Issue View | Council I | 2023 Biennial Meeting

This is a brand new Issue.

Establish written procedures for managing food allergy events

Food establishments should have written procedures that clearly state if and how food employees should respond to patrons having allergic reactions and severe allergic reactions resulting in anaphylaxis. Explicit guidance should be specified for, but not limited to: who is qualified to intervene during an allergic reaction event; whether a food establishment does or does not stock epinephrine injectors, antihistamines, and/or corticosteroids; and when food employees should seek medical help. The 2022 Food Code does not require written procedures for managing food allergy events.

Approximately 10% of adults in the United States have food allergies, and retail food establishments are a frequent location of food allergy events (Gupta 2016, Radke 2017). A 2017 publication from the CDC's Environmental Health Specialist's Network (EHS-Net) reported that managers and staff were not confident in their establishment's ability to effectively respond to an emergency event arising from a food allergen exposure. Among 2,822 individuals included in the Food Allergy Research & Education registry were surveyed and over 50% of respondents who experienced a reaction at retail had informed restaurant staff of the allergy, over 25% of respondents also reported that allergens had been declared on the menu, and 14% occurred when allergens were declared on the menu and establishment staff were informed (Oriel 2020).While recent changes to the Food Code have improved requirements for informing consumers of common allergens, as well as food handler training for food allergens, responding to food allergy event is not addressed.

Currently, the person in charge (PIC) is required to demonstrate knowledge by "Describing FOODS identified as MAJOR FOOD ALLERGENS and the symptoms that a MAJOR FOOD ALLERGEN could cause in a sensitive individual who has an allergic reaction" in section 2-102.11(C)(9). In section 2-103.11 (O) the PIC is required to ensure that: "EMPLOYEES are properly trained in FOOD safety, including FOOD allergy awareness, as it relates to their assigned duties. FOOD allergy awareness includes describing FOODS identified as MAJOR FOOD ALLERGENS and the symptoms that a MAJOR FOOD ALLERGEN could cause in a sensitive individual who has an allergic reaction." Additionally, sections 3-602.11 (B)(5) and 3-602.12 (C) require labeling for major food allergens. However, the 2022 Food Code does not require any form of written plan or procedures for responding to an allergy event.

A written plan for responding to food allergy events can help food establishments to manage liability and designate appropriate individuals to respond, if appropriate. All food employees should feel confident about whether they should or should not intervene during a food allergy event, and if intervention is necessary, what intervention entails.

That a letter be sent to FDA requesting the following to be added to 2-501 Responding to Contamination Events of the most recent edition of the Food Code

2-502.11 Responding to Food Allergy Events.

A FOOD ESTABLISHMENT shall have written procedures for EMPLOYEES to follow when responding to an allergic reaction, and severe allergic reactions resulting in anaphylaxis, experienced in the FOOD ESTABLISHMENT.