NSW Food Authority: Food Safety Supervisor Learner Guide

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NSW Food Authority

Food Safety Supervisor Learner


Guide
Allergen Management
Originally written in 2015 by
Hillary Timma
Simone Fuller
Judy Doulman

In consultation with
David Cusack
Sarah Blain

Compiled by
Andrew Conkey

Updated in 2018 by
Chris Golding
David Cusack

© State of New South Wales through the NSW Food Authority, 2018 You may copy, distribute and
otherwise freely deal with this publication for any purpose, provided that you attribute the NSW
Food Authority as the owner.

Disclaimer:

Every effort has been made to ensure that the information in this document is accurate at the time
of publication (April 2018). However, as appropriate, readers should obtain independent advice
before making any decision based on this information.

Food Safety Supervisor Module Learner Guide – Allergen Management 2


Contents
Instructions to the RTO ........................................................................................................................... 6
Overview ................................................................................................................................................. 7
Introduction ........................................................................................................................................ 7
Fatal reactions to food allergies.......................................................................................................... 7
Key messages to understanding food allergens ................................................................................. 8
Product management to avoid allergic reactions ............................................................................. 20
References ............................................................................................................................................ 27

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Learning outcome, key messages and content

Learning outcomes: Manage allergens and customers with allergies appropriately

Key learning messages:

1. Any food may contain an allergen.


2. Know the 10 common allergens and intolerances.
3. Be aware of business responsibilities regarding communicating allergen information
in food for sale;
 If known to contain allergen, declare or inform consumer.
 If not known to contain allergen, seek clarity and if still unsure, inform
customer that you are unsure.
4. Recipes, ingredients and food components (e.g. purchased sauces used in food
preparation) should be reviewed to understand if they do contain allergens.
5. Read the label on all ingredients used in food preparation. If ingredient does not have
a label, it is not recommended for usage.
6. Be allergy aware during food preparation. Allergens may be introduced through cross
contamination (e.g. peanut oils used to fry non-peanut containing food may introduce
peanut traces to food).

Content
Introduction:
 What is a food allergy?
 What are the 10 most common allergens?

Food service (front of house):


 Implement procedures to ensure food service staff know their obligation to declare
allergens and other substances in food if a customer asks.
 Implement procedures for ensuring all staff know how to access information about
the food products they are selling, including making staff aware that recipes and
ingredients should be reviewed to understand whether they contain allergens (e.g.
sauces or cooking oils used in food preparation may contain an allergen ingredient).

Food preparation (back of house):


 Process steps for preparing meals for customers with allergies:

Food Safety Supervisor Module Learner Guide – Allergen Management 4


o Know what is in your food (i.e. check ingredients) to understand whether it
may contain an allergen.
o Manage the risk of cross contamination between different foods, food and
equipment and food handling practices.
o Store food safely in clearly labelled containers.
o Keep surfaces, utensils and hands clean.

Further links:
Be Prepared Be Allergy Aware NSW Food Authority

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Instructions to the RTO
Allergen management does not map specifically to either of the two Hospitality FSS Units of
competency, however would fit appropriately into the 'Food hazards' section of your learning
materials.

This module must be integrated in full, and all information in this guide must be taught and
assessed for students to successfully achieve the NSW Food Safety Supervisor Certificate.
Training material for students starts on page seven of this module.

RTO’s that do not integrate this module in full, risk regulatory action by the NSW Food
Authority under cl 20 of Food Regulation 2015. This can include mediation, suspension or
cancellation of an RTO approval from the NSW program.

Suggestion: integrate content in this guide into the contaminants or potentially hazardous
foods section of your training tools.

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Overview
Food allergies are becoming more common. It is critical that the Food Safety Supervisor
(FSS) and all food handlers working in a food business understand their obligation to know
what ingredients are in the food products that they handle, make, or sell.

Any food may contain an allergen. It is vital that the business and FSS ensure procedures
and training are put in place, and food service staff understand their obligations to declare
known allergens in food, when a customer asks.

The service of an allergen to a person who is sensitive to it can lead to serious health
consequences, including death.

Food businesses are accountable for knowing the presence of allergens in foods they sell.
Ignorance is not an excuse, nor a defence. This applies whether the food sold is packaged
or unpackaged.

