy-laxis”. Even if the customer is starting to feel better, still call 999. A second wave of symptoms can occur and medical treatment is essential.

3. Help them into the right position. If they’re conscious and not struggling to breathe, help lie them down with their legs raised. If they’re pregnant or having trouble breathing, help them into a comfortable upright position instead.

4. Use a second auto-injector if symptoms don’t improve after 5 minutes, or they return. People diagnosed with allergies should carry two adrenaline auto-injectors with them at all times. You should administer the second adrenaline auto-injector in the opposite leg, if accessible.

5. Inform the on-site first-aider. Alert the designated first aider on site and let them know what’s happened. They can support you until the ambulance arrives.

6. Stay with the customer. Stay calm, reassure the customer and stay with them until the ambulance arrives. Customers should always go to hospital to be monitored following anaphylaxis in case of a delayed, secondary reaction.

After an incident

After an incident, it’s essential to review your processes and procedures, investigate what happened and why, and retrain the team as appropriate.

Many allergen issues come down to a lack of training, poor communication, or inconsistent procedures. That’s why as a manager or supervisor, your job is to set expectations, lead by example, monitor that procedures are being followed, support your team, and create a culture where allergens are taken seriously.

Your role in shaping allergen safety culture

Having good systems and an allergen policy in place is essential but those systems rely on people. Controlling allergens isn’t just about what someone knows, it’s also about how much they care. That’s where allergen safety culture comes in. It’s about the shared values, beliefs, and behaviours that shape everyday practices. It’s the mindset of “this is how we do things around here.” And that culture starts at the top, with you.

Leading by example

Your attitude towards food safety and allergen safety sends a powerful message. If you take allergen safety seriously, your team will follow your lead. But if you cut corners or treat these things as a tick-box exercise, your people may do the same.

Good leaders model the behaviours they want to see. You’re in a unique position to spot non-compliance early, take swift corrective action and promote the kind of culture where food safety and allergen safety are simply part of how your team operates.

Encouraging reporting of ‘near-misses’ when team members spot issues is important to prevent issues from reoccurring. Your procedures are only as good as the management and team on site.

Allergen safety culture needs more than paperwork

Effective allergen management isn’t just about having an allergen policy or an allergen folder. It relies on the attitudes of your team, the training they receive, the support you give and how consistently standards are applied and reinforced. It’s really about what happens when you’re not there.

Here are some key behaviours that help build and sustain a positive allergen safety culture:

• Lead by example

• Model the standards you expect.

• Provide effective training and keep it going with refreshers and on-the-job instruction.

• Supervise to make sure standards are being followed.

• Give constructive feedback, not just when things go wrong but also positive reinforcement when people do things right.

• Take quick corrective action when needed.

• Where possible, base decisions on evidence, not just opinions.

Allergens must be managed as part of a food business’s overall food safety management system, that means allergens need to be included within the Hazard Analysis Critical Control Point (HACCP) plan or within the allergen policy, usually under the ‘controls’ section. For smaller businesses, this could be covered using the Safer Food, Better Business (SFBB) pack.

Whether you’re running a small café or a multi-site operation, the principles are the same.

How allergen control fits into HACCP

Prerequisites

A food business needs to make sure all the essentials are in place first, so they can create an effective HACCP system. These basics, known as “prerequisite programmes”, or PRPs. They are often simple steps that relate to good hygiene practices.

Here are some examples of prerequisites for managing allergens for a food service business:

• A suitable set-up, including well-designed premises and equipment, dedicated handwashing sinks, separate sinks for washing food and equipment, good layout, efficient workflow, and adequate lighting.

• Effective cleaning and disinfection procedures (i.e. two stage cleaning).

• Using trusted suppliers who take allergen control seriously.

• Effective labelling, traceability and recall procedures. Every product and ingredient should be fully traceable so that if there is ever a recall or issue, the movement of food through the supply chain can be tracked.

