) are responsible for over 90% of serious adverse food-induced reactions in the U.S. Products delivered with printed labels indicating allergens should raise little concern. But allergenic content could be used in the oils or other materials used in processing. Should you be concerned about processing agents like pan sprays and coatings? Are there quantities that could cause a customer to have an allergenic reaction?

Similarly, it is important to understand the risk of FALCPA nuances. Did you know highly refined oils and their derivatives produced from the 8 major allergen foods represent a labeling exemption? However, less well-refined and cold-pressed oils can contain protein and can be hazardous for individuals with food allergies.

International Regulations

The EU dictates, to ensure customers receive information on hazards, suppliers of substances and mixtures should ensure they are labeled and packaged in accordance with this regulation before placing them on the market, according to the classification derived. In fulfilling their responsibilities downstream users should be allowed to use the classification of a substance or mixture derived in accordance with this regulation by a processor in the supply chain, provided that they do not change the composition of the substance or mixture. Distributors should be allowed to use the classification of a substance or mixture derived in accordance with this regulation by a processor in the supply chain.

To ensure information on hazardous substances is available when they are included in mixtures containing at least one substance that is classified as hazardous, supplemental labeling information should be provided, where applicable. While a manufacturer, importer or downstream user of any substance or mixture should not be obliged to generate new toxicological or eco-toxicological data for the purpose of classification, he should identify all relevant information available to him on the hazards of the substance or mixture and evaluate its quality.
Major Risk Areas for Allergen Recalls

“You must understand where multiple allergen containing ingredients are stored and identified.”

The manufacturer, importer or downstream user should also take into account historical human data, such as epidemiological studies on exposed populations, accidental or occupational exposure and effect data, and clinical studies. That information should be compared with the criteria for the different hazard classes and differentiations in order for that manufacturer, importer or downstream user to arrive at a conclusion as to whether or not the substance or mixture should be classified as hazardous.

In Japan, a system of labeling for food allergies is necessary for people with allergies. However, proteins and nucleotides from allergens are not necessarily toxins. The threshold dose for the prevention of allergy reactions is often considered to be zero. However, a zero tolerance for the offending food would create enormous practical problems for the food industry. Therefore, the MHLW had to establish a threshold of food allergy labeling and develop the official detection method for specific allergenic ingredients. The MHLW organized a detection method study group and the labeling study group determined the threshold for the labeling system, that is, the definition of a trace amount. The group stated that, “If more than a few μg/mL protein or a few μg/g protein of an allergen are contained in a food, labeling of that allergen is necessary.” Therefore, we had to develop the detection methods for determining a few μg/mL protein or a few μg/g protein in foods based on the definition of a trace amount.

Label Allergens

As stated above products must have a visual label that clearly identifies the allergen present. If there is more than one allergen in the product, for example a cake base, one could have labels for flour, egg and dairy. You must understand where multiple allergen containing ingredients are stored and identified. The next topic: finished product labels. Finished product labels should clearly identify what should be in the final finished product. There should be an identification system that will tie the ingredients with the final product. This is where your product matrix comes in. Your product matrix should be designed and implemented to use no allergens at the start of the production day or week and build-in minor allergens as production moves forward. Single allergens should be added each time a new product is placed into the system. For example, processing a product with only one allergen like flour in the beginning and then add allergens later. Moving to a more complex product, it would have egg and flour, then progressively to egg flour and dairy. And finally, egg, flour, dairy and nuts. Operations staff should be able to clearly identify the allergens that they need at a particular time in production using recipes or formulas that call for allergens at particular points in the process. Finally, any identifier that is used to label the final finished product must have the eight major allergens clearly identified, not only in the ingredients statement, but shown separately as allergens below the ingredient list.
G. Proper Sanitation

Equipment design has a major influence on its cleanability. Hygienic design principles such as smooth surface and absence of crevices and dead spaces should be taken into account when designing equipment. All processing equipment should have an approval from a regulator body or third party that is charged with the investigation and evaluation for its use and its ability to properly be cleaned and sanitized (e.g., National Sanitation Foundation, Underwriter Laboratories, The Baking Industry Sanitation Standards Committee).

Equipment should limit tight corners with less than a quarter of an inch radius, areas that cannot be easily accessed by removing a door or panel, dead ends and openings into any vessel where caps or seals cannot be removed. Just as important as the design of the equipment, is the material that goes into the equipment manufacturing. Soft metals, soft plastic should not be used under any circumstance where materials will accumulate. Stainless steel that is grade “304SS” or above is the preferred metal of choice. Use of lower grades of stainless steel will hamper the ability to clean and maintain smooth interior surfaces of equipment.

Cleaning Methods

In addition to a strong understanding of equipment design, a thorough knowledge of different cleaning processes is important. If you deal with only dry ingredients there is a higher likelihood that we will use dry cleaning methods such as compressed air, dustless sweeping or similar equipment. If the product has a wet component, chances are we will need to introduce a detergent with some form of agitation, followed by a rinse and chemical sanitizing step. We must also evaluate the tools that are used for their potential to accumulate and transfer allergens as part of the sanitization. Any cloth that will be used to wipe down equipment should be collected and laundered prior to being used again. Any scrappers or scalpers should not be made of materials harder than the equipment itself (i.e. not above “304SS”). Any brushes used to scrub interior food contact surfaces should be able to be easily cleaned, sanitized and air dried. They should also be color coded for allergens and stored so they will not contaminate or cross-contaminate any clothes, tools or brushes.

“We must also evaluate the tools that are used for their potential to accumulate and transfer allergens as part of the sanitization.”
When it comes to food allergens, what you don't know could hurt you - as a customer and as a business owner. Up to 15 million Americans have food allergies, including one in every 13 children under the age of 18. Ensuring that a large number of potential customers can safely consume your food is a vital business practice.

Allergens affect people in various ways. Allergens are substances, usually protein in nature, that illicit a reaction that is generically termed an allergic reaction. Allergens do not have to be proteins; they can be chemical, such as sodium bisulfate or MSG (monosodium glutamate) and in non-food settings, they can be dust. Food allergens are an improper reaction of someone's immune system that most of the population tolerates without any problems. For those who are sensitive to an allergen, consuming one of the over 170 foods that contain allergens could result in symptoms that range from minor tingling all the way to death. Consumers with known allergies diligently select the food they consume to ensure they do not trigger a potential allergic reaction. Therefore, food processors that are distributing or serving foods that may cause an allergic reaction have great responsibility. As a food processor, staying current on allergens and understanding how to protect your end consumers is paramount.

Food processors must be aware of newly emerging allergenic foods and be cognizant of geography - specific rules. While food processors in the United States should familiarize themselves with all allergens, it is of utmost importance to focus controls on the top eight foods containing allergies which are found in fish, eggs, soy, peanuts, tree nuts, wheat, crustacean shellfish, and milk. The European Union has a more comprehensive list of allergens that include the following foods and products thereof: gluten, (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridized strains), crustaceans, eggs, fish, peanuts, soybeans, milk, nuts (i.e., almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts and Queensland nuts), celery, mustard, sesame seeds, sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/liter expressed as SO2, lupin, and molluscan. In the Asian markets, Japan's declared allergens are eggs, milk and dairy products, wheat, buckwheat, shrimp/prawn, peanuts, salmon roe, soybean, kiwi, banana, crab, chicken, tree nuts, squid, mackerel, pork, salmon, gelatin yam and peach. As a processor you may be working with any number of these foods.

### Major Risk Areas for Allergen Recalls

**Inspection**

As with any good sanitization program, adequate time needs to be given to the inspection of equipment to verify all ingredients and materials have been properly removed. Without knowing the exact amount of an allergen which


 are in favor of QR codes for ordering and paying.

The carefree guest: This diner persona is eager to dine out in restaurants and less concerned about risks and restrictions. While 29% are comfortable sitting indoors at a restaurant, many more (42%) are limiting visits to outdoor venues. Familiar restaurants are more likely to be on their list—37% are more comfortable dining at places they’ve been to before, but 25% would visit a new restaurant. Bars are not a priority; only 15% of consumers would patronize a drinking establishment.

“As local economies across the country continue to reopen, restaurant operators are navigating the right balance between safety and traditional models for hospitality,” said Joel Montaniel, CEO and co-founder of SevenRooms. “Our research has made one thing clear: Operators need to be flexible. Whether it’s in regard to outdoor dining, virtual waitlists or contactless order and pay—guest have different needs.”

