Food allergens and allergen awareness are hot buttons in the world of food safety. Allergen management is an integral part of the preventive controls regulation found in 21 CFR 117 and has been part of food safety management systems in the U.S. and throughout a large part of the world for many years.
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Explore This IssueDecember/January 2020
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None of us had seen anything like this in the U.S. There is the occasional restaurant that mentions that an item contains a food allergen and there are others such as Applebee’s and Buffalo Wild Wings that will provide customers with a separate allergen menu, but such operations are the exception rather than the rule. The best allergen management program that I have ever seen was developed by a private school that was feeding over 1,000 children per day. They used the Al-Aware tags to introduce the students to allergens and tagged each menu item with the name of the allergen and the colored Al-Aware tags. In addition, they introduced the program in the classrooms so they brought the system directly to the children. The food service manager even designed and patented holding trays that were meant to minimize the potential for cross-contact. Sadly, this program collapsed when the food service director retired. The operation now proudly maintains gluten-free and dolphin-safe instead of what are more common food safety concerns.
Servers in the U.S. are generally rather poorly educated when it comes to allergen awareness. I say generally because there are some persons and restaurants that are knowledgeable and have made the effort to make sure their servers are properly educated about food allergens. A few years back, I was having dinner with friends at local restaurant. The restaurant was featuring shank of wild boar that evening. One of my friends ordered it, but stated that soy was a concern with her. The server thought that might be a problem. He checked with the kitchen and confirmed that part of the marinade was soy sauce, so our friend had to order something. Unfortunately, not all servers are this good nor are restaurants so diligent.
The bottom line is, maybe we should look at what Europe is doing.
European Restaurants and Allergen Awareness
I want to state that this isn’t a scientific evaluation, but the comments of a food scientist who has had the opportunity to travel throughout the European Union and enjoy the food all over. I have also had the change to look over menus and talk to restaurant owners about allergen management.
Thanks to the people at the Food Allergy Research and Resource Program (FARRP), I was able to obtain copies of the EU regulations governing allergens. There are specific regulations for foods that aren’t pre-packaged—that is, foods served in restaurants, canteens, or cafeterias. The EU has defined 14 food allergens: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, peanuts, sesame, soybeans, and sulphites.
There are various ways that operators may comply with these regulations, including:
- Ensure that each menu item that contains allergens properly references the allergen(s) they contain.
- Establish a table that shows all menu items and the allergen(s) they contain.
- Post a conspicuous announcement that the restaurant sells foods that contain food allergens and that sensitive customers should ask their servers about the foods being served.
Let’s look at these three means of complying with the EU regulations. One way to note allergens on a menu is to include color coded and numbered allergens. Customers can cross-reference the numbers or colors next to their menu selection with the master list found at the back or front of the menu. This kind of menu has pros and cons. It allows restaurant patrons to easily understand what allergens are found in each item on the menu, but it places a burden on restaurant owners or operators. Every time there’s a menu change or update, the menu will have to be redone. This can be a real issue with restaurants in tourist areas that change menus with the seasons. They have the option to print addenda that can be provided to customers with the main menu, but it does add costs. It can also stifle creativity in the kitchen as chefs will need to clear menu items in advance and be sure that new items that contain potential allergens will be properly flagged.
The second option is for restaurant operators to create a table that lists all menu items on one axis and the 14 allergens on the second axis. The allergens in each item are checked marked with an X or a check. The advantage of this format is that the restaurant can put together a master list of not only what they are serving but what they might be serving. Both of these formats make it easy for customers, especially potential patrons who are sensitive to certain foods, to find foods that they can safely consume.
The final option is the most complex as it relies on competent servers and observant customers. The restaurant is required to post signage in a visible location in the restaurant or within the menu that the foods they’re serving may contain food allergens. The signage must also state that customers should ask their servers about potential allergens. This requires servers who know the menu and can answer any questions with regard to the presence of allergens. On the whole, a server in a restaurant in the EU is probably better educated with regard to food allergens than a comparable person in the U.S. This may be function of how they do business. Servers in Europe are generally paid better than those in the U.S. and are able to make a living wage in that role. If one talks with persons who have sensitivity to certain foods, however, the consensus is that one really cannot put their faith in the server, whether they are in the U.S. or in Europe.
Any operation that relies on word of mouth to ensure that the message on allergens is delivered to customers must commit to a training program of some sort to ensure that the servers know the menu and which items contain allergens. This program should also include information on the importance of avoidance for sensitive individuals and what happens when such an individual is exposed to a food allergen. Simply telling people that allergens can cause issues such as gastrointestinal distress, skin reactions, respiratory problems, and, in the worst case, systemic problems such as anaphylactic shock and death, really isn’t adequate. We must emphasize this point with photographs and statistics.
There are other materials available to restaurant operators that they can use to augment their allergen management programs. Wiberg Gmbh, an Austrian ingredient supplier, has developed an allergen awareness document that’s used in menus or posted in restaurants. This chart has also been modified for use as a master list. Each item on the chart is assigned a number or letter and the menu items are flagged appropriately. Other organizations such as WKO have developed similar documents.
Lessons for the U.S.
Could we better identify allergens here in the United States? The answer is a resounding YES. There will be challenges, however. One of those is how restaurants and food service are regulated. Individual states and counties or cities within those states need to establish and enforce regulations based on their interpretation of the food code.
A combination of stronger regulation at the state and local levels and a commitment to protecting customers at the restaurant level could enhance allergen awareness in the food service and restaurant industries. This should include, but not be limited to, clearly informing potential customers what allergens are in the menu items and making sure that service staff are properly educated as to what’s in the menu items and the consequences of food allergen exposure. And, finally, the kitchen staff must put into practice programs to avoid cross contact so that foods aren’t inadvertently contaminated with an undeclared allergen. The Applebee’s and Buffalo Wild Wings models would be good examples to follow. Ideally, any person with a food allergy should be able to look at a menu and be completely confident in what he or she orders.
C14 Food Allergens Defined by The European Union
Cereal containing gluten
Source: European Food Safety Authority