What are the implications of Natasha’s Law for food manufacturers?
If you work in the food manufacturing sector, you’ll already know the key standards and guidelines you need to comply with. Customer safety is paramount, and most of the these are designed to ensure manufacturers adhere to this.
In October 2021, Natasha’s Law came into practice in the UK bringing additional protection to the public. The law brought new rules governing how any business handling food must do when producing and labelling products to avoid the danger of allergic reactions.
It has been a few months since Natasha’s Law came into effect. However, many manufacturers are still addressing what they can do to incorporate it into their operations appropriately, minimise risk and guarantee customer safety.
This guide explains the implications of Natasha’s Law in greater detail, including what you must do to comply.
What is Natasha’s Law?
Natasha’s Law is a piece of legislation that came after the tragic death of Natasha Ednan-Laperouse in 2016. Natasha had purchased a sandwich from Pret a Manger at Heathrow Airport, which did not list sesame (which Natasha was allergic to) in its ingredients.
After eating the sandwich aboard a flight, Natasha suffered an anaphylactic shock and later died.
Pret had not listed sesame in the ingredient due to a food labelling loophole, which meant non-pre-packaged fresh food made on-site did not need to be individually labelled with allergen or ingredient information. Instead, Pret simply displayed signs telling customers to raise allergy queries with staff, who, in this case, could not answer Natasha’s questions correctly.
Natasha’s Law was created to close this loophole and provide better protection for allergy sufferers in the UK. Under the law, all food pre-packed for direct sale (PPDS) must list all the ingredients on the labels of each product. This applies to all businesses in the UK – from restaurants and cafes to food processors.
Why does it matter?
There are over two million allergy sufferers in the UK, not including those with intolerances. While Natasha’s death may seem like a rare and extreme case, it is by no means isolated. Between 2019 and 2020, there have been rises in hospital admissions associated with allergies for adults and children. There have also been 187 deaths since 1992 caused by food-induced anaphylaxis.
The food industry needs to do everything possible to protect the public against allergies. This means giving consumers clear sight of the ingredients included in the food they eat.
While there have been rules in place about the labelling and notification of allergens for some time, the addition of Natasha’s Law covers a gap in the guidance and leaves no room for interpretation. This should prevent a tragic case like Natasha’s from reoccurring.
There are also clear benefits for businesses that protect their customers. Natasha’s story generated a lot of press coverage, which negatively hit Pret a Manger. The company was also taken to court, again covered in the press, though ultimately found not guilty.
Although Pret is still standing today, people now associate the brand with the tragedy. The case shows the effects customer tragedy can have, bringing unfavourable press attention. This leads to lost sales and irreversible brand damage, which few businesses – especially smaller firms – will struggle to overcome.
More generally, it shows that any failure in customer safety standards will lead to grave repercussions, including costly product recalls (as seen in the recent Kinder salmonella outbreak), complaints, legal action and fines. These could have a devastating impact on sales, revenue and profitability, a brand ravaged in the industry or even the forced closure of a business.
What should my plant do in response?
Although Natasha’s Law impacts the information displayed on labels whether manufacturing at a plant or businesses carrying out production on-site (such as cafes), there are several things you can do to comply with the pre-printed specifications of your products. This will make accurate labelling easier.
We’ve listed our tips below.
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Understand the requirements of your products
When starting any new project, you must understand the requirements. Firstly, this allows you to create integrated processes that make for more efficient production and higher quality output. Secondly, you will determine if there are any specific arrangements you need to cater to.
Examples of such arrangements could include particular markets the product will be aimed at or allergens that must be avoided. Similarly, understanding the materials you are working with will help you to determine the common allergens that come with it.
From here, you will design processes that account for the allergens or other ingredients you need to avoid – or make it clear from the start what allergens will need to be listed.
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Separate product flows
If you work with multiple product ranges or types, different allergens may be associated with each. You need to prevent cross-contamination to ensure only the pre-determined ingredients are included.