YouGov PLC conducted the survey with 1,237 Americans from July 31-Aug. 3. The four diner personas are identified in the company’s new report, “Restaurant Reckoning: Dynamic Diner.”

MARK YOUR CALENDAR & PACK YOUR BAGS?

September 21-25, 2020
United Fresh Washington Conference
Online Event
To learn more, visit:
www.unitedfresh.org/events

February 25-27, 2021
SEPC’s Southern Exposure
Swan & Dolphin Resorts
Lake Buena Vista, FL
www.seproducecouncil.com/events

CREATED BY LIPMAN FOR OUR VALUED CUSTOMERS

Learn more about us @
www.lipmanfamilyfarms.com
www.suntasticfresh.com

Follow us on social media

Questions or comments about the newsletter?
Contact: joanna.hazel@lipmanfamilyfarms.com
BUTTER

Butter continued to bounce this past week, going up early, down in the middle then up again on Friday to close up .0300 at 1.5150.

- Retail sales are the one thing keeping the butter market from falling. Food service demand did kick in a bit in May and June as many places opened to 50% seating, but with many places pulling back to 25% or going back to take out or delivery only, demand has slowed again.

- So many weddings have been put off until 2021 in hopes of having a “normal” ceremony. Graduation parties were non-existent, and other parties were cancelled or held at home with much smaller guest lists. This also held down butter demand.

- Domestic spot butter pricing is just a couple of pennies higher than the GDT, which is checking in this past Tuesday’s trading session at 1.4900 per lb.

- The extended heat wave has certainly helped retail sales of ice cream, but sales at places like Dairy Queen and other ice cream stands have been slower in many parts of the country due to people not wanting to stand in the heat and wear a mask.

- The USDA box program for stage 3 has not yet been awarded. We will see how much butter is used in these boxes. While butter is a good item to fill these boxes, the item to fill them with would be retail quarters and they are in short supply.

CHEESE

Block and barrel both lost .1700 this past week to close at 1.6500 and 1.3300, respectively.

- Domestic cheddar is now about .0900 high to the GDT price, although a weaker dollar could see some export opportunities start to present themselves.

- The block/barrel spread held steady this week. It is currently at .3300 for the 2nd week in a row.

- It appears that the pipeline may be full although it appears that what we may be seeing is buyers holding off as markets dropped and only buying sporadically because they do not want to get caught with perishable product if everything shuts down again.

- We could also see a reaction to schools starting virtually in large parts of the country which means milk demand usually picked up by school feeding programs will not be as robust at least early in the school year. Some of this will be picked up at retail as kids drink more milk at home but not all of it so it is likely some of the excess milk could end up in the cheese vats.

- Trading was down on the CME with a total of 37 loads traded. There were 9 loads of block and 28 loads of barrel traded.
BEEF COMMENTARY
The market moved from a firmer bias to more of a steadier feel as the week progressed. Last minute holiday buying appeared to largely wrap by mid-week as most orders should be placed and getting ready to ship to ensure proper delivery time. Holiday loin items and rib items have been in higher demand as they are typically enjoyed on the Labor Day holiday. This year is a bit different as many consumers are opting for dine at home rather than the option of dining out, due to the many closures of restaurant businesses that are affected by the pandemic still. Retailers and wholesale stores stepped in to gather additional inventories this year to cover potential ads and to cover additional demand. Interest has been most notable at the retail and wholesale level due to the lack of foodservice business, as many resorts and businesses have continued to be affected by the pandemic. Features remain thin for the upcoming weekend as many retailers have continued to see adequate business without additional featured items.

GROUND BEEF:
Overall, grinds have made a considerable improvement increasing a hefty .40 per lb. going into the Labor Day holiday. We can expect at least another .05 to .10 cent increase before leveling off. They will still be a good value moving forward thru November.

MARKET OUTFRONT:
The bottom line is this— Grinds will be up .08 -.10 cents again for next week. The round and chuck cuts will be up .10 to .15 cents per lb. The market on strips will be up higher up .15-.20 cents per lb. Tenders and rib eyes will be up .25 cents per lb. Thin meats and flap meat will be up .10 to .20 cents per lb. The increases will stop after this week. The market out front will start to fall back down to early August levels by the end of September.

HAVE A GREAT WEEK!
As California continues to see a plethora of challenges that has plagued the Central Valley for the last few weeks from California fires that are currently getting under control in Monterey Co as well as San Joaquin Valley, we are now left with bad air quality. We are being advised to not work outdoors as the air quality isn’t good by current health departments. With 100+ temperatures for the next 2 weeks and unhealthy air quality and COVID regulations that continue to keep people at home, our labor force is really taking a big hit. With the Stone fruit, Citrus and Grape harvest all currently in progress, we are running into a massive labor shortage. The fruit is out there, we just can’t harvest it quick enough. Finding labor has created a bidding war with harvest crews causing labor pricing to skyrocket. This is leading to higher FOBs as their bottom line continues to rise, and fruit is remains limited.

**RED SEEDLESS**

Of all table grape varieties, California red seedless movement has been the strongest through the month of August. Growers and shippers are harvesting excellent volumes of Scarlet Royal, Krissy and Magenta. We’ve seen some heat damage on moderate blocks of fruit, which marketers are pushing through the system at a discount. On good quality fruit, shippers have managed to hold the floor at profitable levels. Pricing on good quality red seedless currently. We should continue to see excellent promotional opportunities on California red seedless through September.

**GREEN SEEDLESS**

The industry continues to harvest green seedless varieties and cold storages are full, with marketers pushing hard to get caught up. Even after the heatwave, overall quality and condition seems to be fine, but we are seeing some problems related to mildew. Certain proprietary varieties that were supposed to come online in October, are now almost 3 weeks ahead of schedule putting more pressure on the market. With so many varieties now available, it’s not unexpected to see such a wide range of FOB’s from grower to grower.
BLACK SEEDLESS

California black seedless movement continues to underperform, even with some promotional activity in weekly circulars. Overall quality and condition have been very good on all black seedless varieties this season. We can expect to see FOB’s unchanged through the balance of the month since overall acreage of black seedless has been significantly reduced.

CALIFORNIA VALENCIAS

We are approaching the end of the Valencia Season and we are now expecting to see a gap as growers’ transition to Navels through mid to late October. Valencia inventory is down, and we are losing volume every day, we cannot build inventory. The Valencia market is remaining red hot and quality is decent to good. We are trying to harvest as many 88/113/138 for food service program orders, but we are still very short on small fruit. USDA programs are also taking a majority of the Valencia’s and the business towards covering other orders. We should be getting spot loading inventory on 88s and larger, but still very limited. Please run any bagging or bin inquiries by us for Valencia orders, please leave a 2-3-day window as we are selling out EVERYDAY. Bag and bin fruit is drying up very fast as prices continue to increase due to supply and labor shortages.

LEMONS

Inventory is down across domestic lemons! The California lemon market is going up as the domestic le


 sales plummeted as a result of COVID, many restaurant brands scrambled to implement curbside pickup. Not surprisingly, these quick-fix curbside solutions consist of rudimentary elements such as a minimal signage package, a few designated parking spaces and a restaurant employee to hand deliver the customer orders curbside. While these initial solutions are contactless and convenient, they deliver a generic, non-memorable customer experience.

Curbside 2.0
There is a significant curbside business-building opportunity as we continue on with the "new normal" created by COVID. Specifically, this opportunity involves advancing curbside from a generic experience to an ownable, branded and memorable customer experience. Innovative solutions are needed. Here are just a few examples to consider:
- Design a curbside customer experience that looks and feels like no other
- Create a prominent welcome and pickup zone that makes your curbside experience unique
- Observe and understand how customers use curbside, and make continuous improvements that create a dazzling customer experience
- Consider a specially designed area where your customers can "drive inside" (the curbside corral)
- Reduce perceived wait time and improve the customer experience by providing engaging merchandising and communications. Give waiting customers something to read, do and enjoy.
- Create innovative packaging, both structure and graphics, that is designed specifically for your menu and curbside experience
- Brand your curbside experience. By doing so customers will easily be able to differentiate and remember you're your brand's curbside experience and benefits

Think in terms of curbside innovations. Not just curbside improvements. Improvements include things like better wayfinding, improved parking, easier-to-use mobile apps. Improvements result in a better version of curbside than what competitors are doing. And they are worthy initiatives. But innovation is about creating something entirely new—an idea, service or feature that has never been implemented before. The need for it may never have been expressed by customers. But they are a game-changer. Think of Apple's introduction of the smartphone. That's innovation.