Introduction

The instances of allergic reactions to various foods have increased dramatically in the past
few decades. The Food Standards Code legally requires ten common allergens to be
declared, but there are many other foods that can cause allergic reactions.

After 26 May 2018 all businesses are required to declare lupins on the label where they
are present in food or ingredients. Food service staff must now also check for lupin on the
label of a product, ensuring they provide accurate information when a customer asks
about allergens in foods that are being served.

Fatal reactions to food allergies

People with food allergies react differently. Some people have a reaction that presents as a
rash or hives, others may suffer swelling or dizziness, which can affect their breathing.
Anaphylactic reactions can occur almost instantaneously in persons who are sensitive to
allergens, and in severe cases, death will occur if the allergic reaction can’t be treated
quickly. Regardless of sensitivity, there is no safe level of exposure for individuals with an
allergy.

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Key messages to understanding food allergens

The main factors to understand about food allergens are described below. These will be
explained in more detail in the following sections:

1. Always treat an allergy request seriously.


2. Any food may contain an allergen. Once a customer informs of an allergy it is the
businesses legal responsibility to prepare food that doesn’t contain the allergen or
notify the customer they cannot guarantee the customer food that does not contain
the allergen.
3. There are ten common allergens. These contribute to over 90% of food allergies and
are legally required to be declared on labels.
4. Review recipes, ingredients and food components such as premade sauces,
checking if they contain allergens.
5. Read the label on all ingredients used in food preparation. If a premade food item or
ingredient does not have a label it should not be used unless you have
documentation listing all ingredients.
6. Be allergy aware during food preparation. Allergens may be introduced through cross
contamination between allergenic and non-allergenic ingredients (e.g. peanut oils
used to fry non-peanut containing food, may introduce traces of peanut into food).
7. Cross contamination during preparation mostly occurs through the following ways:
 Food to food – such as touching or dripping.
 Food to hand - unhygienic handling by cooking staff, front service staff.
 Food to equipment - sharing of utensils.
8. Be aware of business responsibilities about communicating allergen information:
 If the product contains an allergen, you must let the consumer know by
labelling the food product or telling them this is the case, when they ask.
 If you can’t guarantee a customer an allergen free meal, you must notify the
customer.
9. Allergens are an important food safety risk. Heavy penalties, including prosecution
and criminal conviction may apply to businesses complicit in customers experiencing
allergic reactions from their food.

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Learning activity: 1
The recent examples below demonstrate the serious consequences of allergic reactions to
food and how widespread this condition is across different demographics. You can follow the
links to read more about the food allergies involved. Pay special attention to how easily very
small amounts of allergens can cause fatal reactions, even where medical responses are
immediate.

Shahida Shahid, 18, died from an allergic reaction after eating at a local restaurant. Full Story

Paul Wilson, 38, died after eating a dish that contained peanuts. Full Story

Elijah Silvera, 3, died after being a served a grilled cheese sandwich at his preschool. He had a
severe milk allergy. Full Story

Justin Mathews, 33, died after being exposed to walnuts during sandblasting. Full Story

Nainika Tikoo, 9, died after eating pancakes topped with blackberries. Full Story & Full Story

Chloe Gilbert, 15, died after eating a food containing yogurt. She had a dairy allergy. Full Story

Alastair Watson, 3, suffered an anaphylactic reaction during a baked milk challenge. Full Story

Amanda Thompson, 50, died after having an allergic reaction to a Sorbet. Full Story

http://nonutsmomsgroup.weebly.com/blog/remembering-those-we-have-lost-to-food-
allergies

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Read at least two of the articles listed in the box on the previous page. List below two key
messages you can take away from these articles about allergen management. Discuss your
responses with another student or colleague.

_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

Allergies and food intolerances

You need to be aware of and understand the differences between allergies and food
intolerances, as they develop and present differently to one another.

Image link: http://img.allw.mn/content/gk/oh/wxt0ehae.jpg

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Allergies

A food allergy is a response by the body to a protein that the body ‘thinks’ is harmful.
There is no cure for a food allergy. The only way to prevent an allergic reaction is to avoid
eating the food containing the protein.