For example, you might have one production line processing crisps and another processing nuts. The crisps are labelled as nut-free, but a nut from the other line manages to get mixed in. If a consumer with a nut allergy were to come across this unwittingly, it could spell disaster.
To avoid this happening, you need to separate your product flows effectively, particularly when allergens are involved. This will mean handling products in different spaces to avoid any risk of cross-contamination or having thorough cleaning regimes in the event of lines being used for multiple products.
If it’s not possible to do this, you need to ensure it’s stated that your products may include allergens – which means highlighting it on the label.
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Have a strong culture of hygiene
In your bid to minimise the risk of cross-contamination and unaccounted allergens, you need a strong hygiene culture.
By creating a frequent cleaning schedule, you should remove residue between cycles, which is crucial if you process a range of products using the same equipment. Even the smallest fragment of a substance will cause an allergic reaction, so you must be rigorous.
There are many factors to consider to implement a better hygiene programme into your plant. You need equipment that is easy to clean, especially if you are working with sticky substances that are more likely to linger. Features like a waterproof IP rating or tools-free removal of parts will make this process easier.
Next, you need comprehensive cleaning processes that clarify who is responsible and give them access to the resources they need.
It’s also wise to create policies that encourage hygiene among staff as it is possible for allergens and contaminants to make their way into production through user handling. By ensuring good cleanliness, you will reduce the risk of harm while meeting general hygiene standards.
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Utilise product inspection
Product inspection also plays a vital role in reducing the risk of allergens. Depending on your mode of inspection, it’s possible to detect flaws in your products, including cross-contamination or potentially the inclusion of allergens that should not be there.
Once you have uncovered these issues, you will find a resolution before it ends up in your customer’s hands and results in a bigger problem.
It is worth noting that production inspection systems won’t safeguard you against all possible allergens. X-ray is the most comprehensive form, but it still won’t catch everything.
However, it will help you to identify a wide range of contaminations, including those that may potentially cause harm or injury to your customer outside of allergens. It will also improve output quality and customer satisfaction.
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Analyse data
Data collection is another helpful tool when following food safety laws. If something goes wrong – such as an unexpected allergen being found in your products – analysis is crucial to understand the root cause of the issue and address it.
It also makes your auditing easier, should you be called upon to prove you’ve conducted the proper checks and protocols.
Invest in performance monitoring solutions that provide real-time analysis across your production lines, as this will quickly alert you to any problems that could have broader consequences. You can then rectify it promptly before it becomes more significant – saving you further damage and costs.
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Communicate with customers
While you should do as much as you can to reduce risk from your products, it’s not always possible. Logistical and financial constraints may limit your removal of allergens – and, of course, some products will just contain allergens naturally.
However, if there is any risk of allergens in your products, anyone consuming it must be aware. In most cases, this means ensuring that the labelling and ingredient lists are accurate.
It’s your responsibility to ensure it is done correctly and compliantly. If an external body deals with your packaging and labelling, you need to give them insight into how the food has been processed and any potential allergens so that it is labelled accordingly.
If you sell products to other businesses, such as retailers, cafes, caterers and so on, it’s also imperative to communicate any risks with them so they advise their customers accordingly.
By being fully transparent about your products and any allergy or other risk that may occur, you will ensure customers have the information they need to decide if they are able to safely consume them. This should prevent a tragedy from occurring and your business from being liable.
Conclusion
Natasha’s story shows the dramatic consequences that come when unexpected allergens appear in food products. It also highlights how crucial it is that the industry does everything to protect customers – starting from legislation to implementation.
Natasha’s Law reinforces the rules for food businesses of every kind, reducing the room for error in product labelling.
Even if you do not have any control of product labels, food processors must support compliance by doing as much as possible to minimise unnecessary allergens (such as by avoiding cross-contamination and utilising hygiene and quality control processes) and ensuring the right people are aware when there is a hazard to consider.
By doing so, manufacturers will avoid the damage that comes when a customer is put in danger, allowing them to maintain their reputation, reduce the risk of legal repercussions and protect the public.
Speak to Yamato today to learn how we can support you in implementing effective processes with the right equipment to manage risk and protect consumers.