Meaningful Benefits
For restaurant customers, curbside provides contactless pickup, which is "the new gold standard," greater convenience than takeout and no delivery fees.

For restaurant brands and operators, the benefits of curbside are immediate and direct:
- More profitable sales than delivery
- A cost-effective investment and solution to increase sales
- A superior service delivery method that will drive incremental traffic
- The time to develop and implement is shorter than many other business building initiatives

Keep in mind, the curbside restaurant winners of tomorrow will take the lead to develop a proprietary and memorable branded curbside experience.

TRANSPORTATION FACTS
* The average US diesel fuel price rose slightly this week, moving from $2.43 to $2.44 per gallon.
* The average price for a gallon of diesel is $5.44 lower than the same time last year.
* All areas reported price increases with the most significant coming from the Midwest (up $.02).
* As usual, California has the highest price at $3.28 per gallon, while the Gulf Coast remains the low-price leader at $2.10 per gallon.
* The WTI Crude Oil price has fallen 3.0% over the past two weeks, moving from $42.93 to $41.37 per barrel.
* Trucks are coming up short in VA, IL, and WA this week. As vegetable production begins to transition, we're also seeing some slight shortages at Mexico/Texas crossing points, NC, and MI. CA shipping districts still have adequate trucking options available to move their products.
NEWS IN THE GROCERY TRADE

Survey: Most Grocery Shoppers Favor In-Store Purchases Amid Pandemic
By: Russell Redman, www.supermarketnews.com, August 26, 2020

Despite concerns about COVID-19, nearly two-thirds of U.S. grocery shoppers still prefer to make purchases in physical stores, according to a survey by business news website The Manifest. Of 501 U.S. adults polled in late July, 62% said they have favored buying groceries in person at the store over the past three months. At the same time, however, nearly one-quarter of respondents (22%) said they used contactless services such as online grocery delivery and pickup.

People continue to shop in grocery stores, but they limit how frequently they shop each month by stocking up on more items at one time,” The Manifest said in its research report. Indeed, the study found that consumers are spending more on groceries during the pandemic. Though 47% said their grocery spending hasn’t changed, 36% reported shelling out more money for food shopping. Only 15% indicated a decline in grocery spending.

"With limited restaurant and eating options, people’s spending habits on food have changed. More than one-third of people say their average grocery bill has increased during the pandemic,” according to The Manifest. “About one-quarter of people (23%) say their grocery bill has increased by more than $50, while 15% say it has increased by less than $50.”

Among those using online grocery services, delivery holds a slight edge. Twelve percent of consumers surveyed said they use grocery delivery versus 10% using pickup. On the delivery side, that percentage represents a more than tripling of the share of U.S. grocery shoppers using that service.

"While only 12% of people have used grocery delivery services during the pandemic, this change still indicates a significant uptick in the popularity of grocery delivery services," The Manifest noted.

With many people seeking safer ways to buy groceries, they’re also recognizing the convenience offered by online services. More than half (52%) of survey respondents cited time savings as the main draw of grocery delivery, followed by safety (11%), no parking or fuel expenses (10%), personalized order history (7%), bulk ordering (4%) and online discounts (4%).

"As people switch to using grocery delivery services, they consider the benefits: an on-demand service versus traveling to a grocery store," The Manifest explained. “Saving time can be a major asset to a busy consumer. Ordering groceries online allows people to search for items quickly, select the type of food they want and order it to their home at a time that works best for them. Using the past-order history button can also make reordering groceries easier than scanning the aisles for individual items.”

Still, as more people have used online grocery services, they’ve encountered some pitfalls, such as added expense from delivery and service fees, unacceptable produce and inconvenient delivery/pickup times. Twenty-two percent of grocery shoppers polled by The Manifest named fees as the top challenge in online grocery, followed by produce quality (17%), drop-off times (11%), customer service issues (10%), waste (9%) and data security (5%).

“The majority of people still shop in physical stores to buy groceries, which indicates that delivery services have room to improve, such as with fees and produce quality,” The Manifest said in its report. “Grocery delivery services still have a long way to go in terms of customer experience. People say fees are too high and the produce selected is not always ideal,” The Manifest’s study concluded. But the report added that the grocery e-commerce channel continues to build a sizable consumer following. “With large numbers of people trying out grocery delivery services for the first time and liking them, supermarkets may need to prepare for long-term competition.”

*Note: This article has been edited for space and content. To view the entire selection, please visit www.supermarketnews.com
RESTAURANT INDUSTRY NEWS
4 Diner Personas Reveal What Motivates Restaurant Customers in the Age of COVID
By: Patricia Cobe, www.restaurantbusinessonline.com, August 28, 2020

After several months of quarantine, many consumers embraced the return of restaurant dining. But others are still wary, venturing out only to pick up a meal curbside or have dinner delivered to eat at home.

Meanwhile, restaurants are scrambling to enforce health and safety protocols, juggle takeout and delivery with dine-in service, set up outdoor seating and create menus that cover all these scenarios.

The good news is that 38% of consumers are looking forward to dining out again in the next three months, according to a new survey conducted by YouGov and commissioned by SevenRooms, a data-driven guest experience platform. But every potential customer has different needs and expectations.

To make it less challenging for operators to navigate the new dining landscape, SevenRooms grouped these needs into four “diner personas” based on the survey results.

The pickup patron: These consumers won’t be ready to dine out until there’s a vaccine. Nearly 1 in 4 (23%) will only order for takeout or delivery for the remainder of 2020. Restaurants seem to be doing a good job with these platforms—about half of all Americans continue to feel comfortable ordering food to go.

The safety-savvy consumer: It’s no surprise that customers want to see restaurants following health and safety guidelines. Face masks and 6-foot social distancing are given, but this group of guests is looking for more. Over one-third of respondents (37%) want physical barriers between tables, 33% want personal hand sanitizers placed on the table and 24% want their food covered when it’s served to them.

The tech-conscious contactless diner: About 1 in 7 consumers (13%) will only visit restaurants that offer a contactless dining experience. Topping the list are virtual waitlists, with 22% of respondents saying they want to join a waitlist before they arrive so they can be seated immediately. Around the same number (21%) want operators to use contact tracing technology, and 17%


 packaged and exposed meat and products, unless stored at different times or in such a way that the packaging material and the manner of storage cannot be a source of contamination for the meat or products.

A3. have rooms equipped to ensure compliance with the temperature requirements laid down in Chapter III.

A4. have equipment for washing hands used by staff handling exposed meat and products with taps designed to prevent the spread of contamination.

A5. have facilities for disinfecting tools with hot water supplied at not less than 82 °C, or an alternative system having an equivalent effect.

A1. to A5. Compliance regarding design and layout

• Comply with the requirements for production establishments.

A1. to A5. Good practice

The requirements for establishments producing minced meat, meat preparations, and MSM are the same as for cutting plants. See chapter 14 on ‘Cutting of meat’ section A (structural requirements) particularly A2, A3, A6, A9, A10.

1 See chapter 2 on ‘Design and facilities’ structural requirements for all establishments.
A6. Compliance regarding temperature control facilities

- Provide temperature controlled handling and storage conditions of sufficient capacity, and designed to allow temperatures to be monitored and if necessary recorded.

A6. Good practice

Take into account the need to comply with the temperature requirements for meat, provide sufficient refrigerated capacity at every stage of production, storage and transport and the means of monitoring temperatures to be sure that chilling is adequate and that the cold chain is being maintained.

See chapter 10 on ‘Temperature controls’, and chapters 3 on ‘Water supply’, 4 on ‘Maintenance’, 5 on ‘Cleaning’ and 6 on ‘Pest control’ for the hygiene prerequisites for all establishments.

A7. Compliance regarding personal hygiene

- Make sure that every person working in a food-handling area maintains a high degree of personal cleanliness.

A7. Good practice

All staff, as well as managers, officials and visitors, need to comply with the company’s personal hygiene procedures, particularly hand washing and wearing of protective clothing.

See chapter 8 on ‘Personal hygiene’.
Legal requirement

852/2004 Annex II Training: Chapter XII points 1 and 2

Food business operators are to ensure:

A8. That food handlers are supervised and instructed and / or trained in food hygiene matters commensurate with their work activity.

A9. That those responsible for the development and maintenance of the required procedures based on HACCP principles, or for the operation of relevant guides, have received adequate training in the application of the HACCP principles.