The body can react in many ways to an allergen such as; developing hives, swelling, pain,
vomiting, difficulty breathing, dizziness and collapse. The symptoms can be fatal. There is
no safe limit for exposure to an allergen.

Allergies are different from food intolerances.

Image link: https://c2.staticflickr.com/8/7018/6667534395_5177c09e37.jpg

Food intolerances

Food intolerance is the bodies inability to digest or process some foods e.g. gluten in
bread.

Gluten, lactose, yeast, food additives and sulphites are all products which may cause
intolerances in some people. While the symptoms can be unpleasant, and in some cases
severe, they are generally not life-threatening. Food handlers should apply the same
principles to responding to intolerances as allergies.

Cereals containing gluten and their products must be declared on the food package label.
Foods with added sulphites in concentrations of 10 mg/kg or more must also be declared on
the food package label. Where a food product is not required to carry a food label, the
declaration must be displayed on the food or in connection with the display of the food or
declared to the purchaser upon request.

Further links: Food allergy and intolerance (NSW Food Authority)

The ‘top ten’ allergens

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While the ’top ten’ most common food allergens cause around 90% of allergic reactions,
ALL foods can be allergenic depending on individual sensitivity. On 27 May 2017, Food
Standards Australia New Zealand (FSANZ) added lupin to the list of 9 allergens that must be
declared on food labels. Food businesses were given 12 months to meet the requirement,
which comes into effect on 26 May 2018.

The top ten food allergens and the products they make, that must be declared by law, are:
1. peanuts 6. crustaceans e.g. prawns, lobster)
2. tree nuts (e.g. almonds, cashews) 7. sesame
3. eggs 8. soy
4. milk 9. wheat

5. fish 10. lupin


Link to image: http://www.foodauthority.nsw.gov.au/_Documents/retail/be_prepared_be_allergy_aware.pdf

Knowing your products and effectively communicating product information is key to ensuring
the safety of your customers with food allergies.

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Allergens in detail
This section includes a sample list of products for each of the top ten allergens. Each
allergen is frequently used as an ingredient in other foods you may not be aware of. It is
important to review ingredients of all pre-packaged foods when checking for allergens and
look for any trace of allergen or declaration of cross contamination.

Peanuts
Peanuts could be considered the poster food for allergies but are classified as legumes and
not nuts. They contain many potential proteins that may trigger an allergic reaction in
susceptible customers and are common ingredients in many cuisines and premade products
(e.g. satay sauces). Food handlers should be aware, foods containing other nuts may also
have traces of peanut due to cross-contamination during manufacture. Common peanut
ingredients in commercial kitchens include; peanut oil, butter and raw or roasted whole nut.

Tree Nuts
Tree nuts are separate to peanuts and include; almonds, brazil nuts, cashews, chestnuts,
hazelnuts, hickory nuts, macadamia nuts, pecans, pine nuts, pistachios, walnuts and others.
Many with a tree nut allergy will be allergic to more than one type of tree nut, so it is
important for staff in food businesses to check products for any tree nut ingredient, not just
individually declared allergies. Tree nut products include; flours and meals, some non-dairy
milks, bakery products and as flavourings for foods such as ice creams and chocolate.

Eggs
Eggs are another common allergy triggering food, particularly for children. Both the white
and the yolk can cause an allergic reaction, so food handlers should not serve either if a
customer notifies of an egg allergy. Eggs are also a common ingredient in lots of foods,
including; baked goods, meringues, custards and other desserts, pasta and some types of
noodles, dressings such as mayonnaise and aioli, and as a binding agent in processed
foods, including some processed meats.

Dairy
Milk allergies should not be confused with lactose intolerance. Milk allergies are caused by
an immune system reaction to proteins in milk products, whereas lactose intolerance results
from the body lacking the digestive enzyme, lactase. Those with a milk allergy may also
have allergies to other animal milks like goat or sheep. It is important you check with the
customer what alternatives they can consume, as many non-dairy milks are made from other
allergens like soy or almond (tree nut). Because milk products are common, food handlers

Food Safety Supervisor Module Learner Guide – Allergen Management 13


should be mindful of; cheese, cream, powdered milks, yoghurts, whey protein, as well as
fresh milk.

