Posted On: April 10, 2025

Ensuring Compliance with Food Allergen Cross-Contact Prevention

According to the CDC, 33 million adults in the U.S. have a food allergy.

The consequences of allergies can be serious. More than half of U.S. adults with food allergies have experienced a severe reaction, with 200,000 people needing emergency medical care to treat exposure to a food allergen every year.

If you own or manage a restaurant, these can be scary figures. It’s likely that your business will eventually be patronized by someone with a food allergy. What is your responsibility for food allergy safety? How do you keep all your patrons safe? Continue reading to find out.

Know Your Restaurant’s Food Allergen Management Responsibilities

Until recently, there were no governing laws in the U.S. that required restaurants to do anything about food allergens in unpackaged dishes. The Food and Drug Administration (FDA) had requirements for packaged products, but restaurant sales were exempt.

Then, in 2022, the FDA updated its Food Code to include recommendations that establishments post written disclosures for unpackaged retail foods and provide food allergen training to all staff.

The FDA Food Code itself doesn’t represent a legal requirement for restaurants, but many states and local jurisdictions incorporate these model regulations into law. You should keep an eye on the legal requirements near you – especially since the Conference for Food Protection has released similar guidelines for allergen disclosure and education in restaurants.

If food allergen prevention measures aren’t already the law where you operate, they probably will be soon.

Know the Facts About Food Allergens

The first step in food allergen management is making sure you understand what exactly causes a food allergy.

Food allergies happen when someone’s immune system confuses a common protein found in a food with the mark of a dangerous invader. Their immune system attacks the invader, and the person experiences symptoms as a result of this protective response.

Food allergies can cause symptoms on the skin (like hives), gastrointestinal system (like vomiting and stomach cramps), respiratory tract (like wheezing, repetitive coughing, shortness of breath, or the inability to breathe), and cardiovascular system (like a weak pulse, shock, or circulatory collapse).

People can develop food allergies to many different things, but there are 9 major food allergens recognized by the FDA as the most common. In fact, over 90% of allergic reactions to food are caused by proteins found in:

Eggs
Milk
Soy and soybeans
Peanuts
Tree nuts (like almonds, walnuts, or pecans)
Wheat, rye, barley, and oats
Fish
Crustacean shellfish (like crab, lobster, or shrimp)
Sesame

If you learned “the big 8” allergens in the past, the new addition is sesame. It was added to the list of allergens that require disclosure by the FASTER Act of 2021.

In addition to the big 9, gluten allergies and intolerances have become a major source of controversy in recent years. While some gluten intolerances are low-stakes, others are just as life-threatening as any anaphylactic event. As a result, it’s important to take patrons’ concerns seriously.

The Role of Cross-Contact in Food Allergy Safety

Unfortunately, protecting customers with serious food allergies isn’t as simple as offering dishes without any problem ingredients.

Allergic reactions can be caused by imperceptible amounts of allergenic proteins. Many people are aware that using frying oil containing peanuts can put someone with a peanut allergy at risk. But say you dump all the peanut oil, rinse out the vat, and replace it with a non-allergenic oil. If all the components of the fryer aren’t properly decontaminated, it’s possible for any food that touches them or the oil they contain to pick up allergenic proteins.

This is true of any object or person that might touch allergenic and non-allergenic ingredients: counters, utensils, gloves, dishes, and so on. In other words, to guarantee an allergen-free dish, you’ll need to make sure that anything touching that meal during preparation is free of allergens – including your staff.

To make matters more complicated, the decontamination procedures that most restaurants think in terms of killing potential foodborne pathogens. As long as you cook dishes to a certain temperature, cross-contamination is a limited concern for entire living organisms. But allergens are proteins – much smaller and harder to eradicate. It’s not possible to “cook off” an allergen.

To achieve full allergen control, you have two options: never prepare any of the big 9 in your kitchen or have protocols of strict separation or decontamination for all three categories of food allergen cross-contact: food-to-food, person-to-food, and equipment-to-food (including all food contact surfaces).

Ideally, that means a separate prep area and separate equipment. Otherwise, you’ll need a system for very careful, very thorough washing to decontaminate anything that touches food.

In fact, you need a system for avoiding cross-contamination every step of the way: purchasing, receiving, storage, preparation, serving, and cleaning.

Allergen Control vs Compliance

The good news for restaurants is that none of the recent allergen policy recommendations require you to eliminate food allergen cross-contact. Your restaurant isn’t required to be allergy-safe at all – you’re just required to disclose allergen information.

One option is to simply warn customers that you can’t guarantee a lack of allergens in your food.

Food allergen training can run along similar lines. Staff need to be aware of how serious food allergies can be, and they need to be able to accurately set expectations for any customers who might be allergic.