Preparatory Work on Improving Information in Catering Outlets and for Foods Sold Loose (LSA 13/258) Final Report

Commissioned by the FSA

Ms Brigid McKevith Ms Claire MacEvilly Dr Michele Sadler Dr Judy Buttriss

CONTENTS
EXECUTIVE SUMMARY 1. BACKGROUND INFORMATION 1.1 CURRENT SITUATION 1.2 STRUCTURE OF SECTOR 1.3 TERMS OF REFERENCE 2. REVIEW OF NATIONAL PRACTICE 2.1 INTRODUCTION 2.2 METHODS 2.3 RESULTS OF SELF COMPLETED QUESTIONNAIRES 2.4 REVIEW OF CURRENT GUIDELINES AND RECOMMENDATIONS 2.5 IN DEPTH DISCUSSIONS 3. REVIEW OF INTERNATIONAL PRACTICE 3.1 INTRODUCTION 3.2 METHODS 3.3 RESULTS 4. RESEARCH IDENTIFIED 5. RECOMMENDATIONS 5.1 PROCESS USED TO DEVELOP RECOMMENDATIONS 5.2 RECOMMENDATIONS: ALLERGY AWARENESS 5.3 RECOMMENDATIONS: OTHER INFORMATION 6. CONCLUSIONS REFERENCES APPENDIX A. STEERING GROUP MEMBERS B. QUESTIONNAIRES C. FOOD ALLERGY LABELLING GUIDELINES D. UDEX AND OFSCI E. DETAILS OF RESEARCH IDENTIFIED F. TRAINING RESOURCES 3 7

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56

64 66

75 76 78

EXECUTIVE SUMMARY
INTRODUCTION Consumers have identified a number of different information issues with regard to nonprepacked foods including allergens, date marks, logos and nutrition information. Allergens, the use of healthy eating information, logos and origin labelling are also important issues in relation to catering establishments. In late 2001, the British Nutrition Foundation was charged with investigating the provision of information on these topics (see section 1.3 for details) and making recommendations on the way forward, which are practical and realistic but also meet consumer needs. The object of the project was to: 1. 2. 3. 4. establish what research had been conducted in the past on the issues, establish the current national and international practice, explore the issues in-depth with stakeholders, and make suggestions and recommendations as to how the key issues identified could be taken forward.

METHODS A Steering Group was assembled including members from the different stakeholder groups (see Appendix A for membership). Five questionnaires for self-completion were drafted to obtain information on current national practice, barriers and opportunities, and examples of good practice from the different stakeholders. Detailed questionnaires for caterers and caterers working with schools, manufacturers and retailers were also drafted to be used as the basis for in-depth interviews (see Appendix B for copies of the questionnaires). The self-completion questionnaires were distributed by post/email via members of the Steering Group and by the British Nutrition Foundation to a collated list of contacts within the different stakeholder groups. Simultaneously, 40 in-depth interviews were conducted covering the stakeholder groups and guidelines and recommendations from UK organisations were reviewed. Self-completion questionnaires with an international focus were sent to some internationally-based organisations and information was also gathered via in-depth research with companies with international operations. Information on international initiatives was gathered and the Food Labelling Standards of Codex Alimentarius and relevant EU legislation were also referred to for any information on these issues. The recommendations in this report are based on the information collected via the questionnaires and in-depth interviews, and take account of advice and information provided by the Steering Group. Reviewing existing national and international practices and guidelines has also influenced the recommendations. OUTCOMES It was apparent throughout the project that, of the many factors being investigated, concerns about allergy were considered by far the most important. For this reason, the recommendations focus on allergy and allergen awareness. It was agreed by the Steering Group that the priority should be identification of measures aimed at tackling concerns

about peanuts, tree nuts and seeds, as these are causes of particularly serious allergic reactions. However, consideration has also been given to the other matters included in the remit for the project (see Sections 5.3). Summaries of the main areas covered in the project are given below: 1. Research identified (see section 4) Some research was identified but there is a need for further research on these issues, including identification of the type of information consumers want on foods sold loose or through catering outlets and the type of information they need to be able to make healthy and safe choices about the food they eat. 2. Current national and international practice (sections 2 and 3) There is a diverse range of players involved in the provision of foods sold loose and through catering outlets, some of whom are managing the flow of information more competently than others. Different guidelines have been developed by national and international organisations and these share some common themes. 3. Issues identified by stakeholders (sections 2 and 3) The different stakeholders highlighted allergy as a priority. A need for shared responsibility by those in the food chain and by consumers, especially allergy sufferers, was expressed, as well as a need for agreement on commonly used phrases and terminology to increase effective sharing of information. 4. Recommendations (section 5) The overall aims of the recommendations are: (i) to enable the consumer to make an informed choice by provision of accurate information and (ii) to enable the food supplier (including caterers and retailers selling non-prepacked foods) to provide accurate information to their customers and ultimately to the consumer. With regard to allergy awareness Recommendation 1: The FSA should lend its support to approaches which help establish good operating practices with regard to allergens, particularly with regard to nuts, peanuts and seeds. Recommendation 2: The FSA should work with interested parties to develop an agreed list of common allergen-containing foods or food groups. Recommendation 3: The FSA should work with interested parties to develop a definitive list of tree nuts, as these, along with peanuts and seeds, are recognised sources of allergens associated with particularly severe reactions.

Recommendation 4 The FSA should work with interested parties to develop agreed definitions for terms such as free from and may contain, and agreed processes for declaring the presence of allergens. Recommendation 5 With regard to transfer of information about food ingredients (e.g. allergen status or other aspects of labelling information) as foods move within catering establishments (e.g. when packaging is removed or products decanted for storage), the FSA may wish to consider working with interested parties to develop guidance on the transfer and retention of such information. Recommendation 6: The FSA should work with interested parties to define minimum training requirements in relation to allergy awareness for food sector staff. The aim would be to minimise cross contamination and to facilitate provision of accurate information to the consumer. Recommendation 7: The FSA may wish to consider supporting an allergy awareness scheme that could be constructed along similar lines to the Heart Beat Award Scheme. With regard to provision of other information Recommendation 8: The FSA may wish to consider working with interested parties to develop food based guidelines for defining healthy eating options in catering establishments. These could be based on existing materials such as Catering for Health and the Heartbeat Award Scheme. Recommendation 9: With regard to foods sold non-prepacked that require cooking, the FSA may wish to consider actively encouraging the provision of information on cooking method by retailers by providing guidance on the methods and formats that are already in use, e.g. printing information onto price labels, use of leaflets, verbal communication. This might also be extended to cover storage and durability information for foods that do not require cooking. Recommendation 10: The FSA may wish to consider actively encouraging retailers to provide information on country of origin by offering guidance on the methods and formats that could be used, e.g. printing information onto price labels, use of leaflets, verbal communication. Recommendation 11: The FSA should work with interested parties to develop an agreed list of common definitions for terms such as vegetarian and vegan.

Recommendation 12: The FSA may wish to consider working with interested parties to develop guidance on the transfer of information about ingredients as they move within catering establishments (see recommendation 5). Recommendation 13: The FSA may wish to consider working with interested parties to define minimum training requirements in relation to healthy eating options. The aim would be to facilitate provision of accurate information to the consumer. Recommendation 14: The FSA may wish to consider supporting a scheme such as the Heart Beat Award Scheme to give support and recognition to those companies addressing issues such as healthy eating options.

CONCLUSION Many consumers would like further information on the foods they purchase nonprepacked and from catering outlets. The priority for this information should be for allergens because of the danger allergen-containing foods present to susceptible individuals. However, by also addressing other areas such as healthy eating options, country of origin and vegetarian and vegan foods, the FSA can increase awareness and clarity of these issues, help the food industry to improve its current practice and help consumers to make informed choices about the food they buy. Foods sold loose and through catering outlets are managed by many diverse players, some of whom are managing the flow of information more competently than others. Recommendations outlined in this report are relevant to all players but aim to give guidance specifically to those organisations not currently addressing these issues.

British Nutrition Foundation June 2002

1. BACKGROUND INFORMATION
1.1 CURRENT SITUATION In recent years there has been a significant increase in the number of meals eaten outside the home, with people eating on average around three meals per week, for example in restaurants, pubs and other catering establishments (Buttriss, 2002a; FSA, 2002). In addition, a large variety of foods and meals are now sold non-prepacked from many retail outlets. Table 1. Examples of non-prepacked products and outlets in the UK Examples of products sold non-prepacked: Products available at delicatessen counters Home meal replacements Bakery and cakes Fruit and vegetables Confectionery Fish and meat Examples of outlets: Multiple and independent food retailers Delicatessens Butchers Fishmongers Greengrocers Bakers

In order for consumers to make informed decisions when purchasing such products and when eating out, there is a need for greater provision of information about these foods and dishes. This is particularly important for consumers with food allergy. However, such foods are currently not subject to much of the food labelling legislation. The Codex Food Labelling Standards (1985) do not include foods sold non-prepacked or in catering situations. In the UK, many of the food labelling regulations do not apply to these situations either, although this is likely to change in the future. Even without legislative changes, improvements can be made in the provision of information in catering establishments and for non-prepacked foods. Issues regarding healthy eating and food allergy are becoming more relevant to caterers and retailers. However, alternative methods to labelling are needed for communicating such information.

Recommendations for dietary intakes of population groups have been made by COMA (Department of Health, 1991) and include a recommendation that no more than 35% of total energy should come from fat and no more than 11% of total energy from saturated fatty acids. Salt intake should be about 6 grams per day. Data from the most recently published National Diet and Nutrition Survey of adults were collected in the late 1980s; (Gregory et al. 1990) results from the latest adult survey are due in 2002/2003. However, using the annual National Food Surveys, several positive trends can be identified. There has been a decrease in energy intake and in the amount of fat and saturated fatty acids consumed. Although these trends are encouraging, further reductions are needed to meet the recommendations. Figure 1. Trends in energy, fat and saturated fatty acid intakes 1980 2000 (Department for Environment, Food & Rural Affairs and National Statistics, 2001)

2500

120 100 80 60

Energy intake (kcals per person per day)

2000 1500 1000 500 0

19 80 19 82 19 84 19 86 19 88 19 90 19 92 19 94 19 96 19 98 20 00

40 20 0

Year
Energy (kcal) Fat (g) Saturated fatty acids (g)

The Balance of Good Health (FSA, 2001) is the model used to communicate these recommendations and enable consumers to put them into practice. It describes the different food groups and the proportion each component should contribute to our daily intake. There are also eight accompanying guidelines: 1. enjoy your food 2. eat a variety of different foods 3. eat the right amount to be a healthy weight 4. eat plenty of foods rich in starch and fibre 5. dont eat too many foods that contain a lot of fat 6. dont have sugary foods and drinks too often 7. look after the vitamins and minerals in your food 8. if you drink alcohol, drink sensibly

Intake of fats (g per person per day)

The prevalence of proven food allergy (involving the immune system) in children is estimated to be 1-2% of the population and in adults less than 1%. Food allergy can be life threatening and it has been identified as a major consumer and public health concern (Buttriss, 2002b). Food allergy and food intolerance (the umbrella term used to describe a range of adverse responses to food) are often confused; the overall prevalence of intolerance is estimated to be no more than 5-8% of children and less than 1-2% of adults (Buttriss, 2002b). It is estimated that at least 76% of deaths from anaphylaxis occur from consumption of food prepared away from home (Gowland, 2002). Furthermore peanuts and tree nuts seem to account for the largest proportion of anaphylaxis (Bock et al. 2001, Anaphylaxis website, 2002). Traditionally, allergy has not always been covered in the training for people working in catering. However in 2001 Catering for Health (FSA & Department of Health, 2001), developed by the British Nutrition Foundation, was launched. This resource provides guidelines and practical tips for teaching about healthier catering practices as well as allergy. In May 2002, versions directly applicable for use in Wales and Scotland, also developed by the British Nutrition Foundation, were launched. The prevalence of clinically proven coeliac disease is 1 to 3 cases per 1000 people (Buttriss, 2002b). The only treatment for this condition is a gluten-free diet and if this is not followed, there may be serious negative consequences such as increased risk of small bowel lymphoma (Buttriss, 2002b). The Food Labelling Forum Summary Report (FSA, 2000) identified some issues causing concern to consumers, such as lack of fully comprehensive ingredient listing. The need to be able to identify all ingredients used in the production of a food or drink is seen by some as essential to enable consumers to identify ingredients that they either need or want to avoid. This was emphasised by both vegetarians, of whom there is an estimated 4 million in the UK (Mintel, 2001), and allergy sufferers who need to avoid certain ingredients for ethical or medical reasons. This type of information is likely to also be important to the estimated 250,000 vegans in the UK. The importance of clear country of origin labelling was also highlighted in the report. This information may be important for some consumers who, for example, want to buy or avoid products from a specific country. The need for clearer definitions of terms such as produced in was also raised, on the grounds that current usage did not actually give consumers the information they required. (FSA, 2000). Marketing terms such as fresh and traditional were viewed as being occasionally misleading. The Food Advisory Committee has since developed guidance on best practice in the use of these potentially misleading terms (FAC, 2001a). Quantitative research of about 1000 adults conducted for the FSA investigated what information consumers wanted regarding non-prepacked food (FSA, 2000). It was found that: About of the sample shopped for non-prepacked foods. For such foods a wide range of information was relevant to consumers, but no specific type of information was cited by over a third of the adults surveyed. Consumers were most likely to look for the following information:

Basic ingredients used Use of GM ingredients Presence of additives Size of portions Country of origin Nutritional content Presence of allergens Method of cooking Organic status Animal welfare information Vegetarian or vegan status

34% 32% 32% 29% 27% 24% 23% 21% 19% 16% 13%

A stakeholder meeting organised by the FSA in 2001 identified a number of issues needing consideration in relation to the sale of non-prepacked foods: allergens healthy eating options country of origin logos date marking use of terms such as fresh and home-made

In late 2001, the British Nutrition Foundation was charged with investigating with stakeholders the provision of information on these topics (see section 1.3 for details) and making recommendations on the way forward, which are practical and realistic but also meet consumer needs.

1.2 STRUCTURE OF SECTOR The business sector involved in the provision and sale of foods sold loose and in catering establishments is wide ranging. The industry has many members, from single person, home-based enterprises to large, multinational companies employing thousands. However, all are dependent on others in the chain to ensure the success of their businesses (MAFF, 1999). Figure 2 attempts to give an overview of the different parts of the food chain and how they are interconnected. Manufacturers, retailers and caterers may source raw ingredients directly (e.g. from market gardeners and local fishermen) or they may procure goods via a wholesaler. Some manufacturers produce goods specifically for retail or catering customers, while other products are manufactured then sold and distributed via wholesalers. Some smaller catering outlets may not buy their supplies from wholesalers but may rely on local retailers. Members of enforcement agencies (such as Trading Standards Officers and Environmental Health Officers) may be involved in any number of the various stages along the food chain.

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Figure 2. Structure of Sector

RAW INGREDIENT SUPPLIERS

WHOLESALERS

MANUFACTURERS

WHOLESALERS

RETAILERS

CATERERS

CONSUMERS

Members of enforcement agencies may be involved at every stage

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1.3 TERMS OF REFERENCE The project described in this report focuses specifically on foods sold loose through a variety of outlets and foods available via catering establishments. Pre-packed foods available directly to the public are not considered. The aims of the project were to: establish what research had been conducted in the past on the issues (listed in section 4), establish the current national and international practice (sections 2 and 3), explore the issues in depth with industry, enforcement bodies and consumers, and make suggestions and recommendations as to how the key issues identified can be taken forward (section 5). It was not the aim of this project to obtain statistical information about the provision of information for foods sold non-prepacked and in catering establishments. Rather, the aim was to establish the breadth of current practice, what barriers and opportunities are perceived by the different parts of the food chain, and to identify examples of good practice. This report summarises the findings of an industry-wide survey of current national and international practice; past research conducted is identified. The report also summarises the findings of in-depth discussions with industry representatives, enforcement bodies and consumers and makes recommendations as to how the key issues identified can be taken forward. Abbreviations:
EHO FAC FSA GMP HACCP IFST OFSCI BRC TSO UDEX Environmental Health Officer Food Advisory Committee Food Standards Agency Good Manufacturing Practice Hazard Analysis Critical Control Point Institute of Food Science and Technology Optimum Food Service Supply Chain Initiative British Retail Consortium Trading Standards Officer Universal Descriptor Exchange - a commercial database operator

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2. REVIEW OF NATIONAL PRACTICE

2.1 INTRODUCTION This section of the research project aimed to establish the breadth of practice within the industry and identify issues of concern across the sector. 2.2 METHODS A Steering Group was assembled including members from most of the different sectors (see Appendix A for membership). Five questionnaires for self-completion were drafted to obtain information on current national practice, barriers and opportunities, and examples of good practice from the different stakeholders: Caterers Consumer and Support Groups Enforcement Agencies Manufacturers Retailers

Detailed questionnaires for caterers and caterers working with schools, manufacturers and retailers were also drafted to be used as the basis for in-depth interviews (see Appendix B for copies of the questionnaires). The drafting process involved feedback from the Steering Group at several stages to ensure appropriate wording, a clear and concise format, and adequate coverage of the issues pertinent to the different sectors. The questionnaires for self-completion were distributed via members of the Steering Group and also directly by the British Nutrition Foundation to a collated list of contacts within the different sectors. Questionnaires were returned and information collated and analysed. Much of this information was qualitative rather than quantitative. Because the primary intention was to identify good practice, there was no attempt to identify a truly representative sample, although efforts were made to contact companies based in different areas of Britain and in particular to reflect the broad nature and size of such operations. This process took place during February and March to avoid the busy Christmas period. Simultaneously, 40 in-depth interviews were conducted covering a wide range of food chain sectors and stakeholders. Detailed questionnaires were used for caterers and caterers working with schools, manufacturers and retailers, while for consumer groups and enforcement agencies the basic questionnaire was used. Questionnaires formed the basis for discussion (either face-to-face or by telephone) or were completed and returned by post. All Steering Group members were also involved in the in-depth survey. Guidelines and recommendations from UK organisations were reviewed to provide examples of good practice.

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2.3 RESULTS OF SELF-COMPLETED QUESTIONNAIRES Table 2 shows the breakdown of completed questionnaires that were returned. Distribution of the questionnaires, in itself, will have resulted in an increased awareness of healthy eating and allergy issues, one of the projects aims. Table 2. Summary of Completed Questionnaires Stakeholder Group Caterers Consumer/Support Groups Enforcement Manufacturers Retailers Number 187 20 6 26 9

2.3.1 CATERERS Over 180 completed questionnaires were received from a range of catering establishments including sandwich shops, teashops, pubs, restaurants, staff restaurants and contract caterers serving schools and hospitals. Feedback is presented under two headings: food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. (a) Food Allergens All of the responding caterers were aware of the concerns regarding food allergy and almost all are asked about specific ingredients by their customers. Caterers are most commonly asked about the following ingredients or foods: nuts/treenuts (identified by ~90% of caterers) gluten/wheat (identified by ~59% of caterers) dairy (identified by ~44% of caterers) eggs (identified by ~8% of caterers) shellfish (identified by ~8% of caterers).

About 60% of caterers identify the use of nuts/peanuts when their presence is not obvious within the title of the dish e.g. chicken satay; while only about 26% identify other common allergens in dishes they sell. Customers are informed about the use of ingredients by a variety of methods. Over 50% of caterers rely on their staff providing details when asked by customers but other methods used include signs, labels and notices informing customers to ask for help. However, 3 out of every 10 caterers surveyed do not make their staff aware of the precise contents of such dishes or update staff when changes, such as the addition of nuts, are made. Of the foods and ingredients that are bought in, a third of caterers surveyed do not keep the labels or take a note of label information, even though over 80% of caterers think the

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label is a useful tool for providing information about allergens. Nuts/peanuts are not allowed or used in about a third of the catering establishments who responded. Of those who do use them, over half (57%) do not store or label them differently from other ingredients and over three-quarters do not have any special procedures in place when preparing dishes containing nuts. Over 50% of responding caterers had received information about food allergies from sources such as Research Associations, company information, trade journals, other media sources, the Anaphylaxis Campaign and EHOs. About 70% of caterers have regular staff training sessions, with allergies included as a topic in over half of the catering operations responding to the questionnaire. About 50% of respondents have standard advice for customers with food allergy, ranging from notices advising customers to inform them if they have allergies to signs warning customers that dishes can not be guaranteed to be nut free. We need more information about contents of food and why and what causes allergies (comment from one of the responding caterers) (b) Consumer Choice Aside from the issue of allergy, it appears from the responses that customers ask caterers mainly about cooking methods and specific ingredients, suggesting perhaps a need for specific information rather than just general healthy eating information. Over 80% of caterers claim to provide healthy eating choices. Dishes for those looking for healthy eating choices may include: low fat vegetarian, and low sodium options, with salads, pasta and baked potatoes given as examples by respondents. However, the suitability of all the options promoted as healthy eating is not known. There seems to be some confusion about the meaning of terms, with some of the responses from the enforcement agencies highlighting this. Those caterers who do provide the above options also use a wide variety of methods to inform their customers of availability, although staff providing details when asked was the most commonly given response. About one-third of responding caterers do not receive nutritional information from their suppliers or wholesalers; half who do get this type of information receive it from some suppliers/wholesalers and less than 10% get this information from all suppliers/wholesalers. Labels and product specifications are the main ways of communicating this information.

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Figure 3. Types of Healthy Eating Information Asked About by Customers

Catering: Do customers ask for information about healthy eating choices

Number of respondents 100 80 60 40 20 0

No

Yes - healthy Yes - specific Yes - cooking choices ingredients method

Almost all caterers (94%) who responded offer vegetarian choices some or all of the time. Vegan dishes are offered less frequently, with 50% of caterers offering vegan options some or all of the time. However, it is unclear what definitions caterers are using with respect to these terms. These options are mainly communicated to customers via the menu. Most caterers provide information about portion size and the cooking method used and often use descriptions like fresh, home-made and traditional (although one caterer noted they were removing these in line with a recent FAC report). Fewer caterers who responded provide information about country of origin. About 40% of caterers who responded to the questionnaire are asked by their customers for information regarding portion size. Fewer customers ask for information about country of origin and about 60% of caterers are asked whether the food is fresh or home-made and for information about cooking method. Most caterers do not use the internet for sales or delivery to customers but 50% use the telephone, with some providing information to customers via their menus or information leaflets. Comments from responding caterers included: We could give more choices for vegetarians but often forget Restaurants should provide more choice for healthy options which are heart friendly.

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2.3.2 CONSUMER AND SUPPORT GROUPS Twenty completed questionnaires were received plus comments from several organisations. Feedback is given under the two headings used in the questionnaires firstly issues when eating out and secondly issues when buying non-prepacked foods. It was indicated in the questionnaires that personal opinion (as opposed to consumer research or enquiries) was the basis of many of the responses from this sector. (a) When eating out Most respondents in this sector identify nuts/peanuts as the most important allergens, although many other allergens also rate highly, such as shellfish. A number of other allergens were identified by respondents within this stakeholder group that were not listed on the questionnaire (grouped together as other) including latex, wheat and sugar. Interestingly, whilst allergy to wheat gluten and to latex are well established, sugar is generally not regarded as a source of allergic reaction. Figure 4. Importance of Common Food Allergens as Ingredients When Eating Out
Consumer & Support Groups: Importance of common food allergens as ingredients when eating out 20
nuts/peanuts

15 10 5 0 1 2 3 4 5
Scale of importance (1 = not important & 5 = very important)

sesame seeds fish shellfish eggs soya milk other

With respect to healthy eating choices, most of the consumer and support group respondents felt information on the ingredients used is very important for ensuring consumer choice and safety. Gluten-free logos or statements are rated as very important, followed by similar information about vegetarian items. Over 50% of respondents thought information on country of origin and portion size moderately important, giving them a score of 3 or 4 on the scale of importance (1 being not important and 5 being very important).

