1. PPDS foods
If you haven’t already, identify whether there are any pre-packed for direct sale (PPDS) foods which require a compliant label. As a reminder, PPDS foods are:
- Prepared on-site
- Individually packaged
- Fully or partially packaged prior to selection
- Have packaging that would have to be disturbed to access the food
- Not pre-ordered
Explore whether your PPDS range could be reduced and risk mitigated by a consolidation of suppliers and a reduction of the range of ingredients used. With supply chain challenges also anticipated this autumn and winter, this may be a wise move anyway.
2. PPDS recipes
This is an essential step and, if you’re not already doing so, this should be undertaken as an absolute priority! PPDS food recipes are required so that the allergens in each item are known.
Quantities are also needed, so that the ingredients are listed in order of descending weight.
3. Ingredient and nutrition information
By now, you should have confirmed the method for obtaining information and be in the process of implementing it. If not, do explore this as a priority.
For example, will the labelling system, a catering controls platform or on-pack be the preferred method for capturing ingredient and allergen information? It is important that any information is validated by checking details on-pack.
4. Your labelling solution
This is urgently required. Chances are, you have already set one up. If not, go back to step three and look at the options. Over the couple of weeks, make sure you have considered how the labelling solution will works and how it fits into your new process.
Also, what hardware is required, such as printers and where these will be located. The supply chain challenges being experienced by the whole industry is also applicable for label ordering, so its recommended not to leave this too late! Lastly, training on the labelling solution for your team needs to be a priority this month.
Remember to allocate some time to identifying risks associated with your new process and establishing an operational practice to manage each risk. Risks may include delivery of a substitute product by a supplier (a likely concern at present), the allergen information changing on a product, due to inadequate training or simply human error a member of the team not following a recipe or making the decision to use different products when cooking.
A risk could even be the team confusing which labels are for which PPDS items. Again, training and process planning are key here.
6. Cross contamination
As part of step five, it’s a good idea, if you haven’t already, to carry out a risk assessment regarding cross contamination within the processes associated with the provision and preparation of PPDS foods.
Any risks need to be communicated to your customers – pupils and indeed anyone eating from your foodservice operation. Please note that ‘may contains’ should really only be used if a genuine risk has been established rather than as a ‘catch all’ to reduce risk.
This has been touched on in some of the earlier points, but we would recommend you do allocate some time, in what will already be a busy month with school pupils returning, to trialling the new process and carrying out any final training of your team, so that everyone feels comfortable with the new processes, enabling them to be delivered effectively.
There is still time to engage with your local EHO. You can share how you plan to approach meeting the new legislation and get their feedback.
Communicate your approach to Natasha’s Law compliance this month and start to highlight those PPDS foods made on site. This could be done by displaying a poster or adding a sticker to relevant items.
This will encourage your pupils and any other diners to maintain important engagement with the catering team regarding any allergies.
allmanhall’s Natasha’s Law webinar can be viewed here, providing more information. As well as a client toolkit with useful prep materials, the team at food procurement experts allmanhall are on hand to offer support.