The new legislation 'Natasha's Law' comes into force in 2021. But while industry awaits the detail, there is a lot that can be done to pre-empt its introduction, especially by following the lead taken by best-practice in other parts of the food industry.
RSSL’s Simon Flanagan – who was awarded the UK Food & Drink Federation Food Scientist of the Year for his work on helping the food industry better manage allergens – notes that staff training is going to be key to companies delivering on the legislation.
“There has been a lot of discussion within the industry about which products should be defined as PPDS and which are not. Making clear definitions here is indeed a challenge in itself. But the big question for every food producer affected by the new legislation is whether they want to protect consumers from the risk of allergens. The issue is to work out what practical steps, what procedures and systems are necessary, from the ordering of ingredients through to creating the end product, to ensure that finished product labelling is always correct.”
RSSL’s perspective comes from the consultancy, training and testing that it has already done for a wide range of manufacturers of prepackaged and PPDS foods. RSSL advises companies – from major multinationals to SMEs - on every aspect of allergen control covering the sourcing of ingredients, storage, handling, processing, cleaning, testing and indeed, labelling.
“The single biggest risk factor for consumers is if the ‘right’ product goes into the ‘wrong’ package. The same will be true for producers of PPDS foods and also for foods that don’t meet the definition of PPDS. So, Natasha’s Law is welcome and well intentioned, but the challenge for industry is not merely to meet their legal requirements but to do the right thing by consumers. The awareness of staff will be an essential part of this equation, not just in training what to do, but why. For example, when there’s an ingredient or recipe change and a stack of old labels, how do you make sure staff understand that they shouldn’t use up the old labels on the new PPDS. When ingredients are being prepped and stored, how do you implement handling and cleaning procedures that prevent cross contamination? How do you ensure that staff understand and follow procedures designed to protect consumers?”
There is a wider concern too as to whether more labelling will reduce the interaction between some consumers and the food producers. “Whilst supporting the idea of better labelling, we also see that some consumers will place trust in the label, whereas they might previously have challenged staff to explain ingredients. Our view is that staff should retain a primary role in PPDS outlets in explaining ingredients, and having the information available to keep customers well informed about the choices they are making…and to be alert to any potential issues within the outlet that might compromise food safety.”
More information was provided to the industry via an RSSL webinar Natasha's Law - Allergen Information for Food Sold PPDS. To listen to this webinar on-demand, please click here.