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(b) When buying non-prepacked foods Respondents were asked to rate the importance of information on common food allergens as ingredients. A number of common food allergens are deemed important, with information on the use of nuts/peanuts and shellfish being viewed as most important. Figure 5. Importance of Common Food Allergens When Buying Non-prepacked Foods
C onsumer & Support G roups: Importance of com mon food allergens as ingredients w hen buying non-prepacked foods
20 nuts/peanuts

Number of responses

16 12 8 4 0 1 2 3 4 5

sesam e seeds fish shellfish eggs soya milk other

Scale of importance (1 = not important & 5 = very important)

Information on ingredients used is again thought to be the most important information to be provided. Gluten free symbols were also deemed important, followed by vegetarian logos/statements. Most people thought use by dates are also important. Information on the quantity of ingredients and country of origin scored towards the higher end of the scale and, therefore, information on these issues appears to be moderately important. Most thought cooking instructions for raw or uncooked foods sold loose would be useful. Introduce a labelling option which indicates where allergens are used on site although not in the product, thereby allowing the consumer to make realistic risk assessments (one consumers comment)

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2.3.3 ENFORCEMENT AGENCIES Only 6 questionnaire responses from enforcement agencies were obtained. However, 3 additional in-depth interviews also took place (see section 2.4.3). Feedback is given under the two headings used in the questionnaires firstly about eating out and secondly about non-prepacked foods. (a) Eating out Concern about the food allergens in nuts/peanuts, sesame seeds and milk in an eating out context were topics enforcement officers have experience of, with these concerns being raised several times a year in this setting. Concerns about healthy eating, vegetarian/vegan dishes and products, and the use of descriptions arise 4-5 times per year. One respondent reported an increase in complaints from the public regarding businesses promoting misleading healthy eating, vegetarian and vegan dishes. The complaints often related to the promotion of menu items as vegetarian or low fat and suggest there may be some confusion with the interpretation of these terms by some businesses. This was highlighted by the following examples: a bought-in low fat dish having grated cheese added to it yet still being described as low fat fish dishes being given as examples of vegetarian dishes.

(b) Non-prepacked foods With regard to the sale of non-prepacked foods, enforcement authorities have experience with many different allergens, with each responding enforcement officer dealing with concerns about nuts/peanuts occurring up to 10 times a year. They also deal with other issues including country of origin (about 6 times per year), vegetarian/vegan (about twice a year) and the use of descriptions such as fresh and home-made (also about twice a year). Legally define claims so that the consumer/enforcement agency has an unambiguous understanding of their meaning and the assurance that wherever they are used they mean the same thing (recommendation from an enforcement officer).

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2.3.4 MANUFACTURERS Feedback is presented under two headings: food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. (a) Food Allergens Most companies who responded to the questionnaire request information from their suppliers about nuts/peanuts, as well as other ingredients including soya, egg, fish, shellfish and seeds. Some manufacturers also collect information on a range of other ingredients such as the antioxidants BHA and BHT, and food colours. Information of this kind is mainly supplied in the form of a company specification or questionnaire and kept within the specification system. This information is then used in various ways, including the final product specification and ingredient labelling. Most manufacturers request special operational procedures from all their suppliers with regards to nuts/peanuts (some use audits and questionnaires while others refer to the HACCP systems in place). Fewer manufacturers require this type of information for other allergens, even though many immediate clients ask about a number of allergens i.e. not just nuts/peanuts. Of those manufacturers who use nuts/peanuts, most store them in a separate area with distinctive labelling. Special procedures are often in place e.g. separate containers used to transport ingredients on site; segregation procedures which are audited; dedicated line/plant; clean down procedures following production. Most staff receive training about food allergy (mainly at induction) and are briefed on the contents and changes to products. Provide criteria for what free from means (recommendation from a responding manufacturer). (b) Consumer Choice Over half the manufacturers provide products (to be sold as loose foods or via catering outlets) that represent healthy eating choices. They often form part of a healthy eating range, with claims also being made on the label. A similar number of manufacturers produce vegetarian products and about 30% produce vegan products. Some but not all of these products carry a logo or statement. Where applicable, about half the manufacturers provide cooking instructions for raw/uncooked foods.

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2.3.5 RETAILERS Feedback is presented under two headings: food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. (a) Allergens Most of the retailers who responded sell a variety of non-prepacked products (see Figure 6). All respondents were aware of concerns about food allergy and claimed awareness of ingredients used for all of their non-prepacked products. Some have special procedures in place for the display and service of products containing nuts/peanuts, such as notices on service counters. Most, however, have no special procedures in place for products that may contain other allergens. Most responding retailers do not sell non-prepacked nuts/peanuts but one retailer sells them at Christmas in their shells. Another respondent who sells non-prepacked nuts/peanuts has a notice on the counter warning customers of the unsuitability for allergy sufferers of food items. If customers require information, respondents rely mainly on informed staff to answer customers questions and/or the use of display tickets. Most retailers are asked about nuts/peanuts in products and other allergen-containing foods such as wheat, egg and milk. Tomato was also mentioned by one responding retailer as a allergen-containing food that customers enquire about, although this is not a common cause of allergic reaction. Only about half of retailers who responded to the questionnaire brief their staff on the contents and changes to dishes being served.

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Figure 6. Range of Products Sold Non-prepacked by Retailers

Retailers: Types of Products Sold Non-prepacked by Retailers
10

Number of Retailers

8 6 4 2 0
pr u od ct s i el pr u od ct s sh Fi & r c it d tp ru F ke ea o m co t& ot H ea M g ve c hi ke n u od ct s a ls zz ea pi m & e ay ad ick m P aw dy ke ea Ta R ix m er th O

Ba

y er

(b) Consumer Choice Consumers often ask about healthy choices, including the use of specific ingredients and cooking methods. Most retailers have some items which are promoted as healthy choices, mainly through display tickets. Examples of such items include: the salad bar half fat cheese no salt added turkey breast. All of the responding retailers provide vegetarian options and over half also provide vegan options. Customers are informed about these either by staff when asked and/or through use of a display ticket. All retailers provide information about use-by dates/shelf life. Some use descriptions such as fresh and home-made, or provide details on country of origin. Customers most often ask for information on use by dates and the country of origin. For those retailers with internet or telephone services for ordering and/or delivery of food to consumers, the above information is still available to customers - either via a website icon or via the call centre. Most responding retailers provide cooking instructions for raw/uncooked foods. We provide information by a number of means including display tickets, free from listings, website information and a series of fact sheets (examples from one responding retailer of different ways information is provided).

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2.3.6 SUMMARY OF KEY POINTS Many different comments where received from the questionnaires. However, some practical steps were suggested by all of the groups. These include: Better labelling of foods, possibly abolishing the 25% rule as allergic people need full, clear ingredient lists. (Many manufacturers already voluntarily ignore the 25% rule, particularly for nuts and peanuts). Further training would be useful for all. This could include introduction of key issues to vocational courses at catering colleges. Guidelines on allergens would be beneficial including guidance on which allergens should be identified, how they should be identified (e.g. common name), the levels of allergens which cause sensitivity. Set phrases and criteria for what is meant by the terms vegetarian and vegan. Concerns regarding legibility and readability were raised in relation to labels and/or written information. The use of symbols, logos or colour-coded panels were suggested as alternatives.

A number of barriers were perceived by the respondents. These are summarised below: Cost implications were seen as a major barrier by most groups. Consumer groups perceived a reluctance on the part of manufacturers and caterers to respond to concerns. This perception was not echoed by those respondents from industry. Some respondents believe legislation may be needed in this area to ensure adequate attention is given to the issues across the food chain. However, many caterers did not think legislation would be helpful, as many smaller operations already struggle with meeting their business and legal responsibilities. On the other hand, more sophisticated businesses already have a range of policies in place. Some responding retailers regarded keeping relevant information with products that are to be sold loose a difficult task because of the large number of products stocked. As different manufacturing sites and different suppliers may be used for raw materials, manufacturers highlighted the need for flexibility with regard to provision of information e.g. overtly prescriptive legislation would be restraining. It was also noted that the range of food products and their composition are constantly being updated and evolving how are these concerns to be addressed and communicated?

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2.4 REVIEW OF CURRENT GUIDELINES AND RECOMMENDATIONS Over the years, a number of guidelines have been drafted and disseminated to try and address some of the issues covered in this project, especially allergens. These include: the FSAs Be Allergy Aware, the British Retail Consortiums Technical standard and protocol for companies supplying retailer branded food products, the British Retail Consortiums Guidelines for the Handling of Nuts, the Food and Drink Federations Food Allergens Advice Notes, the Institute of Grocery Distributions Voluntary Guidelines for Food Allergens and Gluten, the Anaphylaxis Campaigns Severe food allergies: guidance for caterers, the FSA and Department of Healths Catering for Health, the FSAs Dine out, Eat well, the Vegetarian Societys Catering pages, the Heartbeat Award Scheme, the FAC Committees Review of Food Labelling and Review of the use of the terms Fresh, Pure, Natural, etc in Food Labelling, and guidelines and information from Coeliac UK.

These resources have been reviewed and components of the guidelines have been incorporated in the recommendations of this report.

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2.5 RESULTS OF IN-DEPTH DISCUSSIONS Table 3. Summary of the Completed In-depth Discussions Stakeholder Caterers Consumer/Support Groups Enforcement International Manufacturers Wholesalers Retailers Number 14 3 3 4 7 2 7

2.5.1 CATERING Feedback is presented under the headings food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. Examples of barriers and opportunities given by the respondents are also shown. (i) Large Group Caterers (n = 4) (a) Allergens All were aware of the issue of food allergy. All had experience of customers asking about the use of nuts/peanuts and other potential allergen-containing foods such as eggs, milk, fish, shellfish, additives and sesame seeds. Caterer 1 The company instigated a project on allergens, which is now into its third year. The aim is to develop a common framework across all the groups branded restaurants and hotels. SUPPLIER INFORMATION: The company policy requests all suppliers to have a GMP and HACCP-based strategy for use, handling and declaration of nuts and their derivatives. The company requests information from suppliers in the form of product data sheets, and these are filed centrally by the technical services department. Difficulties are sometimes encountered in getting such information from suppliers. For example some small suppliers do not understand what is being asked, and large companies do not always want to divulge brand information. The information is used to develop allergy data sheets for menu items, and to enable staff to respond to customer enquiries. Labels on locally purchased supplies are seen as a useful means of providing information, but they would be more useful if all the main allergen-containing foods and ingredients were declared. International suppliers have to provide the same level of information as UK suppliers.

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STORAGE AND PREPARATION: HACCP and Standard Operating Procedures are in place across the company. For allergy sufferers, special procedures are in place that relate to taking an order, preparing and serving the meal. TRAINING: Food allergy is covered in staff training. Staff are informed about the ingredients used in dishes as the menus change. DIALOGUE: The menu highlights the use of main ingredients, such as fish and shellfish. Logos are not used to highlight nuts or other main allergen-containing foods. The menus have a statement that allergic customers should ask for the duty manager who will explain the companys policy, and share with the customer the precautions that the company is able and is not able to take. Information provision to customers is taken seriously in order for allergy sufferers to be able to choose dishes with confidence. Caterer 2 SUPPLIER INFORMATION: Most suppliers provide information about the use of nuts and other allergen-containing foods, in the form of specification sheets, which are filed to retain the information. A manual is prepared for communication of this information within the company. May contain labelling for nuts is assumed to reflect well-controlled systems and notice is taken of the information. Some suppliers are requested to have special procedures e.g. biscuits are used as a bar snack, rather than nuts, and the biscuit supplier must ensure that nut lines are not run next to biscuit lines. The company does not rely on product labels, which are not considered a useful method of communication. STORAGE AND PREPARATION: Nuts present in kitchens are not stored differently to any other ambient ingredient, and dishes containing nuts are not prepared any differently to other dishes. TRAINING: Staff induction training includes anaphylaxis. Further training covers other aspects of food allergies. Staff are informed about menu changes. DIALOGUE: The use in dishes of nuts or other foods containing potential allergens is not pointed out on the menu. There is a general menu declaration, advising people with special dietary requirements or allergies to ask for the manager. The company has an advice and instruction document, relating to communication with the customer, that ensures the hotel is prepared if a customer with food allergy asks for information. This policy relates only to communication with the customer. At corporate events clients are asked in advance about special dietary requirements. The company had 3 cases of anaphylaxis last year. In one case, a wedding, they knew in advance that a boy was allergic to nuts. Everything was carefully controlled and checked. When the boy went to bed, chocolates for the adults were brought out, which had almonds on top. Unexpectedly the boy came back into the room and ate one of the chocolates with a big visible almond on the top.

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In the other 2 cases the customers did not tell staff that they were allergic and presumably assumed there were no ingredients that would cause them a problem. Caterer 3 SUPPLIER INFORMATION: As a company supplying products to the rail industry, additives and ingredients are discussed with clients at menu presentations, and this dialogue includes nut derivatives and seeds. The companys own suppliers are requested to provide information about the presence of nuts and peanuts and possible crosscontamination during production and storage. Product labels are not considered useful for this purpose and all ingredients and additives must be listed on the product specification sheet, including the major allergens. Though information is requested from suppliers it is not always forthcoming from international suppliers. The information is retained on a database, and copies of the specification sheets are passed onto the train operating companies. Books containing menu information are given to members of the on-board catering staff. These state whether the products contain nuts, but not other major allergencontaining foods. STORAGE AND PREPARATION: For nut-containing products, suppliers are requested to have a separate production line and storage area, or to use the last production run prior to cleaning. TRAINING: The company has received information from The Anaphylaxis Campaign. On-board catering staff have training on the subject of food allergy. DIALOGUE: The company does not have a policy or advice for consumers with food allergy. However, on-board catering staff have information on ingredients, and menus include the statement that some items may contain nuts. Other allergen-containing foods are not highlighted. Staff are briefed as menus change. Caterer 4 SUPPLIER INFORMATION: Information is requested from suppliers about all uses of nuts and peanuts and about the use of the other main allergen-containing foods. May contain nuts labelling is interpreted by the company to mean a risk of extraneous contamination and customers are warned accordingly. Ingredient information, received in the form of a product specification sheet, is retained as a manual copy and is also stored electronically. In addition, the label is considered a useful means of providing information. STORAGE AND PREPARATION: Suppliers are not requested to follow any special operational procedures. Nuts are not stored differently to other ambient ingredients. There are no differences in the preparation of dishes containing these. TRAINING: Information has been received from The Anaphylaxis Campaign. The company has regular staff training that varies between the branded restaurants, but food allergies are generally not included.

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DIALOGUE: On average 1 request per month is received about nuts/peanuts on the guest-care help line (company serves 1.5 million meals each week). There is a similar frequency of requests for information about gluten, milk and shellfish. Customers are mainly informed about the presence of nuts/peanuts only where their presence contributes to the character or flavour of the dish. However, in some of the companys branded outlets where there is more demand for information, the presence of nuts, milk and shellfish is highlighted. Staff are briefed as menus change and they can provide more details to customers if asked. Most restaurants in the chain have nuts on the premises and the policy is to make customers aware that there is a risk of contamination in any product. (b) Consumer Choice Caterer 1 Customers ask about healthy choices, the use of particular ingredients and how dishes are cooked. Some menus show Weight Watchers points, and there is a programme of salt reduction for recipe dishes. Otherwise healthy eating is not a primary focus. Customers ask for vegetarian and vegan options. All menus show choices that are suitable for vegetarians and staff can provide further details. Portion size (uncooked weight) is shown for steaks and gammons. Marketing terms (such as fresh and home-made) reflect advice from the FAC. Country of origin may be used as a quality designation such as Scottish salmon, Spanish chorizo sausage. Cooking methods are extensively indicated on menus. Caterer 2 Healthy eating choices are indicated as Lighter or Healthier options on some menus, or as ticked products. Examples are grilled chicken, cottage cheese and pineapple. Healthy eating options not usually requested for events with a pre-set menu, e.g. weddings. Vegetarian dishes are available and are requested more frequently than vegan dishes. Staff are informed which dishes fall into these categories, and these choices are also indicated on the menu. The company undertakes a lot of corporate business and asks in advance for information about special dietary requirements. Menus indicate portion sizes. Marketing terms (such as fresh and home-made) are used but the company is aware of legality issues. Menus also indicate country of origin and cooking method. Caterer 3 Customers do not ask for healthy choices. However, the company provides salads, fish dishes, low-fat and low calorie products and low calorie beverages. This information is printed on menus. The company requests nutritional information from all suppliers. The company provides vegetarian but not vegan options, and customers are informed about the status of these dishes on the menu. Hence customers do not generally ask for information about vegetarian or vegan choices.

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The uncooked weight of steaks is provided but not of other items. Marketing descriptions are generally avoided. Regional labelling is used on the menu e.g. Welsh lamb, but not country of origin labelling. The cooking method is generally indicated. Customers ask very occasionally about cooking methods, but not about portion size, fresh/home-made, or country of origin.

Caterer 4 Menus are generally moving more towards fresh steamed vegetables, char-grilling and salads. Customers rarely ask for information about healthy eating choices. Some suppliers provide nutritional information to the company. The menu is the main source of information for customers. Customers rarely ask for information about vegan choices, but there are generally 2 requests per month to the central guest careline about vegetarian choices. Vegetarian dishes include broccoli bake, lasagne and various pies; there are no vegan dishes. Information about vegetarian dishes is printed on the menu. Use of marketing terms such as fresh and home-made are challenged internally within the company and there has to be filed evidence to support use of the claim. British is sometimes used where traceability supports use of the term. The cooking method is indicated in virtually all menu descriptors. Customers ask for information about portion size, but not about country of origin or cooking method. (c) Barriers and opportunities identified by the above caterers Consumers with known allergies must be made more aware of the need to ask, and not be made to feel a nuisance. The challenge of obtaining accurate allergy information and presenting it as consumer-friendly, meal-based information is practically impossible for small singleunit businesses, particularly as the 25% rule makes is difficult to assimilate allergen data. Staff need to have detailed product knowledge or easy access to it, and not just rely on discarded packaging. The onus should be on food suppliers to provide information in an easily accessible format. The main focus should not be on menu information/labelling, but on the requirement to maintain comprehensive reference guides ready for when the consumer asks. However, the retail and catering trades perceive the provision of information as difficult and expensive, particularly the need for training in a sector with a traditionally high turnover of staff. Most emphasis from consumers is on allergens there are more requests than for healthy eating information and it is therefore important to prioritise allergens over healthy eating. There is a danger that if it becomes practice for the more common allergens to be selectively listed on menus that a caterer could be liable to legal action if a less common or unrecognised allergen produced a reaction. Web based solutions have a key role to play in the better provision of allergen and intolerance data to both restaurants and customers. In the near future all allergen and

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intolerance data will be supplied electronically and automatically downloaded onto the product database via a Website. This will be a much more efficient means of gathering allergen and intolerance data than the present method of using manual specifications. The process of producing product data sheets and supplying information to restaurants, customers and the care helpline can be automated, giving the opportunity to have complete information available. However, two barriers remain that do not make extra controls commercially viable the risk of contamination in the kitchen and the small size of the market. (iii) Contract Caterer (n = 1) The company has different arms that include (1) Contract Catering e.g. for companies, hospitals and schools, (2) Retail Outlets e.g. at stations and airports, (3) Motorway Services and (4) Leisure e.g. for one-off catering situations such as large events. Discussion with the audit department across the whole group is summarised below. (a) Allergens Situations vary across the company, but there is an overall policy for food allergens and food intolerance. SUPPLIER INFORMATION: Suppliers are asked for technical specifications including whether the products are free from a range of allergens. The only two possible answers are (1) yes and (2) no. Suppliers are also asked for information about the production facility i.e. are nuts present? Again the two possible answers are (1) yes and (2) no. If yes, suppliers are asked what preventive measures are taken to avoid cross contamination. International suppliers have to provide the same specifications as UK suppliers. If a supplier says a product may contain nuts the company wants to know yes or no. The company would investigate the factory, check their controls and ask questions. STORAGE AND PREPARATION: In some catering units, the company has no nuts or nut oils on site. In others the indiscriminate use of nuts is avoided. However, where nuts and nut products are used they are not stored separately as there are limitations on space. Also, it would be very difficult to implement special operational procedures and check that these are being rigorously followed. TRAINING: The company has its own training department and induction training includes food allergy topics. DIALOGUE: Customers ask about nuts, lactose and occasionally about gluten. Schools are the main clients that request information about nuts. Retail outlets display a statement about the presence of allergens, advising customers to ask staff on display. Staff have access to an operating manual in which they can check the product specification. Alternatively they can contact the audit department. The issue is more difficult to deal with in the retail situation, as the customer wants to buy immediately. In a canteen situation, the customer is seen regularly and there is time to find out information and give advice. In catering units, staff are told daily what dishes are available and what ingredients they contain. In schools with allergic children, the schools would be told

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about the use of specific ingredients. However, there is never a guarantee that a product or dish is nut free, and so it is very difficult to give absolute information. For the branded products that the company sells e.g. salads, the manufacturers state may contain traces of nuts. In order to be more helpful to the nut allergic customer the companys own branded products provide more information. For example, if the products are made in a factory with nuts but nuts are segregated, they state made in an environment where nuts are present but every precaution has been taken to avoid their presence. (b) Consumer Choice Healthy eating is a big topic in schools because of government guidelines. Product specifications are requested and are checked for every product. A nutrition consultant is employed to deal with this. Other than for schools, it is up to the catering unit manager to source low fat and healthy eating products depending on customer requests. Some in-house units have sandwich ranges that are less than 300 calories. The sandwiches have a healthy eating statement about being based on recommendations by BNF and government reports aimed at reducing fat, sugar, salt etc. The company has healthy recipes to which all catering units have access. Canteens offer vegetarian choices, indicated by shelf talkers. The dishes are categorised as vegetarian according to the suppliers definitions. Product specifications are checked carefully to ensure cheese is vegetarian. The companys own vegetarian logo is used on branded products where appropriate. Country of origin when the dioxin problem and the animal-feeding problem in France arose, customers asked particularly about meat origin. With contract catering, these matters can be attended to individually, e.g. if a client asks for English apples these can be provided, depending on the economics of the situation. Country of origin is not flagged up on shelf talkers or labels. The company has the information and could provide this detail if requested. However, the buying arrangements are constantly changing, and thus country of origin may change. (c) Barriers and opportunities identified by the above Contract Caterer These issues are being discussed across the food service sector. One of the key issues is supplies coming into catering establishments where there is no requirement to provide on-pack information, as there is for retailers. For their own-label products some wholesalers do an excellent job in providing information on the outer pack, but this is not always available from branded suppliers. Smaller suppliers/wholesalers do not even know what a product specification is. A standard specification is needed with a legal requirement to provide a minimum level of information that has to be passed to caterers with the products. It should be communicated on outer packs as a prerequisite. OFSCI (Appendix C) is one initiative that is discussing what information needs to be provided. Manufacturers are putting their on-pack information on the UDEX database. For food service they are deciding what allergen information should be included as a mandatory requirement. It can easily be accessed, making information flow easier for everybody. Already 60-70 manufacturers are signed up, which

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accounts for 80% of the groups suppliers. Niche suppliers e.g. patisserie bakers do not have the resources or back-up to comply. There needs to be legislation as there was for genetically modified (GM) foods. Until labelling of GM ingredients became a legal requirement, suppliers would not provide the information when requested, saying there was no legal requirement to do so. However, once this became legal, the company was flooded with information. During discussion with the Government Services arm of the group it was explained that if a customer with food allergy informs staff, the catering unit manager will do their best to ensure that appropriate meals/dishes are provided. The company nutritionist checks the product specifications for suitability. The company has nominated suppliers for particular types of ingredients e.g. chicken nuggets, but some dishes are home-made such as shepherds pie. In schools, parents let staff know that their child has an allergy to nuts or to other ingredients. The kitchen has a photograph of the child pinned up for recognition, and there is a notice of what to do if the child has an anaphylactic reaction. The nutritionist determines what the children can and cannot have, and special dishes can be provided if necessary. Parents can see the product specifications if they wish. Sometimes parents provide dishes themselves. There seem to be more children coming through with allergies, especially to nuts. Recently two headmasters called in one day concerning children with nut allergies it is unusual to have two such calls in one day. On the healthy eating side, chefs are advised not to use salt and not to put salt on the table. They dry fry and do not use oil. The same generally applies to adult provision (e.g. Prisons, Police and Ministry of Defence). A vegetarian and a healthy option are provided each day.