The Food Authority recently prosecuted a business importing coconut milk for failing to
declare milk proteins. The presence of milk proteins was confirmed in these products
through laboratory analysis. The outcome of this matter was a guilty verdict with a conviction
recorded. Further information may be found on the Food Authority website:
http://www.foodauthority.nsw.gov.au/offences/prosecutions.

Further case studies based on actual investigations, may also be found on the website:
http://www.foodauthority.nsw.gov.au/ip/case-studies-project-outcomes/case-studies

Fish
Fish allergies refer to finned fish species, people diagnosed with an allergy for one type of
fish are advised to avoid all other species. However, people with fish allergies have not been
shown to have a significantly increased risk of shellfish allergy. A fish allergy is also more
likely to be diagnosed later in life, in contrast to most other allergies that are more common
in childhood. Food handlers should be aware of processed fish products such as; fish sauce,
imitation crab or lobster (surimi), anchovies, and fish stock, as well as whole pieces of fish in
their menus. Some sauces, including Worcestershire and Caesar salad dressing will include
anchovies.

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Worcestershire sauce

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Caesar dressing

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Shellfish
Shellfish allergies, like eggs, are a well-known allergy and includes all kinds of marine
invertebrae (boneless animals). Shellfish allergy includes crustaceans like; crab, lobster,
prawns, scampi, and crayfish, as well as molluscs like, snails (including escargot), clams,
oysters, mussels, squid (calamari), and octopus. Shellfish are also common ingredients in
Asian soups, sauces, and stocks and as flavourings. Food handlers should ask for
clarification if a customer is allergic to all, or some types of shellfish.

Escargot Lobster

Oysters Prawns

Sesame
Sesame seeds are known to be a very strong allergen, so it is critical to check ingredients for
sesame products. Sesame is a common ingredient in a range of cuisines, from Asian dishes
made with sesame oil, to Turkish and Lebanese foods such as tahini and hummus. Sesame
seeds are used in many types of baked goods such as crackers, biscuits, and pretzels, in
salads as either seeds or oil in dressings, spice mixes, marinades and herb rubs, and in
vegetarian foods.

Food Safety Supervisor Module Learner Guide – Allergen Management 17


Hummus

Tahini
Food Safety Supervisor Module Learner Guide – Allergen Management 18
Soybeans
Soy is another legume allergen that has several common alternative names like; bean curd,
tamari, tempeh, and tofu, which means food handlers should be checking for alternative
names on labels. Aside from obvious soy products like soy milk and soy bean paste, soy is
also a common vegetable product in processed foods, particularly as a meat or dairy
substitute in vegetarian dishes. Soy is also known to be used as a substitute for gluten or
allergy-free breads. It can be found in; vegetable stocks, gums, soup mixes, and as flour or
flavouring in cereals and baked goods.

Tempeh Tofu

Wheat
Wheat allergies should not be confused with gluten intolerance or coeliac disease. A wheat
allergy is an immune sensitivity to wheat proteins, and exposure symptoms are like other
allergic reactions, up to and including anaphylaxis.
Common products containing wheat are; bread, biscuits, cakes and other baked goods,
pasta, and cereals, wheat is also used as a thickening agent in; sauces, lollies like liquorice,
jelly beans, and hard candies, in vegetable gums, hydrolysed vegetable protein, beer and
ales, and processed meat products like hot dogs. Gluten is also found in barley and rye
grains, so it is important to look for the right ingredients when assisting a wheat allergenic
customer.

Lupin
Lupin is also a legume and is increasingly used as a gluten-free alternative to wheat and
other grain flours. However, it is also known for high cross-reactivity with peanut allergies
because it carries similar proteins. After 26 May 2018, food laws1 will require lupin to be
declared on labels when present in a food product. Lupin is typically found where wheat or
other flours can be substituted, such as breads, biscuits and other baked goods, sauces,

1
Australia New Zealand Food Standards Code - Standard 1.2.3 - Information Requirements – Application,
saving and transitional provisions

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pasta, processed meat products like burgers and sausages, and also as a substitute for soy
products.

