Natasha's Law Care Homes
Emily Stuart, for leading meals’ provider, apetito, reminds care homes of the importance of managing food allergies as we reflect upon what has happened since Natasha’s Law became part of food labelling legislation on October 1st, 2021.
The introduction of Natasha’s Law, which came into force on 1st October 2021, will have likely been a prominent feature within the discussions around managing food allergies in a care home environment in the months leading up to the launch of the new law.
Whilst Natasha’s Law, also known as The UK Food Information Amendment, does not apply to food that is prepared and served directly to residents (i.e., without being pre-packaged)(1), care homes will usually be working with multiple suppliers whose compliance will have been essential for catering and management teams to be confident with, so that they can ensure the safety of their residents and have confidence that they are working with reputable and compliant suppliers.
Also, some care home sites will have to have considered the implementation of Natasha’s Law for their own operations, for example those who prepare and pre-package food for sale to consumers – for instance to visitors to their on-site cafés or shops.
The UK has some of the highest frequency rates of allergies globally. National charity, Allergy UK, reports that over 20% of the whole population are affected by one or more allergic disorder, with an astounding 44% of British adults having one or more allergies (2).
International market research company Mintel’s Allergy and Allergy Remedies UK 2010 Report (3) estimated the level of allergy suffering among varying groups of people. Perhaps unsurprisingly, older adults were found to be the least likely to have an allergy, with 30% of those included in the survey found to have or claiming to have an allergy. This may seem like a high percentage, but it does include both food allergies and non-food allergies; for instance, allergies to dust mites are included in this figure. Nevertheless, this is still a staggeringly high figure.
In addition, readers who work in care home settings and are involved in their food service operations daily, will likely concur that incidence of food allergy in care homes is on the rise. This may have been noticed as more residents’ or family members report food allergies.
There will be very few people who haven’t heard of Natasha’s Law, even if they don’t know the finer details. Natasha’s Law was borne following a period of dedicated campaigning by the parents of teenager Natasha Ednan-Laperouse, who sadly lost her life on an airplane, after eating a Pret’ baguette that contained the allergen sesame - but was not labelled as such.
The law sought to strengthen the 2014 Food Information to Consumers legislation, by ensuring that those with allergies were safeguarded against unknown exposures allergens. Prior to the October 2021 launch date, foods prepared in house and packaged for later sale were not required to be labelled individually and allergen content could be communicated by any means, including verbally.
Some examples of the types of foods that fall under Natasha’s Law (referred to in the law as prepacked for direct sale (PPDS)) are:
•Sandwiches and bakery products which are packed on site before a consumer selects or orders them
•Fast food packed before it is ordered, such as a burger under a hot lamp where the food cannot be altered without opening the packaging
•Products which are pre-packaged on site, ready for sale, such as slices of pizza, cooked chicken pieces, salads and pasta pots
•Burgers and sausages pre-packaged on the premises ready for sale to consumers
•Samples of foods such as cookies and cakes, sold to or given to consumers for free which were packed on site.
The Food Standards Agency website has several resources available to support settings with compliance with the law, including further examples of PPDS food and information on how to meet the requirements (4).
Since the launch date, all food businesses have been required to clearly provide full ingredients lists and allergen labelling on ALL foods that are pre-packaged on the premises. The legislation has been introduced to ensure that consumers – and particularly those with allergies – can clearly see what is in the food they buy. Being that residents in care homes are some of the most vulnerable in society, Natasha’s Law serves to reinforce the importance of being vigilant at every turn and with every decision made around food, to ensure that residents are protected from harm.
Managing allergies in a Care Home environment
Vigilance around the management of allergies does not end with labelling and legislation, however. In addition to these requirements, it is vital that your food service operations have a clear allergen policy and a stringent training and development plan. Staff must be trained to ensure they are fully allergy-aware and that they understand any processes that they are expected to undertake when preparing or serving food that contains allergens.
Common concerns that food service staff may have around allergens is knowing which ingredients and their derivatives are considered one of the 14 main allergens, cross contamination, and communicating accurate information to consumers. Staff who communicate allergen information with customers must be able to do so with confidence, knowing where to go for more information and who to speak with if they are unsure.
Increasingly, we have found that care homes are turning to a prepared meal service, which not only ensures consistency of cost and menus, but it helps them manage the needs of residents with allergies in an easy and stress-free manner.
When meals are cooked from scratch on site, it is vital to ensure the separation of foods which are at risk as well as other practical measure such as good hygiene and cleanliness in food preparation environments. Plus, additional factors need to be considered such as the opportunity for unintended cross-contamination of foods and how individual dietary requirements are met within a larger pool of patients. Cross contamination can become one of the biggest challenges for cooks in a busy care home kitchen when they’re catering for residents with severe allergies.
It’s important to note that there is a distinction between meals that are ‘free-from’ and meals that are ‘made without’ allergens, and that there can be inconsistency in the terminologies used and how people interpret them.
Best practice* regulatory guidance recommends that ‘free-from’ meals and products are completely free from the specified allergen, which may be a singular allergen, a combination of a few common allergens, or all the 14 main allergens. That is, that the product recipe does not use any ingredients or compound ingredients (including additives and processing aids) containing the specified allergen which it is claiming to be ‘free from.’ Additionally, to claim ‘free from’, a product should be made in an environment following safe allergen management procedures, and a sampling and testing process that is robust, validated and traceable should be in place.
Meals and products that deliberately exclude certain allergens from the recipe (but do not undergo laboratory testing) cannot be considered ‘free from’, although here at apetito, we have many meals that are made without the ‘main 14’, as well as plenty of gluten free** options. When we are producing ‘made without’ options, we take great care to avoid accidental inclusion of allergens not purposefully present in the recipe. For many residents who have singular or less severe allergies, for example to milk, a meal ‘made without milk’ will be suitable, although for those with serious allergies we have our ‘free from’ range as well – helping homes to confidently cater for the growing variety of nutritional and dietary needs of their residents, including food allergies.
In the case of our own Free From meals, we batch-test these in our on-site laboratory to ensure none of the 14 main allergens are present. These meals are also made without onion and garlic, and we provide menu options that enable care homes to be confident that their residents’ ‘free-from’ needs can be easily met.
For easy, stress-free catering that delivers high quality meals, check out our Care Homes page
Emily Stuart is apetito’s in house dietitian. She has several years’ experience in working as a dietitian in the food industry, and with patients and care home residents in both clinical and community settings.
* Apart from “gluten-free”, there is no specific UK or EU legislation covering “free-from” claims. “Free-from” claims are therefore regulated in accordance with the provisions of General Food Law (Regulation (EC) No 178/2002), as amended.
** Our gluten free meals meet strict legal standards supported by Coeliac UK and are identified in the range with a ‘GF’ symbol
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