(iii) Schools Policy (1 city council and 1 county council) The county council policy is to avoid the use of nuts as an ingredient and to avoid supplies that may contain nut traces, but there is no policy for other allergencontaining foods. The city councils policy is that no peanuts or by-products are allowed. The county council has warning notices in the schools stating that they cannot be 100% sure that all traces of nuts have been avoided. The city council has an arrangement that schools contact the council over such concerns. In practice, in both areas, schools have a list of children with allergies. The kitchens adapt menus to suit these children, on an individual basis. For healthy eating, the city council does not go beyond government guidelines. The county council is very strong on healthy eating and its menus are nutritionally analysed. It focuses on buying the right foods and cooking them in the right way. They try to direct children to make healthy choices through pricing. Both councils have strong policies on avoiding certain food additives. The county council felt that they probably did not communicate this very well and were not sure how aware teachers and parents were of the policy. Non-meat options are available every day in schools and this is communicated via the menu in both areas. 32

Other topics that parents ask about include BSE, dolphin friendly tuna and aluminium.

(iv) Hospital (n = 1) (a) Allergens The kitchen caters for patients, visitors and nurses. Nothing is made in the kitchen, everything is bought in ready-made. In view of nut allergies they try to avoid buying products that contain nuts. Their supplier has worked to ensure that products are nut-free. Products labelled as may contain traces of nuts are avoided. For patients, a nut disclaimer is printed on the menu stating we cannot guarantee these products do not contain nuts. If you suspect that you have a nut allergy, please ask the nurse. The product specification and label are a starting point for information. The kitchen will call the suppliers dietitian if there are any specific queries. The hospital previously experienced a situation where their supplier changed a product and did not inform them that it now contained nuts. There were allergic reactions to the product. Where patients have other food allergies, the nurses are told and the patient is to be put on a special diet. Menus are adjusted for these patients individually. For the dining room (visitors and nurses), a nut disclaimer is not displayed, and the presence of allergen-containing foods is not flagged up. Customers must therefore ask the staff, and requests may filter down to the kitchen. The kitchen staff do not have training on allergens/allergies. They get their information via the dietitians, trade journals such as the Caterer, and they learn by experience (b) Consumer Choice For patients, healthy options are flagged up with a heart logo, which is done by the dietitians. Visitors or nurses must ask the catering staff, or rely on their own knowledge of what is and is not healthy. Vegetarian choices are provided every day, are indicated with a V symbol on the menu. Kitchen staff are rarely asked to cater for vegans, but can buy in appropriate products as necessary. If the kitchen staff were expected to provide more information to patients, visitors and nurses, they would print up and laminate the information, and display it for those who want or need to read it. (v) Group of Branded Chain Restaurants (n = 1) (a) Allergens The company is aware of food allergies. Customers occasionally ask about nuts, but not very often. When they do ask, it is usually about nuts in general rather than specific nuts. Customers do not often ask about other potential allergens as far as the company is aware but some queries include a customer asking about gluten, and whether a dish was truly vegetarian.

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SUPPLIER INFORMATION: The company does not rely on the label for information about supplies, mainly because of the 25% rule and because the law is vague for labelling food supplies to caterers. The purchasing department retains the specification sheets. Suppliers are asked to indicate if products contain nuts. If the company cannot be assured that products do not contain nuts, they put an n on the menu beside the dish concerned. The company does not have the same controls or traceability for other allergencontaining foods. STORAGE AND PREPARATION: Nuts in kitchens are stored in separate containers, with a dedicated spoon, and are not stored above other foods. Special precautions are taken in the kitchens and food handlers are trained not to get nuts onto other foods even from contact with the spoon used to handle them. TRAINING: Food handlers and managers are trained in allergy, but the waiting staff are not trained. Waiting staff are told to ask the duty manager if a customer has a specific request. In general, the company does not get many queries. DIALOGUE: The presence of nuts is pointed out on the menu with an n symbol. There is also a disclaimer that great care has been taken, but the company cannot guarantee the absence of traces of nuts in other dishes. Solicitors were consulted on this. They do not flag up the presence of other potential allergens. Each menu has a telephone number and the name of a person that customers can contact. A customer with nut allergy or other severe allergy is welcome to enter into dialogue with the company, and information can be ascertained from suppliers about the suitability of dishes for the customers needs across the range of company restaurants. The company would go out of its way to be helpful to the individual if asked the specific questions. (b) Consumer Choice Customers do not ask about healthy eating. The company does not flag up healthy dishes as this is not an issue in their restaurants. Customers are out to enjoy themselves! The company could get nutritional information if it was needed. The company does provide vegetarian dishes and these are indicated by a V symbol on the menu. This means dishes contain no meat or fish. They do not provide vegan dishes per se, but customers can make their own vegan choices e.g. from the salad bar. If asked, staff can provide more details about these matters, and questions sometimes filter through to head office. The company can go back and ask its suppliers if necessary. Menus routinely provide the portion size of steaks and burgers. Some marketing terms are used, but less so following the Food Advisory Committee advice. Menus do not generally provide country of origin labelling, unless for quality purposes e.g. Italian sausage. Customers sometimes ask how dishes are cooked, if the menu has not fulfilled their curiosity. But most realise burgers are grilled.

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The company has home delivery for some of their Italian restaurants, but customers buy from a flyer or have seen the menu, so they have the same details as on the menu when ordering.

(c) Barriers and opportunities identified by the above branded chain Customers are out to enjoy their meal, and whilst the restaurant is doing everything to protect the health of their customers with regard to microbiological matters and nut matters, the company does not feel, unless it is advised otherwise by the Food Standards Agency, that it wants to go any further. If told to, it will of course take heed. A balance has to be struck to provide appropriate amounts of information. The company helps with enquiries and enters into dialogue with customers and with suppliers. It always does its best to help if there is a query to which it does not already know the answer. (vi) Multiple Retailer In Store Caf (1) (a) Allergens SUPPLIER INFORMATION: The company requests information about all uses of nuts and peanuts and other major allergens. This is provided as a specification sheet, and the information is retained electronically. It is used to develop free-from lists, which are provided for customers following a range of special diets. Labels and packaging are not therefore used. Suppliers are requested to follow British Retail Consortium guidelines. STORAGE AND PREPARATION: Nuts and peanuts are not used as a separate ingredient, and dishes containing nuts are avoided as far as possible. However where dishes do contain nuts and peanuts they are not prepared any differently to other dishes. The majority of food items available are bought from the shop floor, and thus vary depending on availability. TRAINING: Information has been received from the Anaphylaxis Campaign, MAFF and the British Allergy Foundation. Staff have regular training but allergies are not included. As the in-store cafe is a multi-skilled area training focuses on hygiene, particularly as the staff change regularly. DIALOGUE: Customers ask for information about nuts, milk, eggs, fish, shellfish, soya, maize, wheat, citrus fruit and various additives. The company points out the use of nuts but does not differentiate between different nuts. It does not point out the presence of other allergens where this is not obvious. Customers are advised by point of sale information that dishes could contain nuts and it is recommended that customers with nut allergies do not use the caf or that they choose prepacked items. (b) Consumer Choice Customers ask about healthy eating options and the canteen serves products from its own-label healthy eating range. Customers are informed about this via the menu. Nutritional information is requested from suppliers.

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Customers ask about both vegetarian and vegan choices, and both are routinely provided e.g. vegetable curry. Customers are informed via the menu. No information is given about portion size, fresh/home-made, country of origin or cooking method and it is not known whether customers ask for such information.

(vii) Italian Restaurant (belonging to a chain) (1) (a) Allergens SUPPLIER INFORMATION: Most supplies are basic ingredients as most dishes are freshly cooked in-house; they only buy in desserts. For desserts, ice creams, Danish pastries and ciabatta, label information is retained as these products are stored in their original wrapping. The restaurant could get further information about the ingredients if they asked their suppliers. STORAGE AND PREPARATION: Nuts/peanuts are not stored differently to other ingredients. If a customer says he/she has an allergy the kitchen staff take extra care not to cross-contaminate his/her meal. TRAINING: During the first 4 weeks of employment there is a programme of training, and then every couple of months staff have updates. All staff are trained about the menu so they can advise customers. The restaurant has received information about allergies internally from the company. Staff have a statement to sign in their Health and Safety file about having read the information and their awareness of the issue. Staff are trained to ask the manager if anything difficult arises. DIALOGUE: Customers ask about nuts and about other ingredients such as shellfish. It is not always clear whether this is because they are allergic or for other reasons. The restaurant usually has 4-5 requests/questions per week. The menu highlights dishes that contain nuts with an n symbol and states, there is a small possibility that nut traces may be found in any menu item. Staff can provide more details if customers ask. For example if a nut-allergic customer asked for advice, they would check the product labels and would advise them not to have any products labelled as may contain traces of nuts. Training to be the general manager includes spending 3 weeks in the kitchen learning how all the dishes are made and what they contain. Staff know to ask the general manager or other managers if they cannot answer queries themselves. (b) Consumer Choice Staff are aware of healthier products, as there is a list in the staff manual. They know which products can be made without cream or butter, and can accommodate any special dietary requests. Even if suppliers provide nutritional information, this is not used at the restaurant level. None of the desserts provided are viewed as healthy eating. Vegetarian choices are flagged up on the menu with a V symbol. Vegan choices are not indicated, but some dishes would be suitable for vegans and staff can help with

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identifying these. Also, dishes can be altered in preparation so as to make them suitable for vegans. The restaurant has a vegan customer who comes in regularly. Staff can give specific instructions to the chef about how dishes should be prepared and cooked for individual customers, as everything is prepared on the premises, and is cooked to order. The portion size of steaks is given. The kitchen has specifications to work to for portion size. Chicken breasts are 225g and they have to work to set weights for pasta. Country of origin not a concern. The menu in most cases states the cooking method used (e.g. grilled or oven-baked), so the information is given up front. The restaurant provides take-aways and telephone ordering. There is a take-away menu from which customers can order and if any concerns arise, such as allergies, the staff can deal with this in the same way as if the customers were in the restaurant. The take-away menu goes into as much detail as the restaurant menu.

(c) Barriers and opportunities identified by the above Italian restaurant The general manager, in a previous job, had a customer with an anaphylactic reaction. She had asked for no kiwi fruit without saying why. The chef had therefore removed the kiwi fruit rather than making up a fresh dish and she had a reaction. He felt responsibility for this incident was 50:50. Had she explained the seriousness of her request, a fresh dish would have been made. The restaurant feels that it would be good if people with allergies stopped thinking they are a problem, and are causing too many problems. There is a need to communicate to the public that allergy sufferers or people with specific requests are not a problem and that they can be catered for. If they ask for advice they will have more choice as dishes can be altered specifically to suit their needs. (viii) Small and Ethnic Restaurants (n = 3) Discussions with a single unit fish restaurant highlighted awareness of food allergies and willingness to cater for special dietary requirements, which was indicated on the menu. (a) Allergens SUPPLIER INFORMATION: The restaurant buys in basic ingredients and cooks with these, so the problem of may contain nut labelling does not arise. Products with hidden ingredients are avoided. STORAGE AND PREPARATION: Nuts are stored separately, away from flour to avoid cross-contamination. Special procedures would be used to ensure no cross contamination if they were catering for a nut-allergic person. Nuts are added to dishes as they are cooked and none of the pre-preparation involves nuts. Hence, if a customer is nut allergic all of the nut-containing dishes could be made without nuts. The biscuits made to be served with coffee contain nuts. A roll of biscuits without nuts is kept in case someone is nut allergic, and these are cut separately to avoid cross contamination.

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TRAINING: Staff are briefed daily about the special dishes. There are 3 kitchen staff, 4 to 5 front of house staff per shift, out of a total 6 to 7 front of house staff. Staff are briefed before their shift about the menu. DIALOGUE: Major ingredients are highlighted on the menu, but if a customer has an allergy, the front of house staff know what is in the dishes and how they are cooked and can enter a dialogue with the customer to fulfil their requirements e.g. if the customer is allergic to milk or dairy products, fish can be poached in stock instead of milk. The menu will shortly indicate the use of nuts, which is also seen as an advantage because of the positive aspects of flavour from nuts. Customers with allergies are encouraged to ask the staff. The ambience of the restaurant is catering for the individual. Customers do ask for nut free, and ask whether nuts are used in the kitchen. If this is a concern staff impress upon the customer that they are very careful and are aware of the fact that of small traces are a potential problem. Customers also ask for gluten-free dishes. The restaurant avoids using wheat or flour in soups and sauces, so that customers with problems have more choice. This also makes it easier for the kitchen staff if they are busy, as they dont have to make special alterations to dishes. (b) Consumer Choice No dishes are highlighted as healthy options, as such, since fish is a healthy food and customers are conscious of this. However, some customers are not concerned about the use of butter on fish and potatoes and still feel they have eaten healthily. Some customers do ask about the use of specific ingredients such as butter and cream, and these can be removed from cooking if desired. The menu has vegetarian dishes, and vegans can be catered for. The menu states that the cheese is suitable for vegetarians. Portion size is given for steaks only. Terms such as fresh and home-made are used because all dishes are made on the premises, freshly that day. Staff sometimes enter into discussions with customers about the origin of the fish, more as a talking point, as they use fresh fish from around the world. Cooking methods are stated on the menu. Specials are described verbally including cooking method. (c) Barriers and opportunities identified by the above fish restaurants Listing everything on the menu would be unworkable. If someone says they have an allergy the restaurant can cater for them. But they must say so and in the owners experience people with life threatening allergies do make this known. It appears that the number of people who say they have allergies is rising very quickly. Discussions were undertaken with two Indian restaurants. These were chosen because one declared nuts on the menu, whilst the other had a Website but made no reference to nuts. In the first case, discussion with a waiter highlighted that: Many customers ask about nuts. They may ask for dishes with no nuts at all, or sometimes without a specific type of nut. All staff are trained and are aware of the issue of nuts. Precautions are taken in the kitchen.

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Some customers ask to avoid other ingredients e.g. flours or gluten. Staff are informed and are able to help customers choose appropriately. For example, a customers child needed to avoid dairy products and the waiter advised them not to have pilau rice as this contains milk and butter. The management take notice of these concerns. When asked about may contain labelling on supplies, the response was that all food is freshly cooked from basic ingredients. Some customers ask about healthy eating and some for vegetarian and vegan dishes. Vegetarian dishes are marked with a V symbol but there are no symbols for healthy eating. There are healthy dishes on the menu, but the customer must pick them out themselves.

In the second restaurant, The proprietor was aware of concerns about food allergy, particularly in relation to nuts. All food is freshly cooked from basic ingredients. Nuts are stored in a separate container on a separate shelf. Dishes with nuts are cooked separately and precautions are taken not to transfer nuts to other dishes. There is awareness of this. If someone is known to be allergic, the kitchen staff would be told to take precautions. All staff are trained in health and hygiene which includes allergies. The restaurant staff have received information about allergies, have read about it in catering trade journals, and have bought a booklet about food and hygiene. There was the perception that the EHO checks everything apparently including how they deal with nuts. Customers sometimes ask about nuts in general, and one customer has asked specifically about almonds. On average, they get 1 enquiry per month. Customers do not ask about other ingredients they can see on the menu which dishes have e.g. fish in them. Some of the dishes that contain nuts are indicated on the menu i.e. the specials that provide information about the dish and ingredients. However, regular dishes do not have this detail. For example, Chicken Tikka Masala does not state that it contains almonds, and the proprietor considers that people already know this. In contrast, Kashmiri Chicken Tikka Masala is a speciality of the house and the description of this indicates that it is cooked with fresh cream, almonds, fruits and masala sauce. The staff can advise customers with food allergies on the best dishes for them. On healthy eating it is felt that customers know better than us. There are lower fat dishes on the menu, e.g. tandoori chicken, vegetable dishes, melon, plain rice, but this is not highlighted and it is up to the customer to be able to pick these out. Many customers ask about vegetarian dishes, and there is a wide choice on the menu. Some customers ask for vegan dishes. There are separate sections on the menu for vegetable main dishes, vegetable side dishes and vegetable special meals. Customers sometimes ask how dishes are cooked. Customers are welcome to visit the kitchen, and the staff like to show customers the tandoori oven. The menu states that

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the kitchens are always open for patrons to view the preparation of tandoori and curry dishes. 2.5.2 CONSUMER AND SUPPORT GROUPS (i) Support (n = 2) and Consumer (n = 1) Groups Based on work with food allergic people, Support group 1 considers the availability of information about allergens, gluten-free and vegetarian foods to be more important than healthy eating and country of origin information. At delicatessen counters it is suggested that pre-printed pot lids and stickers are used so that allergen risk information can be transferred to the goods. This can then be read by the end consumer at the point of use. Barriers include the large number of independent retail outlets, language and cultural barriers, misunderstandings through communication, delays in using up old packaging, the need to design new signage for counters, and education of staff. None of these barriers are insurmountable. Based on personal opinion, Support group 2 responded that availability of information about nuts and peanuts when eating out is the highest priority, closely followed by information about other allergens. Information about low salt choices and cooking methods was considered to be of equal importance to the latter. Other nutritional information was considered to be of slightly lower importance, with information about ingredients used being of least importance. Information about vegetarian and vegan options was also considered of very high importance, closely followed by information about organic and gluten-free status. The importance of information when purchasing non-prepacked foods was considered to follow a broadly similar pattern to that when eating out. Cooking instructions for non-prepacked foods such as burgers, chickens and sausages is considered to be very important, along with cooking instructions for pulses. Perceived potential barriers to progress are unwillingness on the part of caterers and retailers to implement potentially time consuming schemes and lack of standardised, easily recognisable symbols. The consumer group also thought that allergies are the most important issue of those listed (see Appendix B), and that all of the allergens listed are important, since allergens are important to the individuals concerned in view of the potential consequences of getting it wrong. The problem of providing misleading or unhelpful information is just as relevant for non-prepacked foods as it is for packed foods, e.g. disclaimers on menus are no more helpful than may contain labelling on packed foods. It is important to provide cooking instructions along with other food safety handling messages, e.g. saying if previously frozen, and the best before date. The Scottish Consumer Council has a healthy choices award scheme that was set up as part of the Scottish Diet Action Plan in 1997. It is a prestigious national healthy eating award for caterers that covers all types of outlets (www.shcas.co.uk). Some findings from recent National Consumer Council (NCC) research on prepacked foods are also relevant.

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The following findings are from unpublished research by NCC for the FSA and should not be quoted until the NCCs Report is published. Consumers do not have time to read lots of information. Logos are therefore helpful as a short cut, provided the logo is recognisable, trusted, and understood. Logos may also be helpful in relation to non-prepacked foods. Qualitative research indicated that diabetics would like better labelling of the foods that are suitable for them. They feel less well catered for than other diet-restricted groups. They look for sugar and carbohydrate information and choose products with no added sugar, sugar-free, and low or reduced sugar. Claims are less trusted than ingredient lists. As diabetics cannot check the sugar and carbohydrate content in unwrapped breads and cakes, or products from bakeries, the contents are assumed by guesswork. Diabetics are aware of advice to eat a healthy diet, but need a confidence boost when choosing products to confirm that they are selecting the right foods for them. As there is a wide range of reasons why people are vegetarian, definitions are more important to some individuals (e.g. some religions) than to others. 2.5.3 ENFORCEMENT (i) Environmental Health Officer (n = 1) An EHO in Bath was selected for interview as the council has had 2 deaths from food allergies in the past 5 years. The first was Ross Baillie, an athlete at Bath University, who was 19 years old. He ate a coronation chicken sandwich not realising that it contained nuts. A second death, Anthony Wong, was due to eating crisps containing powdered milk at a friends birthday party. The local EHOs were made aware of these incidents and wanted to publicise the issue more widely amongst the public and caterers in their region. They wrote a report to their Local Councillor Committee in November 1999, highlighting the 2 fatalities, providing background information about the issues, and suggesting the EHOs pursue an awareness raising campaign. The report was approved. The Bath Chronicle latched onto the campaign giving it front-page headlines. The EHOs wrote to the local MEP and to the two local MPs, who responded to say they had brought the matter to the attention of their parliamentary colleagues. In addition, the EHOs wrote a simple letter informing local caterers about the campaign, and enclosing the MAFF awareness guidelines and stickers. They highlighted the two recent fatalities and stated that businesses should make their staff aware of the issue. The plan was to follow-up 6 months later but the EHOs could not afford the time. They were going to ask if staff in catering establishments had seen the document, recalled what it said and if they would know what to do if a food allergic customer asked questions. The EHOs are aware of leaflets and stickers in a few premises, but new staff in the catering establishments may be unaware of the information.

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The EHOs have a registration pack that is sent out when food businesses register with them, and this includes allergen leaflets. When they do inspections they do not officially include allergen issues, but officers in their region are tuned into this topic. They deal with a lot of schools and nurseries, and can discuss the food allergy matters with those in charge. Nurseries are inspected frequently and on a recent visit, 2 children had nut allergies and 3 had other food allergies. The extent to which EHOs delve into allergen issues on routine inspections essentially depends on the business they are inspecting. In practice if the hygiene aspects are satisfactory there is usually time to discuss allergies. If a company is lax on hygiene this remains the main focus of discussion. It would be progressive to ask all premises if they have policies about food allergens. Some types of premises call the EHOs for advice, such as nurseries and schools. The EHOs can send out leaflets, or can refer people to websites such as The Anaphylaxis Campaign, IFST and other specialist informants. (iii) Public Analyst (n = 1) The role of the Public Analyst is to advise EHOs on sampling and to offer advice. This includes scientific advice about levels to which traces of allergens can be detected, but also includes advice about interpretation of the law, and practicalities of food technology of which EHOs may not have specific knowledge. For example, EHOs may not know what is feasible or what is good practice in trying to avoid contamination with allergens. The public analyst can provide a source of information about what it is reasonable to expect or advise the trader to do. Public analysts regularly test for minute traces of nuts and peanuts, and also for allergens such as eggs, and for gluten. But this is mostly in prepacked foods. Sampling efforts are directed towards prepacked foods, as the samples are easy to take. Public analysts do not undertake much analysis of catering-derived samples. Mechanisms are needed to ensure that reliable supporting information is available for the end seller. There needs to be strong emphasis on traceability, possibly through an accessible electronic database. Demand for information has to come from the consumer through the caterer, but producers need to be required to provide the information. Supplies would then be much easier to audit, from the primary sources. If a trader claims a product or dish is nut-free, with a flag, or indicates this on the menu and it is shown not to be the case, the trader is liable to prosecution. (iii) Trading Standards (n = 1) For allergens and consumer choice matters there is a need to look at a whole chain solution to improving information for consumers at the point of purchase/ consumption.

