Embed Size (px)
Citation preview
1
2015 FDA Pacific Region Retail Food Seminar
Allergen Control At Retail
Chuck Catlin R.S. , M.P.A.
Food Safety Rx
President
602.769.1418
2
Allergen Control At Retail
Different Strategies are employed based upon the following:•Goals of the retail establishment•Regulations•Type of facility •Complexity of operations
3
P.F. Chang’s China Bistro
4
P.F. Chang’s China BistroGoals of P.F. Chang’s China Bistro was to offer a gluten free experience while noting other allergens. They felt that this was an important competitive point-of-difference.
What do they need?•Supplier Approval/Risk Assessment
–Including Distribution Centers •Detailed Specifications •Receiving Procedures•Handling Procedures•Menu labeling•BOH Process & Procedures• FOH Processes & Procedures•Allergen training•Disclaimers
5
Supplier Approval/Risk Assessment
• Supplier Food Safety Assessment: Complete one form for each of your facilities that will manufacture and/or package.
• Complete Recall Team Information – Included in the Information Form - This information is mandatory to facilitate quick access.
• Distributor Food Safety Assessment: Complete one form for each of your facilities that will hold/store/distribute.
–Complete Recall Team Information - The information is mandatory to facilitate quick access.
• Annual Third-Party Audit (FULL REPORT) for each manufacturing/storage facility supplying.
• Corrective Action(s) resulting from Audit performed. Please assure that this information is on company letterhead with QA Leadership signature/position title/date
• Stock Product Specification – Template used to record pertinent product information for Supplier “off-the-shelf” products.
• Custom Product Specification – Template used to record pertinent product information for Custom/proprietary products.
6
Detailed Specifications
•Note Product Name•Picture of Product•Key Attributes – (Sensory & Physical)•Nutritional Panel for 100 grams of the Product•List of Ingredients•Allergens Present in Product•Allergens Present in Facility
7
Receiving Procedures
•Must Inspect Packages–No evidence of cross-contamination
•Temperature Verification and Documentation•Established Storage areas to Prevent Cross-contact
–8 FDA Allergens–Designated Sensitivities
8
Handling Procedures
•Allergen Communication •Practices to Prevent Cross-contact of Allergens & Sensitivities•Specific Delivery Procedures to Assure the Allergen Reduced Meal is Delivered Correctly
9
Accurate Menu labeling
Specific Specifications Stating:•Ingredients •Allergens•Allergens Contained in the restaurant
Accurate recipes with preapproved substitution products
10
BOH & FOH Process & Procedures
Allergen Management Goals & Objectives:
• Inform the guests about what 8 major allergens are present in the restaurant and each menu item.
• Notifying Guests who suffer from common food allergies or dietary restrictions to discuss their needs with a manager or chef before they order. (Noted on the website and on the menu.)
• Manager / Chef review the guest’s reported allergen concerns and creates a report showing menu items that do not contain the guest’s dietary restriction. Guest then chooses a menu item from this list. (Menu items are not to be further modified to accommodate an allergy.)
• Guest must be made aware of the severe limitations PFCB restaurants have in attempting to deliver a Guest Allergen avoidance meal.
• Managers and/or Chef will take the responsibility to ensure that the Guest receives their correct Allergy avoidance order.
• All restaurants must post emergency numbers to provide a quick reference.
• Employees must quickly identify when a Guest is having an allergic reaction and taking appropriate action. (Calling 911, asking guest or family if they carry an EpiPen.)
11
The allergens and food sensitivities at PFCB
FDA 8 Main Allergens:•Milk•Eggs•Fish•Crustacean Shellfish•Tree nuts•Peanuts•Wheat•Soy
12
Other Sensitive Foods Being Tracked At the Bistro
•Corn•Sulfites•Sesame Seeds, Tahini •Legume•Gluten•Mushrooms•Onions
13
Disclaimers
Menu Needs a specific disclaimer about the presence of allergens within the kitchen and noting the chance of cross-contact. Asking the guest to talk with a chef or manger before placing their order.
14
Googles Goal:
Update the menu labeling standards globally to increase transparency around the food served. Model the new standards to mirror the new 2014 EU Allergens.
