Allergen Policy

The Company firmly believes in providing high quality food to our customers and
clients that is safe to eat.

We are therefore committed to reducing the risk to our customers with regards to
the provision of food and the consumption of allergens which could lead to an
allergic reaction.

The Company accept its duty to comply with all relevant Food Regulations,
which states that allergen information must be provided on all food sold.

The Company acknowledges that the successful implementation of this

policy and management of allergens requires the commitment and
support from all employees. To achieve this The Company will:

• Work closely with our supply chain to ensure accurate information

on all products that may contain allergens.
Policy Statement

• Maintain a database of all our recipes, clearly listing ingredients

and highlighting those containing allergens.

• Work closely with our clients in assisting in the support of customers

with known allergies, including meeting with parents, if requested,
to discuss any special requirements.

• Display signs that encourage our customers to ask about allergens

in the foods being served.

• Ensure that our staff have the necessary training and information
to provide our customers with accurate guidance on allergens.

• Through good hygiene practices and adhering to Hazard Analysis

and Critical Control Points (HACCP), reduce the risk of cross
contamination in our kitchens.

• Audit our operations to ensure the above policy and practices are
working effectively and review the policy as necessary.

• Operate as far as is practical a nut free environment within our

primary and secondary school kitchens.
July 2020
Responsibilities
The Directors of the Company will:

• Ensure the development and review the Company Allergen Policy.

• Ensure that the necessary resources are available for implementing the Allergen Policy
and detailed arrangements, as well as the subsequent monitoring of performance.
• Ensure that the appropriate information, training and supervision is provided to all
employees and apprentices.

The QHSE Department will:

• Develop the Company’s Allergen Policy and Procedures to ensure that it is legal and
moral obligations are met.
• Work with the Primary Authority Agreement to ensure the policy and procedures are
assured advice.
• Ensure that the policy and procedures are communicated to all stakeholders to ensure
its effective implementation.
• Provide relevant training material to ensure the effective implementation of the policy.
• Work with the Food Department to review and update policy and procedures when
necessary.

The Procurement Department & Food Department will:

• Effectively communicate the Allergen Policy and procedures to all stakeholders.

• Ensure that all menu cycles are supported with accurate recipes and allergen
information.
• Ensure that all recipes will have the relevant allergen information.
• Ensure that suppliers provide accurate allergen information on products on the
Company Approved Product List (APL).
• Ensure that any changes to products and recipes are communicated to all relevant
Managers.
• Provide additional support at Unit level where necessary.

The Operations Manager will:

• Ensure that all units have implemented the Company Allergen Policy and Procedures.
• Where necessary, with the Unit Manager, meet with Parents of RED category students to
discuss and agree requirements where appropriate.
• Discuss with the Client any issues concerning the means in which information concerning
students with allergens is communicated to the Unit Manager, and the identification of
them, and agreeing a solution to ensure that the allergen procedures can be fully
implemented. Any agreed actions will be recorded in writing, using the Special Diets
Form where applicable.
• Audit the unit annually to ensure the effectiveness of the policy and procedures.

July 2020
The Unit Manager will:

• Ensure that the Company’s Allergen Policy and procedures are followed at Unit level.
• Liaise with the school to identify which students have special dietary needs & use the
school’s procedures to identify them (through wristbands, lanyards)
• With the Operations Manager, meet with any parents to discuss any individual student
requirements. Agreed outcome from any meetings to be recorded on the Special Diet
Form.
• Ensure that where there are any RED category students the correct procedures are
followed at all times.
• Enter student information onto the Unit’s cashless system, where relevant.
• Ensure that all staff are aware of all information relating to students and their allergies.
• Purchase correct products as per the company recipes and company APL.
• Follow all recipes to ensure that allergen information is correct and up to date
• Complete the allergen matrix when producing dishes, using information from recipes
and ingredient packaging.
• Ensure that the all allergen matrices are reviewed and kept up to date to reflect any
changes to recipes.
• To ensure that all allergen matrices are signed and dated when completed and/or
reviewed.
• Check product packaging before use/consumption as the packing will carry the
manufacturer/suppliers up to date information and update allergen information as
necessary.
• Complete the Company’s allergen training and ensure all Unit staff have been trained.
• Support the School/Academy in the implementation of their own Allergy Procedures.
• Immediately report any concerns or issues to their Operations Manager

All Company Employees and Apprentices will:

• Ensure that they follow the correct procedures detailed in the Allergen Policy to ensure
the safety of students.
• Cooperate with the company on matters of allergen management and control,
including completing any training and reporting any concerns to their manager.