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For many foods sold to catering establishments, labelling is minimal because the Food Labelling Regulations (1996) allow information to be provided by means of accompanying documents e.g. invoices and delivery notes. Accurately transposing this information onto menus or to the consumer via verbal descriptions would be desirable. Highlighting in colour foods/meals that contain allergens could be considered. The use of notices and expanded menus is attractive but care must be taken to ensure that the consumer is not overwhelmed by so much information that other important messages are not seen. Although not universally true, it is likely that the smaller the business (particularly in terms of numbers of staff) the more difficult it is for them to deliver on such initiatives. 2.5.4 MANUFACTURERS OF FOODS FOR CATERING AND FOODS SOLD NON-PREPACKED Feedback is presented under the headings food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. Examples of barriers and opportunities given by the respondents are also given.

(i) Large Manufacturers (n = 3 - 1 branded, 1 own-label, 1 ingredients/own label) (a) Allergens All respondents were aware of food allergies as an issue. All responded that suppliers are requested to complete a specification sheet concerning the presence of all the main allergens, and the possibility of traces of nuts being present. One company asks for information about the possible presence of all the main allergens. Information is retained electronically and may be used to develop free from lists, for declarations on products, and for other labelling purposes. Ingredients suitable for nut-free products are distinguished by use of these supplier declarations and assessment of the risk of cross contamination. For nuts, suppliers are audited to understand the risk of cross contamination to other products. However this is not the case for the other main allergens. The branded manufacturer receives many requests about the suitability of products for nut allergy sufferers, but questions about other allergens are less frequent. The own-label manufacturer is requested to provide information about all the major allergens by its clients. One problem is the lack of agreement of what is a nut, as some companies regard coconut as a potential allergen- containing food and others do not. All three manufacturers have robust controls (GMP and HACCP) where nuts are used, to ensure that cross-contamination is avoided, e.g. in one case where nuts are used everything is colour coded red red aprons, gloves, labels, sleeve guards, a separate cooking vessel for nuts only and signs to say nuts are in use. All companies have staff training about allergy issues beginning with induction training.

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(b) Consumer Choice One company has no healthy eating products, another makes products tailored to their clients requirements and the branded manufacturer gave low fat dressings and saltreduced soups as examples of healthy eating options for catering establishments. For these products nutritional analysis is provided and claims are made on the labels. All of the companies manufacture vegetarian products, in some cases by default rather than by design, and these are marked with logos. Instructions are routinely provided where products require further cooking. The own-label manufacturer provides comprehensive information, e.g. for retailer take-away meals. The information is used in the retailers counter book and covers logos, cooking instructions, ingredients, nutritional information, storage life etc. Information is thus available to the store staff if the end consumer has questions. (c) Barriers and opportunities identified by the above large manufacturers Clarity is needed for the top 5 list of allergens so that these are dealt with consistently, across the industry. If the FSA recommends that allergens must be indicated on non-prepacked foods or catering foods, reliance will be on companies complying with this guidance. How is compliance monitored who does it, how, and who pays? A counter view is that providing this comfort blanket for the consumer could cause a problem. The onus should be on the consumer to take responsibility for the foods they choose, in light of information provided by the industry. There is the potential for too many logos on any given pack. In the future, Internet and carelines will provide up to the minute information. It will also be possible to send updated free from lists automatically to people registered with a company, when the lists change (this is currently done for nuts by the branded manufacturer but not in an electronic format). Food Hygiene has been accepted as a standard qualification in catering outlets. Could this be piggybacked to educate staff about allergies in a more detailed and systematic way? A scheme similar to the Heartbeat Scheme could be put into place in outlets that are 'allergy aware'. Outlets could be assessed and recognition given to those that reach a given standard signifying that allergy sufferers can eat there with confidence. There could be a formal test to pass with a certificate and sticker awarded. EHOs and local dietitians could collaborate on this, as with other schemes. Education will be the hardest challenge as English is not the first language of many staff working in catering outlets. There is a danger of making catering establishments so wary of allergies that they consistently advise sufferers to avoid dishes just in case. Cost will be the primary restriction for many businesses. Standards imposed must be the same internationally so that UK and European business are not adversely penalised.

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(iii) Small Manufacturers (n = 4) A manufacturer of desserts for the food service, retail and airline sectors highlighted that the product information requested by their clients is pushed up the supply chain to their suppliers. The manufacturer demands a specification sheet for every raw material that they use. Where multi-component ingredients are used they know the exact proportion of each component. Information is requested from suppliers about the presence of nuts and other major allergens. This information is kept as specification sheets. Suppliers are audited and the company only buys from approved suppliers. Belgium and French suppliers have to provide the same level of information as UK suppliers. Information flow to the end consumer depends on where the product ends up if in a retailer, communication procedures are generally in place. If in a pub via a wholesaler, there is no control over retention or communication of the product information. The company is BRC accredited, and this covers HACCP and nut controls e.g. nuts are stored separately, have distinctive marking (yellow), and there are batch controls. Staff receive training that covers operational procedures, batch control, nut control, HACCP etc. As nuts are used in their factory, all products are labelled with nut warnings as it is not possible to give a cast-iron guarantee that the products are nut free. There are no specific healthy eating products made. Vegetarian products carry a logo or statement. A manufacturer within a large manufacturing group highlighted that the company requests information from its suppliers about all the main allergens. The information is retained as specification sheets. Suppliers are also requested to have special operational procedures in respect of allergens. The companys clients all request this information for nuts, possible traces of nuts, and for other allergens. The company has special operational procedures in respect of nuts, and all staff are trained in the company nut policy. The company provides vegetarian dishes, but these are not labelled as such. Discussion was also undertaken with a very small manufacturer of chocolates and decorations, set up 15-16 years ago. The company buys in chocolate and melts it down into shapes. As nuts have not been used in the factory for at least 7 years, the company claims to be nut-free. They make after dinner mints for hotels and restaurants. Labels state that these products are nut free and GM free. However, they do not always flag up products as nut-free and believe they could probably make more of this in their marketing. Their products are mostly sold in bulk to third party distributors/wholesalers with very few sold direct to the end retailer. Their customers include catering chains, retail (including mail order/in-home parties once customers became aware that the products are nut-free, sales went through the roof), ingredient suppliers and wholesalers.

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Their large customers ask for product specifications and also audit the factory. The company has its own independent external auditors, which includes the nut-free aspect. Smaller customers do not ask for product specifications. A second manufacturer and importer of edible chocolate decorations from EC countries said that any initiative in respect of nut-free would come from their clients. Most chocolate factories have nuts in them. It therefore cannot be assumed there are no traces of nuts in chocolate products, e.g. chocolate cakes on a dessert trolley, unless they are made in a nut-free processing environment.

Information flow through the food service supply chain was outlined by the secretariat to a committee of manufacturers of products for the Food Service Sector. Large catering companies, in response to customer requests, ask their wholesalers for relevant information about the products. These questions filter down to the manufacturer, who responds to the questions asked. The information is fed back via the same route to the end operator, such that customer questions can be answered accurately. The intention in future is to do this electronically, via UDEX. This will include information about allergens, not just for food service but also for the retail chain.

2.5.5 RETAILERS - FOODS SOLD NON-PREPACKED Feedback is presented under the headings food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. Examples of barriers and opportunities given by the respondents are also given.

Multiple Retailers (n = 3) Non-prepacked foods include bakery, deli, fish, fruit and vegetables, hot cooked chicken, meat and meat products, pick-and-mix confectionery, pizza, take-away meals, salad bar, and customer caf, which includes cakes, sandwiches and hot meals. (a) Allergens All are aware of the issue of food allergies. Retailer 1 SUPPLIER INFORMATION: All suppliers provide information about the presence of all uses of nuts and peanuts including potential traces, and all uses of other main allergens. May contain nuts labelling is assumed to reflect well-controlled systems and notice is taken of the information. The information is supplied via specification sheets and retained electronically. Hence, the presence of potentially allergenic ingredients is known for all of the non-prepacked product ranges.

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STORAGE AND PREPARATION: Special operational procedures are requested of all suppliers in relation to nuts/peanuts and gluten. TRAINING: The company has regular staff training that includes allergies. DIALOGUE: Supplier information is retained as product lists and in counter guides. It can be made available to customers at their request. Display tickets indicate products that contain nuts/peanuts. Staff are also informed and can answer questions. Where there is a risk of cross-contamination, counters and shelves carry warning labels that products are not suitable for allergy sufferers, e.g. in-store bakery products. Retailer 2 SUPPLIER INFORMATION: The company requests all suppliers of its own-label products to provide information about all uses of nuts/peanuts and other main food allergens, as part of the comprehensive product specification. If products are labelled may contain, the product specification would clarify what was meant and the reason for this. The specification is received as hard copy, but will eventually be in electronic format. It is retained on paper and re-keyed to retain electronically. It is used to answer customer queries, and requests from support groups. STORAGE AND PREPARATION: Suppliers are required to carry out a HACCP for nuts, and are assisted to develop appropriate controls. They are expected to apply GMP to eliminate cross contamination of products. TRAINING: The company has regular staff training but this does not include food allergies. However staff are trained on the problems of nut allergies and to keep the products separate e.g. on the deli counter. DIALOGUE: Customers ask if products contain nuts and also egg, milk and wheat. The reverse of the display ticket indicates products that contain nuts and other allergens and the server can therefore provide this information. The provision of this information is audited regularly and it is considered a serious offence if it is not present. The staff can also contact head office for more information. However, in most instances customers with food allergies are advised to purchase pre-packed products. Notices at the service counters advise customers with nut allergy (includes sesame seeds) that all products from the counter are not considered suitable for them. The company does not use the phrase may contain nuts, and prefers to state not suitable for nut/sesame seed allergy sufferers, as this is felt to have more meaning for the customer. Retailer 3 SUPPLIER INFORMATION: The company requests information from suppliers about all uses of nuts and peanuts and other major allergens. This is collected via a specification sheet, and the information is retained electronically or as hard copy. It is used to develop free-from lists and the information is held centrally.

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STORAGE AND PREPARATION: Suppliers are requested to follow the BRC nut handling guidelines, as for pre-packed products. TRAINING: The company has regular staff training, which includes allergies. However, staff are not briefed on changes to products or dishes as there are too many products. DIALOGUE: Display tickets indicate products that contain nuts and peanuts, and customers also ask for this information. They also ask about a wide range of other potential allergens. Point of sale notices advise customers to avoid the area if they have an allergy, as products containing nuts/peanuts are not displayed differently to other products. (b) Consumer Choice Retailer 1 Customers ask about healthy eating options, and the use of specific ingredients such as cream and butter, but rarely ask about the cooking method. Display tickets highlight healthy choices. Other information provided about nonprepacked foods includes calories and fat per 100g serving, a salt indication, and additive information. Customers ask about vegetarian and vegan choices. Such products are highlighted with display tickets, and staff can provide further information. Shelf-life information is provided, marketing terms are used as applicable, and country of origin is indicated as legally required. Customers rarely ask about shelf life but do ask about country of origin. For sales and delivery via Internet ordering, customers are informed via vegetarian logos, organic logos and healthy product indications as they order. Cooking instructions are provided on bags for fish, and for take-away meals. Retailer 2 Customers ask about healthy eating options and about cooking methods. The company provides lower-fat items on the salad bar and customers are informed about these through display tickets. Staff can also provide more details if asked. The company provides both vegetarian and vegan options. Customers are informed via the display tickets and staff can provide more details if asked. Descriptions such as fresh, home-made etc. are used, shelf life information is provided, and the country of origin of some ingredients is also provided. Customers sometimes ask about the country of origin of ingredients. Sales by telephone and Internet are provided. There is an information icon against the product on the Internet, which displays product details when clicked. When ordering by telephone, the call centre can access this information. Cooking instructions are provided on the label that is printed out at the meat counter. In other sections, the counter will have information that can be provided by staff on request. Retailer 3

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Customers ask about healthy eating options. Examples of healthy options include low-fat cheeses. Customers are informed via display tickets, but nutritional information is not provided. Customers ask about vegetarian and vegan choices, and are informed about the status of these products via display tickets. Other information routinely provided includes use-by date and the country of origin (via display tickets). Cooking method is not indicated. Customers ask about shelf-life and country of origin, but not about fresh/ home-made etc or about cooking method. Where customers with allergy purchase over the Internet, they are advised to choose fully labelled pre-packaged products. Cooking information is not routinely provided for raw or uncooked products sold non-prepacked.

(c) Barriers and opportunities identified by the above retailers It is felt that research is needed to ascertain consumer information priorities for different foods so that limited space can be used for the most appropriate information. Flexibility is important e.g. just providing fat and calories rather than full nutrition labelling. The small size of the counter indicators is a potential barrier to providing a lot of information. Customers need to be made aware of what may contain labelling really means. Any proposals should be in the form of a goal-based framework, rather than specifics. Consideration should be given to the different capabilities of large retailers and small corner shops, as a one-size fits all approach is a potential barrier to progress. Sandwich Retail Chain (n = 1) Discussion with the Customer Service department at Head Office indicated a low awareness of allergy issues. For example, pesto is added to salad dressings for flavouring and salads have only recently been labelled Contains Nuts. Also, a customer pointed out that where toast is offered with a choice of marmalade, marmite or peanut butter, there needs to be a separate knife to cut the peanut toast to avoid cross contamination. Most sandwiches/salads are made in their own central production unit and are sold pre-wrapped. Hot torpedoes (baguettes) and toasties are sold non-prepacked, and are prepared behind the counter. Nuts are not handled behind the counter except where peanut butter is used for toast. The expectation was that if a customer had an allergy and asked for information about these unpacked items the shop staff (most are not English) would advise them to call Head Office - the telephone number is printed on all of the bags. There did not appear to be any formal staff training process. Mixed sandwich platters are delivered to offices. The sandwiches are cut in the local store. No label information is available with the platter, but specific requests for

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information could be made to the local store or preferably to customer services at head office. However, on dietary restrictions the company currently only caters for vegetarians. On consumer choice matters, following a lot of requests about the fat content of sandwiches by people on weight reducing diets and requests about vegetarian options, the company is now starting to provide nutrition labelling on all sandwiches and a V logo where appropriate. They tend not to be asked about the fat content of the hot torpedoes their customer research shows that men generally purchase the sausage torpedoes, while women worry about fat content, and women on diets are unlikely to purchase a sausage torpedo! They are not asked for country of origin information. Discussion with Operations at the Central Production Unit outlined the large number of products (i.e. ~ 160 different sandwich fillings), and the high turnover of products. They maintain a robust database of raw material data. The unit has recently achieved British Sandwich Association accreditation. Because of the use of nuts in the factory, and the long run lengths, all products are being marked with nut warnings. If in the future other establishments were supplied (in addition to their own stores) the same level of information would be available for the products. The information would be supplied either about individual sandwiches or for trays of sandwiches, but communication of the information to the end consumer would be the caterers responsibility. However, customers could always call customer services at head office where there is access to a database with a lot more information than can be printed on the labels.

Small Retail Shops (n = 2) Both are aware of food allergies. The Craft Bakery shop has a list of products behind the counter that are not suitable for people with special dietary requirements such as nut-free, egg-free and dairy-free. Customers do ask for information most requests about nuts are in relation to children, but requests are now less frequent as nuts have been taken off some products. Queries about wheat tend to relate to more mature individuals. Some customers also ask about milk and dairy ingredients. Customers are not informed up front about specific ingredients and the shop relies on customers to ask. The only exception is that vegetarian pies are sometimes flagged up if they are on special offer. Staff are not trained and give advice based on their own personal experience e.g. how to reheat pies. If staff have any doubt about customer queries they telephone the main bakery where the products are made. Separate discussion with the main bakery confirmed that they request technical specification sheets for all ingredients that they buy in. If a customer phones with an enquiry they can then provide relevant information. Customers do ask about nuts, whey powder, dairy ingredients, animal and vegetable fats and E-numbers. The company is a small craft bakery, they have only one set of equipment, they do use nuts and therefore they would advise those with nut allergies that their products are not suitable. 50

Deli/butcher/bakers is also prepared if customers ask questions. Staff are trained to answer queries (they have all undertaken mini HACCP training), and know to ask the baker or look at the recipes and ingredients for specific dietary requests. Everything is home-made on the premises and ingredients are kept in the original boxes so that the label information is retained. Staff will know the shelf life of products if asked. The establishment is well aware of the issue of allergies as the proprietors niece has nut allergy, and they make gluten-free sausages and burgers for coeliacs. These are made in batches to order, and the shop is on a support group list as a supplier of these items. On the healthy eating side they make low-fat sausages, and customers ask for these. They are not labelled or flagged up as low fat. They did make a range of vegetarian pies and pastries, but demand was not as high as expected. They make 15 quiches of which only 3 contain meat. If customers dont know, it is up to them to ask which are vegetarian. The printed price list indicates the portion sizes of the hot and cold eating pies. It also details the different types of quiches available, and the range of all the other homemade products such as desserts, gateaux and salads.

In both shops there is no attempt to communicate the presence of nuts or other allergens to consumers. They rely on the consumer asking for this information. In the Deli/butcher/bakers there are opportunities to do so e.g. home-made carrot cake is presented in a box which provides the opportunity to indicate that it contains nuts. Waldorf salad is printed on the price list, but there is no mention that it contains nuts. However this raises the question that if nuts or other ingredients are indicated in these cases, will consumers then perceive that they are being told in every case. Any change in consumer expectations could have implications for them asking for information. WI Market Aware of the issue of food allergies. Home-made products sold at the WI markets all have a list of ingredients, and there is a WI market ruling that if products contain nuts they have to be labelled as Contains Nuts or attention drawn to the nut content by underlining or ringing in red. This includes coconut. Other potential allergens are not treated in this way. Reheat instructions are given on pies and Christmas pudding, but not on everything. All products are labelled with the date they were made. There are no rules for vegetarian dishes in the WI market Bible, but in this case a vegetarian makes the dishes so it is assumed that she knows what is appropriate. Dishes are marked as Suitable for Vegetarians.

2.5.6 WHOLESALERS Feedback is presented under the headings food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, 51

portion size and use of descriptors such as home-made. Examples of barriers and opportunities given by the respondents are also given. Large Delivered Wholesalers (n = 2) (a) Allergens Both are aware of the issue of food allergies Clients purchasing products buy from a list and do not have access to the ingredients at the decision of purchase. Hence they enquire of the wholesaler whether products are free from certain dietary items, for both own brand and branded products. Wholesaler 1 Receives approximately 5 requests per week about nuts, 5 about gluten, and fewer about eggs, milk and soya. For own brand products all ingredients, including nuts and the main allergens, are indicated via the ingredients list and via their Website. Branded product information is not available on the Website. There is a nut policy for own brand products - GMP procedures are to be followed, main allergens must always appear in ingredients list, and the list of nuts includes coconut. There is also a policy for gluten-free and for the other main allergens, which is essentially to provide a list, and there is a general policy to make full ingredients declaration. All suppliers are requested to have HACCP procedures in place for handling nuts. The company requests information about all uses of nuts and peanuts, and the other main allergens. The company expects suppliers to only declare nuts when they are added to the product. Information from suppliers is received electronically, stored on a database, and is passed onto customers in the form of allergy lists and advice on individual products. All foods and ingredients are traceable throughout production. International suppliers have to provide the same level of information and standards as UK-based suppliers Wholesaler 2 Is currently working on its own-brand labelling and communication of the possible presence of allergens. They want to keep the questions they ask suppliers about the possible presence of allergens to a minimum number of allergens. Supplies are despatched in large boxes and there is an opportunity for information provision on the box. There is also the opportunity to provide information on the inner packaging, which is usually kept when the outer packaging is discarded. However, this has cost implications, as their packaging suppliers will have to invest in new machinery to be able to print onto the inner packaging. The company operates a 40-hr/week advice centre, which receives 1000 calls per month. Approximately 700 per month are on these topics, e.g. requests for a list of nut free products? Are particular products free of a certain ingredient? It is the exception rather than the rule that clients ask for this level of information, but the sizeable number that do ask still presents a resource challenge. If the need to have information increases and more companies ask, the company would not be able to handle this.

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They are only ever asked about allergens on the EU list, but have not been asked about sulphite. They obtain written confirmation from the manufacturer of branded products stating the product is e.g. nut free, and this statement is passed on to their client. (b) Consumer Choice Wholesaler 1 Receives approximately 2 requests per week about healthy eating options, and information about their healthy eating products is communicated via their help line and Website. Though nutritional information is provided on own-brand products, clients also request further information. Requests for vegan products run at about 5 per week, while vegetarian options are indicated on the price list. Further advice is available via the help line and Website. Portion sizes, country of origin, and cooking method are provided and the company gets requests for information about all of these matters. When ordering on-line or by telephone, customers have access to information via an intranet, and access to an information service. Wholesaler 2 Some products would fit into a healthy eating category, but they do not specifically target healthy eating. Nutrition information can be obtained from suppliers, if a client requests it. Own-brand products are labelled as suitable for vegetarians where applicable, but products are not labelled as suitable for vegans as this is very specialised. Country of origin is not really a problem. Portion size guidelines are given, marketing terms are being phased out, and packaging information gives recommended cooking methods. (c) Barriers and opportunities identified by the above wholesalers Both wholesalers indicated the potential of web-based information and suggested that the forthcoming UDEX scheme being developed by OFSCI should be further investigated. The need for a definitive list of nuts was highlighted despite attempts for consistency across industry, companies are still working to different lists e.g. there are differences of opinion about the inclusion of coconut and pine nuts. There should be a priority list of allergens. There is a need for standardisation of information formats and requirements. It presents a problem if large companies choose to make their own criteria and standards that are different to the norm. Because it is very difficult to get information from branded suppliers, particularly the smaller companies, it should be made a legal requirement to provide the information. Smaller companies are unlikely to comply with a code of practice or with good practice guidelines. Only 50% of delivered wholesale for catering is through large wholesalers; the rest is through many small companies.

