This months Hospital Food + Service magazine features an in-depth article by our Registered Dietitian Ruth Smith on the changes in law to gluten free.
See the full article below or view online in the January / February 2017 edition here.
The change in law to NGCI
Ruth Smith is an experienced industry Dietitian who works for leading prepared meal manufacturer, Anglia Crown, and is a full member of the British Dietetic Association (BDA). Here she looks at the change in law concerning No Gluten-Containing Ingredients (NGCI) labelling, and what it means for those of us in the food industry.
Where we’ve come from
Over the years, we’ve seen guidelines and regulations brought in to help people in the food industry deal with the complexities of feeding those with gluten-free requirements. For example, the Food Information Regulations 2014 that came into force on July 14 2014, that meant local authorities could enforce the European Food Information to Consumers Regulation No 1169/2011 (FIC) to move away from using criminal proceedings to less draconian improvement notices.
Originally, the term NGCI came from EU labelling legislation brought in on January 1 2012. The regulation stated that to claim a dish was ‘Gluten Free’, it should contain less than 20 parts per million (ppm). There is one important thing to bear in mind about these new rules. Even though the labelling law has changed, gluten-free still means foods that are 20 ppm or less.
What changed and when
The new food labelling legislation for NGCI, that changed on July 20 2016, affects how wording can be used on menus and on product labelling, and has had a big effect on how food providers use the term. According to the Food Standards Agency (FSA), food businesses can no longer label individual products or dishes as NGCI, either on packaging or on menus. However, they can still use NGCI as a title on a menu, or on a list of products for sale in shops. But statements such as ‘no gluten-containing ingredients’ (NGCI), are no longer allowed.
How it’s being phased in
By 20 February 2018, we expect all food businesses will bring their menus into compliance. Where this isn’t possible, the best advice for food businesses is to discuss the most effective ways to reach compliance with their enforcement officers. Thankfully, there is a grace period up until 20 February 2018 for menus that still say NGCI next to products, but after this they can’t be used. They can still say ‘gluten-free’ if they contain less than 20ppm gluten, and can also have an NGCI menu where all products are NGCI, but they can’t use the term about an individual product or dish.
What does it mean for caterers and manufacturers?
So, how can you be sure a dish contains less than 20ppm of gluten? Rapid tests are available to manufacturers to get an instant on-site result from a product or a kitchen surface to guide them as to whether the preparation area is indeed gluten free before making a gluten free dish. Product tests can then be carried out on the final product after preparation to check that it does in fact meet the legal definition.
Caterers and manufacturers can also follow guidance from Coeliac UK who have an accreditation scheme to improve the gluten controls in kitchens and factories, which includes an annual audit to ensure necessary conditions are met.
In hospitals, regardless of whether dishes that don’t contain gluten are bought in or made on site, care also needs to be taken during the cooking and serving of these meals to ensure cross-contamination doesn’t occur by sharing temperature probes or serving utensils between dishes.
What do trade bodies like the BDA say?
The BDA Food Services Specialist Group (FSSG), are looking to the FSA and Coeliac UK to advise about the best way to implement the new rules. As far as individual companies and caterers are concerned, it’s up to them to devise the best plan for their own business and menus.
I think this new legislation will work, but there are some vital questions that need to be answered. For example, how can cross contamination be prevented? For instance, it’s been said that a product can only be truly guaranteed gluten-free if it’s been produced in a gluten-free kitchen. But how can this be managed in the confines of a hospital kitchen? And if it can’t what’s the answer? One way to do your best to produce gluten-free meals is simply to do what you always do. Use your standard food hygiene practices, and those required for compliance with the Food Information Regulations, such as supplier checks, personal hygiene, and cross contamination controls. To prevent cross-contamination you’ll need tight allergen segregation controls, careful planning as to when and where gluten-free dishes are made, and rigorous cleaning procedures. As to whether it makes life easier for those eating them, only time will tell, as there has been some confusion caused by different legislation in the past.
So, what does the future hold?
There’s no doubt that the area of gluten-free meals is not only very interesting but also extremely challenging for hospital caterers. It may be more costly for caterers if they have to buy products that are ‘gluten free’; it may mean more robust hygiene practices in place in kitchens to minimise cross contamination and comply with the gluten-free accreditation standards. At the end of the day, if it helps ensure patients requiring gluten free meals receive them, then it will really benefit this group of patients.
Now that the term NGCI can no longer be used to describe foods that don’t contain gluten ingredients, I think we’ll need to apply a pragmatic approach to hospital catering, and make sure we continually discuss all the issues we face with all relevant parties, including the Hospital Caterers Association and the BDA FSSG. Together I’m sure we’ll be able to move forward finding all the right answers.