When most people think of food safety, they think of keeping the mayonnaise cool or using proper handwashing techniques. While these practices protect against foodborne pathogens, there’s another dimension to serving customers meals that won’t send them to the emergency room (ER) for dessert. Commercial foodservice operations increasingly need to be aware of patrons with food allergies and intolerances.

Approximately 9 million American adults (4% of the population over 18) and 6 million children (8% of those under 18) are allergic to one or more foods. The numbers rose about 18% between 1997 and 2007, the most recent year for which figures are available from the U.S. Centers for Disease Control and Prevention (CDC).

Reactions to triggering foods can be severe—the CDC reported that food allergies account for nearly a quarter-million ER visits every year and are the most common causes of anaphylaxis outside the hospital setting. The most common food allergens are milk, wheat, soy, fish, shellfish, peanuts, tree nuts and eggs.

Think about all the places on any menu these items could lurk, not just as featured items but also in condiments or the like. Was that salad dressing finished with eggs for a better consistency? Or maybe a dash of soy sauce makes the beef gravy more flavorful? It takes a complete breakdown of every ingredient in every dish to know exactly what a kitchen is serving its customers.

Armed with that knowledge, servers or managers can confidently respond when diners ask if a dish contains a specific ingredient.

“We are definitely getting more questions than we did 5 or 6 years ago,” says Mark Herman, CEO of Dion’s, which serves pizzas, salads and sandwiches in 17 quick-serve locations in New Mexico and Texas. “People are more aware, and they have more access to information. They want to know more.”

From Knowledge to Action
Knowledge may be power, but there are two more steps beyond menu analysis an operator must take to safely accommodate diners with food sensitivities. The first affects the back of the house; the second involves the entire operation, from owner to bussers.

Cross-contamination of dishes prepared without offending ingredients can occur anywhere in the production process, through shared cutting boards or utensils or grease particles flying from grills. That’s why any kitchen that offers special dishes to sensitive diners must develop specific protocols to keep the meal away from triggering ingredients all the way from cooler to table (see “Tips for Foodservice: Setting Up a Gluten-Free Kitchen”).

The recent dust-up over Domino’s pizza it calls gluten-free illustrates the problem. While the chain spent lots of money developing—and marketing—a crust made without wheat flour, it did nothing to ensure the non-wheat crust would not pick up gluten from the other pies in the kitchen. In fact, by sharing baking benches and ovens with wheat crusts and not following proper food allergen protocols, Domino’s more or less guaranteed that what started out as gluten-free would reach the carryout box as only gluten-not-so-much. At least the stores now post a disclaimer to the effect that its “gluten-free” pizza is not suitable for those who need to follow a gluten-free diet for health reasons.

“Because of how we produce food in our kitchens, it’s impossible to offer a 100 percent gluten-free product,” Herman says. “I’d rather not have it on the menu than to make someone sick.”

Dion’s also doesn’t offer options such as dairy-free cheese because of limited demand, but if diners want to bring in special ingredients, the kitchen would be happy to use them on a pie or in a sub.

Herman sends all his managers to ServSafe® training and all staff to basic food-handling classes. In April, he sent about 40 managers and staff through our Kitchens with Confidence AllerTrain™ training. Now he plans to add the food allergy training to the other educational pieces for everyone from order takers to managers.

“The webinar was the kickoff to see where we have to get better at what we do,” Herman says. “What we learned was that we need to have clear processes in place that are followed at every step.”

This is the second step to keeping your patrons out of the ER. Everyone on staff should be aware of any diner with an allergy or intolerance to any food. If possible, the host should make a note of it when a reservation is made and/or flag the party when they are seated. Servers should always listen to and respect the diner’s request and answer truthfully about what’s in a dish—even if they’re otherwise upselling the special macadamia-crusted prawns in creamy ponzu custard. If a server is unsure, a manager should be available to answer any questions without guessing.

The most critical part of the equation is for the server to communicate the need for a special meal to the kitchen. Once the uncontaminated plate leaves the kitchen, it should be uncovered only in front of the diner. The server should confirm that it meets the patron’s specifications and check back often to be sure.
“We were just trusting that people were listening to customers when they took the order, but once staff understood how important food allergies are, they were really positive about the training,” Herman says. 

Everybody on the Same Page
Once all the kitchen protocols are in place and all the staff has been trained, that should be enough, right? Not necessarily. Constant follow-up is vital.

Students with severe food allergies have been covered by the Americans with Disabilities Act since 1973, which means they are entitled to appropriate substitutions in school lunches. The Food Safety and Modernization Act (FSMA) of 2011 took the requirements further, authorizing the federal departments of education and health and human services to develop voluntary food allergy management guidelines for schools.

Because peanut allergies can be life threatening, many schools now allow allergic students to carry their EpiPens rather than lock them up in the nurse’s office. Some have created nut-free zones in their cafeterias from which the humble peanut butter and jelly sandwich and PayDay® bars are banished. But even these good intentions can go awry.

For example, the parents of a kindergartner followed the American Dietetics Association rules and told the school nurse about their daughter’s peanut allergy; her doctor provided a dose of epinephrine to have on hand. The girl knew she couldn’t eat peanuts, but when she forgot her lunch at home, a cafeteria worker gave her a peanut butter sandwich—and insisted she eat it. Turns out the nurse never communicated the girl’s allergy to the cafeteria, and that oversight sent a 5-year-old to the hospital in anaphylactic shock.

“[The 1946 National School Lunch Act, which requires schools to provide nutritious lunches to children in need] does not impose a statutory duty on the state to identify students with special di-etary needs, develop a flagging regimen or otherwise guard against individual exposure to food allergens,” wrote the appeals court judge in a ruling that let school officials off the hook for the incident.

That—the awareness and ability to identify and accommodate students with dietary sensitivities—is exactly what I hope the FSMA food safety guidelines on food allergy management will provide, even if they are voluntary. A good resource on the subject is available from the National School Boards Association, “Safe at School and Ready to Learn: A Comprehensive Policy Guide for Protecting Students with Life-threatening Food Allergies.” The report can be downloaded in PDF format at www.nsba.org/foodallergyguide.pdf.

As more schools look to outsource foodservice in the face of severe budget cuts, operations like Dion’s may have the opportunity to provide lunches to students. It’s not clear how the federal food allergy rules will apply to them.

“We do some deliveries to high schools for resale in their snack bars,” Herman says. “Mostly we’ve been concerned about keeping things at the right temperature, but when it comes to food allergies, we make sure we have our proper ingredients list available.”

Betsy Craig is the chief executive officer and founder of Kitchens with Confidence LLC and brings more than 25 years of foodservice industry experience to her company MenuTrinfo LLC. Her goal is to ensure her clients meet or exceed new labeling regulations.