The School/Academy will:

• As data controllers, collect information of students with food allergies and intolerances,
ensuring this information is kept up to date.
• Provide the Catering Manager/Supervisor with an up to date list of students with any
food allergies, intolerances or dietary requirements.
• Ensure that any communication between parents and the caterer goes through the
School/Academy and be involved at each stage.
• For primary/infant schools, ensure that the School/Academy has a process of identifying
students with special dietary requirements, such as lanyards or wrist bands. This process
should not be based solely on photographs or teachers identifying the pupil
• Ensure that all staff and lunchtime assistants are adequately trained on allergens and the
school’s procedures.

July 2020
 • Educate pupils about allergies and to support peers with special diets.
• Provide the Catering Manager/Supervisor with information relating to the school’s Allergy
Procedures/Policy.

The Parent/Guardian/Carer will need to:

• Inform the School/Academy of their child’s allergy as soon as possible.

• Complete the Special Diets/Allergy Form and return to the school, providing a medical
support for food allergies.
• Where necessary meet with the Operations Manager/ Unit Manager to discuss any
specific requirements relating to their child’s allergy. Information from these meetings to
be recorded on the Special Diets Form by the Operations Manager/Unit Manager.
• Inform the School/Academy of any changes.

The Student will:

• Work with the catering team to follow agreed procedures relating to foods.
• Take care to knowingly avoid any foods which may cause an allergic reaction.

July 2020
Arrangements for Schools/Academies & Colleges

As the majority of the company’s business is in the education section the following
arrangements apply:

It is important for the safety of our customers that a Unit has accurate and relevant allergen
information on the foods that it produces and services. The information on the 14 allergens will
be recorded on Company recipes and Unit Allergen Matrices

Working with suppliers, allergen information is uploaded onto the recipe database. All
company recipes are kept on this database where each ingredient is clearly listed.

Due to the possible severity of nut and peanut allergies, as a company we will not knowingly
serve foods containing nuts or peanuts, such as peanut butter, Nutella, nut oils and foods
containing nuts within our primary and secondary schools. Only with the signed agreement of
our client will we serve products that contain nuts.

Whilst we are unable to completely eliminate the possibility that nut, or nut products may be
present in ingredients supplied to us, we require our suppliers to make practicable efforts to
ensure they comply with this. However, in colleges and workplaces we do not avoid products
containing nuts or peanuts.

It is our legal obligation to provide accurate allergen information about the foods that we
produce and service. However, in order to meet this obligation, we need schools to provide us
with up to date and accurate information of students that have allergies or intolerances.

Where we have been informed of a student with severe allergies or who has suffered from
anaphylactic symptoms they will be categorised as RED and will be treated in line with the
procedures set out. Other students with an intolerance will be categorised as AMBER.

Some families and students may have a dietary preference based on lifestyle choosing to
exclude or include certain foods. These students will be categorised as BLUE

Working with the school/academy we will seek to make the relevant information available to
parents/carers of students who have food allergies.

Photos and allergy requirements of students should be supplied by the school/academy to the
catering team in hard copies which are visible within our kitchens. Where systems allow, this
information will also be entered on to the Unit’s cashless systems. Catering teams are briefed on
requirements and made aware of allergies and special dietary requirements.

Clear signage is displayed, specifically directing any customers with allergy concerns to a
member of our catering teams. Our teams have access to print outs from our recipe database.
Further escalation of this process can be taken directly to the catering manager on site and
subsequently to our team of Operations Managers and Head of Food

The successful implementation of the Allergen policy requires the support and cooperation of
the Procurement Department, Food Team, Unit Manager/Supervisor, all employees, The
School/Academy, The Parent/Guardian/Carer and the Students.

Failure to follow the allergen procedures will be deemed as a breach of Company policy and
result in disciplinary action which could result in dismissal as gross misconduct.

