Celia Marsh had a severe milk allergy and died after eating a Pret a Manger wrap that had been labelled vegan but included dairy protein. The yoghurt was meant to be vegan but was subsequently found to contain traces of dairy protein. The protein was in an ingredient called COYO that contained an extra ingredient called HG1 that was cross contaminated with dairy during manufacture.
Pret a Manger was originally charged with food safety offences following Mrs Marsh’s death, but the prosecution was later dropped due to lack of evidence.
The manufacturer of the dairy-free yoghurt had in its possession documents which flagged this risk, but this risk was not passed on to its customers, the coroner ruled.
The coconut yoghurt used as dressing came from Australian brand COYO and was licensed for manufacture in the UK to British firm Planet Coconut.
The coroner stated that “Planet Coconut had information which should have alerted them that their COYO yoghurt may have contained milk and this information was not passed on to Pret.
Since Mrs Marsh’s death Pret a Manger chief executive Pano Christou said Pret had taken “significant steps” involving its suppliers and labelling policies to ensure all customers were fully informed about the food they were buying.
Planet Coconut stated that a product information form that said the HG1 was “not suitable for a free-from claim” was first shared with them in February 2018.
Bethany Eaton, managing director of Planet Coconut, told the inquest she was unaware of the risk the starch posed and that she had been assured the yoghurt was made in “an allergen-free environment”
The coroner concluded that the coconut yoghurt dressing had been cross contaminated with milk protein during manufacture.
This incident highlights the importance of supplier management, and the coroner said the death was preventable if important information had been shared along the supply chain.
“It is absolutely imperative that there is full transparency throughout the whole supply chain and that if there is anything even including the risk of contamination, that that information is passed on down the food chain.”
What can you do with your suppliers to prevent such tragic incidents?
When it comes to your suppliers you should expect the following as basic requirements:
- Be able to supply the products that you want and in the volume that you need
- The products meet your quality standards
- The food will be safe
- They can provide you with a detailed and accurate list of allergens in their products
- They can verify any free from claims and provide you with the details
- However, relying on the checks of others would be unlikely to be deemed sufficient due diligence in the event of a food safety incident and in this case both businesses could have been liable
- Businesses, at all steps in the supply chain must understand sub ingredients, formulated components and finished product characteristics
- Suppliers should do a thorough risk assessment and you should ask to see this information from suppliers and carry out your own risk assessments when making claims:
- At its most basic level, an allergen risk assessment involves examining any product or dish to understand its composition and production, and thus the likelihood of allergen content
- Consideration should then be given to finding out whether non-ingredient allergens are handled nearby, and whether there is any way in which they could get into the original product or dish
- This involves examining the process and the character of the product or dish being made, the potential for unintended allergen presence, and the nature of any unintended allergen – whether liquid, powder, grain etc.
- Consideration should then be given to existing controls and ways to segregate, physical distance, time separation and scheduling production, covering or wrapping, washing and cleaning
- Businesses should validate and verify the supply chain
- Have a balance decision making process erring on the side of caution and consumer protection.
Choosing A Supplier
When it comes to selecting food suppliers, you must also ensure they are safe and compliant.
- Build a good relationship.
- Open and honest communication is key when choosing which suppliers to work with as it’s a critical element of effective allergen management
- Make sure your suppliers quickly update you on any product or ingredient changes
- They have a legal obligation to provide you with the exact ingredient composition of any foods you buy from them
- Act on these updates immediately ensuring all associated documentation is revised and communicated
- Check your supplier is certified.
- Make sure your suppliers are certified to specific food safety and hygiene standards such as SALSA or BRC Global Standards and check the certification is authentic
- Also make sure the audit certificate provided is in date (they typically last for one year and have expiry dates on them) and the scope of the certificate (description of the processes audited) covers the food that you are buying
- Check safety standards
- Visit your supplier and check their safety standards or ask an expert to audit your supplier
- Food Alert has a team of experts that can help with food safety advice and guidance.
- Maintain supplier information.
- Having the correct certification is not a one-off exercise. You must make sure certificates are maintained and in date. If suppliers fall short of your expectations, then you should act and delist them
- Use Alert65 supplier module to send notifications when certificates are about to expire
- This also sends an email to suppliers reminding them of your expectations from them as your supplier
- Free from’ foods
- Free from’ foods are manufactured for a particular market of people who need to avoid certain foods to protect their health, or who to choose to do as part of a personal dietary regime
- They tend to use substitute ingredients, such as tapioca, rice or potato instead of gluten-containing flour (e.g., wheat), or soya, rice or coconut instead of milk
- Steps such as allergen segregation are required to make such claims and this should involve laboratory batch testing of ingredients, before allowing them onto the production site
- The assurance of ‘free from’ claims require a combination of strict supply standards to ensure all raw materials are free from the claimed allergen
- The strictest storage, handling, production and packing controls, to ensure complete segregation, with no risk of any cross-contamination
- Only 2 of the 14 UK/EU regulated food allergens have concentration limits for labelling purposes.
- Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg, or 10 mg/litre (parts per million)
- Gluten free’ may only use this claim if the gluten content is 20 mg/kg (parts per million) or less
- Do not rely on a ‘vegan’ logo and assume it will be free from milk, fish, crustacean, mollusc and/or egg food allergies – always check with manufacturers that the products are allergen free before making any claim
- May contain warnings
- Food allergens are known food hazards. So, where allergenic foods might be present because of unintentional cross contamination, then it is required in food hygiene legislation to apply HACCP principles and processes to identify where allergen cross-contamination might occur and determine the likelihood of that occurring.
- Once this is done businesses decide whether a precautionary allergen warning should be added to the ingredients allergen declaration to warn sensitive consumers to avoid the product
- It is good practice that this information is passed to the final consumer
- Food allergens cannot be removed by cooking, so it is essential to practise good kitchen hygiene, as well as careful separation, storage and labelling of ingredients when preparing food
- Allergen information for non-prepacked food can be communicated through a variety of means.
- The requirement is to provide information about the use of allergenic ingredients in a food. Where a food business chooses for this information to not be provided upfront in a written format (for example allergen information on the menu), the food business must use clear signposting to direct the customer to where this information can be found such as asking members of staff. In such situations there must be a statement that can be found on food menus, chalkboards, food order tickets, food labels.
- Alert65 Allergens Module can help you create allergen matrices for your food.
- Foods that are sold prepacked for direct sale (PPDS) must be fully labelled with allergens highlighted emphasised on the list of ingredients
If you require any further information or advice or assistance with supplier management please contact Food Alert Advice Line on firstname.lastname@example.org or 0844 445 7412.