• Labelling also plays a vital role in managing allergens effectively within the business.

• Team training to ensure people are confident, capable, and understand their role.

• Effective personal hygiene procedures, for example, thorough handwashing.

• Effective pest and waste management, to prevent not only the spread of bacteria but also allergens.

• Clear procedures for dealing with customer complaints, incidents and near-misses.

• Procedures for managing visitors in the kitchen, such as pest control contractors or maintenance teams, to ensure they follow allergen control procedures.

Hazard Analysis Critical Control Point (HACCP)

In terms of HACCP, a Food Business Operator needs to:

1. Identify risks. This means identifying which allergens are present in the dishes or products, where in the process allergen cross-contamination could occur and the level of risk this presents to food hypersensitive customers.

2. Implement procedures. Once the risks are known, these must be documented and procedures implemented to manage them. The aim should be to prevent or minimise allergen cross-contamination for the risks that have been identified. For example, using separate equipment for allergen-free meals, following strict cleaning procedures, a robust storage policy or clearly labelling food items during storage.

3. Design the kitchen and workflow to minimise allergen cross-contamination. For example, by using separate storage (i.e. for allergenic ingredients like nuts and flour), dedicated preparation areas and equipment for free-from foods (such as for gluten-free foods), implementing a linear workflow, and ensuring all surfaces and equipment can be effectively cleaned.

4. Inform the team. It’s essential that all team members are aware of allergen procedures and follow them consistently. This includes induction training, annual refresher training and updates whenever procedures or recipes change.

5. Monitor procedures. Put in place systems to check that procedures are being followed and are effective. This might include spot checks, internal or external audits, observing food handling practices, reviewing cleaning standards and order-taking procedures. If you find issues, act quickly.

6. Monitor suppliers. Suppliers can introduce allergen risks into your business. It’s essential to monitor what your suppliers are providing you. You may ask them to agree to inform you if there are any changes to allergens and ingredients, and then, you will need to monitor that they are actually doing this.

7. Review regularly. Allergen procedures should be reviewed at least once a year and whenever things such as operations, processes or recipes change.

8. Keep customers informed. If allergens in a dish or product change, the customer needs to know. This can be done verbally or in writing. Also, include a note on menus that customers should check regarding allergens every time and not assume the recipe remains unchanged.

Investigating and improving

If something goes wrong, a food business operator, manager or supervisor should investigate. This should include identifying:

• what happened

• why it happened

• what needs to be done to prevent it from happening again. That might require you to update the allergen policy, HACCP documentation and retrain the team.

Verification

It’s important to regularly check that everything is still working well. To do this you might:

• Review customer complaints or other incidents relating to allergen management.

• Review EHO or audit reports to check for any non-conformities that have not been resolved.

• Conduct mystery diner checks to verify communication of allergen information to customers.

• Conduct allergen audits of back of house and front of house. These audits could be external or external by a competent auditor.

• Use allergen swabs to test for allergens after cleaning. These can be a good way to assess the effectiveness of cleaning.

• Review allergen information to ensure it is accurate and up to date.

• Carry out competency testing for all food handlers. For example, asking questions, conducting team quizzes etc.

Every team member needs to understand their role in keeping customers safe. While the details may vary depending on the setup of your business, there are key areas that should always be covered.

Everyone in the team should know who has overall responsibility for allergen management in the business, how to confidently handle allergen requests from customers (even if that’s just knowing who to pass them on to), and how to prevent cross-contamination at all times including during storage, preparation, service, and cleaning.

Front of house responsibilities

Front of house (including bar staff, events team, room service, spa team etc.) are often the first point of contact when a customer mentions allergen requirements. Training should ensure they know the specifics in your business including:

• Who is responsible for handling allergen enquiries? Is it every team member, or is there a designated person who may be referred to the ‘allergen expert’ or ‘allergen champion’ on each shift, like a manager, head chef or team leader?

