Gluten Free delivery in hospitals BDA and Coeliac UK relationship on CPD for dietitians and Nutrition & Hydration Digest (2012 and 2017) My brief for today: labelling and legislation around GF/signposting on menus/Implications for patients/GF catering accreditation Norma McGough, Director of Policy & Research, Coeliac UK

‘From Coeliac Society to Coeliac UK’ Registered charity since 1968 – our 50th anniversary this year Now 65,000 members; 75 local support groups Offices in England, Scotland and Wales Legacy relating to food information and GF standards and legislation; GF catering accreditation; XG licensing for pre-packed foods; FSA and Codex on revised standard and introduction of legislation. 2008 – HCA; LAST 5 years NACC; Since 2012 focus on GF catering accreditation as a platform for dialogue.

Ability to find a GF meal…in hospital Although there’s been a lot of developments in terms of accessing safe GF food in and out of the home, there’s still a way to go… This is from a survey in 2016 around eating out. The overall survey showed significant improvement but access to GF food in hospital can still be an issue.

Overview of gluten related legislation for today Allergen labelling Directive 2003/89/EC introduced in 2005 Revised Codex Alimentarius gluten free standard in 2008 Regulation on gluten free (EC) No 41/2009 introduced in 2012 Food Information Regulation for Consumers (EUFIC) No 1169/2011 introduced in 2014 Commission Implementing Regulation (EU) No 828/2014 on absence or reduced presence of gluten in food came into force in July 2016 EU Directive 2009/39/EC on food for particular nutritional uses (PARNUTS) was repealed and replaced by a new regime under EU Regulation 609/2013 on food for specific groups (FSG) in 2014 and implemented in 2016 So, let’s look at the developments in legislation… There’s been a lot going on in the last 15 years or so… Food legislation has also evolved, notably with the 2011 Food Information to Consumers (FIC), 2006 Nutrition and Health Claims, and 2006 Fortified Food Regulations and the 2002 Food Supplements Directive. PARNUTs applies to a broad category of ‘dietetic foods’. The Directive is complemented by specific legislation concerning infant food, slimming food, and food for persons with gluten intolerance. New regulation for specific groups aims to protect specific vulnerable groups of consumers (infants and young children, people with specific medical conditions and people undertaking energy-restricted diets to lose weight) by regulating the content and marketing of food products specifically created for and marketed to them. EU legislation covering the term ‘gluten-free’ was published in January 2009 and came into force in January 2012 (Regulation (EC) No 41/2009). Changes to European legislation take effect in 2016 which affect gluten-free labelling – Regulation (EC) No 41/2009 was repealed from 20 July 2016. From this date, rules relating to gluten will be provided by Regulation (EU) No 1169/2011 on the provision of food information to consumers (FIC), and Commission Implementing Regulation (EU) No 828/2014.

Food Information Regulation for Consumers (EUFIC) 1169/2011 All deliberate ingredients listed in ingredients list introducing Annex IIIa (14 allergens) Introduced in December 2014 - Food Information Regulation for Consumers (EUFIC) No 1169/2011 with new format requirements for allergens There is a minimum font size making it easier for people shopping and reading labels Allergens must be emphasised Allergy box (never part of the law) was prohibited – signposting to the ingredients list Caterers have had to be able to provide information on allergens/gluten in food served on menus, verbally… All ingredients have to be listed in the ingredients list, since 2005 New law, Food Information Regulation, applies from December 2014 Allergens must be emphasised Gluten-containing cereals are one of 14 allergens, so you’ll also see these allergens emphasised Directive 2003/89/EC introduced Annex IIIa, which is a list of allergenic foods that must always be labelled when present in a product. Directive 2007/68/EC has the most recent amendment of Annex IIIa. It lists all the allergenic foods that must be labelled as well as a few products derived from these foods for which allergen labelling is not required.

Hidden gluten? I’ve read that manufacturers can hide gluten in foods such as flavourings, emulsifiers and bulking agents, is this true? You can’t hide gluten any more! It has to be declared whether prepacked or foodservice. GF claim triggers the GF law and compositional requirement around GF.