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2.5.7 SUMMARY OF KEY POINTS The in-depth exploration enabled a detailed discussion of the issues with representatives of the different industry sectors. Many practical points were raised, and suggestions to help make progress included: Clarity is needed for the top 5 list of allergens so that these are dealt with consistently, across the industry. The need for a definitive list of nuts to ensure a consistent approach across the industry. The need for a legal requirement to provide a minimum level of information that has to be passed to caterers with the products. Standardisation of information formats and information requirements that apply consistently across industry. The need to embrace the potential of web-based information in the future. The development of standard minimum qualifications or training to ensure those in the industry are informed about allergies in a systematic way An allergy aware scheme for retailers and catering establishments. Consumers with known allergies must be made more aware of the need to ask, and not be made to feel a nuisance. Emphasis within catering establishments on the requirement to maintain comprehensive reference guides ready for when the consumer asks for information, rather than on menu labelling. Prioritise information for use on non-prepacked foods and in catering establishments e.g. provide fat and calories rather than full nutrition labelling. Consumers priorities should be established through research. Any proposals should be in the form of a goal-based framework, rather than specifics. A number of barriers were also highlighted. These are summarised below: Recommending that allergens must be indicated on non-prepacked foods or catering foods, will place emphasis on compliance which will be very difficult to police. The potential for too many logos on any given pack or menu. Education will be the hardest challenge particularly where catering staff do not have English as their first language. Cost implications were seen as a major barrier, particularly for smaller companies. Standards imposed must be the same internationally so that UK and European business are not adversely penalised. Meeting the challenge of obtaining accurate allergy information and presenting it as consumer-friendly meal-based information is practically impossible for small singleunit businesses, particularly as the 25% rule makes is difficult to assimilate allergens data. There is also a danger that if the more common allergens are routinely listed on menus that a caterer could be liable if a less common or unknown allergen produced a reaction.

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Consideration should be given to the different capabilities of large retailers and small corner shops, as a one-size fits all approach is a potential barrier to progress. The perception that providing information is difficult and expensive, particularly the need for training in a sector with a traditionally high turnover of staff. For non-prepacked foods, the small size of the counter indicators is a potential barrier to providing sufficient information.

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3. REVIEW OF INTERNATIONAL PRACTICE

3.1 INTRODUCTION: Although this project is investigating issues relating to the UK, many of these topics are relevant to a number of countries. The food industry has become increasingly global and it is not uncommon for ingredients to be sourced in one country, a product manufactured in another then distributed and sold in a third country. Therefore, it is important that companies that function in this international environment share their perspectives in this project. It is equally important to learn from what other organisations have already done, in terms of developing guidelines and setting up initiatives. 3.2 METHODS: Self-completion questionnaires with an international focus were sent to some internationally-based companies. Information was also gathered via in-depth research with companies with international operations. Information on international initiatives was gathered using an extensive web-based search and information from the self-completed questionnaires and in-depth research. The Food Labelling Standards of Codex Alimentarius and relevant EU legislation were also referred to for any information on these topics. 3.3 RESULTS: 3.3.1 SELF COMPLETED QUESTIONNAIRES Several international organisations and companies returned questionnaires. Responses from the 3 international manufacturers did not differ greatly from those based in the UK: If not routinely provided with information about nuts/peanuts and other allergens, this information is requested The information obtained via specification, memo or list provided by the supplier is then incorporated into the final product specification and/or label Only 1 of the 3 requested special operational procedures from suppliers in relation to nuts/peanuts and none requested this for other food allergens Some immediate clients (i.e. caterers) request information about the presence of nuts/peanuts and other food allergens Nuts/peanuts are often stored in a separate area, with distinct labelling, but only 1 of the 3 respondents has special procedures in place for preparation of products containing these Staff are aware of products containing nuts/peanuts and are briefed when ingredients change, but training does not seem to be common 2 of the 3 respondents produce healthy eating choices and use claims and nutritional analysis to inform clients about the composition of these products 2 of the 3 produce vegetarian products and 1of the 3 produces vegan products. Not all of these products carry logos/statements Comments received from these international companies include:

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UK usually good rest of Europe improving with regard to information provided by suppliers on food allergies and providing nutritional information Educate consumers to ask questions Two non-UK based consumer and support groups returned questionnaires. One suggested warning food-allergic individuals never to eat anything unless they know all of the ingredients. At restaurants, food allergy sufferers should speak directly to the manager or chef and inform them of the food allergy, its severity and what they need to know about the cooking techniques and ingredients. 3.3.2 IN-DEPTH RESEARCH Information gathered from the in-depth research about international suppliers and operators indicates that, in most cases, international suppliers to UK companies have to provide the same level of information as UK suppliers. Companies with international operations were able to give a perspective about these issues in other countries (a hotel chain, a contract caterer, a branded manufacturer and a retailer). They generally commented that information provision is less of a concern in other parts of Europe, particularly Southern Europe, compared with the UK, and it appears that the UK is more advanced in these issues compared to other countries. Feedback is presented under the headings food allergy and consumer choice, the latter including healthy eating options, cooking method, vegetarian, vegan, country of origin, portion size and use of descriptors such as home-made. Examples of barriers and opportunities given by the respondents are also given. Hotel Chain (n = 1) (a) Allergens For operations in Europe and Africa there was awareness of concerns about food allergy. SUPPLIER INFORMATION: Suppliers are requested to provide information about the presence or possible presence of nuts. Note is taken of supplies labelled may contain traces of nuts. Suppliers also provide information about the other main allergens, but this is in accordance with national and international laws, which vary from country to country. STORAGE AND PREPARATION: The kitchen chef and the purchasing manager record information about the presence of allergens in supplies. They review all products in storage and/or in use in the kitchen. The information is recorded in a reference book. The information is passed onto customers on request. The use of nuts and peanuts in kitchens is not treated differently to other ambient ingredients, and there are no special procedures for preparing dishes containing nuts. TRAINING: Staff are informed about changes to the contents of dishes as menus change. Regular staff training includes allergies - there is on-the-job coaching and training, and off-the job training sessions. The company has received information about allergens

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through the national, regional and/or local health and sanitation organisation within each country. DIALOGUE: The menu highlights the use of main ingredients, such as fish, and customers ask about nuts and peanuts, seeds, gluten, but the number of requests varies between hotels. Main ingredients and condiments are listed on the menu. The following statement is printed on the menus For those with special dietary requirements or allergies who may wish to know about the food ingredients used, please ask for the manager. (b) Consumer Choice Customers ask about healthy eating choices, the use of ingredients such as cream or butter, and the cooking method. Healthy eating choices are provided, and this is indicated on the menu. Staff can also provide details if asked. Follow your Colour is a key component of the recently launched breakfast concept that provides information about the nutritive value and ingredients of food items. Nutritional information is requested from suppliers. Customers ask about both vegetarian and vegan choices and both are provided, although this varies from one hotel to another and reflects the local/regional and seasonal food offered. These dishes are indicated on the menu. Portion size is indicated for meat and shellfish such as lobster. Descriptions such as fresh and home-made are used, the country of origin is applicable to meat and vegetables, and the cooking method is also indicated. Customer requests for this information vary between hotels. When telephone sales are taken, staff can refer to the reference book. (c) Barriers and opportunities identified by the above hotel chain Clear labelling on all items and ingredients is needed, and international Codes of Practice are needed. Contract Caterer (n = 1) (a) Allergens The Quality Manager International, based in Europe, revealed awareness of concerns about food allergies. However, there are differences within and between different countries. SUPPLIER INFORMATION: Some suppliers in some countries provide information about all uses of nuts/peanuts and other food allergens. The information is understood to mean different things for different suppliers, but note is taken of the information. Information is provided via packaging and product specifications and is retained in a product specification catalogue. In some countries labels are kept where goods are decanted for storage. In other cases, the label is thrown away before the goods are used. Information about foods/ingredients that are suitable for nut-free products is retained as a product specification sheet.

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STORAGE AND PREPARATION: Special operational procedures in relation to nuts/peanuts are requested for some suppliers, particularly for hospital catering. Where nuts/peanuts are used in kitchens they are not stored any differently to other ambient ingredients, and dishes containing nuts/peanuts are not prepared any differently to other dishes. TRAINING: Staff are briefed on the content of dishes as menus change. The company has received educational material about food allergens and it has a programme of regular staff training including food allergies, particularly for its dietitians. DIALOGUE: Product information is passed on through the companies own product specifications, and to customers through menus and blackboards. Customers ask about the presence or use of nuts/peanuts in the kitchen and in dishes. They also ask about other food allergens. Where their presence is not obvious, the presence of nuts/peanuts is pointed out on menus, blackboards, or through information with staff, but this is not the case for other allergens. (b) Consumer Choice The company requests information about the nutritional content of products and ingredients from its suppliers. Depending on the country and restaurant type, there are requests for information about healthy eating choices from consumers. Examples of healthy choices include fitness meals (no meat), whole-wheat meals, light meals, and diets in hospitals. The company routinely provides vegetarian choices, but not vegan choices. Requests are received for information about vegetarian choices. Consumers are informed about both healthy eating and vegetarian choices through the menus, by staff providing details, or through intranet sites on IT systems. The company also routinely provides information about portion size, the country of origin, the cooking methods and descriptions such as fresh and home-made. Customers also ask about these. The company offers sales and delivery by Internet ordering and telephone ordering. Their menu procedure is ISO 9000 compliant. (c) Barriers and opportunities of the above contract caterer Practical steps to ensure workable solutions should be agreed at both the European and world-wide levels, as incompatible legislation at these levels is a barrier to progress. Currently, the UK is more ahead than other European countries because its labelling and legislation are more advanced. Branded Multinational Manufacturer (n = 1) (a) Allergens From experience of international operations, Northern European countries appear to be as aware of allergies as the UK, but some Southern European countries are less aware and it is generally necessary to verify further any information provided. However the companys quality system applies world-wide and this includes storage and preparation.

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(b) Consumer Choice Some healthy choices and vegetarian products are provided in all countries, but more so in the USA and Northern Europe. Cooking instructions are provided on foods all over the world. Compared to international suppliers, the UK suppliers are more aware and more able to provide accurate information than some other countries, especially Southern Europe. Even where it is not a legal requirement to provide nutrition information, this is still provided on the label. Multinational Retailer (n = 1) Information available for non-prepacked foods sold abroad varies from country to country, but is generally less than that provided in the UK. Staff training is focused on hygiene.

3.3.3 INTERNATIONAL GUIDELINES AND INITIATIVES GUIDELINES America One international organisation highlighted a set of guidelines that exist in America - the Food Allergen Labelling guidelines. These were developed by the Food Allergy Issues Alliance which includes industry and consumer groups. These guidelines can be accessed via the following webpage www.usii.net/sfa/allergyguides.html and also appear in Appendix B. In summary the guidelines are as follows: (i) Identify the major food allergens (ii) Advocate the use of terms commonly understood by consumers for the major food allergens (iii) Call for manufacturers to disclose the presence of major food allergens when they are an intentional part of the food, regardless of the source (iv) Establish guidelines when the use of supplemental allergen statements is appropriate. A code of practice on managing food allergens has also been developed in the USA by the National Food Processors Association (NFPA). This code states that NFPA members subscribe to the following practices: 1. Labelling (in terms commonly understood by consumers) the major food allergens in their ingredient declarations, including those that are part of natural and artificial flavours or other food ingredients. 2. Use good manufacturing practices (GMPs) and other allergen control strategies to manage and minimise the potential cross-contamination of major food allergens. 3. Where GMPs and other allergen control strategies are being followed but are not reliable to sufficiently minimise the risk of allergen cross-contact, then ingredient declaration or supplementary information would be appropriate. 4. Take an active role in educating employees, business partners, food service customers and consumers about food allergens.

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5. Continue to develop processing, analytical and operational strategies to further reduce the risk to allergic consumers of ingesting food allergens. Canada The Food and Consumer Products Manufacturers of Canada have developed an Allergy Beware programme. This is an employee education programme and covers the four As in minimising cross-contact and mislabelling: 1. awareness of how cross-contamination or mislabelling can potentially occur 2. accuracy in ingredient listings and labelling 3. correct procedures for avoidance of cross-contact or mislabelling 4. recognition of how and when to take action if accidental cross-contact or mislabelling occurs. The training programme has been running since 1993 and other organisations have used it as a model for their own communication initiatives. Australia/New Zealand Within Australia and New Zealand there is a new Food Standards Code which requires the declaration of certain substances (e.g. gluten, shellfish, nuts and soy) at all times on food labels. There are also restrictions on the use of generic names for these substances. Several different types of food are exempt from the code, however, including foods sold loose or foods sold from catering establishments. Currently in New Zealand it is possible to access allergen-free commercial food lists such as those compiled by the Manufactured Foods Database (www.mfd.co.nz). However the databases depend on voluntary contributions by food manufacturers and the printed commercial food lists are only published yearly (although the website lists are updated biweekly). Internationally The Institute of Food Science and Technology have a statement on food allergens. In this they suggest focusing on the major serious allergens (MSAs) as over 170 foods have been documented as causing allergic reactions. Guidance is given on dealing effectively with MSAs, labelling, the retailers responsibilities, the caterers responsibilities and novel foods. Codex Almentarius currently only has food labelling standards for pre-packed foods (Codex, 1985). However, within this there are guidelines regarding foods and ingredients that are known to cause hypersensitivity and should always be declared.

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Table 4. Foods and Ingredients that Should be Declared in Prepacked Foods (Codex, 1985) Cereals containing gluten, i.e. wheat, rye, barley, oats, spelt or their hybridized strains and products of these Crustacea and products of these Eggs and egg products Fish and fish products Peanuts, soybeans and products of these Milk and milk products (lactose included) Tree nuts and nut products Sulphite in concentrations of 10 mg/kg or more

The EU currently has a draft proposal covering the labelling of foodstuffs and ingredients recognised as causing hypersensitivity (Table 5). Table 5. Ingredients/foods the in EU Proposal Cereals containing gluten and products thereof Crustaceans and products thereof Eggs and products thereof Fish and products thereof Peanuts and products thereof Soybeans and products thereof Milk and dairy products (including lactose) Nuts and nut products Sesame seeds and products thereof Sulphite at concentrations of at least 10 mg/ kg INITIATIVES The following initiatives addressing matters such as customer information about food allergies and healthy eating when eating out and purchasing non prepacked foods, in other countries, were also investigated. Finland In Finland there are regulations on the food labelling and the obligatory provision of information about allergens. However, these regulations do not concern catering establishments. Restaurants and catering establishments today voluntarily give additional information. This is an expanding trend for this kind of information because of consumer demand. (AHA: marja.pohjanpalo@elintarvikevirasto.fi)

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Sweden The Swedish Green Keyhole labelling scheme, which highlights foods that are low in fat and high in fibre, is applicable on restaurant dishes provided their fat content is below 17g/serving. The symbol is therefore occasionally found on menus in some restaurants. However, in view of the need for chefs to monitor the fat content of dishes as served, this part of the labelling programme is fraught with difficulties. (The National Food Administration: akbr@slv.se) Australia and New Zealand Smart Choice is run by the New Zealand Heart Foundation. The logo is used on menu items that meet certain specified recipe criteria. This programme is not felt to be a huge success, but nevertheless is thought to have potential and is therefore being re-evaluated. A group of hotels run a similar programme, which was developed by Harvard University. Strategies to extend the Pick the Tick programme in New Zealand into the take-away arena are also being developed and the major take-away chains have expressed interest. (gareth.hughes@ghapl.com.au)

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4. RESEARCH IDENTIFIED
The questionnaires asked for details of any relevant research known by the respondents. Some sent in copies of articles and/or references to articles that were thought to be relevant. These included: Reading, A (2000). Views on Defensive food labelling from a consumer organisation. Food Allergy and Intolerance 1 (2): 77-82 FSA September 2000 Consumer information needs for food sold through catering outlets and loose foods Taylor SL & Hefle SL (2000). Good manufacturing practices for allergenic foods the use of shared equipment. Food Allergy and Intolerance 1 (1): 47-50 Leitch, IS, Blair IS & McDowell DA (2001). The Role of Environmental Health officers in the Protection of Allergic Consumers. International Journal of Environmental Health Research 11: 51-61 (see Appendix E) Unspecified research performed by the Coeliac Society Seaton A (2001). Diet and the development of asthma. The Asthma Journal 6: 128130 National Asthma Campaign Fact Sheets Diet and asthma in babies; Food reactions and asthma Latex allergy list of references given from the Latex Allergy Support Group Steenhuis IHM (2002). Feasibility and Effectiveness of Environmental Interventions in Worksite Cafeterias and Supermarkets. PhD Thesis University of Maastricht Steenhuis IHM, Assema P Van & Glaz K (2001). Strengthening environmental and educational nutrition programmes in worksite cafeterias and supermarkets in the Netherlands. Health Promotion International 16: 21-33 (see Appendix E) Several groups identified a need for further research. They suggested this research should include what information consumers want on foods sold loose or through catering outlets and what information they need to be able to make healthy and safe choices about the food they eat. The following research programmes were also highlighted during the course of the survey: National Food Agency, Finland: monitoring allergens in bakery products Starting in March 2002 a national project is being conducted to monitor allergens in bakery products. Bakery products have been chosen as they are most likely to have errors in allergen labelling. Local authorities will inspect the labelling on products. The project will monitor breads, buns, pastries and processed bakery goods. The products will be inspected for the following allergy-causing ingredients: 1) peas, fish, egg, milk, soybeans and shellfish as well as products made from these; 2) peanuts, almonds and nuts; and 3) oats, barley, wheat and rye. The objective is to investigate: 64

1) Whether the allergens are contained in recipes and whether these are indicated on packages of bakery products intended institutional kitchens and consumers, as well as wholesale and transport packages, or documents for unpacked bakery products intended for shops and institutional kitchens; 2) 2) Whether there is a possibility of cross-contamination of allergens from items previously produced on the same production line and whether this is indicated on packages or in documents (for example, the package can be labelled to indicate that it may contain nuts even if nuts are not an ingredient in the product) 3) Whether allergens and related labelling and the possibility of cross-contamination and related labelling have been taken into consideration in bakeries' in-house control. (National Food Agency: info@nfa.fi) Heart Beat Limburg, Holland In Southern Holland, within the regional community project Heart Beat Limburg, a food intervention programme was set up to label lean meat in butchers with the fat content. This intervention programme, called Lekker Gezond (Nice and Healthy), was in cooperation with a meat company called Van Melik Food Group. Twelve butchers participated, labelling lean meat products and providing advice for customers about the products and how to prepare them. The research found that the programme had no influence on various determinants of behaviour of customers towards buying lean meat products or the use of liquid fats when preparing meat. However, sub-analysis showed that those exposed to the initiative had a more positive opinion about the price of lean meat products, viewed themselves as more able to buy lean meat products and were more likely to buy lean meat products in the future. The research also showed that not all shop personnel felt sufficiently prepared to fulfil their role in the programme. Though they had undertaken training, they had low self-esteem with regard to their efficacy in communicating information. (M. Steenbakkers: M_Steenbakkers@zzl-ggd.nl) Australia and New Zealand The Australian and New Zealand Heart Foundations have run intervention studies in typical fish and chip shops (no further details available). (gareth.hughes@ghapl.com.au)

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5. RECOMMENDATIONS
5.1 PROCESS USED TO DEVELOP THE RECOMMENDATIONS The recommendations put forward in this report are based on the information collected via the questionnaires and in-depth interviews, and take account of advice and information provided by the Steering Group. Reviewing existing national and international practices and guidelines has also influenced the recommendations. The overall aims of the recommendations are: To enable the consumer to make an informed choice by provision of accurate information To enable the food supplier (including caterers and retailers selling nonprepacked foods) to provide accurate information to their customers and ultimately to the consumer

5.2 RECOMMENDATIONS: ALLERGY AWARENESS It was apparent throughout the project that, of the many factors being investigated, concerns about allergy were considered by far the most important. For this reason, the recommendations focus on allergy and allergen awareness. It was agreed by the Steering Group that the priority should be identification of measures aimed at tackling concerns about peanuts, tree nuts and seeds, as these are causes of particularly serious allergic reactions. However, consideration has also been given to the other matters included in the remit for the project and which influence the consumers ability to select food items with confidence (see Sections 5.3). It was also apparent that some companies have already expended considerable effort in developing appropriate procedures and that some excellent examples of good practice exist in both large and smaller companies, which may help others to improve their operational practices and information provision. Key aspects that require urgent attention are the conveyance of product information through the food chain to the end consumer; agreement on a definitive list of common food allergens and related terminology and descriptions; and provision of relevant training, focusing on allergy awareness, particularly for staff who interface with the public but also those who need to understand the importance of avoidance of cross contamination during food (and meal) production. Furthermore, it was evident that a balance needs to be struck. Reactions to some allergens are far more serious than others (and can be life threatening) but on the other hand, the vast majority of the population is unaffected. If the blanket exclusion of allergencontaining ingredients, as has taken place in some school meal services with regard to nuts, was extended to other common allergen-containing foods (such as milk, eggs, soya and seafood), dietary variety and nutrient provision would be seriously compromised for

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the whole population (not just the minority who react to certain foods). Furthermore, the current willingness of some manufacturers, retailers, and caterers to accommodate the need for caution with regard to nuts, peanuts and seeds might be overwhelmed if they were required to apply these measures to a wide range of ingredients. Clearly, therefore, there is a need to prioritise and target actions. 5.2.1 GOOD OPERATING PRACTICE WITH REGARD TO ALLERGENS

Recommendation 1: The FSA should lend its support to approaches which help establish good operating practices with regard to allergens, particularly with regard to nuts, peanuts and seeds. This recommendation is of particular relevance to the catering sector and other situations where food is sold non-prepacked, but it is also pertinent to all other situations where allergen control could be improved. Improvement in operating practices could be based on an approach known as the fourstrand approach (provision of information; good operating practice for back of house; training; and dialogue). Details are given below. Such an approach is of particular relevance to the catering sector but could also be applied to other sectors. One of the major barriers to improvement concerns the flow of information about product composition (particularly allergen status). The Agency may wish to consider whether there should be a legal requirement for a minimum level of information to be passed to caterers by suppliers with products (e.g. an indication of whether the product contains any of the major allergens). Furthermore the Agency should support initiatives that equip staff in catering outlets with comprehensive reference guides in which they can respond to customer enquiries on the allergen status of individual dishes. This is considered a preferable approach to the use of logos and other forms of labelling on menus. Using the four-strand approach, examples are given below of the type of advice that could be included in each of the four areas for catering establishments.

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Provision of information It is good practice to obtain information on raw materials from suppliers. This should include as a minimum the presence/absence of peanuts, tree nuts and sesame seeds. Information on the other common food allergens could also be obtained. This information needs to be accurate and up-to-date. This could involve keeping the packaging of products that are decanted into other containers before storage or transferring this information to a central point. If it is not possible to obtain accurate and up-to-date information on raw materials, then customers must not be misled or lulled into a false sense of security allergic reactions can be life-threatening. Dialogue It is good practice to establish a dialogue with consumers with food allergy. There should be acknowledgement of the issue of allergy e.g. statement on the menu. Dialogue should be encouraged with customers e.g. notice displayed in restaurant. There should be interaction with allergy sufferers e.g. staff trained to be able to identify a need for further information and to involve supervisor/manager. Information about dishes should be shared with customers to enable them to make an informed decision about which meal to select e.g. have information/packaging of different components of the meal available. If information is not complete, accurate and up-to-date, it is wrong to make guesses this could be fatal for someone with a life-threatening food allergy. In this situation, staff should be honest with the customer, giving them any information that is available, explaining what information is missing/inaccurate and letting the consumer decide what is appropriate under the circumstances. Good operating practice for back of house It is good practice when preparing an allergy sufferers meal to: Clean and sanitise equipment before weighing out ingredients. Use ingredients which are known to be allergen-free based on reliable information provided by suppliers. Clean hands, work surfaces and utensils after handling foods containing major food allergens. Cook the meal using thoroughly cleaned equipment and utensils. If it is not possible to abide by these steps, then allergy sufferers should be alerted to the fact that allergens may be present in the meals on offer. Training It is good practice to train front and back of house staff with regard to allergy: Allergy and allergen awareness should be included in induction training. Staff should be updated when menu/dishes change. Management should receive further in-depth training. If staff are untrained in allergen awareness, then allergy suffers should be alerted to the fact that allergens may be present in the meals on offer.