July 2020
Special Diets

In order to ensure that the safety of students, particularly at primary school, the following
procedures categorises the student depending upon their needs:

• RED severe reaction/anaphylactic symptoms disclosed

• AMBER food/allergen intolerance
• BLUE excludes foods due to lifestyle preference

• RED will have an agreed plated meal prepared & served if requested
• AMBER will be a suitable meal served from the counter
• BLUE will be a suitable meal served from the counter

Prior to the beginning of each term the school must provide the Unit Manager with written
confirmation of the allergen and special diet requirements for the students that have allergies
or dietary requirements. In addition, the school must provide this information for new students or
any changes throughout the year.

Ideally this information should be provided using the Company’s Special Diets Form and signed
by the student’s Parent/Guardian/Carer and supported by medical evidence where
appropriate. The information on this form will be used to categorise the student’s dietary needs.
A photo of the student should be supplied as well. If a student is categorised as RED, then the
Operations Manager/Unit Manager may need to meet the parents/guardian/carer to discuss
the students’ needs and agreed actions in other to minimise any risk. This will also include
permission to share any information with the catering team. These must be documented on the
Special Diets Form.

Best practice, to ensure that this information is clearly communicated to all of the Catering
Team is to transfer the student’s photo and details of the foods that MUST NOT be served onto
the relevant Allergen Sheets – RED, AMBER or BLUE

Ideally these sheets should be displayed in a prominent area of the catering department, near
to the service point, where staff can easily refer to them at service. However, they should not be
in view of others, such as teachers, visitors and students. Where this is not possible then a file
containing this information, in the same format, must be available. Whatever method is used all
staff must be trained and made fully aware of it.

RED Category Controls

Once the procedures above has been followed and a menu agreed for the student the
following controls must be in place at all times

The Manager/Chef must communicate to the kitchen when food for RED category students is
being prepared. Where possible this should be in a separate area, if this is not possible then
separated by time from other foods containing allergens. Prior to preparation the area and all
equipment must be thoroughly cleaned using the 2-stage cleaning method and/or dishwasher
to prevent cross contamination.

When preparing the meals, the Manager/Chef must thoroughly wash their hands and wear a
disposable plastic apron over their uniform to prevent cross contamination. (The same control

July 2020
used when handling raw meat should apply). Care must be taken at all stages to prevent any
allergen cross contamination including storage of ingredients, preparation, cooking and
service.

Once completed the meal must be plated and double wrapped in cling film, then clearly
labelled with the student’s name, date and dish description. If the cling film at any time is torn,
removed or damaged the meal MUST NOT be served and immediately disposed of. It is the
Manager/Chef’s responsibility to check the dish before service to ensure that it is correctly
covered and labelled.

The meal must be clearly identified to the members of staff responsible for serving the student,
this information must be communicated directly to the staff by the Manager/Chef during the
pre-service briefing.

The meal must be served directly to the student by the nominated member of staff responsible
for serving the student.

The Allergen Free Meals Sheet must be signed by the person who has prepared the meal and
the person who has served the meal. A master copy of this can be found in the Unit Allergen
Folder.

It is for the student’s safety that the above procedures are followed at all times, if at any time
this cannot be followed then the Unit Manager must agree an action with the school

At no time can a RED student be served food from the counter due to the risk of cross
contamination, unless agreed by the parent and documented on the Special Diets Form.

AMBER & BLUE Controls

Students that are AMBER or BLUE can be served from the counter ensuring that they are served
the correct meal. Staff must be briefed before service by the Unit Manager/Chef using the Pre-
Service Briefing Sheet.

For delivered Services the above procedures must be followed for RED, AMBER & BLUE students.
Any RED meals need to be double wrapped in cling film and transported to avoid cross
contamination, ideal in a separate container. If this is not possible the parents of RED student
must be made aware of transport arrangements and clear that they are sufficient. In addition,
a completed accurate Allergen Matrix for all dishes must accompany the food being delivered
for service. The matrix must be completed and signed by the production kitchen and handed
to the service employees, who must sign upon receipt. This matrix must be kept for a period of 6
weeks.