Precautionary labelling ‘should only be used when, following a thorough risk assessment, there is a demonstrable and significant risk of allergen cross-contamination’ Used to let customers know that it might contain an allergen… Not best practice to use GF and may contain gluten. VITAL?

Gluten Free /NGCI Terminology…… ≤ 20 ppm gluten Applies to packaged foods, loose foods and in catering Can be used for individual products, dishes on menus or menus Very Low Gluten 21-100 ppm No gluten containing ingredients (NGCI) Factual statement AND NOT WITHIN LAW No deliberate gluten containing ingredients Steps in place to control cross contamination Not produced to a guaranteed level of gluten Phased out since July 2016 – February 2018 Can still be used to describe lists of products or dishes eg menus or Food and Drink Guides but NOT on individual products or dishes This leads on nicely to terminology and where we are with terminology in view of the GF law.

https://acss.food.gov.uk/sites/default/files/gluten-guidance.pdf Refer to the FSA website.

Catering in hospitals In 2015, the Hospital Food Standards Panel in NHS hospitals (England) published its report recommending five legally binding food standards be incorporated into NHS Standard Contracts The BDA’s Nutrition and Hydration Digest (2012 and updated in 2017) underpins one of these standards and recommends that all hospitals should have a policy that covers gluten free provision and ensures that food preparation and labelling of food is consistent with the law and guidance from the Food Standards Agency Information on hospital food standards for England, Northern Ireland, Scotland and Wales is available on the Coeliac UK website www.coeliac.org.uk/hospitalfoodstandards

What’s on hospital menus…..? Use of GF on dishes..Southampton

And another, using G for gluten free..Salisbury

Combining NGCI and GF – 2015! But still not right approach! Leeds

Leicester

Derby

How we can help… Online training Face to face training Accreditation Consultancy Catering how to get it right

Our GF accreditation scheme Audit standard specific to gluten management Audit grades Corrective actions Mystery Diner Complaints Risk based sampling Auditor training Quarterly reports for overall scheme Individual business reports to compare progress and results Reporting to Food Standards Committee twice a year Launched in 2012 on back of the legislation. Based on 2 different phases of research and working with an audit company to develop a GF standard for foodservice. Journal of Food Protection, Vol. 79, No. 2, 2016, Pages 282–287

Coeliac UK accreditation: THE DEAL A symbol that establishments can use to show that they follow the correct processes to produce gluten-free meals according to the law Can only be used by those who have worked with us on accreditation and meet our standards Developed the Gluten-free standard alongside audit company NSF International. The standard covers all aspects of gluten-free preparation as well as ensuring training is in place Caterers are audited against the gluten-free standard A proportion of sites are audited making sure a geographical spread is covered, as well as a range of quiet and busy restaurants   GF standard covers the following areas: Knowledge of the law – caterers must know about the laws on gluten-free and general food safety. Choosing and using the right ingredients – making sure caterers know the right ingredients to use, and ensuring they are using reputable suppliers. Storage – ingredients and finished dishes are stored correctly to avoid cross contamination. Preparation – cross contamination risk is controlled at all stages of preparation, for example using clean oil for frying, clean water for boiling, clean surfaces. Cleaning – clean utensils and surfaces. Personal hygiene – hands washed between use of gluten-containing and gluten-free ingredients. Communication – there must be a system in place to ensure that customers are provided with correct information. Training – Training must be provided for all staff on all aspects of preparation and serving of gluten-free food. Quality assurance – caterers must ensure that processes, documentation and training are kept up to date and carry out regular internal checks. Complaints – customer complaints must be logged and investigated with reference to procedures in place.

Further information Coeliac UK Food Standards Agency www.food.gov.uk Food industry professionals area of the website: www.coeliac.org.uk/food Catering newsletter Crossed Grain and Monthly newsletter Food Standards Agency Technical Guidance www.food.gov.uk

Thank you