A7. to A8. Compliance regarding training, instruction and supervision

Make sure that:

- food handlers are instructed and / or trained in food hygiene matters commensurate with their work activity

- staff responsible for the development and maintenance of the required procedures based on HACCP principles, or for the operation of relevant guides, have received adequate training in the application of the HACCP principles

A7. to A8. Good practice

Instruct all food handlers, including temporary staff and those who inspect raw materials, in hygienic processing skills, about the food safety hazards associated with raw meat, awareness of food safety principles especially the need for temperature controls and personal hygiene, the need to follow instructions and to report failing controls promptly.

Supervise staff as appropriate. Issue reminders if lapses occur. Keep accurate, dated individual training records to show what instruction / training has been given.

HACCP training – make sure that at least one person in the business has sufficient training in the application of HACCP principles to develop and maintain HACCP-based procedures or to follow guides to control the food safety hazards in the business. See chapter 9 on ‘HACCP Principles’ section A. and chapter 7 on ‘Training’.
B. Raw materials and general processing

**Legal requirement**

852/2004 Article 5 point 1

B1. Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles.

**B1. Compliance regarding HACCP-based procedures**

- Implement and maintain a permanent procedure or procedures based on the HACCP principles.

**B1. Good practice**

HACCP-based procedures are necessary to ensure that food safety hazards, including microbiological cross-contamination during processing and growth of bacteria through inadequate temperature control, is minimised. This is done by setting and applying operational limits and procedures for processing and maintenance of the cold chain (for example, during storage and transport) and, where appropriate, freezing, thawing, and thermal processing.

Set out in the HACCP plan, the procedures for controlling hazards, the limits that are to be monitored, the checks to be carried out, the corrective actions to be taken to ensure the safety of the meat and the records to be kept of those checks and actions.

See chapter 9 on ‘HACCP Principles’.

**Microbiological testing** – can help validate / verify the effectiveness of HACCP-based procedures. Food safety criteria have also been set for certain products – see chapter 13 on ‘Microbiological criteria’.
Legal requirement

**852/2004 Annex II Foodstuffs: Chapter IX points 1, 2, 5, 8**

**B2.** An FBO is not to accept raw materials or ingredients, other than live animals, or any other material used in processing products, if they are known to be, or might reasonably be expected to be, contaminated with parasites, pathogenic micro-organisms or toxic, decomposed or foreign substances to such an extent that, even after the FBO had hygienically applied normal sorting and/or preparatory or processing procedures, the final product would be unfit for human consumption.

**B3.** Raw materials and all ingredients stored in a food business are to be kept in appropriate conditions designed to prevent harmful deterioration and protect them from contamination.

**B4.** Raw materials, ingredients, intermediate products and finished products likely to support the reproduction of pathogenic micro-organisms or the formation of toxins are not to be kept at temperatures that might result in a risk to health.

Food businesses manufacturing, handling and wrapping processed foodstuffs are to have suitable rooms, large enough for the separate storage of raw materials from processed material and sufficient separate refrigerated storage.

**B5.** Hazardous and/or inedible substances, including animal feed, are to be adequately labelled and stored in separate and secure containers.

**B2. to B5. Compliance regarding receiving raw materials for processing**

- Do not accept raw materials if they are known, or reasonably expected, to be contaminated with parasites, pathogenic micro-organisms or toxic, decomposed or foreign substances to such an extent that, even after the hygienic application of normal sorting and/or processing, the final product would be unfit for human consumption.

- Arrange for:
  - the sorting of incoming raw materials including meat
  - suitable rooms, large enough for the separate storage of raw materials from processed material
  - sufficient separate refrigerated storage
  - separate storage of exposed meat from packaged meat and packaging
  - adequate storage for inedible and hazardous materials in labelled, separate and secure containers

- Keep food premises clean and maintained in good condition, in compliance with 852/2004 Annex 1 Chapter I point 1.

- Maintain suitable ventilation as per 852/2004 Annex 1 Chapter I point 5.

- Put adequate procedures in place to control pests, in compliance with 852/2004 Annex II Chapter IX point 4.
B2. to B5. Good practice

**Deliveries** – make adequate arrangements to accept deliveries of meat and other non-meat raw materials. Meat should be kept under temperature control – see ‘Refrigerated storage’ below.

**Sorting** – inspect and sort raw materials on arrival to make sure that:
- meat and other products of animal origin are sourced from approved establishments – see ‘B6. to B9.’
- all products of animal origin are correctly identified, for example, health / id marked meat – see ‘B6. to B9.’
- they meet temperature requirements
- they are not contaminated by, for example, foreign bodies parasites, pests; and
- they meet company quality specifications and have any required documentation

**Action** – take action if your company’s food safety and quality standards are not met. Depending on the problem, action may include:
- holding, for example, to await documentation
- treatment, for example, trimming otherwise fit meat of visible contamination
- divert to production of heat treated product
- disposal
- a return to the originating premises - but note that where the meat received is not fit for human consumption then it must be handled as an animal by-product; it cannot be returned to the supplier unless they are authorised to receive animal by-product

**Sampling** – if incoming raw materials are sampled for laboratory testing, and a positive release system is in place, these raw materials will need to be held until the results become available. In all cases, robust arrangements are needed so that test results can be matched to sampled products.

**Batch identification** – preserve the identity of incoming batches for stock control and traceability purposes.

**Stock rotation** – it is advisable to rotate stock to use the oldest first (FIFO – first in, first out).

**Storage** – areas and containers for storing meat and non-meat food stuffs need to be cleanable and be kept clean, well maintained and adequately ventilated so as to keep the raw materials in good condition and to minimise the risk of contamination, for example from pests. Include storage areas in company maintenance, cleaning and pest control arrangements.

**Refrigerated storage** – the hygiene regulations set maximum temperature requirements for meat – see relevant sections below


 system or in the potties of the market portable restrooms. Not in the grass, on the ground or pavement or in the
   storm drains.
4. The hand washing water container can be used to wash produce for sampling.

“CLEANING, RINSING AND SANITIZING” STATION:
1. All cutting boards and non disposable utensils used for sampling must be able to lie flat and or totally submerged
   in the wash and sanitizing basins. After cleaning, rinsing and sanitizing allow cutting boards and utensils to air dry.
2. A sanitizing solution is 1 teaspoon of household bleach per gallon of water. Allow submerged items to remain in
   solution for 30 seconds. Rinse and air dry. Sanitizing is a process that kills disease-causing bacteria.
3. Produce intended for sampling must be washed with potable water to remove any soil material in order that it is
   wholesome and safe for consumption. Cantaloupe, watermelons and other melons should be cleaned in a very
   mild bleach and water solution.
4. Both the “Hand Washing” and the “Cleaning, Rinsing and Sanitizing” stations must be set up before samples can
   be distributed.
Essential required items for proper sampling: disposable single use utensils, covered sampling container, a knife and cutting board, disposable latex or plastic gloves, tongs and waste basket w/liner.

Vendor should provide containers with hinged covers to prevent food contamination from customer by touching samples.

Marin County EHS approves of the method pictured above. The customer can obtain a sample with the toothpicks next to the covered container.

In this example the vendor gives out a sample using tongs.

This method provides the best way to keep the sample from being contaminated.

The vendor is in complete control of his sampling process and this method is highly recommended by the Marin and Alameda County EHS.
Here is an other example of how to protect your samples. Notice the samples have tooth picks already so customer does not have to touch the sample. The cake cover acts as a sneeze protector.

If you are sampling nuts of any kind, you must use a nut-shaker similar to the ones pictured above.
Examples of Sneeze Protected Samples<|endoftext|>Food Allergens: A Comprehensive Approach For Food Processors To Prevent Unintended Allergens In Their Foodstuffs

- Dairy
- Egg
- Crustacean Shellfish
- Fish
- Tree Nuts
- Wheat
- Peanuts
- Soybeans

A Food Safety Guide for Food Processors

EHA
Contents

Chapter 1: Introduction p.3

Chapter 2: Allergens and Food Processors p.4

Chapter 3: Food Processors’ Allergen Challenges p.5

Chapter 4: Major Risk Areas for Allergen Recalls p.6

Part 1. Controls

A. Product Intake Handling
B. Allergen Identification
C. Storage
D. Cross-Contamination
E. Product Matrix
F. Labeling
   i. US Government Regulations
   ii. International Regulations
   iii. Label Allergens
G. Proper Sanitation
   i. Cleaning Methods
   ii. Inspection
H. Testing Allergens
   i. Actions That Have To Be Taken

Part 2. Employee Training

Chapter 5: Moving Forward p.16

Part 1. Processor
Part 2. Customers

Chapter 6: How EHA Consulting Group, Inc. Can Help p.17

About EHA Consulting Group Inc.