Product management to avoid allergic reactions

Know your products Communication of


Food preparation
and their ingredients ingredients
•Be aware of ingredients •Give staff and customers •Only use ingredients listed,
added to products ingredient information (full do not replace one
disclosure) both in written ingredient with another
• Know the process of documents and in
preparation and response to verbal •Always use clean and
opportunity for cross- questions sanitised equipment
contamination
•Provide a safe •Know and be confident
•Only use labelled environment for staff to that an allergen-free
ingredients feel comfortable to ask product is being produced
management and others
about products if unsure •Food allergens cannot be
destroyed through heating
•If you can't guarantee an or cooling
allergy or intolerance free
meal notify the consumer, •Only use ingredients that
so they can decide what to are labelled, DO NOT
do next. MAKE ASSUMPTIONS or
GUESS

•Avoid cross-contamination
by not reusing any
equipment for different
ingredients

There are many processes that you and your food service staff should know and follow to
minimise the risk when preparing, displaying, or selling foods that contain known allergens.

Know your products

It is vital that you and your staff know the products that you make and sell as well as their
ingredients. The FSS should check product labels of all foods and ingredients used in the
business for allergens, including allergens listed by alternative names. All staff should be
informed of allergens in products.

All staff should be aware of:

Food Safety Supervisor Module Learner Guide – Allergen Management 20


 Checking ingredients in pre-packaged foods, especially products manufactured off-
site, for example, commercial mayonnaise.
 Only using labelled ingredients and products. For example, if a bag of dried porcini
mushroom and herb risotto mix does not list all the contents, then the product should
not be used.
 Any ingredients added to products in-house. For example, peanut butter added to a
curry, or sesame oil used in a salad dressing.
 Only using reliable suppliers, and checking-in with them for allergens when products
are reformulated or changed.

Communicate with customers

Food handlers must tell any customer who asks, if food items they sell contain known
allergens. It’s also vital food handlers know what to do if they are unsure when asked about
allergen content. All food establishments should follow these principles so that staff can
make informed decisions:

 Give staff and customers ingredient information (full disclosure) both in written
documents and in response to verbal questions.
 If unsure, staff should feel comfortable asking management and others about
products.
 Explain to staff that they must tell the customer if they cannot guarantee an allergy
free or intolerance free meal.
 Tell all kitchen and service staff an allergen free meal is being prepared.
 Discuss with the customer how you will manage their allergy, they may be able to
advise preparation techniques to assist you.

Information about known allergens in food can also be


provided by listing them clearly in an obvious place such
as:
 a menu
 chalkboard
 information pack

If information is not provided upfront, let your customers

Link to image:
http://www.food.gov.uk/sites/default/files/multimedia/pdfs/publication/loose
foodsleaflet.pdf

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know where they can get it, either in writing or verbally.

Ignorance is no excuse
The cartoon below provides example of how to respond to customers if they ask about
allergens in food.

Source: http://www.food.gov.uk/sites/default/files/multimedia/pdfs/publication/thinkallergy.pdf

Learning activity: 2

How would you respond to the following queries from customers about different allergens?
Write your answers on the lines provided below or discuss with colleagues or other students.

1. A customer asks you if the stir-fried beef on your lunch menu contains peanuts or
traces of nuts. If you are not sure, what would you say to her? Discuss your
response with another student or colleague.
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

Food Safety Supervisor Module Learner Guide – Allergen Management 22


_________________________________________________________________________
_________________________________________________________________________

2. A customer at your hotel explains that he is allergic to cow’s milk and wants to know
if you have an alternative to prepare custard. What would you say to him if you also
have light soy milk and almond milk in the refrigerator? Discuss your response with
another student or colleague.
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

Manage food preparation

When a customer alerts you to a food allergy, you must take steps to minimise the risk of
cross-contamination. Everyone who handles food needs to be informed and remain updated
about the products they prepare or sell, and the ingredients contained in those products. To
assist staff, known allergens must be identified and communicated.

