1. 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

2. ‘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.

3. 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.

4. 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EU Directive 2009/39/EC on food for particular nutritional uses (PARNUTS) was repealed and replaced by a new regime under EU Regulation 609/2013 on food for specific groups (FSG) in 2014 and implemented in 2016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.

5. Food Information Regulation for Consumers (EUFIC) 1169/2011
All deliberate ingredients listed in ingredients list introducing Annex IIIa (14 allergens)
Introduced in December 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.

6. 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.

7. 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?

8. 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
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.

9.
Refer to the FSA website.

10. 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

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

12. And another, using G for gluten free..Salisbury

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

14. Leicester

15. Derby

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

17. 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

18. 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.

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

20. Thank you