Preventing food allergy tragedies
The tragic loss of Louis Tate, a 13-year-old boy who died in a Victorian hospital in October 2015, emphasises how important it is for health and aged care facilities to have appropriate food safety risk management strategies in place.
Louis Tate died after being admitted for overnight observation following an asthma attack. The Victorian Coroner Phillip Byrne recently found that a contributing factor to Tate’s death was anaphylaxis, believed to be from a single mouthful of breakfast he ate at the hospital. According to the inquest1, Louis had a history of asthma and allergies to cow’s milk, raw eggs, peanuts and tree nuts and suffered a reaction despite the hospital being informed by his mother of his food allergies.
To avoid exposing patients with food allergies to risk, a robust risk management strategy should be integrated into your organisation’s food safety program. In turn, this should be part of a company-wide, safety-first culture.
Know your obligations
Victoria has been a leader in food safety administration and enforcement for many years with the introduction of mandatory food safety programs for healthcare and aged-care facilities (and other food businesses) in 1999 (before the national approach).
Healthcare or aged-care organisations need to have a Hazard Analysis Critical Control Point (HACCP) based food safety program which must meet the legal requirement of Food Safety Standard 3.2.1. of the Australia New Zealand Food Standards Code, and additional requirements of state and territory food law.
The HACCP based food safety program system operating in your organisation should be a risk-based systems approach, supported with the appropriate policies and documented procedures to manage chemical, microbiological and physical risks associated with the production, processing, distribution and consumption of plated meals and other foods.
Food allergen hazards need to be identified with appropriate controls in place. This information needs to be included in the HACCP based food safety program. Every hospital and aged-care operation needs to be aware of the risks that food allergies pose to consumers and/or customers who may be consuming their product.
Having a documented food safety program that extends to ward areas does not go far enough. Healthcare and aged-care organisations must be able to demonstrate that they are complying with their food safety program and conduct a regular internal review of that program:
- at least annually or at planned intervals,
- when new equipment is purchased,
- when changes to the cooking methods or new or changed menu are introduced,
- when there are new cleaning chemicals, or
- if you outsource your food service operations to a third-party contractor.
Regular reviews will help to ensure continuing suitability, adequacy and effectiveness.
It is the responsibility of senior management to be involved in any review as it’s not about having oversight but insight into the effectiveness of the process. To transfer this responsibility to another manager is not acceptable.
When it comes to allergy management, the best way to minimise risks for patients and your organisation is to build mitigation strategies into your food safety program. Management and employee training across the organisation is critical.
Key questions to consider are:
- Who is responsible for food safety in your organisation?
- Who will check the ingredients used in menu items and note any that contain common allergens?
- What steps should food handling staff follow to avoid cross-contamination?
- How are a patient’s food allergies communicated to staff to ensure awareness?
- What training is given to staff to ensure they understand the processes required for patients with allergies?
- What is the role of the dietitian, food services manager and food safety supervisor in the identification and control of food allergens?
- How should staff members handle an allergic reaction if it occurs?
- Do you have an electronic food management system to help manage allergies and if not, what system do you have in place?
In my experience (over many years) as an industry consultant and former food regulator, where a food safety program has been implemented the processes are not fully understood by operational management and employees, or there is inconsistent understanding of the processes.
Consider the risks
When it comes to food safety, there are several common and challenging issues facing healthcare and aged-care organisations that require careful consideration. To be effective, these issues need to be reviewed in terms of capacity, capability, consistency and risk. Consider the following:
1. Is there a high level of consistency, reliability and accuracy for all food handling practices and processes across your organisation?
2. Is the role of the food safety supervisor — whose duty it is to supervise the handling of all food products, identify food safety hazards including food allergens and is involved in staff training — meeting your organisation’s needs?
3. Are all procedures and practices documented, implemented and monitored, to ensure consistency of approach and minimise risk?
4. Has your workforce been trained to identify and manage risks?
Managers need to regularly review the competence, experience, qualifications, capabilities and abilities of staff relative to the skills required by your organisation for current and future activities. Based on this review, managers should establish what training needs to be carried out and over what period.
A key requirement of Food Safety Standard 3.2.2 relates to the skills and knowledge of food handlers. Managers of healthcare and aged-care facilities are responsible for ensuring food handlers are competent in the tasks they perform.
Any training program needs to be structured, and must address commitment, accountability and implementation issues. It must include all employees who are part of the food chain process and should be part of a company-wide push to ensure a safety-first culture. Otherwise, if a team member is trained off-site and returns to a workplace where there is no change, there still exists many triggers to revert to old behaviour.
Managers need to develop appropriate training strategies to ensure success. The vast majority of hospitals and aged-care operations still focus on generic compliance approaches and this poses a significant challenge for their business.
For many facilities, it’s a ‘box ticking’ exercise — measuring the number of employees trained. This leads to compiling statistics to satisfy the regulator, but real success comes from behaviour change as a result of a training initiative, because this is aligned with strategic and/or operational goals.
Ultimately, to achieve the desired food safety improvements, managers of healthcare and aged-care organisations need to ensure they consistently produce good quality and safe food and go beyond just meeting the minimum compliance standards. Integrating all food safety related business risks into daily activities to ensure the consumer receives safe and suitable food will go a long way to protecting both the patient and your organisation.
Proactively manage risk
Ignoring risks which are associated with your business activity and its operations could negatively impact on:
- the health and safety of staff, patients and visitors,
- your organisation’s financial position, and
- your organisation’s reputation.
A proactive approach to risk management will help in:
- improving decision-making processes by ensuring the adopted strategies cover all contingencies and are hooked into appropriate mitigation actions,
- developing a tailored approach to suit your organisation and in assisting in creating value,
- developing an approach in reducing the risk of food contamination events occurring.
1. Inquest into the Death of Louis Oliver Tate (2018) Coroners Court of Victoria COR 2015 5382 (26 February 2018) (Coroner Mr Phillip Byrne), http://www.coronerscourt.vic.gov.au/home/coroners+written+findings/findings+-+538215+louis+oliver+tate
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