Natasha’s Law: Is your school ready?

On 1 October 2021, the law on allergen labelling for pre-packed for direct sale (PPDS) foods will change.

This means that any food business selling PPDS foods will have to include full ingredients on the product label with allergenic ingredients emphasised within that list. Ensuring food safety in schools is a catering management issue that is set to become more complex with the introduction of Natasha’s Law later this year.

In October 2021, new food information regulations for England, Wales, and Northern Ireland will come into force. These come under Natasha’s Law – legislation resulting from lobbying and consultation after the death of Natasha Edan-Laperouse from an allergic reaction to a pre-packed sandwich.

Schools will need to make sure that the food and ingredients they provide pre-packaged on-site meet all the labelling requirements of the new legislation.

For most schools, this will become a supplier management issue since, in many, cases, they rely on outsourced caterers to supply food for pupils on-site. However, for schools that make and wrap food in house they will need to provide this information.

What is Natasha's Law?

Natasha died from an allergic reaction to sesame seeds, which were an unlisted ingredient in the pre-packed baguette she was eating.

Leading a lobbying group, her parents campaigned for a change in the law to close the loophole which allowed this to happen.

The baguette’s packaging contained no specific allergen information, and therefore Natasha thought it was safe for her to eat.

Under the new rules, food that is pre-packaged for direct sale (PPDS) must display the following clear information on its packaging:

1. The food’s name
2. A full list of ingredients, emphasising any allergenic ingredients.

This marks a big change for caterers and organisations providing catering services, including schools.

How will Natasha's Law apply to school catering? 

Food allergies are common in children. It’s estimated that around one in five children has a food allergy, so the potential implications of getting this wrong are huge.

Children’s immune systems react in different ways to certain foods. A certain type of food might be safe to eat, but the body mistakes the proteins in it as harmful and responds by producing an antibody.

Some symptoms will be more severe than others, ranging from a runny nose and itchy eyes to skin reactions, breathing difficulties, nausea, and diarrhoea. For schools with a high concentration of pupils on-site, there are serious implications, both for children’s health and their own duty of care.

What do the new rules say? 

The Food Standards Agency has published guidance about the new requirements for PPDS food.

https://www.food.gov.uk/business-guidance/introduction-to-allergen-labelling-changes-ppds

https://www.food.gov.uk/business-guidance/prepacked-for-direct-sale-ppds-allergen-labelling-changes-for-schools-colleges-and-nurseries

It explains that PPDS food is classed as food that is packaged at the same place that it is offered or sold to consumers.

Therefore, if schools provide pupils with food that caterers pre-pack on-site, this will need to comply with all the necessary regulations.
It applies to food that people can select for themselves or that which is offered from behind a counter.

PPDS doesn’t apply to:

• Food that is not in packaging or is packaged after the consumer orders it
• Food packed by one business and supplied to another – this must already have full labelling, including full ingredients with any allergens emphasised.

How can schools prepare for Natasha's Law? 

The Food Standards Agency has urged all food vendors to prepare themselves by making any necessary changes sooner rather than later.

For schools, the new labelling requirements will apply to all food they make on-site and package, such as sandwiches, wraps, salads, and cakes. It applies to food offered at mealtimes and as break-time snacks. And, as mentioned earlier, it will apply to food the pupils select themselves or that caterers keep behind the counter.

The implication with any law is that people should comply with it once it is announced, even if it has not yet reached its mandatory date for implementation.

Therefore, schools should be acting now, working alongside caterers, to ensure compliance and protect the welfare and wellbeing of all pupils.

Why Natasha's Law is a catering management issue? 

A key aspect of maintaining food safety standards is keeping track of your catering and using the best tools to manage it.

There are specific catering management questions that Natasha’s Law asks, such as:

• What is the impact for trusts with multiple sites?
• How will it affect the procurement and purchasing of catering services?

These questions will need to be discussed with all relevant persons responsible for managing the catering facilities within their schools.