The LiberEat team recently sat down with Caroline Benjamine, Founder of Food Allergy Aware and co-founder of HASUK, to discuss her work in the food allergen management arena.
If you’ve missed the first part of this interview, you can read it here, and in this second and final part, we discuss topics such as her role in Food Allergy Aware and do a deeper dive into the Anaphylaxis ‘Near Miss’ Campaign.
Can you tell us how Allergy Aware and HASUK first started?
I founded Food Allergy Aware in 2013 after I started to get reactions to food, and it was really difficult and complicated for me to go out and eat. Initially, I was wondering if I should create foods and dishes for people with dietary requirements, but then I noticed that there were already lots of businesses doing quite well with those kinds of products.
Because of this, I decided to focus on Food Safety & Allergy Awareness training, and the first event I went to was in 2013, just before new food regulations such as the Food Information Regulations 2014 were brought in.
My colleague Sally Trice and I worked with the Royal Society for Public Health (RSPH) to develop the resources for their RSPH Level 2 Award in Identifying and Controlling Food Allergy Risks for those working within Food Business Operations [FBOs]. Along the way, we introduced more bespoke training courses and joined up with Highfield to offer their accredited training, in addition, we built up our consultancy leg of the business.
Following this, Jacqui McPeake and I were working together. Jaqui had her own allergen training business, JACS Ltd, and I have Food Allergy Aware, so it made sense for us to collaborate, attending events and joint marketing projects. This allowed our services to cover the whole UK, so HASUK was formed as a joint venture.
In both businesses, we have been working to create training for specific sectors, e.g. schools & hospitals, management workshops, bespoke training on request, and consultancy. We have worked with the cruise industry, pub chains, high street brands, and the NHS, and in unique situations like these, you can’t set out a plan based on a template; it was individually developed, and that takes a lot of time.
I spend a lot of time working with other colleagues, such as Sally, our Food Safety Consultant whom I met back in 2013. She’s an expert on food safety but also does a lot of food allergy-related training and consultancy. My colleagues and I can do pretty much anything within the allergen management and food safety spectrum.
You carry out forensic auditing. What does that usually entail?
If you were a Local Authority going in and doing an inspection, it would just be top level; they’ll look at your menu, look at a few items that are in your store cupboard, they’re just going to look at the very basics. They’re primarily focused on food safety and often cross-contamination while we take a much deeper look.
We ask people to send us their policies, documentation, processes, and allergen matrixes.
We’ll also go online and check out their website, and on most of our consultancy projects, we will be a mystery diner, dining anonymously prior to the audit. If there are specific processes that are supposed to be adhered to, we check against the company standards, we also give recommendations on processes to gain a higher standard.
The audit involves everything from ordering, storage, deliveries, delivery notes, and documentation; we look at how things are prepared, served and cleaned in great detail.
We take lots of pictures as a reference point, usually, when we are on-site, we are there for about two and a half hours per outlet, and we can take up to 100 pictures. On completion, we will return to base and write up the report.
Prior to our visit, we send the venue a pre-audit questionnaire to complete, and then we review their response against our visit.
When completing the report, we give feedback on what works well and what is not working. In addition to the report and the recommendations, we also create a RAG (Red Amber Green) document, which will highlight any urgent issues. If we see something on site that’s a ‘red flag’ issue, such as cross-contamination, we will report back on the day or include it in the report as appropriate to the urgency.
As part of that forensic auditing service, are you looking at specification documents and information from suppliers as well, or are you mainly focusing on what’s in-house?
Yes, the audit is more than in-house; we’ll look at the supply chain and ask to review the allergy matrix and look at their software packages which are used to create the matrices or online information.
We also review recipes and ingredients to ensure accurate information is available. We don’t necessarily need the cooking method unless high risk, e.g. Wok cookery, but we do need to understand the ingredient branding and the supply chain.
We then look at the background information for products. If we’re not happy with the information, such as if there’s incorrect or dubious information present, we’ll highlight that as an urgent issue.
What do we consider to be a ‘near miss’ in anaphylaxis incidents?
For example, Coffee shops and barista roles can be pretty high risk. Somebody may be allergic to nuts, but they’re heating soya milk on the same nozzle as the milk containing nuts, like almond milk. Somebody may order a plant-based coffee like a cappuccino, but then the staff has sprinkled hot chocolate on it, which has milk traces. These sorts of things are widespread.
What would you say the definition of anaphylaxis near miss is when thinking about the campaign specifically? We know a log is being created for anaphylaxis deaths, so what do we consider an anaphylaxis ‘near miss’ to be compared to that?
Well to give an example, I’m aware of somebody who’s reacted recently to eggs. She told her server that every step of the way, she was allergic, but unfortunately, they still served her food containing eggs. She ended up going into anaphylactic shock, had CPR, and ended up in hospital, but she survived the ordeal.
We’d consider that an incident as well, but it’s a ‘near miss’ in the sense that she’s still here with us.
So basically, it’s any incident that hasn't ended in a fatality with an anaphylactic shock involved. Do you imagine that there's a vast amount of those?
Oh, there are loads out there that aren’t being registered.
Some cases take years to go to court, and if a Local Authority is not involved and a private prosecution we may not hear anything at all
There are many similar stories like this, I know of at least two or three from this year where this sort of thing happened. If we can’t share what happened, how can learn from other people not to make the same mistake? We must ensure this isn’t repeated in another hotel, a restaurant, or a pub. We need to ask what, how, and why it went wrong and learn from these incidents.