What do they need?•Receiving and handling procedures•Ingredient labeling•Staff allergen training •Disclaimers
15
What Was the Current Labeling
● Mercury● Spicy/hot
Allergen Symbols: All illustrated allergen symbols:
● Milk● Egg● Peanut/Tree Nut● Finfish● Shellfish● Soy● Wheat
Sensitivities: ● Pork● Alcohol
16
What Was the Current Labeling
Raw: ● R - Raw ingredients have not been heated above 118ºF
(48ºC)● R* - Raw & Vegetarian● R** - Raw and vegan● Often note the cooking method
17
Food Labeling
What it looked like
18
List of New Allergens & Sensitivities
AllergensGluten*Tree nuts*PeanutsMilkEggsFinfishCrustaceans (Shrimp, Crab, Lobster)
Mollusks (Clams, Mussels, Oysters, Scallops, Octopus, Squid)
SoyBuckwheat (New, previously Soba)Celery (New)Mustard (New)Sesame (New)Sulfur dioxide and sulfites (New)Lupin (New)
Sensitivities Monosodium glutamate (MSG)BeefPorkAlcohol
Consumer Information** = Vegan (no animal products)* = Vegetarian RU = (raw /undercooked)
* Note that with Gluten and Nuts, the specific ingredients will be called out (ie. Almonds, Oats). More on the next slide.
19
What’s Being Added - Allergens/Sensitivities
● Celery● Mustard● Sesame ● Sulfur dioxide and sulfites ● Lupin● Buckwheat (previously noted as soba) ● Monosodium Glutamate (MSG)● Beef
ShellfishShellfish will now be noted by two separate allergen listings
● Crustaceans (like shrimp, crab, or lobster)● Mollusks (like clams, mussels, oysters, scallops, octopus, and
squid)
SobaSoba is being replaced with Buckwheat (the actual allergenic ingredient)
20
List of Gluten and Tree Nuts
Here’s the full list of specific grains and nuts to be noted in parenthesis in the Contains summary.Example: “Contains: Gluten (Wheat), Tree Nuts (Almond)”
Gluten (some examples)● Wheat● Wheat starch● Wheat bran● Wheat germ● Cracked wheat● Durum● Einkorn● Emmer● Farina● Faro● Fu● Gliadin● Graham flour
Tree nuts (some examples)● Almond (Amygdalus communis L) ● Hazelnut (Corylus avellana) ● Walnut (Juglans regia) ● Cashew (Anacardium occidentale) ● Pecan (Carya illinoinensis)● Brazil (Bertholletia excelsa) ● Pine Nut (Pinus pinea)● Pistachio (Pistacia vera)● Macadamia and Queensland
(Macadamia ternifolia)● Coconut - while not a tree nut has
similar proteins causing cross reactions.
● Bulgur● Rye● Barley● Oats (some may be gluten
free) ● Spelt● Couscous● Kamut● Seitan● Triticale & Mir
21
Food Labeling
What it will look like
When possible the key allergens are noted in the name of the dish
Ingredients containing allergens bolded
List allergens at bottom under “contains”
No more allergen symbols
22
Additional Examples of The New Menu Labels
RU with the Smoked Salmon denotes a menu item that is Raw or Undercooked
The asterisk with the Mix Green Salad denotes that this is a vegetarian dish
23
Example of Bi-lingual Labels
rice, chorizo, chicken, onion, paprika, saffron, garlic, olive oil, diced tomato, caper, chili
pepper, green olive, tarragon, bay leaf, thyme, sanon sugar, white wine, vegetable extract
(eggplant), fish extract (swordfish)
Contains: alcohol, finfish, pork
Paella (Chorizo & Chicken)
白米、チョリソー、鶏肉、玉葱、パプリカ、サフラン、
にんにく、オリーブオイル、ダイストマト、ケッパー、唐辛子、グリーンオリーブ、エストラゴン、ローリエ、タイム、三温糖、白ワイン、野菜エキス（茄子）、
魚エキス（カジキ）
アルコール、魚、豚肉を含む
パエリア（チョリソー&チキン）
What it will look like
The size of the menu card for bi-lingual labels is A6
Menu labeling in local language should follow the same rules
24
Sensitivities
Sensitivities will be noted the same as allergens in our new system.
New sensitivities:● Monosodium Glutamate (MSG)● Beef
And as always, they will still note:● Pork● Alcohol
Please check with your purchasing team to make sure that you are not sourcing foods containing hidden ingredients like MSG or high fructose corn syrup.
25
Providing More Information - Cultural Sensitivities
Kosher/HalalNo changes for Kosher/Halal menu labeling. These ingredients can be noted in the ingredient section by manually adding the note. For example “Chicken (Halal)”
GelatinsSince most gelatins can contain either beef and/or pork, we will be noting both beef and pork when gelatins are present in the menu item.
AlcoholThey will continue to note ingredients that contain alcohol.