EHA Consulting Group, Inc. (EHA) offers comprehensive public health consulting, epidemiology and food safety services before, during and after a crisis. We provide these services to Retail Food, Food Service, Food Processing, and Contract Food Service Management companies.

Need our Services? Call us today at 800-969-1441.

Visit us at www.ehagroup.com. Follow us on Twitter @EHAConsultingGp.
Introduction

“The proper control of food allergens in a food processing plant presents numerous challenges. The ubiquitous presence of allergens in the human food supply, coupled with increased awareness of food allergies, warrants undertaking appropriate preventive measures to protect sensitive consumers from unwanted exposure to offending food allergens. Food processors must have an allergen prevention plan to determine potential sources of contaminating allergens and create appropriate controls to prevent allergen introduction into food products.”

The proper control of food allergens in a food processing plant presents numerous challenges. The ubiquitous presence of allergens in the human food supply, coupled with increased awareness of food allergies, warrants undertaking appropriate preventive measures to protect sensitive consumers from unwanted exposure to offending food allergens. Food processors must have an allergen prevention plan to determine potential sources of contaminating allergens and create appropriate controls to prevent allergen introduction into food products.

The following guide from EHA Consulting Group, Inc. (EHA) contains information, best practices, and tools for a food processing company to avoid allergen-related recalls. Key factors in allergen control include poor identification, poor handling, poor storage, improper product matrix, improper labeling, poor sanitization, and inadequate testing. The purpose of this guide is to educate you and your staff on the proper steps to protect your brand and your business from the negative ramifications of an allergens incident and potential recall.
Allergens and Food Processors

“Up to 15 million Americans have food allergies, 1 in every 13 children under the age of 18.”

When it comes to food allergens, what you don’t know could hurt you - as a customer and as a business owner. Up to 15 million Americans have food allergies, including one in every 13 children under the age of 18. Ensuring that a large number of potential customers can safely consume your food is a vital business practice.

Allergens affect people in various ways. Allergens are substances, usually protein in nature, that illicits a reaction that is generically termed an allergic reaction. Allergens do not have to be proteins; they can be chemical, such as sodium bisulfite or MSG (monosodium glutamate) and in non-food settings, they can be dust. Food allergens are an improper reaction of someone’s immune system that most of the population tolerates without any problems. For those who are sensitive to an allergen, consuming one of the over 170 foods that contain allergens could result in symptoms that range from minor tingling all the way to death. Consumers with known allergies diligently select the food they consume to ensure they do not trigger a potential allergic reaction. Therefore, food processors that are distributing or serving foods that may cause an allergic reaction have great responsibility. As a food processor, staying current on allergens and understanding how to protect your end consumers is paramount.

Food processors must be aware of newly emerging allergenic foods and be cognizant of geography-specific rules. While food processors in the United States should familiarize themselves with all allergens, it is of utmost importance to focus controls on the top eight foods containing allergies which are found in fish, eggs, soy, peanuts, tree nuts, wheat, crustacean shellfish, and milk. The European Union has a more comprehensive list of allergens that include the following foods and products thereof: gluten, (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridized strains), crustaceans, eggs, fish, peanuts, soybeans, milk, nuts (i.e., almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts and Queensland nuts), celery, mustard, sesame seeds, sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/liter expressed as SO2, lupin, and molluscan. In the Asian markets, Japan’s declared allergens are eggs, milk and dairy products, wheat, buckwheat, shrimp/prawn, peanuts, salmon roe, soybean, kiwi, banana, crab, chicken, tree nuts, squid, mackerel, pork, salmon, gelatin yam and peach. As a processor you may be working with any number of these foods.
Food Processors’ Allergen Challenges

“Undeclared allergens were the single largest cause of recalls from the USDA in the second quarter of 2013.”

As a processor, you are charged with great responsibility to ensure that allergens are handled safely. Teams responsible for intake, storage, transfer, processing, labeling, cleaning and testing all have important roles in preventing allergens. Teamwork, communication, and strong control processes are paramount.

Unfortunately, food processors are currently experiencing more challenges with preventing allergen-related issues, leading to recalls and government intervention. Undeclared allergens have been a top trend setter in USDA and FDA recalls for the past six quarters, according to Whitworth of Food Quality News. Undeclared allergens were the single largest cause of recalls from the USDA in the second quarter of 2013, accounting for 60% of recalls and almost doubling from 33% in the first quarter of 2013. A study from Gendel and Zhu from the FDA uncovered trends from recalls between 2007 and 2012. Gendel and Zhu identified that bakery products were the most frequently recalled food type and milk was the most frequently undeclared major food allergen.

Gendel and Zhu also found that use of the wrong package or label was the most frequent problem leading to food allergen recalls. This finding tells us that food processors have (at least) one of the following problems:

1. Controls: Processors do not have checks and balances, allowing for mismatch


 product definitions. The recommendation was approved.

**Task force on responsibilities of participating states**

This task force was given six problems. However, problems 2 and 4 were combined.

Problem 1: Should split samples be reduced to a frequency of once a year? The task force recommended that the present requirement of two sets of split samples per year be retained. The recommendation was unanimously approved by the delegates.

Problems 2 and 4 called for ways of making volume control more meaningful and for stricter compliance with volume control provisions. The task force recommended that, when inadequacies are found by either the shipper or receiver, the methods presently outlined in Section VII of the "Procedures" dealing with "Complaints and Challenges" should be used. The delegates approved this recommendation.

Problem 3 recommended changing the first line in Section V-C, Subitem 4 to read, "If results of the laboratory and sampling surveys are not . . . . " The task force recommended the adoption of this change and the recommendation was approved by the delegates.

Problem 5: Consider the need for a specific and detailed sampling procedure to be developed to sample milk in receiving states. The task force stated that Section IV, A, 3, dealing with uniform Bill of Lading and Seals, and Section VII, dealing with Complaints provide adequate guidelines to handle the situation. The delegates approved the recommendation.

Problem 6 asked for methods for identifying the manufacturer of single-service containers. The task force stated that the Public Health Service report on this subject as presented to the Conference provides
for adequate means of identifying the manufacturer. The delegates approved the recommendation.

Task force on responsibilities of the PHS

This task force was given five problems. Problem 1 asked the PHS to consider establishing an advisory committee composed of experienced survey officers to review and revise Bulletin No. 678 to place greater emphasis on enforcement procedure evaluation. The task force recommended that the PHS review and update Bulletin No. 678, "Methods of Making Sanitation Rating of Milk Sheds, 1966 Edition" as soon as possible so as to reflect current conditions. The delegates approved this recommendation.

Problem 2 requested that new survey officers be accredited by a written or an oral examination along with an evaluation. The task force recommended no action on this request. The recommendation was approved by the delegates.

Problem 3 asked that recertification of survey officers be conducted simultaneously with spot checks. The task force felt that present procedures already allow for this and, therefore, recommended no action. The delegates approved. Problem 4 recommend that PHS establish bacteriological procedures and standards for co-mingled raw milk prior to its entrance into a milk plant. The task force recommended no action and the decision was approved by the delegates.

Problem 5 asked that the PHS be encouraged to carry on adequate training of survey officers in certifying single-service manufacturing plants. The task force felt that steps for adequate training have already been taken and therefore recommended no action. This decision was approved by the delegates.

Task force on procedures for handling complaints and challenges of validity of ratings

This task force was given two problems. The task force recommended that the IMS Conference require, by July 1, 1973, the delisting of all shippers from the IMS list from any state or municipality which does not have reciprocal inspection agreements or does not abide by the Conference Agreements for all IMS rated supplies, and it further recommended that the IMS Executive Board refer this matter to the proper task force for implementation. James Smathers presented a minority report concerning the above mentioned recommendation stating that the industry should not be penalized for conditions over which it had no control. After considerable discussion, the recommendation was tabled until the report of Task Force 8 could be presented. After the completion of the report of Task Force 8, the above mentioned task force recommendation was voted upon and defeated by the delegates by a vote of 35-7.

The task force recommended that the IMS Conference require, by July 1, 1973, the delisting of all shippers from the IMS list from any state or municipality which does not accept the accreditation program for brucellosis and tuberculosis as outlined in the U. S. Public Health Service Grade A Pasteurized Milk Ordinance, 1965 Recommendation. It further recommended that the IMS Executive Board refer this matter to the proper task force or to a special committee for implementation. This recommendation was tabled until after the report of Task Force 8 was presented. It was then formally voted upon and defeated by a vote of 40.5 to 1.5.