• How to respond when a customer makes an allergen request, that might mean locating the written allergen information or referring the customer to the allergen expert.

• Where the written allergen information is kept, and how to communicate cross-contamination risks clearly, without guessing or assuming.

• How to liaise with the kitchen and record an allergen-free order accurately, using the system your business has in place.

• How to ensure the allergen-free meal gets to the right customer. For example, using a flag, marker, or sticker or coloured or shaped crockery.

• Recognising symptoms and knowing what to do if a customer is having an allergic reaction (i.e. anaphylactic shock).

• How to handle allergen requests for takeaway or delivery orders, including how to label and pack meals safely.

Back of house responsibilities

Kitchen teams play a critical role in allergen control and even one small mistake can have serious consequences.

Back of house training specific to your business should include:

• What processes are to be followed when a food allergy order is received.

• Clarity on who prepares allergen-free meals? For example, is it the head chef or any trained team member?

• How to check food deliveries including checking for allergen information, substitutions or ingredient changes, and knowing what to do or who to inform if something doesn’t match up.

• What to do when recipes are changed or adapted, and how to ensure allergen information is updated and shared.

• Knowing who’s responsible for maintaining and updating the written allergen information, and how to raise changes or issues with them.

• How to clean surfaces, utensils, and equipment thoroughly to remove allergens, (i.e. following the 2-stage cleaning process) and how to deal with spillages safely.

• Correct storage practices including using sealed, clearly labelled containers, and retaining ingredient lists when packaging is removed.

• Understanding the importance of effective hand washing.

• Having an awareness of hidden allergens including in garnishes, toppings, sauces, and dressings, and making sure these are left off allergen-free meals as required.

• Ensuring allergen-free dishes are clearly identified for service, using your business’s tracking system to avoid mix-ups.

Let’s take a look at some ways that training can be done:

Induction training: This should happen before someone starts work. It should cover the basics, including how to respond to allergen requests and how to prevent cross-contamination. Everyone in the business should receive induction training, including those not directly linked to food service. Induction training should be tailored to the business.

Completing a formal training course: This helps with the theory, understanding the legislation, the risks, and the key controls. But training shouldn’t stop there. Completing a formal training course should form part of a wider training programme that focusses on the way things are to be done in your business. It should also be supported by practical application of what has been learnt.

On the job training: This covers the specific allergen controls and procedures used in your business, so each team member knows exactly what’s expected of them in relation to their tasks, and how to work safely.

Buddying: Pairing less experienced team members with experienced ones can help new starters to learn what is required and to see good habits in action.

Ongoing supervision: Supervision is key. If bad habits start to creep in, you can and should correct them straight away.

Refresher training: This is important because people forget things over time and food safety habits can fade, especially in a busy kitchen. It’s also important to ensure that team members keep up to date with the latest information. The Food Standards Agency recommends that food businesses “Provide staff with suitable allergen and food hypersensitivity training on an annual basis, to appreciate the potential consequences of providing incorrect information – which could be life threatening.”

Refresher training is also essential, after an incident, when you introduce new procedures or equipment or when recipes and products change.

If things go wrong or near-misses occur, it’s important to investigate thoroughly. This not only shows your commitment to guest safety; it also helps to prevent the same issues occurring again.

Near miss reporting is important because it helps identify weaknesses in allergen controls, allowing a business to learn from mistakes and prevent a serious incident from happening in the future.

Here’s a checklist to help you:

• Encourage your team to report allergen incidents and near-misses. For example: A meal containing peanuts is accidentally plated for a customer who requested “no peanuts,” but the error is spotted before it reaches the table.

• Take full customer details, including contact information and how they were affected.

• Speak to all team members directly involved to gather accurate information.

• If possible, retain a sample of the food for testing.

• Focus on support, not liability. You may choose to avoid offering free meals or compensation on the spot and instead address this after the investigation.

