Allergen Control at Retail
Jennifer Jobrack
Senior National Director of Advocacy
Food Allergy Research & Education
April 22, 2015
“Most parents’ worst nightmare is a car
accident, a bus accident; someone kidnaps
your kid, something like that. My worst
nightmare is simple. It’s a crumb.”
What is FARE?
3
Food Allergy Research & Education
 To improve the quality of life and the health of
individuals with food allergies, and to provide them hope
through the promise of new treatments.
• LIFE. Support the ability of individuals with food allergies
to live safe, productive lives with the respect of others
through our education and advocacy initiatives.
• HEALTH. Enhance the healthcare access of individuals
with food allergies to state-of-the-art diagnosis and
treatment.
• HOPE. Encourage and fund research in both industry
and academia that promises new therapies to improve
the allergic condition.
4
Facts about food allergies
 Although nearly any food is capable of causing an
allergic reaction, only eight foods account for 90 percent
of all food-allergic reactions in the United States. These
foods are:
 Peanut
 Tree nuts
 Milk
 Egg
 Wheat
 Soy
 Fin Fish
 Shell Fish
5
Symptoms may be mild or severe
 Vomiting and/or stomach cramps
 Hives
 Shortness of breath
 Wheezing
 Repetitive cough
 Shock or circulatory collapse
 Tight, hoarse throat; trouble swallowing
 Swelling of the tongue, affecting the ability to talk or breathe
 Weak pulse
 Pale or blue coloring of skin
 Dizziness or feeling faint
 Anaphylaxis, a potentially life-threatening reaction that can impair breathing and send the body into
shock; reactions may simultaneously affect different parts of the body
PAST REACTIONS ARE NOT PREDICTIVE OF THE SEVERITY OF FUTURE
REACTIONS!
6
Food Allergy is a serious and growing public health issue
Including
6 million children
Putting it into perspective
If the food allergy community were a
state, it would be the 5th largest state in
the U.S. by population – right after
California, Texas, New York and Florida.
8.245 Million
The number of people with food
allergies in the U.S. is greater than the
entire populations of New York City, Los
Angeles and Chicago combined.
2.707 Million
3.82 Million
National prevalence
2011, Northwestern University
Food Allergy is on the rise
 According to a recent study by the
Centers for Disease Control and
Prevention, there has been an 50%
increase in food allergy between
1997 and 2011.
 In addition, more than 30 percent
of children with a food allergy
(almost 1 in 3) have multiple food
allergies.
FOOD
ALLERGIES
Impact on retail industries
11
Recalls
 Undeclared allergens can have serious public health
implications for susceptible individuals and are an
important reason for a food safety recall.
 Since the implementation of the Food Allergen
Labeling and Consumer Protection Act (FALPCA) in
2006, allergens have triggered more FDA recalls
than any other reason.
 In the fourth quarter of 2014, FDA saw 105 recalls
involving 94 manufacturers of 13.8 million recalled
units. Half of the FDA recalls were for undeclared
allergens
12
Litigation
 March 2015: Alabama family sues Publix
Supermarkets after child dies from eating unlabeled
cookie that contained walnuts. Ongoing.
 March 2011: Chicago Public Schools settles with
family of seventh-grader who died from an allergic
reaction to peanuts at a school party. Settlement:
$3M
13
Restaurant Industry
14
Allergen awareness among restaurants
National Restaurant Association contracted Product Evaluations to
interview 225 foodservice operators. Participants were screened for
being the purchase decision maker at the unit and for begin in charge of
training staff members on food safety topics.
Respondents completed a 17-minute interview, which covered three main
topic areas:
 Importance and awareness of food allergens
 Current food allergen training practices
 Concept review and rating
• Employee certification program
15
Allergen awareness among restaurants
Awareness of Specific Food Allergens
These operators were well aware of the eight major allergens, though one-third were
unaware of Soy and Tree Nuts as allergens. On average, operators were aware of 6.7
allergens.
Which of the following food allergens are you aware of?
100 %
99
97
93
92
82
80 %
69
62
60
Soy
Tree nuts
60 %
40 %
20 %
Base: 225
0%
Peanuts
Milk/dairy
Wheat/gluten
Other allergens (from write in responses):
Fruits
5%
Vegetables
4%
Chemical Ingredients
2%
Sesame
1%
Honey
1%
Shellfish
Eggs
Fish
Over half of these operators claim they are currently training their staff on the allergen topic. Non-commercial
respondents are highly likely to train on this topic, while FSR Independents are lagging in adopting food allergen
training. Those who do not train generally do not see the need for it for their operations.
Do you (or your organization) currently train staff on food allergens?
100 %
80 %
60 %
88
Yes
43
66
64
60
57
No
52 48
40
36
40 %
34
12
20 %
0%
Total (n=225)
FSR Chain (n=50)
FSR Independent
(n=50)
QSR Chain (n=50) QSR Independent
(n=50)
Non-commercial
(n=25)
Why don’t you conduct Food Allergen Training? (Open end response)
Base n=96 (those not offering Food Allergen Training)
I cover the basics/don’t think additional training is needed
No reason/never really thought about it
Don’t have any training programs/information to use
26%
24%
23%
Don’t serve allergen foods/not applicable to us
Don’t have the budget for it/costs too much
Don’t have time for this additional training
9%
2%
1%
Over half of the operators that train on food allergens state their materials were created by themselves or
their organization. Many claim they are sourcing informal materials/information from health departments
and/or from the internet.
What information or materials do you use to train staff about food allergens?
