Doing the right thing with allergen information
Victoria Cross, from Instinctif Partners, explores the need for change in allergen information provided not only on labels, but in restaurants and food vendors too.
After teenager Natasha Ednan-Laperouse suffered a fatal anaphylactic reaction in 2016, a new Law (known as Natasha’s Law) was passed, which tightens rules on allergen information on food packaging. This requires that, from October 2021, foods which are pre-packed directly for sale carry a full list of ingredients.
Very recently, another case has hit the headlines which raises further concerns around allergy labelling – but this time relating to restaurant food. Owen Carey, who had a dairy allergy, died on his 18th birthday after ordering chicken from Byron burger. He told staff about his allergy, but they did not tell him the meal contained buttermilk, which caused a deadly anaphylactic reaction, according to a recent BBC report.
This has sparked further debate around how allergy information is communicated to restaurant customers.
Commenting after the Coroner’s Court hearing, Owen’s sister told the BBC: “It is simply not good enough to have a policy which relies on verbal communication between the customer and their server, which often takes place in a busy, noisy restaurant where the turnover of staff is high and many of their customers are very young.”
For non-pre-packed food, such as that sold in a restaurant, information for every item that contains any of the 14 allergens must be provided, but according to the Food Standards Agency, this could be either on a menu, chalkboard or information pack, or through a written notice explaining how customers can find out more information, for example by asking a member of staff for details.
Speaking after the hearing, Byron Chief Executive Simon Wilkinson, acknowledged that: “It is clear current rules and requirements are not enough, and the industry needs to do more – more to help customers with allergies and more to raise awareness of the risks of allergies.”
Unsurprisingly, Owen’s family, and others, are now calling for a change in the law – an ‘Owen’s Law’ to complement Natasha’s Law. Byron acknowledged the industry needs to do more – but it does not need to wait for a possible future legislation to create a food safety and quality culture.
Issue eight of the BRC Global Standard for Food Safety contains a recently added clause which requires food business operators (FBOs) to “define and maintain a clear plan for the development and continuing improvement of a food safety and quality culture.”
FBOs with high employee turnover, such as those employing casual staff in a food service environment, have the task of ensuring that every new recruit is inducted in the organisation’s food safety processes and then follows them unfailingly at all times.
There is no ‘one size fits all’ solution to food safety culture and a programme that works for one FBO will not necessarily work for another. Similarly, activities that work for one part of a business might need adapting for another. Tailoring might also be necessary for employees in different roles, in different locations or in any number of ways specific to the organisation.
Such differences may be partly the result of the characteristics of the employees in question. But perhaps the crucial factor in determining the strength of food safety culture is the attitude and style of the local leadership. If the local restaurant manager does not demonstrate a strong commitment to food safety, then it is unlikely that their employees will either, even if the senior management team at regional and head office recognises its importance.
But before taking any action, it is important to understand the problem. This might take the form of immersion sessions with kitchen and front of house restaurant staff or employee focus groups or surveys. The key is to identify actual issues, rather than relying on perceptions, and to ensure a wide range of employees – from a cross-section of sites, functions and levels – are consulted.
Once problems are identified it is time for an action plan to be developed. For maximum buy-in, this is best achieved collaboratively by working with employees to develop a programme, which has the additional benefit that employees will be able to devise activities they know will succeed.
In practical terms, this might include clearer venue-specific visual signage designed by employees about avoiding cross-contact, guidance on how to ‘whistle-blow’ any concerns about inappropriate behaviour, or even role-playing sessions to ask the right questions of customers and truly understand their situation – a food intolerance is very different from a food allergy.
Expert in making business resilient instinctive, we can support companies to develop a food safety culture that inspires people to do the right things at the right time, not because they have to but because they want to – and because they have the information and support they need to make it happen.
Is it not time to do the right thing because it is the right thing to do, not because the law says so?
About the author
Victoria Cross is the Managing Partner at Instinctif Partners. She advises clients at all stages of their growth on how strategic communications can help maximise opportunities and minimise threats to their corporate brand. Her strategic counsel includes comprehensive risk assessments, crisis procedures development and training and delivery of crisis simulation exercises as well as 24/7 response.