• Show empathy and take responsibility without assigning blame.

• Keep a detailed log of all incidents and near-misses, this helps identify whether it was a one-off or part of a recurring issue.

• Try to categorise issues (i.e. equipment, training, staff etc.), this will help you identify patterns and key areas for improvement.

• If multiple reports relate to the same issue, conduct a root cause analysis to uncover systemic failures and take corrective action.

• Communicate the outcome of the investigation to the customer, including any changes made to improve safety. At this point you might choose to discuss recompense as appropriate. Although, in many cases, it’s likely that the main thing the customer will want is to understand what happened and what changes will take place to prevent a similar issue. For example, staff training, adapting processes etc.

As a manager or supervisor, you play a vital role in protecting the food hypersensitive customer. That means setting clear standards, training your team to meet them, and supervising to ensure those standards are followed in day-to-day practice. To help with this, here’s a checklist of key things to get started:

Leadership and responsibility

• Do you lead by example and set clear expectations and responsibilities for allergen safety and allergen management across the team?

• Do you ensure that all your team are trained, confident and regularly refreshed on the allergen procedures in your business?

• Is an ‘allergen expert’ or ‘allergen champion’ available on shift to manage requests from customers? If so, do all your team know who this person is?

• Do you supervise daily practices, especially during busy periods to ensure procedures are followed? (You may also consider implementing mystery diners to do spot checks.)

• Do you maintain accurate allergen information and ensure the safe preparation and service of allergen-free meals?

• Do you log and investigate all incidents and near-misses, using them to drive continuous improvement?

• Do you consider allergens as part of menu design?

Communication and signage

• Do you display clear signage telling customers where and how they can access allergen information?

• Is this signage displayed in a prominent place where customers choose their food?

• Are team members confident and trained to have conversations with customers about their allergen requirements?

• If you provide allergen information digitally, do you also have an accurate hard copy back up?

• Have you considered every touchpoint with the customer to make the process easier? For example, if your first contact with a customer is when they book via your website or by phone; could their requirements be discussed then or before they arrive via phone or email?

Takeaway and delivery orders

• Do you have documented allergen procedures for takeaway and delivery orders?

• Do your team know how to handle delivery, collection and takeaway orders?

Cross-contamination

• Do team members understand the risks of allergen cross-contamination and how to prevent it?

• What are the current cross-contamination risks in your processes? Could they be re-evaluated to see if any could be eliminated altogether?

Updating allergen information

• Does the kitchen team know how to record changes to recipes and who to report these to?

• Do you have clear procedures in place, and responsible, trained team members to update allergen information when products, ingredients or recipes change?

• Is there someone to verify this information?

• Do you have delivery procedures that include ensuring what was delivered matches what was ordered?

• If there are substitutions from suppliers, do you have a procedure for approving, recording and communicating these changes?

• Do you have a product recall procedure in place?

• Do you have a reliable system for updating allergen information whenever your menu changes?

• Is this information currently up to date?

• Are your suppliers providing you with accurate information?

Cleaning and procedures

• Are there clear procedures for cleaning of the premises, equipment and utensils, including how to clean up spillages safely?

Training and emergencies

• Do you provide annual allergen training, as recommended by the Food Standards Agency?

• Does your training include all of the team?

• Is the training you provide effective?

• When selecting and providing training, do you consider the different ways in which people learn and also any language barriers?

• Do you discuss allergens regularly such as during team meetings?

• Do you provide ongoing training to your team such as through quizzes, Q&As etc.?

• Does your team understand your allergen policy, your processes and procedures?

• Does your team know what to do in an emergency situation, like an allergic reaction?

• If something goes wrong, do you have a process to review procedures and retrain the team, where necessary?

Current processes

• Are these effective and up to date?

• Are they achievable in practice?

• Are they followed by your team?

• Could your current recipes or dishes be adapted? i.e. could anything be removed or substituted?