Natasha’s Law

1. Since 1 October 2021, how many Pre-packed for Direct Sale (PPSD) food businesses have been inspected to ascertain compliance with food labelling laws? Specifically, in relation to the requirements introduced from Natasha’s Law?

We do not currently identify businesses as “Pre Packed for Direct Sale” (PPDS) businesses. Many food business will at times engage in activities which meet this criteria. Trading Standards Inspections are dynamic in nature and advice will be provided on a range of legislation and activities. We have identified 35 food businesses which have been provided with advice on the Pre Packed for Direct Sale requirements in the time period as a result of inspection, however there are likely to be more that engage in this activity, have been inspected, but have not required advice on the issues. Amendments to data recording codes may be implemented in future years that permit reporting.

2. Since 1 October 2021, how many PPSD food businesses within your local authority area have been found to be non-compliant with food labelling laws?

The comments regarding identification of PPDS business above apply here. 22 business which have received PPDS advice on inspection were classed as non-compliant at the time in relation to food labelling legislation. In addition other forms of work identified 31 business engaged in PPDS activities which were also non complaint in some aspect of food labelling legislation.

3 Since April 2020 until June 2022, please can you detail any support that has been provided and/or made available to local PPSD food businesses to support compliance with allergen labelling legislation?

Specific project work has been carried out relating to the control of allergens in food between April 2020 and April 2021. This work covered all aspects of allergen management including where applicable products sold as PPDS. Standard practice is to refer businesses to official FSA guidance on allergens which includes PPDS. The 2020/21 Allergens project included a range of enforcement activities including:
• * A programme of Allergens Awareness webinars conducted in September and October 2020 – hosted by Better Business for All and carried out in partnership with the Growth Hub, Devon and Plymouth Chamber of Commerce, Federation of Small Businesses, Institute of Directors, the Southwest Tourism Alliance and Visit Devon. Trading Standards and Environmental Health Officers gave presentations outlining the legislative requirements in relation to the control of allergens in order to support businesses and help achieve future compliance. 416 businesses registered attendance and 275 attended live Webinars which included PPDS specific advice and a Q&A session covering PPDS. Feedback requested further guidance on PPDS which we subsequently responded to by carrying out further webinars in 2021. The webinar was subsequently published on You Tube and the Devon, Somerset and Torbay Trading Standards Service website
• * School visits were carried out to inspect catering facilities and provide advice on the control of allergens
• * Specific allergen management advice was published on the Devon, Somerset and Torbay Trading Standards Website

The 2021/2022 Allergens project which ran from 01 April 2021 to 31st March 2022 was scheduled to take place during the pandemic and much of the planned sampling and inspection work was delayed due to FSA restrictions on conducting on site visits. The following work did take place:

• * Two PPDS webinars were carried out in July 2021 involving Trading Standards and Environmental Health Officers with approximately 200 food businesses in attendance
• * A sampling programme was conducted at approx. 52 food outlets analysing ready to eat foods for the presence of undeclared allergens. For the reasons identified above it isn’t possible to say if any of these are specifically PPDS businesses but advice on PPDS requirements would be issued as standard when carrying out follow up visits to cover any eventuality that businesses may in future opt to sell food as PPDS

From April 2022 this service has a programme of work which is published on the official Food Standards plan for 2022/23 which includes a sampling programme of 100 informal samples primarily targeting premises selling PPDS products and premises with previous failures. These samples are being analysed for undeclared allergens.

4. Since April 2020 until June 2022, can you state the number of PPSD food businesses you have provided support to in relation to compliance with allergen labelling legislation?

The comments regarding identification of PPDS business above apply here and it is not possible to state a figure. In addition to the activities above 1638 New Food Business Registrations will have received advice.

5. Please can you detail any changes to environmental health /or food enforcement activities your organisation has implemented in response to Natasha’s Law?

As detailed in question 3 virtual training in the form of online webinars were provided to food businesses specifically covering the changes to allergen laws as a result of Natasha’s Law with approximately 200 food businesses in attendance. In 2022/23 an informal sampling programme has been implemented targeting food businesses selling PPDS products and analysing for the presence of undeclared allergens. Follow up work to unsatisfactory samples on a risk based approach may include telephone advice, written advice including signposting to official FSA guidance and where appropriate a full inspection

6. How many breaches of allergen labelling compliance have you been notified of from within your Local Authority area since October 2021?

40

The above information relates to the Devon, Somerset and Torbay Trading Standards Service to April 2021 and then to the Heart of the South West Trading Standards Service. The Heart of the South West Trading Standards Service also covers Plymouth City Council’s area, but Plymouth City Council retain routine Food Standards work and therefore may be able to provide further information on activities in 2021/2.