July 2020
General Food Production and Service

It is important to reduce the risk of cross contamination with allergens in the general production
and service of foods within the business. The following procedures are in place to reduce the
risk:

• Cleaning work areas down, using 2 stage cleaning, in between preparing different
foods.
• Ensuring all equipment and utensils are cleaned in-between usage.
• Storing ingredients and foods in closed and labelled containers, this includes the Dry
Stores, fridges and freezers.
• Keep ingredients containing allergens separate from others.
• Washing hands thoroughly between preparing different foods.

Cooking can also result in cross contamination – such as chips cooked in the same oil as fish
cannot be considered gluten or fish free.

When cooking allergen free foods, the use of separate clean oven cloths maybe needed to
prevent cross contamination where relevant.

Due to nature of the business it is not possible to completely eliminate the risk of cross
contamination, unless a meal is produced for an individual in line with procedures for a RED
category student.

At no time will the company make a free-from claim.

Any allergens contained within the foods produced on site must be clearly communicated to
any customer upon request. This information is produced in the form of an Allergen matrix and
must be available for all foods in all service areas.

An accurate Allergen Matrix must be available for all foods served in the Unit to ensure that
verbal information is accurate and can be cross referenced.

Allergen Matrices for lunchtime service must be reviewed/updated each time the dishes are
prepared within the menu cycle, the matrix must signed and dated.

Allergen matrices for services such as cold deli, hot deli, cakes must be reviewed at a minimum
of once a term unless ingredients or product recipes have changed. The matrix must be signed
and dated at each review.

Staff should also be aware and vigilant of cross contamination during service, such as salad
bars, unwrapped cakes sharing a display unit, serving utensils & spillages.

It is a legal requirement that any brought in pre-packed foods containing any of the key
allergens must be clearly labelled to identify them. Some products may also contain the
statement ‘may contain’ which highlights the possibility of cross contamination from the factory
or production. These products will not be suitable for students with severe allergen risk due to
the risk of cross contamination.

It is important that all foods be labelled to identify if they contain any of the key allergens,
therefore all in house produced will be labelled with the appropriate allergen label when stored
in the fridge, freezer or dry stores. In addition, any foods that have been decanted from the
original packaging will need to be labelled with the appropriate allergen label. Foods still in the

July 2020
original packaging do not need an allergen label as the manufacturer’s information is
available, even if opened, however they still need to be date labelled.

Foods such as in-house sandwiches & baguettes do not need labelling as the allergen
information is available on the relevant allergen matrix, until the requirements of Natasha’s Law
are implemented.

The Allergen Notice must be clearly displayed in a prominent position in all service areas
instructing customers to ask a member of the Catering staff about allergens in the food
produced on site.

Hospitality Catering

Where possible it should be established at the time of booking if any persons attending have
any allergies or special dietary requirements.

If YES separate foods must be prepared and labelled - following the procedures list in the RED
category controls section.

An Allergen Matrix needs to be completed for each booking to ensure that any allergen
information can be accurately communicated upon request. This needs to detail each item
being served.

If the hospitality is taking place during normal service times, then an A5 sign needs to be
displayed

For hospitality booking outside of normal service times or in remote locations then completed,
accurate Allergen Matrix must be sent.

July 2020
Arrangements for all other businesses (workplace/general public)

Any allergens contained within the foods produced on site must be clearly communicated to
any customer upon request. This information is produced in the form of an Allergen matrix and
must be available for all foods in all service areas.

An accurate Allergen Matrix must be available for all foods served in the Unit to ensure that
verbal information is accurate and can be cross referenced.

Staff should also be aware and vigilant of cross contamination during service, such as salad
bars, unwrapped cakes sharing a display unit, serving utensils & spillages.

It is important to reduce the risk of cross contamination with allergens in the general production
and service of foods with the business. The following procedures are in place to reduce the risk:

• Cleaning work areas down, using 2 stage cleaning, in between preparing different
foods.
• Ensuring all equipment and utensils are cleaned in-between usage.
• Storing ingredients and foods in closed and labelled containers, this includes the Dry
Stores, fridges and freezers.
• Keep ingredients containing allergens separate from others.
• Washing hands thoroughly between preparing different foods.

Cooking can also result in cross contamination – such as chips cooked in the same oil as fish
cannot be considered gluten or fish free.

When cooking allergen free foods, the use of separate clean oven cloths maybe needed to
prevent cross contamination where relevant.