Task force on application of conference agreements and special problems

This task force was given five problems. Problem 1 recommended that the PHS update the Frozen Dessert Ordinance and make it a standard under Conference Agreements. The task force recommended no action and the delegates concurred. Problem 2 asked that consideration be given to including aseptically packaged milk and cream under the scope of the Conference. Sam Noles moved that the recommendation be amended as follows: "That the Conference request the PHS to develop definitions and standards for production, processing, ultra-high temperature treatment, and aseptic packaging of sterilized or sterile milk and milk products." The amended motion was passed with only two negative votes.

Problem 3: Recommend to the PHS that "Acceptable Enforcement Rating" be deleted from Section II of the PMO. The task force recommended that this change not be made. The delegates approved the recommendation. Problem 4 recommended that the wording in Section VIII, A.1 of the "Procedures" be changed to read," . . . shall apply to raw milk for pasteurization and to pasteurized milk and milk products." The task force recommended that the "Procedures" be changed accordingly so that the entire section involved reads: "Section VIII, Application of Conference Agreements. A. Products Covered. 1. Agreement..."

The delegates approved the recommendation. Problem 5 asked for ways to eliminate duplicate inspection, including the possible formation of a study committee. The task force recommended that the Conference chairman appoint an operating committee of five charged with the responsibility of receiving reports of lack of reciprocity, investigating such reports and taking, in respect to the facts determined, warranted action within the powers of the Conference Agreements, that the financing of the
committee's expenses be arranged by the Executive Board of the Conference and finally that the committee submit to the 1971 Conference a resume of its functions with recommendations. After considerable discussion by the delegates Sam Noles proposed to amend the recommendation by striking out the words "that the financing of the committee's expenses be arranged by the Executive Board of the Conference." The amended motion was unanimously accepted by the delegates.

After the conclusion of the task force reports, Chairman Johnson called for any unfinished business. Dr. Richard Parry of Connecticut recommended that the Committee for Single-Service Containers be continued. His recommendation was approved by the delegates. Chairman Johnson then announced that the 1971 Conference will be held at the Chase-Park Plaza Hotel, St. Louis, Missouri, May 16-20. The final general session of the 12th meeting of the National Conference adjourned at 11:45 a.m., Thursday, May 29, 1969.

REPORT OF COMMITTEE

(Continued from Page 289)

Chairman J. Marion Johnson introduced the new members of the Board from Region I, namely Sam Rich, Bill Arledge, Wendell Carr, and E. Marion Caussey.

Each member of the Board received a list showing the various hotels which had submitted proposals to host the 1973 meeting. After a considerable discussion, the meeting was awarded to the Savery Hotel, Des Moines, Iowa. The exact dates will be arranged later.

Chairman Johnson then called for the election of new officers. Both Chairman Shelby Johnson and Secretary-Treasurer J. C. McCaffrey were unanimously re-elected to their respective offices.

It was decided to hold an interim board meeting at Louisville, Kentucky, during the meeting of the International Association of Milk, Food, and Environmental Sanitarians, Inc., the time to be determined by the Chairman.

Chairman Johnson appointed John Schilling to serve as Local Arrangements Chairman for the 1971 meeting which is scheduled to be held at the Chase-Park Plaza Hotel, St. Louis, May 16-20.

There being no further business, the meeting was adjourned at 1:35 p.m.

In accordance with the instruction given the Committee in 1967 by the Conference the "Committee on Scope" respectfully submits this report. It will be presented at the business session on Thursday on the question of its adoption.

Harold J. Barnum, Co-Chairman
Clarence K. Luchterhand, Co-Chairman

Summary of Recommendations
Subcommittee on Available Procedures and Standards

Existing standards and model regulations for products not included in the Pasteurized Milk Ordinance were studied by this subcommittee. Some of the subcommittee recommendations have been incorporated into the main body of this report. Additional recommendations by the subcommittee include:

1. All products covered by the provisions of the Agreement should be supervised and coordinated by the state and federal agencies which are presently operating the program.

2. Where applicable products should bear the plant identification number as outlined by the recommendations of the National Labeling Committee.

3. The committee considers the framework for determining sanitation compliance ratings of sources already existing within the provisions of the Conference agreements. Should the inclusion of other dairy products within the provisions of the agreement materialize, federal agencies could establish a numerical evaluation for sanitation items.

Summary of Recommendations
Subcommittee on Need for Uniformity and Reciprocity

This subcommittee was assigned the task of gathering in-
THE ROLE OF AN INDUSTRY SANITATION CONSULTANT IN FOOD PLANT SAN


Such an analysis could reveal that fewer barriers exist than are currently perceived.

Where to start?

It can be overwhelming to see this long list of barriers and think: There is too much in our way – we’ll never achieve transformation! After the dialogues were completed, the research team identified two initial steps can make the task of dismantling barriers more manageable.

First, the barriers can be narrowed by only focusing on those found to block progress toward several food system changes. In other words, the 14 barriers presented in Figure 1 now become the focus of analysis. This can be a useful step since a combination of changes will likely be needed to transform to sustainable food systems, and these 14 barriers represented roadblocks to a range of changes.

Second, the barriers can be reframed into leverage points – or places in a system where intervention can result in changes to that system and prioritise those with the most leverage for systemic, transformative change. The potential of leverage points to effect systems change can be scored on a continuum. On one end are those interventions – termed ‘shallow’ leverage points – that are relatively easy to implement yet have limited potential for transformative change. This could be an intervention such as creating an infrastructure for centralised, harmonised database for food system information. For example, digital infrastructure like the Food Systems Dashboard could be expanded and adapted for detailed data collected at the Nordic level. At the other end of the continuum are those interventions – termed ‘deep’ leverage points – that require more time, resources and effort, but have the potential to unlock transformative change (Figure 2 next page). An example would be adopting a mindset where sustainable diets are a public right.

In between on the continuum, there are what are referred to here as ‘promising’ leverage points. These make important steps in changing the fundamental functioning of food systems by changing the design of a system or information flows. One example could be designing food systems in a more circular way.

Since the Nordics have already begun tackling many of the ‘low-hanging fruits’ – the shallow leverage points – this Insight Paper focuses on deep and promising leverage points that can lead to transformational change. From here, the list of 14 barriers identified in Step 1 can be narrowed even further to identify seven critical leverage points.

Deep leverage points: Goals, mindsets and paradigms

Deep leverage points are powerful because they target changes to the goals of the system, the mindsets of individuals who shape the system, and the paradigms that guide decision-making about the system. Several barriers discussed in the dialogues identified different goals, mindsets, values and paradigms as blockages to systems change. Below, these barriers have been reframed as deep leverage points for changing Nordic food systems.

Securing political support will require that the mindsets and goals of policy-makers change. Demonstrating political will and leadership are key aspects of political support. Strong thought leadership is also key to empower others to associate change with opportunity rather than risk.

Changing food culture will mean creating a new ‘cultural paradigm’ that steers our eating habits in a more sustainable direction. This also includes involving a diverse set of actors to co-create guiding principles (not dogmas) that lay the foundation of this new paradigm.

Managing vested interests will start from the recognition that all actors have interests and goals as well as differing levels of power and influence over food system change. Conflicting interests need to be brought to light and resolved.

Changing individuals’ mindsets will require us to find new ways to change individuals’ preferences, beliefs, values and lifestyle choices related to food.
Promising leverage points: System design and information flows

While unlocking deep leverage points would be powerful in affecting change, there are other leverage points – which are referred to here as promising leverage points – that hold slightly less, but still significant transformative potential. Promising leverage points target the design of a system and the information flows within that system. In the Nordics, the following examples illustrate promising leverage points:

- **Increasing individual knowledge and cooking skills about sustainable diets** can be achieved by improving credible information flows through many channels, including formal education, higher education of health care professionals, advertising and public campaigns.

- **Improving food environments** – the physical, social, economic and cultural spaces that shape our food-related behaviour – can be a way to significantly change the design of the food system and the influence the food system has on our individual choices. This includes food labelling, marketing and the affordability and accessibility of food.

- **Creating ambitious policies that support sustainable food futures** is another way to significantly shape the design and purpose of a food system. This includes creating safe spaces where new approaches can be tried and tested.

![Figure 2](image-url)

**Figure 2**: Activating deep leverage points (changing goals, mindsets, and paradigms) can help overcome system lock-ins and transform current food systems into desired food systems. Yet there are also promising leverage points (changing system design and information flows) that can move us closer to sustainable transformations. Other shallow leverage points (changing the infrastructure, parameters or feedback loops of a system) are not discussed here. Figure adapted from the leverage point approach literature. Figure by Azote.