Tell us more about the ‘Near Miss’ campaign you have spearheaded concerning the food-hypersensitive customer.
Jacqui and I were collaborating through HASUK. In the last mock trial event I ran, I presented on near-miss reporting.
The FSA picked it up at the time, and it was just after this that they did their pilot scheme for reporting that was quite interesting, but they decided not to go down the route of not continuing the project. The FSA have said they will do surveys and similar stuff but with the pilot, they were unable to capture important information or retain it and use it in a helpful way.
This encouraged us to think about what we could do. Greenwich University contacted us, as their lecturer encouraged students to work with industry for their final year project dissertations.
We worked with a hospitality student who produced the hospitality survey, whilst Jacqui and I produced a survey for Food Hypersensitive (FHS) customers. We used both surveys and held one-to-one workshops with those who completed the surveys.
We had a small number of responses from the hospitality sector. Those who did respond were positive in reporting near misses; we felt those who didn’t do so well were keeping quiet about it. The FHS customer survey had a good number of responses, and their information gave a good overview of the current situation from their point of view.
We also ran a workshop with Local authority staff, including EHOs and TSOs. An interesting point was raised by one of the EHO Officers who was vegan: she informed us that she had eaten in a vegan restaurant and had an allergic reaction. She is allergic to crustaceans. It turned out the restaurant had straws made from chitosan, which includes crustaceans. It highlights how environmental products are great, but you never know what’s in your product.
Absolutely. Most people won’t think to check the contents of a straw because straws used to be made of plastic, but now they're made of various things.
So, I think you’ve covered where the idea originated and what motivated you to lead the initiative, How did Natasha’s Law play a part in that? You'd started your business just before Natasha's law came into play, so how do you think that's changed things, How is that shaping things from your side?
We started up in 2013, and then Natasha tragically passed away shortly after; and we talked about Natasha’s Law extensively between 2019-2021.
The inquest showed us that many businesses had no processes to record near misses or customer complaints. However, following Natasha’s Inquest, there was definitely an improvement in food allergen safety standards.
Have you noticed any patterns or common triggers in 'near miss' incidents that could help design preventive strategies?
Definitely, from what I’ve seen, communication and training are absolutely essential, as well as having gateways in place to encourage staff to make checks at each step of the customer’s journey. For example, You need to ask about any allergies on arrival, on seating customers at the table, and when handing out the menus. You will ask if they want anything clarified, read the order back, talk to the chef, and ensure the dish is exempt from allergic ingredients before handing it to customers – these are just some of the checks you should have. It might seem too much, but you can never be too careful.
What does success look like for this campaign? What is the ideal outcome from your perspective?
Our aim for change is:
- For Near Miss Reporting to be part of ‘Business as Usual’ in ALL hospitality outlets
- The FSA to update the SFBB by adding a Near Miss Reporting Template, with a summary explanation and examples of Near Miss Reporting, including how to review the issue, covering how, what and why it occurred, and the corrective actions to prevent It from happening again.
- For the FSA to educate and inform Local Authorities – EHO’s & TSs on the best practice of Near Miss Reporting to be encouraged at all levels within the food service business. To ensure a consistent message and businesses are not downgraded on the FHRS when completing Near Miss forms.
- For UK Hospitality to update Catering Industry Guide to Good Hygiene Practice to include Near Miss Reporting as best practice
- For Auditing/software organisations to add near-miss reporting as a standard within their organisation for clients.
How does the ‘Near Miss’ Campaign fit with the work of the Owen’s Law Campaign?
One of the things Owen’s Law is asking for is for people to communicate positively, asking people about potential allergies every step of the way but also communicating all the information with complete ingredient information on menus, for example. The campaign is effectively giving another way to ensure these gateways are implemented. Communication is key.
Will the 'Near Miss' Campaign collaborate with medical professionals and emergency responders to enhance anaphylaxis awareness and preparedness?
Probably not, because they do a different type of training. We don’t medically train, though we would like to go into universities and do a forty-minute session to highlight what it means to have an allergy. I feel like, within the medical profession, they don’t know much about allergies unless they specialise in allergens. That said, I have been trying to introduce medical authorities to local authorities to potentially do a project on the outcomes of the Celia Marsh inquest. Watch this space!
Are there any plans to extend the campaign's reach beyond the UK, considering anaphylaxis is a global concern?
Not at this stage, as countries outside the UK – EU / Arab states manage allergens in different ways – we will, however, discuss and send across recommendations – but we do not have that reach yet.
What role can the public play in supporting the campaign's objectives and creating a safer environment for individuals with allergies?
They can report a near miss when it happens, no matter how small. We will be setting up a database to capture data from FHS customers and businesses to share issues and encourage best practices – it’s not about naming and shaming but preventative measures to avoid further fatalities. Food safety is not a competition.
What advice would you give to businesses, individuals or families affected by anaphylaxis who wish to get involved or support the campaign?
For individuals, I’d say to try and share the campaign and encourage hospitality businesses you visit to be aware of what best practice looks like and register their near misses.
For businesses, I recommend looking at the near-miss report once it’s available and reviewing their own processes based on the findings we’ve got in there. I’d consider whether near-miss reporting is carried out and consider having a no-blame culture within their business.
Thanks for talking with us, Caroline! There’s been lots of helpful advice, and we have many more exciting interviews with industry professionals planned in the future, so follow us on LinkedIn to stay updated.
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