Due to nature of the business it is not possible to completely eliminate the risk of cross
contamination.

At no time will the company make a free-from claim.

It is a legal requirement that any brought in pre-packed foods containing any of the key
allergen must be clearly labelled to identify them. Some products may also contain the
statement ‘may contain’ which highlights the possibility of cross contamination from the factory
or production. These products may not be suitable for customers with severe allergen risk due to
the risk of cross contamination.

It is important that all foods be labelled to identify if they contain any of the key allergens
therefore all in house produced will be labelled with the appropriate allergen label when stored
in the fridge, freezer or dry stores. In addition, any foods that have been decanted from the
original packaging will need to be labelled with the appropriate allergen label. Foods still in the
original packaging do not need an allergen label as the manufacturer’s information is
available, even if opened, however they still need to be date labelled.

Foods such as in-house sandwiches & baguettes do not need labelling as the allergen
information is available on the relevant allergen matrix, until the requirements of Natasha’s Law
are implemented.

The Allergen Notice must be clearly displayed in a prominent position in all service areas
instructing customers to ask a member of the catering staff about allergens in the food
produced on site

July 2020
Allergen Investigation

Any Allergen incident or near miss must be report by the Unit Manager to their Operations
Manager immediately. The QHSE Department and Head of Food must all be informed the
same day.

All incidents must be investigated by a member of the Operations Team within 24 hours of the
incident occurring in order to establish the root cause of the incident. This includes a review of
procedures, employee knowledge and compliance with procedures. Once completed the
findings will be communicated to all relevant parties and any required action taken.

Any allergen incident resulting in hospital treatment will be reported to Worcestershire

Regulatory Services under the Primary Authority Agreement by the QHSE Department.

Training

All employees must complete the relevant training necessary in order to keep our customers
safe and support the effective implementation of the Allergen Policy. This includes:

Allergen Induction Training

All employees complete this either pre employment or on Day 1 of employment.

• Introductions to Allergens
• The importance of allergen management and controls
• How allergen information is provided within our business

Allergen Policy and Procedures

This training is completed by all employees involved in food production and service. The roles &
responsibilites section will vary depending who is being trained. This is completed during Week 1
where necessary

• Company Allergen policy and Unit procedures, company recipes and allergen matrices.
• Roles and responsibilites in dealing with allergens,
• Red, Amber and Blue category students and relevant procedures
• Risk of cross contamination when storing preparing and serving foods and relevant
controls.
• Supporting documentation

Online Allergen Training

All employees complete the online Allergen training within the first 3 weeks of employment. The
training includes:

• The 14 food allergens

• Symptoms of an allergic reaction
• The law concerning allergens
• How to help someone suffering from an allergic reaction

July 2020
Allergen Management Level 3

A one-day course for key personnel within the business as required.

Refresher Training – as required, minimum once a year.

All training is recorded on an employee’s Training Record Card

Documentation

Copies of all documentation can be found in the Unit Allergen Folder or as electronic versions in
the Document Library on WHISK

Dealing with Severe Allergic Reaction

When someone has an allergic reaction to a food it is important that all staff should know what
to do.

Important - Warning signs

It is not always clear if someone is having an allergic reaction because other serious conditions
can have similar symptoms.

However, warning signs to look out for are:

• if they are finding it hard to breathe,

• if their lips or mouth are swollen,
• itching around the mouth
• wheezing
• rashes
• vomiting
• diarrhoea
• may collapse

If the above happens, this is what you should do:

• Do not move the customer. This could make them worse.

• Call 999 immediately and describe what is happening; explain that you think the
customer may be having a serious allergic reaction or anaphylaxis (pronounced anna-
fill-axis). It is important to mention the word anaphylaxis to ensure that the urgency of the
situation is communicated, and that appropriate medication will be available.
• Ask the customer if they carry an epi pen and, if necessary, help them retrieve it.
• If a staff member or first aider is trained in administering adrenaline, and the customer is
struggling to self-administer, then
• offer to assist them.

July 2020
 • Send someone outside to wait for the ambulance while you stay with your customer until
help arrives.

We operate a Primary Authority Agreement with Worcestershire Regulatory Services who have
approved our policies and procedures.

July 2020