Working together to activate leverage points

Looking at the seven leverage points discussed above, it is clear that there is no simple way to activate each leverage point. For example, to change food culture, several factors within the food system might need to change, such as guidance from the public sector in setting new norms related to food; involvement of chefs and other food influencers to bring the concepts of sustainability onto a plate in a tasty, attractive way; and work from food business and retailers to produce and stock new types of ingredients, foods and meals.

Adopting a food systems approach – one that looks at the food system as a whole and appreciates the linkages between and feedbacks among parts of the system – will be critical. Only with systems thinking can we understand the multiple drivers that create and reinforce food system barriers.

One way to encourage systems thinking is through collaboration of actors across the food system. Working together will allow actors to get the most transformative potential out of each leverage point. Below (Table 2), ten collaborations are proposed that can help activate each leverage point. These collaboration ideas were developed after the dialogues by the research team. It is important to
note that while these collaboration ideas are evidence-based, the effectiveness of each collaboration will only be known if societies have the courage to test them out. Crucial to this experimentation is the willingness to learn from successes as well as from failures. This is not a one-time process. Support for an iterative, active learning process needs to be in place.

While the collaborations presented below use a single leverage point as an entry point for change, the collaborations end up activating multiple leverage points. For example, by working to change current food environments, collaborators would also likely help to create policies that support sustainable food futures, increase individuals’ knowledge and change food culture. Thus, investing in one leverage point is likely to have positive ripple effects across other leverage points.

Table 2. Potential collaborations to activate deep and promising leverage points in Nordic food systems.

Leverage points and potential collaborations
Examples of core collaborators
Potential actions
Linkages to other leverage points

Secure political support

Collaboration 1:  Develop food systems goals and indicators
• All national and local government departments
Clear goals for sustainable food systems can be set by local and national governments. Formal goals will help prioritise and accelerate action on food system change, providing a clear direction of change and indicating the necessary level of ambition. Indicators should also be developed to assist in the monitoring and evaluation of action. A mechanism should be established to ensure that the best available scientific evidence is regularly used to inform food system goals and indicators.*
• Create ambitious policies  • Improve food environments  • Change food culture

Change food culture and Individuals’ mindsets

Collaboration 2:  Co-develop a national and regional food identity
• Tourism authorities  • Citizens  • Food service professionals  • Civil society organisations  • City planners  • National food authorities  • National education authorities  • Private sector (including small- and medium-scale enterprises, SMEs)  • Governments
Over the past 17 years, food culture has rapidly evolved in the Nordic region, sparked by the New Nordic Food Movement. The concept of modern Nordic food continues to evolve. Domestic tourism authorities can adapt their strategies to promote sustainable food systems as destinations, experiences and as a component of a desirable lifestyle. Civil society, food service professionals, national authorities and city planners can include (where not already existent) food education and educational spaces that engage not only school-age children but also families and the community at large. The private sector and governments can provide innovation spaces to support entrepreneurs in filling gaps in the market as societal needs change. Citizens and governments can revisit and revise national and regional food-related manifestos, without becoming dogmatic.
• Increase individuals’ knowledge  • Improve food environments

* Many research projects across the Nordics are aiming to develop food system goals. In Sweden, for example, the Mistra Food Futures program is developing food system targets and indicators, which could then be fed into the public sector process for setting national food system goals.
### Leverage points and potential collaborations

Manage vested


8” pan to heat:
4 c. canned sliced peaches (or other fruit)
Add:
1 tsp. cinnamon or nutmeg
2 Tbsp. sugar
Pour on:
9 oz. white cake mix prepared as directed
or 2 c. Bisquick and juice from fruit to make dumplings

Cover and bake 20-30 min. Serve with whipped topping.

**Fruit Crisp**

Pour:
21 oz. can fruit pie filling in bottom of Dutch oven or 8” pan to heat.
Top with:
9 oz. white cake mix (dry) with ¼ c. margarine worked in w/fingers.
or 9 oz. pie crust mix (dry) with ¾ c. brown sugar worked in

Cover and bake 20-30 min. or until topping is brown.

**Hillbilly Cobbler**

1 stick margarine
1 c. sugar
2/3 c. milk
1 c. flour
2 tsp. baking powder
Your choice of 1 can pie filling, 21 oz. size

Melt ½ stick of margarine in each of two 8” or 9” cake pans. In a separate bowl, mix the flour, sugar, baking powder and milk. Pour ½ of the batter into each of the two cake pans. Pour ½ can of pie filling over each pan of batter. DO NOT STIR! Bake at 350° for 35 minutes or until lightly browned. These pans will stack perfectly in one 12” Dutch oven. Use two clean wire tent stakes on the bottom pan to maintain separation between pans.
Pineapple Upside Down Cake

1 can sliced pineapple
½ c. brown sugar, packed firmly
¼ c. butter
2 pkg. yellow cake mix
additional ingredients necessary for cake mix
Maraschino cherries, drained (optional)

Line the oven with aluminum foil. Place oven on heat, level it, and melt the butter in the oven. When melted, add the brown sugar, then the pineapple slices (drain them first) with a cherry in the center of each slice. While butter is melting, mix the cake according to package directions. Pour the cake mix over the glaze and put lid on pan. Bake in coals about 25 minutes, until golden brown and cake tests done. Lift out of pan by edges of aluminum foil and invert onto plate. Remove foil. Serves 12.

VARIATION:
- Instead of yellow cake mix, use 1½ pkg. Pound cake mix, 3 large eggs, 1 ¼ c. milk
- Pour: 20 oz. can crushed pineapple in bottom of Dutch oven or 8” pan to heat. Pour on: 9 oz. white cake mix prepared as directed. Cover and bake for 20-30 min.<|endoftext|>Tofu Tacos

Source: Healthy Eating for Life for Women by Kristine Kieswer; recipe by Jennifer Raymond, MS, RD

These tacos can be made with fresh or frozen tofu. The frozen tofu gives it a texture similar to ground beef. To freeze the tofu, put the whole package in the freezer. Defrost it in the refrigerator. Once thawed, remove the tofu from its package and squeeze out the excess water.

About the Recipe

118 Calories · 5.7 g Protein · 3.2 g Fiber
Dinner

Ingredients

*Makes 6 Servings*

- 1 small onion, chopped
- 1/2 small bell pepper, seeded and cut into cubes (optional)
- 8.8 oz (249 g) firm tofu, crumbled
- 3 tsp (15 mL) chili powder
- 1 tbsp (15 mL) nutritional yeast (optional)
- 1 tsp (5 mL) garlic powder
- 1/4 tsp (1.2 mL) ground cumin
- 1/4 tsp (1.2 mL) dried oregano
- 1 tbsp (15 mL) reduced-sodium soy sauce
- 6 corn tortillas
- 1 head romaine lettuce, chopped
- 2 green onions, chopped
- 1/2 c (76 g) tomato, diced
- 1/3 c (86 mL) salsa
- 1/2 avocado, sliced (optional)

Directions
1. Heat 1/4 c (60 mL) water (or low-sodium vegetable stock) in a nonstick pan. Add the onion and bell pepper and cook over high heat, stirring often, between 2 and 3 minutes.
2. Add tofu, chili powder, nutritional yeast (if using), garlic powder, cumin, oregano, and soy sauce. Reduce heat to medium and cook for 3 minutes, stirring often.
3. Heat a tortilla in a dry heavy pan, turning it from side to side until it is soft and flexible.
4. Place a small amount of tofu mixture in the center, then fold the tortilla in half and remove from heat.
5. Garnish with lettuce, green onions, tomato, salsa, and avocado, if using. Repeat with each remaining tortilla.

