Preparing for the worst: How an understanding of food allergy can help you manage a crisis.
An Anaphylaxis Campaign conference – October 2014
Allergens and incident management: right product, wrong box!
Product recall in the age of Social Media
Looking back over two decades: the evolving story of food allergy
Food allergy and recalls – an enforcement perspective.
Managing and assessing risk: the perspective of the FSA
Pleasing and protecting allergic customer in food service
When things go wrong: actions and learning
As director of Crisis Management at Leatherhead for many years, Food Tony Hines is all too familiar with the crises caused both by food recalls and by food fraud – both of particular relevance when dealing with allergens.
20 years ago there was very little awareness of the seriousness of food allergy or of the potentially fatal consequences of things going wrong. But although awareness within the general population is today much higher, among workers on the factory floor, things have scarcely improved – which may be why the level of food recalls is no lower today than it was 20 years ago.
There are two main hazards to guard against in this area: food fraud and labeling issues. The wrong product in the right box, the wrong product in the wrong box, the right label on the wrong product etc
While most people think of food fraud in the context of horsemeat or dog meat in Chinese restaurants, substitution of ingredients for cost purposes (the substitution of peanut flour for almond flour being the most common and the most dangerous) is extremely relevant in food allergy. The highest risk area in this context is takeaways which, for a serious allergic, should probably always be off bounds.
With regard to labeling issues surrounding food allergens and the recalls resulting from them, the UK’s rate of recalls is more than twice that in Europe or the rest of the world. Around 47% of recalls in the UK relate to allergens in contrast to only 16% in Europe and 15% in the rest of the world although it is not clear whether this is because the UK is more careless, most honest or just has more robust enforcement.
Of those 47% of recalls, approximately 60% relate to processed foods, and 20% to cereals – much the same proportion as in Europe and the rest of the world.
These recalls happen right across the spectrum, from SMEs to multi nationals, are nearly always triggered by labeling issues and usually occur when there are line changes. They can include omissions of allergens, errors in labeling design or printing, formulation changes that are not reflected in the labeling or literally he wrong product being put in the right box.
To combat this really well designed systems are essential, especially around line changes. Moreover, everyone in the factory needs to be educated about food allergy and to genuinely understand the implications for a seriously allergic consumer of a mistake at their end.
A mere 20 years ago communication was by phone, by fax and by letter. There was no social media, no mobile phones, no texting – there was no internet! If there was a crisis that triggered a product recall, you had time – what was known as the golden hour – when you knew about the problem but no one else did. So you had time to investigate the problem and plan a response.
Today, between social media, texting and the internet, the chances are that the consumer will know about the problem before you do and you may be learning about your own crisis from one of your customer’s tweets! So you have no time to investigate or plan. And, not only do you have to respond immediately, but that response will set the tone for how the crisis develops – so how you handle that response is absolutely vital.
Communication via social media is fast, transparent and two way. It is also unedited. But, while it allows little time for the company to ‘think’ it does allow it to gather information quickly and identify its own ‘supporters’. Given that only 1% of social media users make original contributions and that only 9% comment on those contributions, the remaining 90% of traffic being ‘lurkers’ who just RT or tell their friends, there is plenty of opportunity for the company to ‘lead’ the conversation by stepping in quickly. By stepping in and making it quite clear that they are ‘on the case’, investigating the problem and taking action, the situation can often be diffused and ‘the story’ downgraded.
However, if the company’s response is slow, inadequate or perceived to be any sort of a cover up, then the poor response will become a story in itself – a story welcomed by the more traditional media, most of whom are themselves on social media and use to it find stories that they can develop further.
In most companies, social media management lives with the PR or marketing team or in the press office but it is essential that, in a crisis, those teams liaise very closely with the production and crisis management teams so that the messages that go out are clear and transparent. It is also essential that the social media teams are sensitive and responsive, not merely pushing the messages out. What the Twittersphere needs to hear – and believe – is:
The tone, especially on Twitter, is vital – informal and friendly but not flippant – while a sensitive ‘ear’ for the comments that are being made will allow the team to recognise whether the Twitter storm will subside of itself or whether further intervention will be needed to control it.
Because a company has so little time to deal with an emerging crisis, it is essential that crisis management has not only been planned in advance but carefully rehearsed as one poor knee-jerk response via a social media platform can escalate a crisis from manageable proportions to potentially catastrophic.
David Reading, one of the founding members of the campaign and, until 2008, its CEO gave a short run down of the campaign’s history in this, its 20th year.
In 1993, as Tony Hines had already pointed out, very little was known or understood about serious food allergy. His daughter, who died of peanut anaphylaxis that year, did not even know that her peanut sensitivity could be life threatening. However, her death along with that of three other teenagers that year prompted a good deal of media interest which coincided with the publication of the first serious paper on food anaphylaxis by the late Dr David Hide, and a self help group was started.
The Epipen for delivering a life saving shot of adrenaline (epinephrine) had been developed in the 1980s in the USA from a military combat pen designed to deliver antidotes to chemical warfare. By the late 1980s it had become available in the UK.
Then in the early 90s and prompted by the campaign, the then minister for food, Nicholas Soames launched an allergy awareness campaign throughout the food industry while the Ministry of Agriculture, Fisheries and Foods, as it then was, developed allergy guidance for caterers. When the Food Standards Agency took over responsibility for allergy they further developed their allergen guidance for the industry, the food service industry and for the consumer and launched a food allergy research programme which continues today.
Meanwhile, thanks to a National Lottery Grant, the campaign itself was able to move into proper offices and staff a helpline which also continues to this day.
In 2003 new legislation on allergens abolished the dreaded 25% rule (if an ingredient – such as the salami or sausage on a pizza – made up less than 25% of the whole dish you did not have to label its ingredients) and set in train the allergen legislation which will reach its final state of refinement this December.