(Base: Those currently training on allergens)
100 %
80 %
60 %
54
49
49
40
40 %
31
30
20 %
0%
Created by me/ my
organization
Sourced from outside
organization
Formal Training Materials
Base: 129
Health department
Internet/online resources
Word of mouth/experiencedbased information
Informal Training Materials
News stories
The primary method for alerting patrons of food allergens is through staff (when they are asked).
Secondarily, it is posted on the menu or somewhere else in the restaurant. 11% of these operators state
they do not reference allergens at all/not applicable.
How do you let your customers know about any allergens in your operation?
(from a pick list with open end)
100 %
80 %
76
60 %
40 %
20 %
28
17
6
10
1
0%
Staff tells
Noted on menu It is posted in
customers
the restaurant
when they are
where people
asked
can see it
Base: 225
Other method
I don’t
Not
reference
applicable/we
allergens at all don’t offer any
foods with
allergens
The $ math
15,000,000 people with food allergies
Conservative est. 20% require reasonable accommodation
x 3 (average family size)
x $50 average check
$45,000,000 in potential lost revenue/week
6,000,000 children with food allergies
Conservative est. 10% require reasonable accommodation
x 10 (average special occasion party size)
x $150 average annual spend on special occasion
$900,000,000 in potential lost revenue/year
Introduction
ServSafe, provided by the National
Restaurant Association, partnered with FARE
to create the ServSafe Allergens™ Online
Course to make restaurant dining safer for
the 15 million Americans coping with food
allergies.
TO G E T H E R , W E AR E P R O V I D I N G R E S TAU R AN T P E R S O N N E L W I T H
E V I D E N C E - B AS E D E D U C AT I O N , T R AI N I N G AN D R E S O U R C E S .
ServSafe Allergens™ Online Course
Course Topics
UNDERSTANDING
FRONT OF THE HOUSE
BACK OF THE HOUSE
FOOD ALLERG IES
OPERATIONS
OPERATIONS
• Defining food allergies
• Proper communication
• Importance of food labels
• Recognizing symptoms
• Preventing cross-contact
• Handling food deliveries
• Identifying allergens
• Proper food preparation
• Dangers of cross-contact
• Workstations and selfserve areas
• Proper cleaning methods
• Special dietary requests
• Dealing with emergencies
• Cleaning and personal
hygiene
FoodAllergens.com
Advocacy Goals
 Goal: Restaurant personnel to be trained on food
allergens similar to training about food safety
 Michigan
 Virginia
 Earlier : Massachusetts, Rhode Island
 Also looking at modifications to FDA Food Code
25
Massachusetts
 Food Allergy Awareness Act signed into law January 2009. “To minimize risk of
illness and death due to accidental ingestion of food allergens by increasing
restaurant industry and consumer awareness of regulations and best practices
with respect to major food allergens.”
 Requires certain food establishments comply with regulations developed by
MDPH including:
• prominent display of a food allergy awareness poster in the staff area of food
establishments
• notice on menus for consumers with food allergies
• additional food allergy training for certified food protection managers. The FAAA also
 Requires MDPH, MRA and FARE to develop a program for restaurants to be
designated as "Food Allergy Friendly'' and to maintain a listing of restaurants
receiving that designation on the MDPH website. Participation is voluntary. FAF
designation includes, but is not limited to:
• making available to the public, a master list of all the ingredients used in the preparation
of each food item available for consumption
• strict adherence to procedures that prevent cross contamination.
26
Virginia
 CHAPTER 356
 1. That §§ 35.1-14 and 35.1-15 of the Code of Virginia are amended and reenacted as
follows:
 § 35.1-14. Regulations governing restaurants; advisory standards for exempt entities.
 A. Regulations of the Board governing restaurants shall include but not be limited to the
following subjects: (i) a procedure for obtaining a license; (ii) the safe and sanitary
maintenance, storage, operation, and use of equipment; (iii) the sanitary maintenance
and use of a restaurant's physical plant; (iv) the safe preparation, handling, protection,
and preservation of food, including necessary refrigeration or heating methods; (v)
procedures for vector and pest control; (vi) requirements for toilet and cleansing facilities
for employees and customers; (vii) requirements for appropriate lighting and ventilation
not otherwise provided for in the Uniform Statewide Building Code; (viii) requirements for
an approved water supply and sewage disposal system; (ix) personal hygiene standards
for employees, particularly those engaged in food handling; and (x) the appropriate use of
precautions to prevent the transmission of communicable diseases; and (xi) training
standards that address food safety and food allergy awareness and safety.
27
2013 FDA Food Code brought some changes…
“2012 Conference for Food Protection (CFP) requested that FDA amend §4-602.11
to require that equipment food contact surfaces and utensils that have contacted
raw animal foods that are major food allergens be cleaned before use with other raw
animal foods. FDA recognizes that…the unintended presence of major food allergens
in foods may occur through cross-contact…While most cross-contact can be avoided
through control of the environment during food production and preparation, the CFP
request only addresses allergen cross-contact from raw animal foods that are major
food allergens and therefore, falls short of comprehensive allergen cross-contact
control for all eight major food allergens. Although limited in scope, such a change
supports the continued efforts of FDA to work in cooperation with the CFP toward
control of food allergens in retail food establishments.
Therefore, §4-602.11 was amended to require that food contact surfaces of
equipment and utensils that have contacted raw animal foods that are major food
allergens, such as raw fish, must be cleaned and sanitized prior to contacting other
types of raw animal foods.”
…but there is more work to do
4-602.11 Annex 3 page 509 2013 FDA Food Code
28
Thank you
29