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FSA 22-06-07 Food Hypersensitivity (FHS) – Update on Workstreams and Recommended Next Steps

FSA 22-06-07 Annex F – Research on allergen management in large chains

This document contains a high-level summary of some of the key themes and useful findings extracted from the full report.

Last updated: 7 June 2022
Last updated: 7 June 2022

Purpose of this summary 

This document contains a high-level summary of some of the key themes and useful findings extracted from the full report.  

As per the Privacy Policy for this project, the full report is not to be published.  During discussions with participants, it became clear that there was an interest in sharing some key findings that chains may find useful.  All participants have confirmed that they are happy for this extract to be shared between other participants and the FSA Board. 


The Foods Standards Agency (FSA) commissioned Ipsos MORI to explore large chain food businesses’ allergen management policies.  Large chain food businesses have been recognised as a group where good practice and innovative approaches to allergen management take place.  

This research aimed to explore how large restaurant chains in the UK cater for people with food hypersensitivity (food allergies, intolerances and coeliac disease).  This included understanding any changes or innovative approaches to allergen management that have been trialled or implemented in recent years that can inform allergen management guidance for the wider restaurant industry.  The research was designed to investigate the following questions: 

  • What approach do large chains take to allergen management and what are the reasons behind this?  
  • How do large chains present allergen information to consumers?  
  • How do large chains manage allergens in the supply chain?  
  • How do large chains train staff to deal with allergens?  
  • How do large chains ensure standards and consistency of allergy management policy across multiple operating sites?  

Ipsos MORI conducted qualitative interviews with representatives from large chain food businesses.  This allowed researchers to explore the detail and nuance of chains’ policies, procedures, challenges and any recent changes.  A total of thirteen qualitative interviews were conducted with fieldwork taking place between 15th October and 15th November 2021.  Each interview lasted up to 45 minutes and followed a discussion guide. 

Reading this summary 

Throughout this summary we have referred to the individuals who opted in to participate in our research as “interviewees”.  We have referred to the food businesses that they represent as “chains”.  

Qualitative research is designed to be exploratory and provide insight into people’s perceptions, feelings, and behaviours.  The findings are therefore not intended to be representative of the views of all large restaurant chains, but rather highlight and indicate key themes expressed by those we spoke to.  

Key themes 

Involving staff in the development of allergen policies can help to generate staff buy-in and ensure approaches are practical for use in restaurants.  Chains maintain standards through training programmes, both internal and external audits, mystery shopping, and accreditation schemes.  

Engaging customers in a conversation about their allergy is a critical part of chains’ allergen management to enable them to implement their allergen policy, for example the way foods are prepared in the kitchen.  However, approaches to doing this differ:  

  • proactively asking every customer if they have an allergy.  This is often used by chains that offer table service but relies on staff consistently asking all customers.  
  • including prompts on menus, posters and apps/online.  This places the responsibility on the customer for asking about allergens. 

Chains using counter service tended not to ask each customer about their allergies given the number of questions already being asked by staff at the till. 

Most chains do not include allergen information on their main menu as this could discourage customers from disclosing an allergy to staff.  This is because the customer may feel they have all of the allergen information they need from the menu and can therefore eat safely without discussing their allergy.  This creates significant risk, as if staff are not aware they will not know to follow the relevant allergen procedures.  This could lead to an allergen incident due to cross-contamination when preparing and serving the food.  It can also make it more difficult to keep allergy information on menus up to date if a recipe changes or ingredients need to be replaced.  

In some cases, while the menu does not specify where allergens are present, it will indicate when a product is new or where an existing product has a new recipe.  This is designed to encourage regular customers to have a conversation about their allergy with staff.  

Supply chain complexity can make it more challenging to provide full ingredient lists to consumers.  Chains described how integrated digital systems can help to manage this process.  

Recent upheavals in supply chains, the Covid-19 pandemic and the introduction of Natasha’s Law have led chains to review and update their allergen management policies.  Notably, this has accelerated a shift towards digital systems to provide allergen information to consumers without the need to handle physical documents.  Digital systems can also provide real-time updates on ingredients, meaning changes in the supply chain can be immediately communicated to all sites.  

Most chains do not manage allergen orders via third party delivery services.  Instead, they prompt online customers with allergies to place a click-and-collect order with the restaurant directly.