What is the new legislation?
A new EU law will come into effect on 13 December 2014, meaning customers in your pub need to be made aware of any of 14 allergens (listed below) found in any dishes or, in the case of sulphites, wine you serve, should they ask.
Why is it happening?
The law is intended to help customers make the right, and safe, choices when eating and drinking out, in the same way that labelling in supermarkets and shops now highlights allergic ingredients.
What are the allergens?
The 14 allergens are: cereals containing gluten (such as wheat, rye, barley and oats) crustaceans (shellfish), fish, eggs, molluscs, soybeans (soya), milk (including lactose), nuts, peanuts, celery, mustard, sesame seeds, sulphites and lupin flour.
How does it affect me?
Any customer eating in your pub will have the right to have ingredient information provided to them, in particular the above allergens, which may cause a reaction, or something more serious.
The responsibility is firmly on you and your pub to comply with these changes, which are enforceable by local authority fines - of up to £5,000 - if you are found to be in breach of these rules. More serious implications could follow, depending on the severity of the situation.
What do I need to do?
The Food Standards Agency (FSA) is still in consultation with eating-out businesses about final guidance to interpret the law, as are the Department for Environment, Food and Rural Affairs (DEFRA), which are both due imminently. In the meantime, there are a variety of ways we feel you can adequately prepare your business.
Firstly, check with your suppliers - make sure they know what is required of them, and that they are passing on the correct information to you. Keep up-to-date ingredients information for all foodstuffs in your kitchen, including oils and ready-made foods that you use such as sauces, toppings or garnishes. This information should be found on invoices or labels.
We suggest ensuring there is a written, visible and legible sign either at point of purchase, if ordering at the bar, or on menus or clearly visible in the dining area which directs customers to ask members of staff about allergic ingredients.
Make sure all staff are aware of what the allergens are, and nominate one or two people on each shift who to direct enquiries to.
Do I need to provide a written factsheet?
As part of the legislation, it is imperative to have written verification, as a back-up to what staff can orally advise customers. Ensure there is a booklet or folder on site, easily accessible by staff, to confirm which dishes contain which ingredients. If you change ingredients in a certain dish, make sure you update this information and tell staff about the change.
With all the extra paperwork and admin involved, technology has a clear role to play. There are low-cost solutions available that will do the heavy lifting in calculating the presence of allergens in dishes, as well as other nutritional information. These systems can be owned centrally by a multi-site operator but made available to each outlet via PC, tablet or smartphone.
If a customer orders a meal and asks to see allergen information, what should I do?
Ensure your staff check with their nominated allergen specialist on shift, and confirm with the written verification. If they check but are still not sure, make sure they tell the customer this, so they can decide for themselves.
What about the specials board?
This legislation doesn’t herald the end for special boards and changing menus, but ensure that you are updating your ingredient factsheet, as well as your staff whenever you change or add a dish.
What if I need further help?
For further advice, visit the FSA website on guidance for business.
To find out more about technology available to make the legislative changes as simple as possible, or for a free 30 day trial, go to the Fourth Hospitality website.