5.2.2

INFORMATION PROVISION

There needs to be a focus on information provision as a starting point if progress is to be made, whilst recognising that the value and impact of this approach is dependent on other key factors, e.g. what happens back up the supply chain. It is not the intention to burden businesses with unrealistic demands for information and the following recommendations address key areas that should be addressed.

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Recommendation 2: The FSA should work with interested parties to develop an agreed list of common allergen-containing foods or food groups. Recommendation 3: The FSA should work with interested parties to develop a definitive list of tree nuts, as these, along with peanuts and seeds, are recognised sources of allergens associated with particularly severe reactions. Recommendation 4 The FSA should work with interested parties to develop agreed definitions for terms such as free from and may contain, and agreed processes for declaring the presence of allergens. Recommendation 5 With regard to transfer of information about food ingredients (e.g. allergen status or other aspects of labelling information) as foods move within catering establishments (e.g. when packaging is removed or products decanted for storage), the FSA may wish to consider working with interested parties to develop guidance on the transfer and retention of such information In relation to recommendations 2-5 above: The survey highlighted that some respondents from each of the different stakeholder groups thought it would be useful to agree a priority list of the most common allergens for the purpose of labelling supplies to the catering trade. It would seem logical that the priority list should be in line with the recent proposal from the EU (Directive 2000/13/EC, see Table 5). It was also considered essential, in order that progress can be made, that a priority list of definitive list of tree nuts (see Table 6) for use throughout the food chain be agreed. There was also recognition among the different groups of the need for clearer definitions of terms used for example the term nuts. Any such consensus should take into account other definitions currently in use and those being developed. Furthermore, there was support for the requirement that major allergens should be listed in the ingredients list of all products, using the specific name (not generic) of the allergen-containing ingredient (e.g. hazel nut rather than nut), irrespective of amount (this would require removal of the 25% rule). The exception to this would be where the derived ingredient does not contain the causative protein, e.g. highly refined peanut oil would not be subject to labelling. The words used for such ingredient listing should be simple, standardised, practical and helpful. However, it is important that such terminology does not limit consumer choice. For example, use of the word milk instead of casein could mean people with lactose intolerance would avoid the food even though it could be lactose free and hence suitable for them. As well as appearing in the ingredients list of products supplied to caterers, it was suggested that the presence of allergens should also be highlighted e.g. in bold text or in a separate box/statement. 69

Another priority is to reach agreement with stakeholders on terms such as free from, contains and is suitable for. Agreed terms should be used consistently as part of the product specification. The Steering Groups preference is for use of the phrase contains. Guidance is needed for caterers (in particular) on what to do when the information provided (on major allergens) is inaccurate or incomplete (e.g. the 25% rule has been applied). For example, in such situations, no judgement can or should be made to the customer or end consumer on the suitability of the food. Associated with this, guidance is needed for caterers on the means of transferring product information in situations when packaging is removed or products decanted. One option is to transfer all information to a central storage point. Table 6 Tree Nuts Lists Utilised by Different Organisations
Organisation ILSI* FAIA ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !

Tree Nut Almond Brazil Cashew Chestnut Hazelnut/ filberts Macadamia nut Pecan Pine Nuts Pistachio Walnut

CODEX ! ! ! ! ! ! ! ! !

CFIA* ! ! ! ! ! ! ! ! !

FSA ! ! ! ! ! ! ! ! ! !

BRC ! ! ! ! ! ! ! ! !

(* ILSI International Life Sciences Institute, CFIA Canadian Food Inspection Agency)

5.2.3 TRAINING Recommendation 6: The FSA should work with interested parties to define minimum training requirements in relation to allergy awareness for food sector staff. The aim would be to minimise cross contamination and to facilitate provision of accurate information to the consumer. From the questionnaires, all the different sectors, as well as the Steering Group, identified training as being vital. Training across the food chain is an important component of many international and national guidelines reviewed for this project. Therefore there is a need to look at the training needs of those working in manufacturing, retail and catering as well as enforcement (as EHOs and TSOs appear to be key sources of information) and also the needs of consumers (particularly those at potential risk). It is envisaged that within some sectors this training component may be incorporated or linked with existing training (e.g. NVQ, Chartered Institute of Environmental Health and Royal Society of Health courses).

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Training should include elements of recommendations from this report, in particular the four-strand approach (see section 5.2.1). The emphasis would be on practical and transferable information and skills. Key underlying themes in relation to allergy could be: understanding the issues: the importance of supplying correct information to people with severe food allergy; what to do in an emergency (e.g. caterers confronted with anaphylaxis); how to communicate this information (e.g. most retailers and caterers rely on their staff for sharing information with consumers, so staff who interface with the public need to know what questions to ask, why and the priorities); shared responsibility (e.g. acknowledging that allergy sufferers need to be pro-active and involved in the communication process) and improved understanding of the labelling used on products and the information already available to them (retailers, caterers and consumers in particular). Although much information may already be supplied (e.g. nutritional information and ingredients on product specification sheets), the Steering Group felt that some sectors may not know how to utilise this information effectively and efficiently and these issues should be addressed by training.

Examples of the form this training might take are outlined in Appendix F. 5.2.4 RECOGNITION SCHEME

Recommendation 7: The FSA may wish to consider supporting an allergy awareness scheme that could be constructed along similar lines to the Heart Beat Award Scheme. Operations and companies which make a commitment to providing information on allergy, may want to inform potential customers of this. Several initiatives have already been developed, including one by Surrey County Council (see Appendix G for further details). Therefore a voluntary scheme could be developed that recognises these efforts. Any scheme: should not be part of legislation should be based on the four-strand approach principle should incorporate a training programme for staff should be a nationally-run scheme should not be overly prescriptive should aid consumer confidence but not overtly disadvantage businesses who choose not to be involved in such a scheme.

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5.3 RECOMMENDATIONS: OTHER INFORMATION Issues other than allergy were also addressed in the research, namely: healthy eating options country of origin logos date marking use of terms such as fresh and home-made portion size (with reference to catering establishments) The research highlighted some areas that appeared to be of greater concern than others, such as information on healthy eating options. However, several of the above topics did not appear to be areas requiring much attention because consumer interest was lower and/or current practice was meeting consumer needs. The Steering Group also felt that importance should be given to those topics that had not previously been addressed and/or required further consideration. Therefore no new recommendations are made in the following areas: Date marking The FAC (2001a) has already recommended that durability information requirements for pre-packed foods also be applied to foods sold loose. Portion size Consumers think this type of information is moderately important, many caterers provide or can provide this information if required. Therefore no specific recommendations are made. Use of terms such as fresh and home-made The FAC (2001b) extensively reviewed the use of such phrases and put forward recommendations. In this current research, the use of such phrases did not appear to be a priority, and so no further recommendations are made.

5.3.1 INFORMATION PROVISION Recommendation 8: The FSA may wish to consider working with interested parties to develop food based guidelines for defining healthy eating options in catering establishments. These could be based on existing materials such as Catering for Health and the Heartbeat Award Scheme. Catering for Health provides guidance on the application of healthy eating advice in a number of settings, including schools and hospitals. Clearer labelling of foods supplied to caterers may make it easier for these sectors to pass on this type of information and therefore help consumers wishing to choose healthy options. Although legal definitions

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for claims exist for pre-packed foods (Food Labelling Regulations, 1996) and the FSA has given guidance on some specific claims e.g. low fat, high fibre, use of these is generally not appropriate for catering situations (as caterers can not be expected to calculate nutritional values of composite meals and dishes). However, consumers who are interested in healthy eating currently have few guidelines on which to judge the nutritional balance of dishes sold in catering establishments that may or may not be described as healthy choices. At this stage, we do not feel it appropriate to make recommendations on the use of healthy food symbols or logos. This does not mean that they may not prove useful in some settings should clearer guidelines be set. Recommendation 9: With regard to foods sold non-prepacked that require cooking, the FSA may wish to consider actively encouraging the provision of information on cooking method by retailers by providing guidance on the methods and formats that are already in use e.g. printing information onto price labels, use of leaflets, verbal communication. This might also be extended to cover storage and durability information for foods that do not require cooking. Where appropriate, consumer and support groups responding to the survey thought information on storage and cooking for non-prepacked products should be given to increase consumer protection. This type of information is currently provided in some settings e.g. take-aways from retailers. However, in other instances this could be improved. Reliance on verbal communication for this type of information may be useful, especially in specific settings, e.g. for meat purchased from a local butcher. Information on cooking methods is often already given by many caterers so no specific recommendations are made for catering establishments. The Agency may also wish to move forward the FAC recommendations on durability (see above) by providing guidance on the methods already in use to communicate this type of information, e.g. directly marking the food, providing information in writing (e.g. on the price ticket) or orally at time of purchase, and use of websites. For example, provision of information of this type for perishable foods sold on deli counters might be expected to increase consumer protection. Recommendation 10: The FSA may wish to consider actively encouraging retailers to provide information on country of origin by offering guidance on the methods and formats that could be used e.g. printing information onto price labels, use of leaflets, verbal communication. Research has shown that retailers are often asked about country of origin and consumers rate information on this as moderately important. As many caterers provide or can provide this information if required, no specific recommendations are made for catering

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establishments but the provision of such information could be improved for nonprepacked foods. Recommendation 11: The FSA should work with interested parties to develop an agreed list of common definitions for terms such as vegetarian and vegan. The definitions should take into account those already in use and be acceptable to manufacturers, retailers, caterers and consumers. Information collected during the research suggests that a variety of different definitions are currently being applied, some of which are very misleading. Recommendation 12: The FSA may wish to consider working with interested parties to develop guidance on the transfer of information about ingredients as they move within catering establishments (see recommendation 5). Although this recommendation appears in the previous section in relation to allergy awareness, the transfer of other information (e.g. ingredient information, country of origin) may also be important. 5.3.2 TRAINING Recommendation 13: The FSA may wish to consider working with interested parties to define minimum training requirements in relation to healthy eating options. The aim would be to facilitate provision of accurate information to the consumer. Training could be based on the food-based guidelines developed (recommendation 7) and agreed definitions (recommendation 10). Catering for Health contains the basis of a curriculum. 5.3.3 RECOGNITION SCHEME Recommendation 14: The FSA may wish to consider supporting a scheme such as the Heart Beat Award Scheme to give support and recognition to those companies addressing issues such as provision of healthy eating options. As the Heart Beat Award Scheme has already been successfully run, the FSA may wish consider supporting an initiative of this type to encourage companies to recognise the importance of providing healthy eating options. Such a scheme could also look at the provision of other information such as information on vegetarian and vegan choices.

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6. CONCLUSIONS
Many consumers would like further information on the foods they purchase nonprepacked and from catering outlets. The priority for this information should be for allergens because of the danger allergen-containing foods present to susceptible individuals. However, by also addressing other areas such as healthy eating options, country of origin and vegetarian and vegan foods, the FSA can increase awareness and clarity of these issues, help the food industry to improve its current practice and help consumers to make informed choices about the food they buy. Foods sold loose and through catering outlets are managed by many diverse players, some of whom are managing the flow of information more competently than others. Recommendations outlined in this report are relevant to all players but aim to give guidance specifically to those organisations not currently addressing these issues.

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REFERENCES
Bock SA, Munoz-Furlong A & Sampson HA (2001). Fatalities due to anaphylactic reactions to foods. Journal of Allergy and Clinical Immunology 107: 191-193. British Retail Consortium (2001). Technical standard and protocol for companies supplying retailer branded food products. BRC, London. British Retail Consortium (1998). Guidelines for the Handling of Nuts. BRC, London. Buttriss J (Ed.) (2002a). Findings of the National Food Survey for 2000. Nutrition Bulletin 27: 37-40. Buttriss J (Ed.) (2002b). Adverse Reactions to Food. Blackwell Science, Oxford. Codex Alimentarius (1985). Prepackaged Foods. Codex Standard 1-1985 (Revised 11995). Department for Environment, Food & Rural Affairs and National Statistics (2001) National Food Survey 2000. The Stationery Office, London. Department of Health (1991) Committee on Medical Aspects of Food Policy. Dietary Reference Values for food energy and nutrients for the United Kingdom. Report on Health and Social Subjects 41, HMSO London. Food Advisory Committee (2001a) Review of Food Labelling. FSA, London. Food Advisory Committee (2001b) Review of the use of the terms Fresh, Pure, Natural, etc in Food Labelling. FSA, London. Food and Drink Federation (1998) Food Allergens Advice Notes. FDF, London. Food Standard Agency (2001) The Balance of Good Health. FSA, London. Food Standard Agency (2001) Be allergy aware. FSA, London. Food Standard Agency (2001) Dine out, Eat well. FSA, London. Food Standard Agency (2000) Food Labelling Forum Summary Report. FSA, London. Food Standard Agency & Department of Health (2001). Catering for Health. Foods Standard Agency, Middlesex. Gowland MH (2002). Food allergen avoidance: risk assessment for life. Proceedings of the Nutrition Society 61: 39-43.

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Gregory J, Foster K, Tyler H & Wiseman M (1990) The dietary and nutritional survey of adults. HMSO, London. Institute of Grocery Distribution (2001). Voluntary Labelling Guidelines for Food Allergens and Gluten. IGD, Watford. Leitch, IS, Blair IS & McDowell DA (2001). The Role of Environmental Health officers in the Protection of Allergic Consumers. International Journal of Environmental Health Research 11: 51-61. Ministry of Agriculture, Fisheries & Farming (1999). Working Together for The Food Chain. MAFF, London. Mintel (2001). Meat Free Foods Report. Mintel International Group, London. Proposal for a Directive of the European Parliament and of the Council amending Directive 2000/13/EC Official Journal of the European Communities 27th November 2001. Reading, A (2000). Views on Defensive food labelling from a consumer organisation. Food Allergy and Intolerance 1 (2): 77-82. Seaton A (2001). Diet and the development of asthma. The Asthma Journal 6: 128-130. Steenhuis IHM (2002). Feasibility and Effectiveness of Environmental Interventions in Worksite Cafeterias and Supermarkets. PhD Thesis, University of Maastricht. Steenhuis IHM, Assema P Van & Glaz K (2001). Strengthening environmental and educational nutrition programmes in worksite cafeterias and supermarkets in the Netherlands. Health Promotion International 16: 21-33. Taylor SL & Hefle SL (2000). Good manufacturing practices for allergenic foods the use of shared equipment. Food Allergy and Intolerance 1 (1): 47-50. The Anaphylaxis Campaign (2002). Severe food allergies: guidance for caterers. http://www.anaphylaxis.org.uk/

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APPENDIX A STEERING GROUP MEMBERS Dr Judy Buttriss (Chairman) Les Bailey (LACORS) Jane Baynton (British Sandwich Association) Samantha Calvert (Vegetarian Society) Rod Dale (Kerry Ingredients) Dionne Davy (Food Standards Agency)* Hazel Gowland (Anaphylaxis Campaign) Johanna Hignett (Nestl) Rosemary Hignett (Food Standards Agency) Brigid McKevith (British Nutrition Foundation) Tom Miller (Whitbread) Dr Martin Rawlings (British Beer and Pub Association) Dr Michele Sadler (MJSR Associates) Ann Savage (Geest plc) Eileen Steinbock (Brakes) Karen Tonks (Tesco) David Alexander (National Consumer Council)

Kate Deakin (Minutes Secretary) *Observer

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APPENDIX B COPIES OF QUESTIONNAIRES

SELF-COMPLETION QUESTIONNAIRE CATERING

There are no right or wrong answers but honest answers will be of most help. Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQ Fax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk A. Food Allergies People with food allergy need to avoid certain foods, such as nuts/peanuts, shellfish or milk. Eating out is difficult, as they dont always know whether these foods have been used in specific dishes. We are trying to find out about the sort of information available to consumers at the moment, so that we can make recommendations that will help people when eating out in the future. 1. Are you aware of concerns about food allergy? ! Yes No Dont Know 2. In relation to food allergy, do your customers ever ask about ingredients in the food you serve? ! Yes No Dont Know 3. If yes, which ingredients or foods do they usually want to know about?

4. Do you point out the use of nuts/peanuts where their presence is not obvious from the name of the dish? e.g. Chicken Satay (peanuts not in name of dish).

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! Yes No Dont know

If yes, which nuts:

5. Do you point out the use of other ingredients to which people may be allergic - such as fish, shellfish, milk where their presence is not obvious from the name of the dish? e.g. soup containing milk, where milk is not in the name of the dish. ! Yes No Dont know If yes, which ingredients?

6. If yes to questions 4 or 5: how do you inform customers about the use of these particular ingredients? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means please state in space provided Dont know Other means:

7. In relation to the foods and ingredients that you buy in: i) If you remove the goods from the packaging e.g. decant into storage containers/freezers/fridges etc, do you keep the labels or a note of the label information? ! Keep labels Take a note of the label information Dont know ii) Is the label a useful method of providing you with information about food allergens, or do you throw away the packaging before the goods get into the kitchen?

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! Useful means of providing information Not useful label thrown away before goods are used Dont know 8. If you use nuts/peanuts as an ingredient, how are these stored and labelled? ! No differently to other ingredients In a separate area, with distinctive labelling Dont know Not relevant dont use nuts/peanuts 9. How do you prepare dishes containing nuts? ! No differently to other dishes Special procedures are in place please state Dont know Not relevant dont use nuts/peanuts 10. Are your staff aware of the precise contents of dishes, and any changes to them e.g. addition of nuts/peanuts? ! Yes No Dont know 11. Have you ever received information telling you about food allergies? ! Yes No Dont know If yes, from where:

12. Do you have regular staff training sessions? ! No Yes but allergies not included Yes allergies included If yes, how frequently:

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Dont know

13. Do you have any standard advice for your customers who have food allergies? ! Yes If yes, please give details of advice:

No

Dont know

B Consumer Choice Some people are interested in healthy eating or where food comes from, and may like to have this information when eating out. 14. Do your customers ever ask for information about healthy eating choices? ! No Yes they ask about healthy choices Yes they ask about use of specific ingredients such as cream/oil/ butter/salt Yes they ask about cooking method e.g. if food is fried, grilled, baked etc Dont know 15. Do you provide any dishes for people that are looking for healthy eating choices? ! Yes No Dont know If yes, please give some examples:

16. How do your customers know about them? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means:

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Other means please state in space provided We dont see a need to tell them Dont know

17. Do your suppliers/wholesalers tell you about fat and calories (and other nutrients) in products/ingredients? ! None of them Some suppliers/wholesalers All suppliers/wholesalers Dont know 18. Do your customers ever ask for information about vegetarian or vegan choices? ! Vegetarian Yes No Dont know ! Vegan If yes, how is the information provided:

19. Do you provide vegetarian or vegan choices? ! Vegetarian Always Sometimes Never Dont know ! Vegan If always or sometimes, please give some examples?

20. How are customers informed about these dishes? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means:

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Other means please state in space provided We dont see a need to tell them Dont know 21. Do you provide any of the following information about the dishes you serve? !Yes - please give details Portion size such as the size of a steak or other item ! No ! Dont know

Descriptions such as Fresh, Homemade, Farmhouse, Traditional etc

The country of origin of the ingredients/ food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed Pan fried chicken, deep fried cod

22. Do your customers ever ask for information of this type? ! Yes Portion size If the food is Fresh, Homemade, Farmhouse, Traditional etc The country of origin of the ingredients/ food e.g. British beef, French chicken ! No ! Dont know

Cooking method e.g. fried, grilled, baked, steamed

Anything else ..

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23. Do you provide either of the following? Yes ! Sales/delivery via Internet ordering Sales/delivery via telephone ordering No ! Dont know !

24. If yes, are any procedures in place to inform customers who may want information about allergens, healthy eating, vegetarian products etc?

!
Yes

If yes, please give details:

No

25. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

26. And do you foresee any barriers that will make progress difficult to achieve?

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27. Please add any further comments or observations

Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Business Name Main function of business/opera tion Your Name Address Tel Fax E-mail

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SELF COMPLETION QUESTIONNAIRE CONSUMER AND SUPPORT GROUPS

The Food Standards Agency wishes to support consumer choice when people with food allergy eat out or purchase non-prepacked foods. Information about other issues of consumer choice is also being considered. This questionnaire is designed to canvas your experience and your views in relation to these issues.
Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin, The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQ Fax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk 1. To ensure consumer choice and safety when eating out, which of the following issues do you think it is important for consumers to have information about? a) Use of common food allergens as ingredients

Nuts/peanuts Sesame seeds Fish Shellfish Eggs Soya Milk Other please state . b) Healthy eating choices

Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

Ingredients used Nutrient content Low-fat choices Low-calorie choices High-fibre choices Low salt choices Cooking method, e.g. fried, baked Other please state . c) Logos or statements

Vegetarian Organic Gluten-free Other . d) The country of origin of the ingredients/food e.g. British beef, French chicken

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e) Portion size f) Other please state Are your responses to question 1 based on: ! Consumer research Consumer enquiries Other information Personal opinion

If based on research, please give details/references

2. To ensure consumer choice and safety when buying non-prepacked foods, which of the following issues do you think it is important to have information about? a) Use of common food allergens as ingredients

Nuts/peanuts Sesame seeds Fish Shellfish Eggs Soya Milk Other please state . b) Healthy eating choices

Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 Importance Scale of 1 (not) 5 (very) Please circle 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5

Ingredients used Nutrient content Low-fat choices Low-calorie choices High-fibre choices Low salt choices Cooking method, e.g. fried, baked Other please state . c) Logos or statements

Vegetarian/Vegan Organic Gluten free Other please state .

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d) The country of origin of the ingredients/food e.g. British beef, French chicken e) Use by date f) Quantities of main ingredients g) Other please state

1 1 1 1

2 2 2 2

3 3 3 3

4 4 4 4

5 5 5 5

Are your responses to question 2 based on: ! Consumer research Consumer enquiries Other information Personal opinion 3. What do you think about the usefulness for consumers of providing cooking instructions for raw or uncooked foods such as burgers, sausages and chickens that are sold non-prepacked? If based on research, please give details/references

4. To help us make recommendations on any of the above issues can you think of any practical steps that would be helpful to consumers?

5. And, do you foresee any barriers that will make progress difficult to achieve?

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6. Do you know of any research [consumer or industry practices] that has been conducted in relation to any of these issues, either within the UK or internationally?

7. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Organisation Your name Address Tel Fax E-mail

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SELF-COMPLETION QUESTIONNAIRE MANUFACTURERS

This questionnaire relates to products sold to the catering industry, and sold non-prepacked to the end consumer. There are no right or wrong answers please base your answers on current practice. Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin, The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQ Fax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk A. Food Allergies The Food Standards Agency wishes to help consumers with food allergy to select foods with confidence when they eat out or purchase non-prepacked foods. The questions in this section are designed to review current manufacturing practice for products sold to the catering industry, and also for products that are sold non-prepacked to the end consumer. 1. Do your suppliers routinely provide information about all uses of nuts/peanuts as ingredients (including very small amounts), or of the possibility of traces of nuts/peanuts being present in the goods that you purchase? Please focus your answer on products that are to be sold nonprepacked to the end consumer or sold to the catering industry. ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know

2. Do your suppliers routinely provide information about all uses of other food allergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively common cause of food intolerance. Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry.
! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know 3. Where information is received: What format is it in? How does your company retain it? If some or all, which allergens:

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How is it used by your company, and passed on to your consumers? 4. Does your company request any special operational procedures from suppliers in relation to nuts/peanuts? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! From no suppliers From some suppliers From all suppliers Dont know If some or all, please provide details

5. Does your company request any special operational procedures from suppliers in relation to other food allergens? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! From no suppliers From some suppliers If some or all, please provide details

From all suppliers

Dont know

6. Do your immediate clients request additional or specific information about the presence of nuts/peanuts, including traces of nuts/peanuts, in your products or about the operational procedures? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! No clients request this If some or all, please provide details

Some clients

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All clients

Dont know

7. Do your immediate clients request additional or specific information about the presence of other food allergens in your products or about the operational procedures? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! No clients request this Some clients All clients Dont know If some or all, please provide details

8. If your company uses nuts/peanuts as an ingredient in foods that are to be sold non-prepacked to the end consumer and in products sold to the catering industry, how are the nuts/peanuts stored and labelled? ! No differently to other ambient ingredients In a separate area, with distinctive labelling Dont know 9. How are products containing nuts/peanuts prepared? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! No differently to products that do not contain nuts Special procedures are in place please state

Details of special procedures

Dont know

10. For products that contain nuts/peanuts, are staff briefed on the contents and on any changes to the products being made? Please focus your answer on products that are to be sold nonprepacked to the end consumer or sold to the catering industry.

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! Never Yes Dont know

If yes, how frequently:

11. Does your company undertake any staff training about the issue of food allergy? ! No Yes Dont know B Consumer Choice 12. Does your company provide healthy eating choices to the catering industry or for products that are to be sold non-prepacked to the end consumer e.g. products promoted as low in fat, low in calories, high in fibre, low in salt etc? ! Yes No Dont know 13. If yes: how are your immediate clients informed about these products? ! Claims are made on the label Nutritional analysis is provided Products are part of a healthy eating range Dont know If yes, please give some examples If yes, how frequently:

14. Does your company manufacture vegetarian or vegan products (that are sold to the catering industry or to be sold non-prepacked to the end consumer)? ! Vegetarian Yes No Dont know ! Vegan If yes, please give some examples

15. If yes: do they carry a logo or statement?

94

! Yes No Dont know 16. Do you routinely provide any cooking instructions for the end consumer for raw or uncooked foods such as burgers, sausages and chickens that are to be sold non-prepacked to the end consumer?

!
Yes

If yes, please give details of how this information is provided:

No

C The Future 17. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

18. And do you foresee any barriers that will make progress difficult to achieve?

19. Please add any further comments or observations

Your help in completing this questionnaire is much appreciated.

95

Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

96

SELF-COMPLETION QUESTIONNAIRE RETAILERS

This questionnaire relates to products sold non-prepacked to your customers. There are no right or wrong answers please base your answers on current practice. Please return questionnaire as soon as possible, but no later than 18th February, to: Kate Deakin, The British Nutrition Foundation, 52-54 High Holborn, London WC1V 6RQ Fax: 020 7404 6747 E-mail: k.deakin@nutrition.org.uk 1. Which types of non-prepacked products do you sell? ! Bakery products such as bread, buns, rolls etc Delicatessen products such as cold meats, pates, cheese, prepared salads Fish Fruit and vegetables Hot cooked chicken Meat and meat products such as sausages and pies Pick and Mix (confectionery) Ready made Pizza Take away meals Other (please specify): ..

A. Food Allergies People with food allergy need to avoid certain foods, such as nuts/peanuts, shellfish or eggs. Buying non-prepacked foods can cause problems, as customers dont always know which ingredients have been used. We are trying to find out about the sort of information available to customers at the moment, so that we can make recommendations that will help people with food allergy in the future. 2. Are you aware of concerns about food allergy? ! Yes No Dont Know 3. For the foods that you sell non-prepacked, are you aware of which ingredients have been used. For example, would you know if nuts/peanuts or shellfish, milk or eggs were present in a product you sell? ! Not for any products For some products

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For all products Dont know 4. If you sell non-prepacked products with nuts/peanuts, how are these displayed and served e.g. on delicatessen counters? ! No differently to other products Special procedures are in place (please state what these are) Dont know Not relevant Details of any special procedures

5. How are non-prepacked products containing other ingredients to which some people are allergic (e.g. sesame seeds, shellfish) displayed and served e.g. on delicatessen and bakery counters? ! No differently to other products Special procedures are in place (please state what these are) Dont know Special procedures

6. How are non-prepacked nuts/peanuts displayed and served, e.g. pick and mix counters? ! No differently to similar products Special procedures are in place - (please state what these are) Dont know Not relevant Special procedures

7. If your customers need to know whether nuts/peanuts (or other ingredients that cause an allergy) are in non-prepacked products, are you able to help them? ! We cant help Staff are informed and can answer questions Display tickets indicate products that contain nuts/peanuts We go back and ask our supplier/wholesaler Dont know

98

8. Do your customers ever ask if nuts/peanuts are in any non-prepacked products? ! Yes No Dont know 9. Do your customers ever ask about the use of other ingredients in non-prepacked products to which they may be allergic e.g. fish, milk, eggs? ! Yes No Dont know 10. For non-prepacked products containing nuts/peanuts, and other important food allergens, are your staff briefed on the contents and on any changes to the ingredients of dishes served, e.g. change in the type of nut used? ! Never Yes Dont know If yes, how frequently: If yes, which ingredients:

B Consumer Choice 11. Do your customers ever ask for information about healthy eating choices in relation to nonprepacked products? ! No Yes they ask about healthy choices Yes they ask about use of specific ingredients such as cream/oil/ butter/salt Yes they ask about the cooking method such as fried or baked Dont know 12. Are any of the non-prepacked products you sell promoted as healthy choices e.g. products low in fat, low in calories, high in fibre, low in salt? ! Yes No Dont know 13. If yes: how do your customers know? ! Through display tickets Other means If yes, please give examples

99

Staff provide details if asked Other means (please state) Dont know 14. Do customers ever ask for information about vegetarian or vegan choices in relation to nonprepacked products? ! Vegetarian ! Vegan Yes No Dont know 15. Where vegetarian or vegan products are sold non-prepacked how is the customer informed? ! Through a display ticket Staff provide details if asked It is communicated by other means (please state) Dont know We dont sell products for vegetarians We dont sell products for vegans Other means

16. Do you provide any other information about the products sold non-prepacked? Yes ! Descriptions such as Fresh, Homemade, Farmhouse, Traditional etc No ! Dont know !

Use by date or shelf-life information

The country of origin of the ingredients/food e.g. British beef, French chicken

17. Do your customers ever ask for information of this type for non-prepacked products? Yes ! If the food is Fresh, Home-made, Farmhouse, Traditional Use by date or shelf-life information No ! Dont know !

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The country of origin of the ingredients/food e.g. British beef, French chicken Anything else ..

18. Do you provide either of the following? Yes ! Sales/delivery via Internet ordering Sales/delivery via telephone ordering 19. If yes, are any procedures in place to inform customers who may want information about allergens, healthy eating, vegetarian products etc, in relation to non-prepacked products? No ! Dont know !

!
Yes

If yes, please give details:

No

20. Do you routinely provide any cooking instructions for raw or uncooked foods such as burgers, sausages and chickens that are sold non-prepacked?

!
Yes

If yes, please give details of how this is done:

No

101

C The future 21. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

22. And do you foresee any barriers that will make progress difficult to achieve?

23. Please add any further comments or observations:

102

Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

103

DETAILED QUESTIONNAIRE CATERING

There are no right or wrong answers but honest answers will be of most help. This questionnaire can either be filled out and returned by DATE to: OR it can form the basis of a telephone interview. A. Food Allergies 2. Are you aware of concerns about food allergy? ! Yes No Dont Know The Food Standards Agency has agreed a four-strand approach to help consumers with food allergy select foods with confidence when they eat out. The questions in this section are designed to review current practice in each of these four areas. Information for your customers 2. Do your customers ever ask whether nuts/peanuts are used in your operation/kitchen, or are present in any dishes? ! Yes No Dont know 3. Do your customers ever ask about other ingredients to which they may be allergic e.g. milk, fish, shellfish? ! Yes No Dont know 4. Do you point out the use of nuts/peanuts where their presence is not obvious from the name of the dish? E.g. Chicken Satay (peanuts not in name of dish). ! Yes No If yes, which nuts: If yes, which ingredients: If yes, indicate the number of requests for information per week If yes, please indicate the number of requests for information per week

104

Dont know

5. Do you point out the use of other ingredients to which people may be allergic - such as fish, shellfish, milk where their presence is not obvious from the name of the dish? E.g. soup containing milk, where milk is not in the names of the dish. ! Yes No Dont know If yes, which ingredients?

6. If yes to questions 12 or 13: how do you inform customers about these particular ingredients? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means please state in space provided Dont know Other means:

7. Does your company have any policy or advice for your customers who have food allergies? ! Yes If yes, please give details

No

Dont know

Storage and preparation 8. If your company uses nuts/peanuts as an ingredient, how are these stored and labelled? ! No differently to other ambient ingredients

105

In a separate area, with distinctive labelling Dont know

9. How are dishes containing nuts/peanuts prepared? ! No differently to other dishes Special procedures

Special procedures are in place please state

Dont know

10. For dishes containing nuts/peanuts, are staff briefed on the contents and on any changes to the dishes served e.g. use of different types of nut? ! Never Daily As menus change Dont know Training 11. Has your company ever received educational information about food allergies? ! Yes No Dont know If yes, where from:

12. Does your company have regular staff training? ! No Yes but allergies not included Yes allergies included Dont know Information received from suppliers/wholesalers If yes, how frequently:

106

13. Do your suppliers/wholesalers routinely provide information about all uses of nuts/peanuts as ingredients (including very small amounts), or of the possibility of traces of nuts/peanuts being present in the goods that you purchase? ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know 14. When products are labelled May contain traces of nuts, what does this mean to you and how do you use the information? ! It reflects well-controlled systems we take note of the information It is a general warning that appears on many products we dont use the information It means different things for different suppliers Dont know Other please specify

15. Do your suppliers/wholesalers routinely provide information about all uses of other food allergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively common cause of food intolerance. For example do they flag up Contains Egg? ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know If some or all, which allergens:

16. When information about allergens is provided: Please give details: What format is it in?

How does your company retain it?

How is it used by your company, and passed on to your consumers?

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How do you distinguish between foods/ingredients that are suitable for nutfree products and those that are not?

If foods/ingredients are suitable for nut-free products, do you keep the packaging or other means of retaining this information?

17. Does your company request any special operational procedures from suppliers/wholesalers in relation to nuts/peanuts? ! From no suppliers If some or all, please give details

From some suppliers

From all suppliers

Dont know

18. In relation to the foods and ingredients that you buy in: i) If you remove the goods from the packaging e.g. decant into storage containers/freezers/fridges etc, do you keep the labels or a note of the label information? ! Keep labels Take a note of the label information Dont know ii) Is the label a useful method of providing you with information about food allergens, or do you throw away the packaging before the goods get into the kitchen? ! Useful means of providing information Not useful label thrown away before goods are used Dont know

108

B Consumer Choice 19. Do your customers ever ask for information about healthy eating choices e.g. dishes that are low in fat, low in calories, high in fibre, low in salt etc? ! No Yes they ask about healthy eating choices Yes they ask about use of specific ingredients such as cream/oil/ butter/salt Yes they ask about the cooking method such as fried or baked Dont know If yes, how many requests per week

20. Does your company provide healthy eating choices e.g. dishes that are low in fat, low in calories, high in fibre, low in salt etc? ! Yes If yes, please give some examples

No

Dont know

21. How are your customers informed about the status of these dishes? ! It is printed on the menu Staff provide details if asked It is communicated by other means please state We dont see a need to tell them Dont know 22. Do your suppliers/wholesalers provide information about the nutritional content of products/ingredients? ! No suppliers provide this Some suppliers All suppliers Our company requests it Other means:

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Dont know 23. Do your customers ever ask for information about vegetarian or vegan choices? ! Vegetarian Yes No Dont know If yes, how many requests per week ! Vegan If yes, how many requests per week

24. Does your company routinely provide vegetarian or vegan choices? ! Vegetarian Yes No Dont know ! Vegan If yes, please give some examples

25. How are your customers informed about the status of these dishes? ! It is printed on the menu Staff provide details if asked It is communicated by other means please state We dont see a need to tell them Dont know 26. Do you routinely provide any other information about the dishes you serve, on a voluntary basis? Yes ! please give details Portion size e.g. the size of a steak is often given on the menu is the portion size of any other foods given? Descriptions such as Fresh, Homemade, Farmhouse, Traditional etc The country of origin of the ingredients/ food e.g. British beef, French chicken No ! Dont know ! Other means:

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Cooking method e.g. fried, grilled, baked, steamed

27. Do your customers ever ask for other information about the dishes available? Yes please state number of requests per week Portion size If dishes are Fresh, Home-made, Farmhouse, Traditional etc The country of origin of the ingredients/ food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed Other . 28. Do you provide either of the following? ! Yes Sales/delivery via Internet ordering Sales/delivery via telephone ordering 29. If yes, are any procedures in place to inform customers who may want information about allergens, healthy eating, vegetarian products etc ! No ! Dont know No ! Dont know !

!
Yes

If yes, please give details:

No

C International Practice 30. In relation to any international operations that you have: Please comment on any differences between UK and international operations in the following areas? Food Allergies Comments Storage/preparation of dishes containing allergens

111

Staff training

Informing customers

Consumer Choice Providing healthy eating choices

Comments

Providing vegetarian or vegan dishes

Indicating portion size

Providing descriptions such as Fresh, Home-made, Farmhouse, Traditional etc Providing information about the country of origin of ingredients/ food e.g. British beef, French chicken Providing information about the cooking method e.g. fried, grilled, baked, steamed

31. In relation to your international suppliers/wholesalers: Please comment on any difference between UK and international suppliers in the following areas? Food Allergies Comments Information provided by suppliers

Consumer Choice Providing nutritional information

Comments

112

Providing information about vegetarian and vegan products

Providing information about the country of origin of ingredients/ food e.g. British beef, French chicken 32. Are you aware of any research [consumer or industry practices] conducted in relation to any of these issues, either within the UK or internationally?

D The Future 33. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

113

34. And do you foresee any barriers that will make progress difficult to achieve?

35. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details these will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

114

DETAILED QUESTIONNAIRE MANUFACTURERS

Relating to products sold to the catering industry, and non-prepacked to the end consumer. This questionnaire can either be filled out and returned by DATE to: OR it can form the basis of a telephone interview. There are no right or wrong answers your answers should be based on current practice. A. Food Allergies The Food Standards Agency wishes to help consumers with food allergy to select foods with confidence when they eat out or purchase non-prepacked foods. The questions in this section are designed to review current manufacturing practice for products sold to the catering industry, and also for products that are sold non-prepacked to the end consumer. 1. Do your suppliers routinely provide information about all uses of nuts/peanuts as ingredients (including very small amounts), or of the possibility of traces of nuts/peanuts being present in the goods that you purchase? Please focus your answer on products that are to be sold nonprepacked to the end consumer or sold to the catering industry. ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know

2. When ingredients you buy are labelled May contain traces of nuts, what does this mean to you and how do you use the information, particularly in relation to your products that are sold non-prepacked to the end consumer or sold to catering establishments. ! It reflects well-controlled systems we take note of the information It is a general warning that appears on many products we dont use the information It means different things for different suppliers Dont know

115

Other please specify

3. Do your suppliers routinely provide information about all uses of other food allergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively common cause of food intolerance. For example do they flag up Contains Egg? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. For example do they flag up Contains Egg? ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know 4. Where information about allergens is received: What format is it in? If some or all, which allergens:

How does your company retain it?

How is it used by your company, and passed on to your consumers particularly with reference to your products that are sold nonprepacked to the end consumer and sold to catering establishments?

How do you distinguish between foods/ingredients that are suitable for nutfree products and those that are not? If foods/ingredients are suitable for nut-free products, do you keep the packaging or other means of retaining this information?

5. Does your company request any special operational procedures from suppliers in relation to nuts/peanuts? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! If some or all, please provide details

116

From no suppliers From some suppliers From all suppliers Dont know

6. Does your company request any special operational procedures from suppliers in relation to other food allergens? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! From no suppliers If some or all, please provide details e.g. which allergens

From some suppliers

From all suppliers

Dont know

7. Do your immediate clients request additional or specific information about the presence of nuts/peanuts, including traces of nuts/peanuts, in your products or about the operational procedures (for foods that are to be sold non-prepacked or through catering establishments)? ! No clients request this Some clients All clients Dont know If some or all, please provide details

8. Do your immediate clients request additional or specific information about the presence of other food allergens in your products or about the operational procedures (for foods that are to be sold non-prepacked or through catering establishments)? E.g. preparation of meringues within a flour environment in relation to the possible presence of gluten. ! No clients request this If some or all, please provide details

117

Some clients All clients Dont know

9. If your company uses nuts/peanuts as an ingredient in foods that are sold non-prepacked to the end consumer and in products sold to the catering industry, how are the nuts/peanuts stored and labelled? ! No differently to other ambient ingredients In a separate area, with distinctive labelling Dont know 10. How are products containing nuts/peanuts prepared? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! No differently to other products Special procedures are in place please state Dont know 11. Are operational staff aware which products contain nuts/peanuts, and are they briefed when ingredients change, e.g. if nuts/peanuts are added or removed from products? Please focus your answer on products that are to be sold non-prepacked to the end consumer or sold to the catering industry. ! Never Yes Dont know If yes, how frequently:

Details of special procedures

12. Does your company undertake any staff training about the issue of food allergy? ! No Yes Dont know If yes, how frequently:

B Consumer Choice

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13. Does your company provide healthy eating choices to the catering industry or that are to be sold non-prepacked to the end consumer e.g. products promoted as low in fat, low in calories, high in fibre, low in salt etc? ! Yes No Dont know If yes, please give some examples

14. If yes: how are your clients informed about the status of these products? ! Claims are made on the label Nutritional analysis is provided Products are part of a healthy eating range Dont know 15. Does your company manufacture vegetarian or vegan products (that are sold to the catering industry or to be sold non-prepacked to the end consumer)? ! Vegetarian Yes No Dont know ! Vegan If yes, please give some examples

16. If yes: do they carry a logo or statement? ! Yes No Dont know

17. Do you routinely provide any cooking instructions for the end consumer for raw or uncooked foods such as burgers, sausages and chickens that are to be sold non-prepacked?

!
Yes

If yes, please give details of how this information is provided:

119

No

C International Practice 18. In relation to any international operations that you have: In relation to foods that are to be sold non-prepacked to the end consumer please comment on any differences between UK and international operations in the following areas? Food Allergies Comments Supplier information provision

Storage/preparation of dishes

Consumer Choice Providing healthy choices

Comments

Providing vegetarian/vegan dishes

Providing cooking instructions for raw or uncooked foods

19. In relation to your international suppliers: Are you aware of any difference between UK and international suppliers in the following areas? Comments Food Allergies

120

Information provided by suppliers

Consumer Choice Providing nutritional information

Comments

Providing information about vegetarian/vegan products

20. Are you aware of any research [consumer or industry practices] conducted in relation to any of these issues, either within the UK or internationally?

D The Future 21. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

22. And do you foresee any barriers that will make progress difficult to achieve?

121

23. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated. Please provide your contact details in order that I can contact you to clarify any of the information. These details these will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

122

DETAILED QUESTIONNAIRE RETAILERS

Relating to products sold non-prepacked to your customers. This questionnaire can either be filled out and returned by DATE to: OR it can form the basis of a telephone interview. There are no right or wrong answers your answers should be based on current practice. A. Food Allergies The Food Standards Agency has agreed a four-strand approach to help consumers with food allergy select foods with confidence when they eat out. These issues are also relevant to foods that are sold non-prepacked to the end consumer. The questions in this section are designed to review current practice in each of these four areas. I Information received from suppliers/wholesalers 1. Do your suppliers/wholesalers routinely provide information about all uses of nuts/peanuts as ingredients (including very small amounts), or of the possibility of traces of nuts/peanuts being present in the goods that you purchase that are sold non-prepacked to customers? ! No suppliers provide this Some suppliers All suppliers Our company requests it Dont know 4. When products are labelled May contain traces of nuts, what does this mean to you and how do you use the information? ! It reflects well-controlled systems we take note of the information It is a general warning that appears on many products we dont use the information It means different things for different suppliers Dont know Other please specify

3. Do your suppliers/wholesalers routinely provide information about all uses of other food allergens (including very small amounts)? Other main allergens are found in: sesame seeds, eggs, milk, soya, fish and shellfish; gluten (found in wheat, barley, rye, oats) is a relatively common cause of food intolerance. For example do they flag up Contains Egg? ! No suppliers provide this information If some or all, which allergens:

123

Some suppliers All suppliers Our company requests it Dont know 4. Where information about allergens is provided: What format is it in?

How does your company retain it?

How is it used by your company, and passed on to your consumers?

How do you distinguish between nut-free products and those that are not? If products are nut-free, do you keep the packaging or other means of retaining this information?

5 Does your company request any special operational procedures from suppliers in relation to nuts/peanuts, for goods that are sold non-prepacked? ! From no suppliers From some suppliers From all suppliers Dont know If some or all, please provide details:

6. Does your company request any special operational procedures from suppliers in relation to other food allergens? ! From no suppliers If some or all, please provide details e.g. which allergens

From some suppliers

124

From all suppliers

Dont know

II Display and serving 7. How are products containing nuts/peanuts displayed and served e.g. on delicatessen counters? ! No differently to other dishes Special procedures are in place - please state Dont know Not relevant Special procedures

8. How are non-prepacked nuts/peanuts displayed and served, e.g. on pick and mix counters? ! No differently to similar products Special procedures are in place - please state Dont know Not relevant Special procedures

9. How are products containing other important food allergen sources (e.g. sesame seeds, shellfish) displayed and served e.g. on delicatessen and bakery counters. ! No differently to other dishes Special procedures are in place - please state Dont know Not relevant Special procedures

125

10. For products containing nuts/peanuts, and other important food allergens, are your staff briefed on the contents and on any changes to the ingredients of dishes served, e.g. change in the type of nut used? ! Never Yes Dont know If yes, how frequently:

III Training 11. Does your company have regular staff training? ! No Yes allergies not included Yes allergies included Dont know IV Information for the customer 12. If your customers need to know if nuts/peanuts or other ingredients are in products, how are they informed? ! Display tickets indicate products that contain nuts/peanuts Staff are informed and can answer questions A display ticket suggests that customers ask staff We go back and ask our suppliers/wholesalers Dont know Other means: If yes, how frequently:

13. Do your customers ever ask whether nuts/peanuts are present in any non-prepacked products? ! Yes No Dont know

126

14. Do your customers ever ask about use of other ingredients to which they may be allergic e.g. fish, milk, shellfish? ! Yes No Dont know 15. Does your company have any policy or advice for customers with food allergies in relation to non-prepacked products? ! Yes No Dont know B Consumer Choice 16. Do your customers ask for information about healthy eating choices? ! No Yes they ask about healthy eating choices Yes they ask about use of specific ingredients such as cream/oil/ butter/salt Yes they ask about the cooking method such as fried or baked Dont know 17. Are any of the non-prepacked products you sell promoted as healthy eating choices e.g. products low in fat, low in calories, high in fibre, low in salt? ! Yes No Dont know 18. If yes: how is the customer informed about these products? ! Through display tickets Staff provide details if asked Communicated by other means e.g. leaflets, tent cards, menus Dont know 19. Do you provide any other nutritional information about foods sold non-prepacked e.g. calorie or fat content? ! If yes, please give some examples If yes, please give examples of products If yes, how many requests per week If yes, please give details If yes, which ingredients:

127

Yes No Dont know

20. Do your customers ask for information about vegetarian or vegan choices? ! Vegetarian Yes No Dont know If yes, how many requests per week ! Vegan If yes, how many requests per week

21. Where vegetarian or vegan products are sold non-prepacked, how are your customers informed? ! Through a display ticket Staff provide details if asked It is communicated by other means please state Dont know We dont provide products for vegetarians We dont provide products for vegans Other means

22. Do you routinely provide any other information about the products sold non-prepacked, on a voluntary basis? Yes please give details ! Descriptions such as Fresh, Homemade, Farmhouse, Traditional etc No ! Dont know! !

