Are you in control of allergen risks?

The risks around providing food and drink containing allergens to customers have been extensively publicised in recent months following incidents involving large food chains. Allergy diagnoses amongst people in England have been increasing^[1], with a 2024 British Medical Journal^[2] report estimating as many as 6% of the UK adult population — around 2.4 million people — might have a clinically confirmed food allergy.

In this insight, we look at some core principles and best practice to help you manage the growing risks posed by allergens.

Key principles of managing allergen risk

Similar to risks in other industries, managing risks from allergens depends on combining robust risk management systems with an embedded culture, set by the most senior leaders in your organisation. It’s about both having suitable and appropriate processes in place, and having reasonable assurance your people are following these processes routinely.

As shown by the findings of an inquest into the death of an individual, a culture where people fail to follow the processes in place can be equally as dangerous as having no processes at all.

Managing allergen risks with robust systems

All management systems (including health and safety, quality and environment) follow a plan, do, check, act (PDCA) cycle.

1. The plan phase of any management system focuses on establishing a policy statement. In the context of allergens, this would mean committing to preventing allergic reactions among customers. The plan phase also includes the risk assessment process, designing it to ensure once you implement your planned activities, the risk will be reduced to a tolerable level.
2. The do phase requires developing and implementing control measures, which include safe systems of work and training, plus testing the effectiveness of training. The do phase should also consider barriers and employees’ individual abilities to process and understand information.
3. The check phase involves verifying that your agreed control measures, including training, have been effectively implemented and are being adhered to. You can verify this through regular inspections and audits, which can be conducted by internal or external specialists. External audits can offer valuable independent perspectives on your control measures and their effectiveness.
4. The act phase focuses on learning from reactive data, such as claims and accident information, and proactive data from inspections and audits. This helps you decide if you need to make any changes to your management system to ensure it meets its objectives.

Ensuring reasonable assurance on your allergens risk management

It’s critical that responsible executives and managers ask themselves whether they have reasonable assurance that the processes they think are in place for managing allergens risks are both designed and operating effectively.

Documenting and keeping records of processes is important, but mean little if they don’t include key steps required to truly mitigate the risks, or your people don’t understand and adhere to these processes in practice.

Implementing control measures can be particularly challenging for staff responsible for adhering to process steps in sometimes difficult circumstances. For example, staff may easily confirm an order and allergen status repeatedly and separate order preparation areas in a calm and quiet training environment. But can they replicate the same processes in a noisy, busy and pressurised real-world environment? Crucially, does your organisational culture support every employee in sticking to these essential steps, rather than bending the rules to meet service targets?

Checklist: Are your allergen control measures sufficient and appropriate?

Asking a series of key questions can help your organisation determine whether your allergen control measures are sufficient and appropriate:

• What is the purpose of a given step in a process and what risk is it intended to mitigate?
• If the process is executed exactly as documented, will it effectively control the identified risk?
• In the most challenging conditions your staff could reasonably face, would they still adhere to this process?
• How do managers and leaders ensure processes are consistently effective across all locations?
• How are your employees informed about a process, and will they remember the details several months after learning about it?

To find a smarter way to manage allergens risks, get in touch with our specialists.

Footnotes

1. “Food allergy diagnoses in England doubled in a decade, say researchers Return to article undo
2. “Up to 6% of UK adults might have a food allergy, says report Return to article undo