You and your staff should:

 Always document and verbally alert kitchen and wait staff when a customer has
ordered an allergen free meal.
 Only use ingredients listed in recipes - do not replace one ingredient with another.
For example, do not use sesame seeds instead of poppy seeds, a customer may
have chosen the meal and not disclosed an allergy.
 Understand allergen proteins are not destroyed by cooking or cooling processes.
 Try to keep a designated allergen free meal preparation area set aside, and regularly
clean and sanitise preparation areas to remove residues - tiny amounts can still
cause allergic reactions.
 Always use clean and sanitised utensils when storing, preparing, or serving an
allergen free meal.
 When preparing an allergen free meal, make it fresh, and prepare it first. Depending
on the type of dish ordered, check with the customer what a suitable alternative might
be, for example, laying foil on a grill when cooking a steak to avoid contamination
with fish cooked earlier, or using olive oil instead of butter on pasta.

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 Avoid cross-contamination by not reusing any equipment for different ingredients. For
example, do not reuse a cutting board used for preparing chopped peanuts to
prepare vegetables for a salad. All utensils must be thoroughly washed and dried
between uses/products.

Link to image: http://a.abcnews.go.com/images/Health/cb_food_allergy_warning_label_ll_121206_wg.jpg

Learning activity: 3

Explain how you would minimise the risks associated with the following practices:

a) A wok containing peanut oil is wiped out with a paper towel and then the wok re-used
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

b) A chocolate mud cake, which may contain traces of tree nuts, is displayed on the
same tray as a lemon meringue pie.
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

c) A jar of Thai curry paste does not have ingredients listed on the label.
_________________________________________________________________________
_________________________________________________________________________

Food Safety Supervisor Module Learner Guide – Allergen Management 24


_________________________________________________________________________
_________________________________________________________________________

Training staff

Ongoing training and updating of knowledge in allergen management for staff is a necessary
part of any food business. All food handlers need to understand the severity of allergic
reactions to foods by some people, and how to deal with any situations that may arise.

All staff should be trained in how to inform customers about known allergens in food and
how to deal with situations when they don’t know or are unsure about food items they sell.

When training staff in allergen management, you need to ensure they:

 Are aware of the food items and processes involved in preparing products
 Are aware of foods that contain allergenic products.
 Avoid cross contamination by changing gloves and preparing foods following
appropriate food hygiene procedures.
 Are comfortable reading ingredients or seeking clarification from management if they
are unsure about a product’s ingredients.
 Know who to ask, when information is requested by a customer, if the presence of
allergens in a food product is unknown.
 Do not serve or sell a product to customers if there is any known risk.
 Communicate to all appropriate staff involved, if they are aware that a customer has
an allergy.
 Know to call 000 immediately if a customer has an allergic reaction.

Click on the highlighted link above to access a video on how to avoid cross contamination.

The following guidelines will assist all food handling staff in front and back of house to
manage food allergens:

Food Service (front of house):

 Implement a procedure to ensure food service staff know their obligation to declare
allergens and other substances in food if a customer asks.
 Implement a procedure for ensuring all staff know how to access information about
the food products they are selling, including making staff aware that recipes and

Food Safety Supervisor Module Learner Guide – Allergen Management 25


ingredients should be reviewed to understand whether they contain allergens (e.g.
sauces or cooking oils used in food preparation may contain an allergen ingredient).
 Update information regularly so that staff are correctly informed.

Food Preparation (back of house):

Ensure food preparation staff know and understand these process steps for preparing meals
for customers with allergies:

 Only accept correctly labelled foods from the supplier.


 Avoid cross contamination (in the context of allergen control).
 Store food safely in clearly labelled containers.
 Keep surfaces, utensils and hands clean.

While food allergens can cause reactions in some people, informed and well-trained food
handling staff will be able to minimise the risks involved when preparing, displaying and

selling food products to customers.

Link to image: http://farm5.static.flickr.com/4093/4863621966_7457814350.jpg

Knowledge is empowering and in the case of allergen awareness, it can be lifesaving. Don’t
risk the lives of others by taking risks.

Food Safety Supervisor Module Learner Guide – Allergen Management 26


References
Be Prepared, Be Allergy Aware. NSW Food Authority
http://www.foodauthority.nsw.gov.au/_Documents/retail/be_prepared_be_allergy_aware.pdf

http://www.food.gov.uk/sites/default/files/multimedia/pdfs/publication/thinkallergy.pdf

Allergy & Anaphylaxis Australia www.allergyfacts.org.au

Food allergy and intolerance NSW Food Authority

Food Safety Supervisor Module Learner Guide – Allergen Management 27

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