The campaign, now under the guidance of Lynne Regent who took over from David in 2008 has gone from strength to strength providing enormous support to allergic consumers and, through conferences such as the present one, to the food and the food service industry.
Amanda started her talk by stressing that her actual job title was a ‘regulatory support officer’ (rather than an ‘enforcement’ officer) and that her job was to support businesses to ‘comply and grow’, not just to prosecute. While she would, of course, prosecute if prosecution was appropriate TSAs actually aim for minimum intervention to ensure that the problem will not recur.
While Trading StandardsOfficers tend to focus on composition, labeling and chemical contamination, Environmental Health Officers focus on food safety, food hygiene and licensing. However, there is a good deal of cross over which means that consistency of approach can sometimes be difficult. Moreover, there are 433 local authorities and many businesses are multi-sited. This can cause further consistency problems when there are differences of approach, especially as the primary authority is always regarded as the one where the head office is situated.
A food business’ legal requirement is to label accurately under the Food Safety Act 1990 and the Food Safety and Hygiene Regulations 2013. Incorrect labelling remains a criminal offence whether or not it is intentional although proving due diligence (keeping good records, using HACCYP etc) may prove an adequate defence if the offence was unintentional.
It may also be that the food business itself was the victim of fraud – such as when peanut flour is fraudulently substituted for almond flour by a supplier. Trading Standards would not expect a small business to test all of their ingredients provided that they believed that they were buying from a reputable supplier who was labeling those ingredients properly, but they might expect a larger business to investigate their supply chain in more detail.
Staffordshire has more than 3,000 caterers in their area quite apart from any other food businesses so they are limited in the interventions they can make. However complaints, especially from the public, are always taken seriously but open mindedly as they can be either malicious or mistaken. So the first reaction to any complaint is to check whether the complainant is a reliable witness and to check the previous history of the food business. They will then check all documents which may be relevant to the complaint, check the premises, take samples and discuss the complaint with the owner of the business. Further action will always be tailored to that case. For example:
Amanda quoted a case where there was a complaint from a member of the public about a cheese board with nuts being put on her table at a function when the caterer had been comprehensively warned that this guest was nut allergic. However, the caterer had a very good record and on further investigation it was found that the wrong cheeseboard had been put on the table by a temporary waiter who had only been engaged for that night and didn’t know. After discussion with the owner the decision was made not to prosecute but that in future the company would only use regular staff to serve allergic guests.
There is currently a massive awareness raising campaign being run by the FSA who are the source of information most widely used, and EHOs/TSOs will certainly be monitoring allergens on their regular visits. If food businesses are found to be non-compliant they will certianly be ‘advised’ as to how to become so. However, while all new packaging must be compliant after 13th December (2014) you are allowed to use up old packaging, even if that takes several years. The regulators will probably be relatively lenient with small businesses struggling to reach compliance, but less so with large businesses especially if they had already been ‘advised.’ However, if a business does end up in the Magistrates Court the fine can be up to £5,000.
Two other points that Amanda made in response to questions:
Vegan statements should not be taken as dairy/milk or egg free statements as vegan products (chocolates for example) may well be manufactured in a factory which also uses dairy products or nuts.
Up till now testing for EHOs/TSAs has always been done by the public analyst but, as a result of the horsemeat scandal, analysis standards needs to be tightened.
Despite the changes in the regulations the consumer remains responsible for checking their food for allergens and, in a catered situation, for telling the food business about their needs.
The FSA provides best practice guidance for all sections of the food industry encouraging them to think about, assess, manage and communicate risk – and only to use ‘may contain’ warnings if there is a genuine, identified risk.
The EU continues to work towards ‘action levels’ for all major allergens as they did not feel able to adopt the VITAL 2 levels set up by the Australians/New Zealanders because allergens covered are significantly different. They have therefore opted for a risk assessment approach but across the whole EU population. When these levels finally do come into operation compliance will be voluntary rather than mandatory to allow for changes as research develops around such issues as portions sizes. (Guidance is based on specific portion sizes eg 30g serving for a cereal – but many people eat larger or mutiple portions and how is guidance accommodate that?)
For food service allergen management is all about understanding the hierarchy of risk. The most serious risk is providing the wrong information – labelling and getting it wrong is more dangerous than no labelling at all.
The principles of risk management are very simple:
Communication and traceability remain the corner stones in managing the risk efficiently – and efficient risk management not only reduces the risk for allergic consumers but improves profit margins for the operator.
There are 20–30 deaths a year from anaphylaxis, and most food deaths occur within the catering sector – which covers not only corporate catering (restaurants, pubs, cafés etc) and food sold loose (markets, deli counters etc) but not for profit (schools, prisons, hospitals, the military, works canteens) and transport (trains, airplanes) – yet, according to a survey in the Caterer, 43% of restaurateurs are unaware of the allergen regulations deadline.
How should caterers approach the problem?
They need an ingredient matrix – a simple spread sheet or graph – covering the ingredients they buy in and their recipes, and the allergens that they include.
Communication is vital over:
In assessing allergen risk it must be remembered that it is the amount of the allergic protein that is left in the allergen that is crucial and that the nature of the protein (whether it is sticky or dusty) that is in important is assessing how easy it is to eliminate.
Barbara suggested that everyone involved in food service should at the very least do the FSA on line training.
Finally Lynne brought delegates up to date with the Anaphylaxis Campaign’s own alerts service. Working closely with both the FSA and the industry they text alerts directly to all members while also flagging them up via their own social media outlets.
Lynne reported that the number of alerts had been dropping since a peak in 2012 – but no one has any idea what may happen once the new regulations come into force.