Use by date or shelf-life information

128

The country of origin of the ingredients/food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed

23. Do your customers ever ask for information of this type? Yes - please state number of requests per week If the food is Fresh, Home-made, Farmhouse, Traditional etc Use by date or shelf-life information The country of origin of the ingredients/food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed Other 24. Do you provide either of the following? Yes ! Sales/delivery via Internet ordering Sales/delivery via telephone ordering 25. If yes, are any procedures in place for non-prepacked foods to inform customers who may want information about allergens, healthy eating, vegetarian products etc ? No ! Dont know ! No ! Dont know !

!
Yes

If yes, please give details:

No

26. Do you routinely provide any cooking instructions for raw or uncooked foods such as burgers, sausages and chickens that are sold non-prepacked?

!
Yes

If yes, please give details of how this is done:

129

No

C International Practice 27. Do you have any international operations? If yes, please answer the questions below. If no, please go to Q23. In relation to foods sold non-prepacked please comment on any differences between UK and international operations in the following areas: Food Allergies Comments Display and serving of nonprepacked products

Staff training

Informing customers about foods that may contain allergens

Consumer Choice Providing healthy options and nutrition information

Comments

Offering vegetarian or vegan dishes

Use of descriptions such as Fresh, Home-made, Farmhouse, Traditional etc

Use by date or shelf-life information

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Providing information about the country of origin of ingredients/ food e.g. British beef, French chicken Providing information about the cooking method e.g. fried, grilled, baked, steamed Providing information on goods ordered by Internet or telephone for home delivery Providing cooking instructions for raw or uncooked foods

28. In relation to your international suppliers/wholesalers: Please comment on any differences between UK and international suppliers/wholesalers in the following areas in relation to foods sold non-prepacked: Comments Food Allergies Information provided by suppliers/wholesalers

Consumer Choice Providing nutritional information

Comments

Providing information about vegetarian and vegan products

Providing information about the country of origin of ingredients/ food e.g. British beef, French chicken Other .

29. Are you aware of any research [consumer or industry practices] conducted in relation to any of these issues, either within the UK or internationally?

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D The future 30. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

31. And do you foresee any barriers that will make progress difficult to achieve?

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32. Please add any further comments or observations:

Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details these will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

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DETAILED QUESTIONNAIRE SCHOOLS POLICY

There are no right or wrong answers but honest answers will be of most help. This questionnaire can either be filled out and returned by End Feb 2002 to: OR it can form the basis of a telephone interview. A. Food Allergies 1. In relation to nut allergies, does your local authority have a policy on the use of nuts in school meals? If yes please provide details.

2. If yes, how is this policy communicated to schools, parents and caterers?

3. If there is a policy not to use nuts, is there any policy for the use of ingredients that may have come into contact with nuts through the supply chain? ! No The suppliers deal with this issue We have a policy please give details Details

4. Do parents ever ask whether nuts/peanuts are used, or are present in any dishes? ! Yes No Dont know

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5. Are there any policies for other ingredients to which children/teachers may be allergic e.g. milk, fish, shellfish? ! Yes No Dont know 6. How is the use of other ingredients to which people may be allergic - such as fish, shellfish, milk, gluten communicated, particularly where their presence is not obvious from the name of the dish? E.g. soup containing milk, where milk is not in the names of the dish. ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means please state in space provided Dont know If yes, which ingredients:

Other means:

7. Please add any further information relevant to food allergies e.g. are children with particular allergies dealt with individually? Further information

B Healthy Eating - nutrition 8. In relation to healthy eating, does your local authority have a policy on healthy eating in addition to any statutory guidelines? If yes please provide details.

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9. If yes, how is this policy communicated to schools, parents and caterers?

10. Do parents ever ask about healthy eating policy? ! Yes No Dont know 11. How do children and teachers identify healthy eating options? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means please state in space provided Dont know Other means:

12. Any further information e.g. are children with particular dietary requirements dealt with individually? Further information

C Use of food additives 13. Does your local authority have a policy on use of food additives? If yes please provide details.

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14. If yes, how is this policy communicated to schools, parents and caterers?

15. Do parents ever ask about food additives policy? ! Yes No Dont know 16. Please add any additional relevant information

Further information

D Vegetarian/Vegan Options 17. Does your local authority have a policy on vegetarian and/or vegan options? If yes please provide details.

18. If yes, how is this policy communicated to schools, parents and caterers?

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19. Do parents ever ask about vegetarian/vegan policy? ! Yes No Dont know 20. How do children and teachers identify vegetarian/Vegan options? ! It is printed on the menu It is chalked on the blackboard Staff provide details if asked Other means please state in space provided Dont know Other means:

21. Please add any additional relevant information Further information

E Other Issues 22. Does your local authority have a policy on any other issues, e.g. GM foods, Organic foods? If yes please provide details.

23. If yes, how is this policy communicated to schools, parents and caterers?

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24. Do parents ever ask about these or any other issues ? ! Yes No Dont know 25. Is any other information routinely provided about dishes served? Yes ! please give details Portion size Descriptions such as Fresh, Homemade, Farmhouse, Traditional etc The country of origin of the ingredients/ food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed No ! Dont know ! Which issues?

26. Is such information ever asked for? Yes Portion size If dishes are Fresh, Home-made, Farmhouse, Traditional etc The country of origin of the ingredients/ food e.g. British beef, French chicken Cooking method e.g. fried, grilled, baked, steamed Other . 27. Are you aware of any research [consumer or industry practices] conducted in relation to any of these issues, either within the UK or internationally? No ! Dont know !

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F The Future 28. To help us make recommendations on any of the above issues, can you suggest any practical steps that would be helpful to consumers and workable for you?

29. And do you foresee any barriers that will make progress difficult to achieve?

30. Please add any further comments or observations:

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Your help in completing this questionnaire is much appreciated. Your contact details would be helpful should we need to clarify any of the information and to avoid us contacting your organisation again. These details these will be treated in confidence and your answers will not be attributed either to yourself or to your organisation. Company Main function of business Your Name Address Tel Fax E-mail

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APPENDIX C FOOD ALLERGY ISSUES ALLIANCE (FAIA) FOOD ALLERGY LABELLING GUIDELINES (i) Major Food Allergens The Food Allergen Labelling Guidelines focus on the Major Food Allergens, which have been estimated to cause more than 90% of all food allergic reactions. For the purposes of this programme, the Major Food Allergens are defined as the allergenic proteins from: 1. Crustaceans (such as crab, crayfish, lobster, and shrimp) 2. Eggs; 3. Fish; 4. Milk; 5. Peanuts; 6. Soy; 7.Tree nuts (almonds, Brazil nuts, cashews, chestnuts, filberts/hazelnuts, macadamia nuts, pecans, pine nuts, pistachios, and walnuts); and, 8. Wheat. Additional food allergens may be added to this list of Major Food Allergens as their public health importance becomes recognised. An ingredient that is derived from a Major Food Allergen is not subject to these guidelines when it does not contain the causative allergenic protein. By way of example, highly refined peanut and soybean oils would not be subject to these labelling guidelines to the extent that the allergenic proteins are not present in the oils. (ii) Use of Ingredient Terms Commonly Understood by Consumers Ingredient terms commonly understood by consumers for the Major Food Allergens in the product should appear within, or in immediate proximity to, the ingredient declaration of the food label. Examples of acceptable ingredient terms commonly understood by consumers of Major Food Allergens include, eggs, fish, milk, peanuts, shrimp, soy, walnut or wheat. (iii) Label Declaration of Major Food Allergens A food that contains a protein of a Major Food Allergen should be labelled in a manner that informs the consumer of the allergens presence, regardless of its source. Ingredient declarations, which appear on the information panels of food labels, are the primary vehicle for communicating information about food allergens to the at-risk population. Information on Major Food Allergens should appear within, or in immediate proximity to, ingredient declarations. A Major Food Allergen should be disclosed even where a labelling exemption might otherwise apply (e.g., as a component of a flavour). Food processors should request from their suppliers, and those suppliers should provide, information about the presence of Major Food Allergens in all food ingredients, such as flavours. Food processors should carry this information forward to the ingredient declarations on labels of foods that use those ingredients. The ingredient terms commonly understood by consumers for Major Food Allergens should be disclosed on the information panel, within, or in immediate proximity to, the ingredient declaration, by using one or more of the following methods:

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1) The use of a statement, such as Contains __________, with the blank filled in with the ingredient term commonly understood by consumers for Major Food Allergens (e.g., Contains soy and milk). This statement may be prefixed by an allergy information statement phrase (e.g., Allergy information: Contains soy and milk). This statement should be placed at the end of, or in immediate proximity to, the ingredient declaration. 2) The use of an asterisk or other reference mark next to the ingredient name or class name that refers the consumer to a statement that identifies the ingredient term commonly understood by consumers for Major Food Allergens. This statement should be placed at the end of, or in immediate proximity to, the ingredient declaration. For products that contain two or more ingredients that contain the same Major Food Allergen, the same asterisk or other reference mark should be placed after each relevant ingredient in the product. For example, casein*, whey*, semolina, natural flavor would appear in the ingredient declaration, referring the consumer to a statement such as *milk, wheat following the ingredient declaration. 3) The use within the ingredient declaration of a parenthetical statement following the ingredient name or class name that identifies allergens that are present in the ingredient (e.g. natural flavour (peanuts and soy), whey (milk)). 4) The use within the ingredient declaration of a name that identifies the presence of the allergen such as natural walnut flavour, or natural peanut flavour. 5) The use of bolding or other highlighting within the ingredient declaration or in allergy information statements in immediate proximity to the ingredient declaration. Food companies also should follow FDAs current guidance regarding the labelling of incidental additives that contain or are themselves a Major Food Allergen, by declaring the Major Food Allergen in the ingredient list of the food. (iv) Supplemental Allergen Statements Food processors that prepare foods potentially exposed to inadvertent contact with Major Food Allergens acknowledge that labelling is not a substitute for good manufacturing practices (GMP). Supplemental allergen statements should be used judiciously only when all four of the following criteria are met: 1) The presence of a Major Food Allergen is documented through visual examination or analytical testing of the processing line, equipment, ingredient or product, or other means; 2) The risk of presence of a Major Food Allergen is unavoidable even when current GMPs are followed; 3) A Major Food Allergen is present in some, but not all, of the product; and, 4) The presence of a Major Food Allergen is potentially hazardous. 5) If some, but not all, of these criteria are met, food and ingredient manufacturers should consider food allergen control and/or labelling strategies other than supplemental allergen statements.

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When all four of these criteria are satisfied, the supplemental allergen statement should be placed in close proximity to the ingredient declaration. When using an ingredient that utilises a supplemental allergen statement, the food processor should carry that supplemental allergen statement forward to the label of its food only when these four criteria are met. Any supplemental allergen statement should be as accurate and conspicuous as possible, to help allergic consumers make a clear decision about whether or not the food is appropriate for them to eat. Any supplemental allergen statement should be placed at the end of, or in immediate proximity to, the ingredient declaration. Food processors should strive to label the same product consistently, even if it is produced in different locations or in different package sizes. Such label consistency would be useful to food allergic consumers.

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APPENDIX D UDEX AND OFSCI UDEX (Universal Descriptor Exchange) is a limited company, established in 1997. The companys main aim is establishing and maintaining a global file of complete, structured, commonly coded product descriptions (and their associated barcodes) produced to common global standards which would become the Industry Standard throughout the supply chain. Advantages to this system may include a decrease in manual workload and a reduction in errors, both leading to cost savings. UDEX is independent and non-partial and makes its product descriptions available to any reputable organisation on a consistent commercial basis. The biggest single investor and shareholder in UDEX is 3i. UDEX has no 'trade' investors and hence no conflict of interest. A number of suppliers and retailers are members including Nestl, Sainsburys and Tesco. OFSCI (Optimum Foodservice Supply Chain Initiative) has been set up by The Federation of Wholesale Distributors and the Food and Drink Federation along with leading suppliers, distributors and operators. UDEX are working with OFSCI on meeting 4 key objectives: 1. removing unnecessary costs from the supply chain 2. shortening lead times 3. the reduction of working capital in the chain 4. to drive service levels A number of definitions are currently being discussed by the group including vegetarian, vegan, lactose-free, Halal and Kosher. It is thought that technology of this kind may be useful in sharing up-to-date and accurate information about ingredients and foods across the food chain. -

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APPENDIX E DETAILS OF RESEARCH IDENTIFIED The Role of Environmental Health Officers in the Protection of Allergic Consumers. Leitch I, Blair IS, McDowell DA (2001). International Journal of Health Research 11: 51-61. Research was undertaken in Northern Ireland with 37 EHOs who regularly carried out food hygiene inspections in a range of retail and service premises. The aim of the research was to establish the EHOs recognition of peanut allergy and to examine their response to such risks Just over half (19/37) of the EHOs recognised peanuts as major food allergens, and 24/37 recognised nuts as major food allergens. The control of nuts/peanuts was included in 6/37 EHOs assessment of hazard analysis systems. Only 1/6 EHOs had received hazard analysis training in the control of nuts/peanuts during their primary professional training. Where aspects of peanut/nut control were included within inspections, 5/6 EHOs established whether or not peanuts/nuts were used in the premises, 3/6 checked if the proprietor asked suppliers to ensure that all deliveries of nut/peanut containing products were clearly labelled as such, and 2/6 established whether or not the proprietor asked for written information about ingredients from all food suppliers, including notification of any changes. In relation to cross contamination, 4/6 EHOs assessed whether or not foods containing nuts/peanuts were clearly identified by labelling at all stages of production, 3/6 assessed arrangements for the separation of peanuts/nuts from other foods during storage, 5/6 assessed whether or not nuts/peanuts were kept in closed, labelled containers, and 1/6 assessed whether or not food premises used colour-coded equipment when preparing foods containing nuts/peanuts. No respondents assessed cleaning schedules to determine if any special instructions were given about cleaning the equipment used to prepare foods containing nuts or peanuts. Only 2/6 investigated the training of food preparation or serving staff in relation to food allergy. The authors concluded that the results suggest a need for co-ordinated, formal, pre and/or in-service training of EHOs in food allergen control, and indicated the importance of incorporating guidance on food allergen control into hazard analysis guidance documents that are supplied both to EHOs and to the food industry. (Dr Ian Leitch, Omagh District Council - Tel: 02882 245321)

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Strengthening environmental and educational nutrition programmes in worksite cafeterias and supermarkets in the Netherlands Steenhuis IM, Van Assema P, Glanz K (2001). Health Promotion International 16: 2133. The research objectives were to assess the feasibility and effectiveness of two environmental interventions aimed at changing dietary behaviour at worksite cafeterias and supermarkets in the Netherlands. In worksite cafeterias both interventions were studied (1) changes in the range of foods available i.e. increased choice of low-fat food products and increased variety of fruit and vegetables, and (2) food labelling low fat products labelled with a sign. In supermarkets, food labelling was studied i.e. low-fat products in 9 categories were labelled with a shelf label (meat, meat products, spreads, desserts, milk, cheese, sauces, sweet biscuits, and salted biscuits and snacks). Brochures, recipe cards and a self-help manual were also available with the both interventions. Twenty semi-structured interviews were conducted with representatives of worksite cafeterias and supermarkets and the results suggested that environmental interventions are feasible provided certain requirements for programme design and implementation are taken into account. These included not making the educational programme too obtrusive or dominant, that the programme should not take too much time, and it should emphasise the positive. Appropriate materials were found to include brochures, flyers, handouts, posters, displays, self-help guides, and newsletter articles. Information provided on receipts and audio messages were found not to be workable. The labelling programme should only label healthy products, labelling of a group rather than single products is preferred, and providing too much information must be avoided. Prices should not increase and limited changes to the range were found to be desirable. Evaluation of the programme at 17 large worksite cafeterias (1013 respondents) showed that respondents were generally positive about the programme. However they also reported that it was of low personal relevance and they did not gain more knowledge of healthy nutrition as a result. No effects of the interventions were found on consumption data of the whole study population. A short-term effect was found for labelling low-fat products for respondents who believed they ate a high fat diet. No convincing effects of the environmental interventions were found on behavioural determinants of eating less fat and more fruit and vegetables. Analysis of sales data revealed a significant effect of the labelling programme on desserts, but not on other products. Evaluation of the nutrition-labelling programme in 13 supermarkets (2203 customers) showed a generally positive response, with those aware of the programme indicating that it had a positive effect on determinants for eating less fat. However the data failed to show significant effects on fat intake, consumption of targeted products or behavioural determinants of eating less fat. Overall it was concluded that using environmental intervention components at Dutch worksite cafeterias and supermarkets is feasible. However interventions including

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labelling at worksite cafeterias and supermarkets were not successful in changing dietary behaviour. (Ingrid Steenhuis Ingrid.Steenhuis@ou.nl)

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APPENDIX F EXAMPLES OF TRAINING MATERIALS Lesson Plan AIM: To understand the importance of food allergy within a catering environment OBJECTIVES: 1. To be able to understand what allergy is and why it is important 2. To know the main food allergies 3. To have some knowledge of the different food allergies that affect different age groups of the population 4. To know how common food allergies are 5. To know what to do in an emergency 6. To understand the four-strand approach 7. To understand what is meant by the following terms: allergy, allergen, anaphylaxis, free from and other agreed phrases 8. To understand why some people need/want to avoid certain ingredients/foods 1. ALLERGY Food allergy is a specific form of food intolerance that involves the bodys immune system. As a result of already being sensitised to a food or food ingredient, a small minority of people experience allergic reactions to foods that are harmless for other people. These food allergies are abnormal reactions to foods. Allergic reactions to food can vary in severity and can be life threatening. Therefore, it is important that if you are asked about the ingredients of a dish, you take such requests seriously. Case study recent case study to demonstrate how food allergy can be life threatening.

2. MAJOR FOOD ALLERGENS There are more than 270 foods that someone somewhere has had an allergic reaction to! However the main foods (and ingredients) which can cause problems because they contain allergens (specific proteins) are: Cereals containing gluten* (a protein) i.e. wheat, barley, rye Shellfish* Eggs* Fish* Peanuts* Soybeans* Milk and dairy products Nuts* Sesame seeds* Sulphite (this is used as a preservative) * plus products containing these (This list is from the proposed EU Directive)

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Milk protein can cause an allergic reaction but the sugar in milk, lactose, can also result in a form of intolerance lactose intolerance. Suggested Activity Identify the foods containing the major food allergens from the list below. (Picture cards or real foods could be used) Mayonnaise Satay sauce Rice Pesto Ice cream Marzipan Potato Prawn crackers Tomato Sesame seeded roll Tofu Bread Hummus Worcestershire sauce

3. WHO DOES ALLERGY AFFECT? The types of food people of different ages react to and whether the reaction is lifelong tends to vary. Typically it is young children who react to milk and eggs and about 8 in 10 of those who react out grow their reactions by the time they go to school. Peanut and nut allergies also usually start in childhood but tend to be lifelong. Reaction to shellfish is more often a form of allergy seen in adults. 4. HOW COMMON IS ALLERGY? Media coverage of this topic might suggest that allergy is very common, affecting a large proportion of the population (perhaps as many as 3 in every 10). But, perhaps surprisingly, carefully conducted studies have shown that allergy affects about 1-2% of children and less than 1% of adults. Food intolerance in general (which includes allergy and reactions such as lactose intolerance) affects about 5-8% of children and less than 12% of adults. Nevertheless, the condition can be a very serious one even life threatening, and so people who handle food have an important responsibility to their customers. 5. IN AN EMERGENCY Symptoms of food allergy can include some or all of the following: Swelling of throat and mouth Difficulty swallowing or speaking Difficulty breathing Skin rash or flushing Abdominal (stomach) cramps, nausea, vomiting Sudden feeling of weakness Collapse and unconsciousness If a customer has any of these symptoms: Call 999 and ask for an ambulance Say your customer could have anaphylaxis (anna-fill-axis) Stay with your customer until help arrives

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6 FOUR-STRAND APPROACH As in recommendations focus on steps relevant to functions staff will perform. 7. STANDARDISED TERMS Some people want to avoid or reduce certain foods or ingredients for reasons other than allergy - for example, ethical or health reasons. You need to know what the following phrases mean: free from may contain 8. INFORMATION ABOUT LABELS Ingredients ingredients are listed in descending order of weight so the main ingredient when the food was prepared is shown first different names used for the food components responsible for reactions (e.g. for milk; casein, whey, lactose may be used) not all ingredients have to be labelled by law (composite products contributing less than 25% of final product e.g. where toffee is an ingredient of an ice cream, and is less than 25% of the weight of the finished product, it could be labelled as toffee (contains flavouring) rather than as the butter and sugar it contains; some flavourings and additives). Therefore your manager may need to check with the supplier for full details Role-play A waiter shows a customer to their table and hands them a menu. How can the waiter explain that the restaurant knows about food allergy and may be able to accommodate special requirements? If the customer has an allergy and does not want any shellfish, what might the customer say? How should the waiter react? Suggested dialogue: Waiter: As mentioned on our menu some of the dishes we serve contain nuts and other allergens. Customer: W: C: W: Can you please tell me which dishes dont have shellfish in them? Is that because you dont like shellfish or because you are allergic? I am allergic to shellfish. Ill get the manager to come and speak to you. She will be able to help you and be able to provide you with some information so you can decide if any of the dishes are appropriate for you.

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Appendix G Surrey County Council Pilot Scheme A pilot scheme is being run by Surrey County Council from April 2002, encompassing the issue of allergy. Entitled Allergy Aware Responsible Retailer Scheme, it aims to increase awareness of the issues relating to food allergy and gives practical guidance. Retailers who can demonstrate they are allergy aware and are taking steps to minimise risks, may be eligible to join the scheme. Once the retailer has joined they receive a poster for display in their business, information leaflets for consumers about the scheme, guidance notes and a code of good practice. The business will be audited by a TSO/EHO to ensure the required standard is being met and food samples may be taken and analysed as part of this process.

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