26
Menu Labeling
Transparent by Design● All ingredients – every ingredient – must
be listed (even salt and pepper!)● This includes cafes, catering, and grab-n-
go● Ingredients must be listed in descending
order of weight● Follow the new process for purchased sub
ingredients (like Heinz Ketchup, Lee Kum Kee Hoisin Sauce, Sriracha) that have too many ingredients to fit to provide full transparency to diners
27
Labeling Rules - Easy as 1, 2, 3!
Step 1: Name the dish using the allergenic ingredient ● We will use the major allergenic ingredients in the name
of the menu item. ○ For example, “Spicy Chicken and Shrimp Pad Thai
with Peanut Sauce” will be used instead of just calling it Pad Thai. This type of labeling can be especially important with desserts.
○ If needed, note cooking method and level of spiciness in the menu item title. For example: “Spicy Pan Seared Pork Dumplings”
○ Call out allergenic ingredients by weight and always prioritize the allergenic ingredients that are not easily seen. For example, if nuts are used in a filling of a dessert please use the name “Nut” in the title.
28
Labeling Rules
Step 2: Bold the allergens in the menu card● All allergenic ingredients must be noted with bold
lettering on the menu cards. For example, Tahini, Peanuts, Peanut oil, Soy
Sauce and Red Wine Vinegar are bolded in this menu label.
● Each ingredient must be listed in descending order by weight or volume. The first ingredient would be the largest concentration of the dish.
29
Labeling Rules - Easy as 1, 2, 3!
Step 3: Call out the allergens in the Contains section
● Summarize the specific allergen in the dish’s ingredients in the Contains section
○ For example: “Contains: alcohol, peanut, sesame, soy”
● Note that when ever we use Gluten and Nuts, the specific ingredients will be called out in parenthesis
○ For example: Tree Nuts (Almonds), Gluten (Wheat)
30
Using Sub Ingredients
Purchased Sub Ingredients with too many ingredients to fitPurchased ingredients, like pre-prepared sauces, are what are referred to as sub ingredients. Think of food items like Heinz Ketchup, Fish Sauce, Lee Kum Kee Sriracha Mayo are examples. They sometimes contain many ingredients that can be hard to fit onto menu label.
For this reason, there is a different method for labeling sub ingredients to ensure that every ingredient and allergen are documented.
31
Labeling Sub Ingredients
How to Label Purchased Sub Ingredients in Menu Cards
● When using purchased sub ingredients, use the name of the sub ingredient (such as Lee Kum Kee Sriracha Mayo, Fish Sauce or Heinz Ketchup reduced sugar) in the menu card.
● When the sub ingredient contains any listed allergen(s), the name of the sub ingredient will be bolded.
● The allergen(s) in the sub ingredient will be called out at the bottom of the menu card with other allergens after “Contains:”
Food team members must have a handout available in the cafes showing all the ingredients of this sub ingredient for inspection.
Lee Kum Kee Sriracha Mayo contains Vinegar, Egg, Gluten (Wheat) and Soy so it is bolded in the ingredient section and the added allergens are noted in the contains section.
Note that the vinegar would have also required alcohol to be called out but the other ingredients already contained alcohol
32
Providing Sub Ingredient Handouts
Food team members must have a handout available in all cafes showing all the ingredients of all sub ingredients used. These sub ingredient handouts must be readily available for any guest to review and for inspection. This is now an SOP that will be audited with NSF.
● In our recommended method, each sub ingredient name and its ingredients listed on the label would be manually typed out. For example, Sriracha Mayo would look as follows:
Sub Ingredient List 11-08-2014Lee Kum Kee Sriracha MayoIngredients Mayonnaise (Soybean oil, eggs, water, distilled vinegar), chilli, garlic
33
Allergen Disclaimer
34
BOH & FOH Procedures
As part of your written SOP’s, the new allergen management must be addressed. These SOPs must include:
● Allergen training must be established for all food team members. ● 100% accuracy of ingredients and allergens. Responsibilities for the
procedures surrounding menu labeling (including grab-n-go and catering) must be established and all food team members trained to act appropriately. Frequent partner management review of the process is a must.
● How to create a sub ingredient pamphlet. The pamphlets must be available to review at a request of a Googler or guest.
● Ingredient change management. For example, if a dish’s ingredients change, it is the chef/food team member who changed the ingredients’ responsibility to make sure the update ends up on the menu card (unless otherwise agreed upon by SOPs). If the front of house staff updates the menu cards, there must be a system in place for them to be notified about any menu changes and for menu cards to be updated immediately following the change.
35
Questions???
36
Thank You