**Nutrition Facts**

Per taco:

Calories: 118
Fats: 4.1 g
  - Saturated Fat: 0.7 g
  - Calories From Fat: 31.4%
Cholesterol: 0 mg
Protein: 5.7 g
Carbohydrate: 16.9 g
Sugar: 2.8 g
Fiber: 3.2 g
Sodium: 321 mg
Calcium: 116 mg
Iron: 1.6 mg
Vitamin C: 10 mg
Beta-Carotene: 371 mcg
Vitamin E: 1.1 mg<|endoftext|>Keegan-Michael Key
Gets Serious

French Revolutions
Cycling a stage of the Tour de France

Tasty Stays
The world's most delicious new hotels

Sneakers and spritzes for summer
The World’s Most Delicious New Hotels

Hotel dining used to mean room-service club sandwiches and limp iceberg lettuce salads at the brightly lit lobby bar. Not anymore. Now, the best meals to be had on the road—from Berlin to Brooklyn—are an elevator ride away.
The Dewberry
CHARLESTON, SOUTH CAROLINA

The Dewberry opened its doors last July, immediately becoming the place to stay in Charleston thanks to its luxe yet refined Mid-Century Modern design, central location, and, most important, its Dixie-inflected French restaurant, Henrietta’s (which is saying a lot, considering what a foodie destination Chucktown is). Waiters in white jackets whisk out plates of steak frites and flounder meunière in the airy dining room, but the must-order dish is a mere “for the table” starter: gougerès with chicken liver mousse. These buttery, Gruyère-laden yet surprisingly light puffs of pastry are as French as you can get, but executive chef R.J. Dye drew from his own Southern history for Henrietta’s presentation. “We serve the warm gougerès in the same manner that steaming hot baskets of buttermilk biscuits were delivered to the table by my grandmother,” he says. But rather than wrapping them in a tea towel, he nestles the puffs in an elegant ceramic dish with a slate top that he decorates with a swipe of chicken liver mousse, a totally rich and over-the-top accompaniment that is nonetheless absolutely necessary. He finishes with a bit more Southern flair: a sprinkling of toasted benne seeds, a cousin of the sesame seed that has deep Low Country roots. Dye says he adds them not for the history but for the taste: “The subtle nutty and earthy flavor profile keeps the gougerès grounded.” Whatever the reason, you’ll want a second order. –EC<|endoftext|>The Importance of Food Labelling

25 August 2010

Ensuring food safety is a shared responsibility between governments, producers, industry and consumers. Food labelling is one way in which consumers can get knowledge about the food they consider buying. Correctly following the information provided on food labels (such as expiry dates, handling instructions and allergy warnings) can help consumers prevent unnecessary food-borne illness and allergic reactions.

Expiry dates

In the European Union (EU), an intricate set of legislation and standards has been developed and implemented to ensure safety throughout the entire food chain. Perishable foods, judged from a microbiological point of view (such as cooked meat products, prepared foods and salads), display a 'use by' date on the package and should not be eaten after this date, as this could present a health risk. In addition, many foods display a 'best before' date, which gives an indication of the “minimum durability”, or the period during which the food retains its specific properties when properly stored. In other words, a product whose “best before” date has expired may still be safe to eat, but the manufacturer no longer guarantees the sensory properties of the product (e.g. taste, smell, appearance etc).

In a recent nationally representative survey from the UK, only half (49%) of the over 3000 respondents correctly identified the ‘use by’ date as the best measure of safety and 47% said they would never eat cooked meat beyond its ‘use by’ date. Most respondents were found to be using expiry dates as a point of reference and relying on their own judgement to decide if the food was safe to eat by smelling it (74%) or by just looking at the food (65%). In a nationally representative study from Ireland (


Implementing the strategy and measuring progress

How the FSA will implement its 5-year strategy and measure progress in priority areas.

This strategy sets our direction for the next five years. We expect our organisation and our work to evolve to meet the ambitions we have set out.

We will need to be flexible in our approach, particularly as we explore new areas of our strategy such as our vision for food that is healthier and more sustainable.

We are setting our corporate objectives and work plan for the first year alongside this strategy and will set work plans for subsequent years through our corporate planning process. We will discuss these at public Board meetings. We will also work with external stakeholders to inform work planning, as part of our commitment to work with and through others.

We know from the last five years with EU exit and the COVID-19 pandemic that our context can change significantly. But we expect this strategy to provide the framework with which to face those changes: clarity about our vision, our objectives, and how we are going to do our work.

Having set out our strategy, we will need to make sure that the FSA has the capacity and capability to deliver on it. We will include in our work plans some internal pieces of work that help us to build that resource, and to ensure that the guiding principles are fully embedded in the FSA.

Our people plan

We are developing a new people plan to enable us to deliver on our strategy. Its focus will be on maximising organisational capability, living our values, ensuring an excellent employee experience and growing and developing our people.

Services approach

We believe it is important to see some of our work as a ‘service’ for the public, industry, local authorities or other parts of government. We have applied a service design approach to our digital services for some time but are now expanding this into other areas of our organisation. This will include increasing the amount of feedback we receive on our work, establishing and monitoring performance metrics and redesigning some of our processes to work more smoothly. Through this process we aim to make it easier for businesses to meet their obligations and do the right thing.

Measuring progress

Existing measures

The food system is incredibly complex. To measure the successful delivery of our strategy, we will need to consider a range of metrics acknowledging the complexity involved in measuring progress in the food system.
There are also many actors, including the FSA, with different roles and responsibilities to make food safe, what it says it is and healthy and sustainable. This means we will need to look at progress from several angles.

The FSA has a performance reporting system with a cascade of metrics and targets, from our top-level strategic objectives down to the daily activities of our frontline work. We publish performance data on a regular basis, for example in performance and resources reports to the FSA Board’s Business Committee.

We plan to evolve this performance reporting system and use it to measure progress against our new strategy.

Many of the existing measures already align with our new strategy including on whether food is safe and food is what it says it is.

For example, relating to our vision that food is safe, we publish figures for the number of laboratory confirmed cases of the ‘big four’ food pathogens. These are the number of cases, confirmed by laboratory tests, of four of the main sources of foodborne illness – E. Coli, Salmonella, Campylobacter and Listeria. This allows us to measure an outcome in the food system we want to see - that cases remain low.

Lab confirmed cases of ‘Big 4’ food pathogens (000s)

We regularly measure consumer perspectives on the food system and of the FSA:

Percentage of consumers who are confident in food safety and authenticity
We also publish measures of the contribution the FSA and others in the food system make to achieving these outcomes.

For example, we report on the percentage of Food Business Operators (FBOs) achieving FHRS ratings of five (meaning very good) and those receiving a rating below three (meaning below satisfactory). We also report on the percentage of meat FBOs who are rated as satisfactory or above for compliance and audit activity.

**Percentage of businesses achieving FHRS score five (very good)**

**Percentage of meat businesses audited rated 'good'**
These measures continue to represent a picture of the performance of the FSA and the food system as a whole and provide a useful baseline to measure progress against.

**Updated and new measures**

We will develop new metrics and revise our performance reporting to fit this new strategy.

To effectively evaluate our strategy, our metrics will go from ‘end-to-end’, so we have numbers for own our activities and outputs, for how the food system overall is doing and how those join together so we can assess our particular contribution:

- Developing and improving measures covering our core role in food that is safe and food is what it says it is.
- Incorporating the right set of measures to understand progress in the area of food that is healthier and more sustainable (building on existing nutrition measures we use in Northern Ireland).
- Incorporating measures relevant to protecting wider consumer interests in food, such as food insecurity and affordability.
- Expanding the measures relating to how we are embedding our principles, for example measures of FSA service delivery such as user feedback, or how long it takes us to perform certain actions.
- Tracking the benefits we have delivered in areas covered by our strategy, for example what corporate plan milestones have we reached and what impact we can demonstrate for consumers (either as forecasts or retrospective evaluations).

Ultimately this strategy is all about delivering food you can trust for consumers. By using a robust and varied set of measures to track delivery and impact over the next five years, we will be able to adjust our approach where needed, deal with change, and ultimately be sure that everyone has food that is safe, is what it says it is, and is healthier and more sustainable.<|endoftext|>Food Allergens: A Comprehensive Approach For Food Processors To Prevent Unintended Allergens In Their Foodstuffs

- Dairy
- Egg
- Crustacean Shellfish
- Fish
- Tree Nuts
- Wheat
- Peanuts
- Soybeans

A Food Safety Guide for Food Processors

EHA
Contents

Chapter 1: Introduction p.3

Chapter 2: Allergens and Food Processors p.4

Chapter 3: Food Processors’ Allergen Challenges p.5

Chapter 4: Major Risk Areas for Allergen Recalls p.6

Part 1. Controls

A. Product Intake Handling
B. Allergen Identification
C. Storage
D. Cross-Contamination
E. Product Matrix
F. Labeling
   i. US Government Regulations
   ii. International Regulations
   iii. Label Allergens
G. Proper Sanitation
   i. Cleaning Methods
   ii. Inspection
H. Testing Allergens
   i. Actions That Have To Be Taken

Part 2. Employee Training

Chapter 5: Moving Forward p.16

Part 1. Processor
Part 2. Customers

Chapter 6: How EHA Consulting Group, Inc. Can Help p.17

About EHA Consulting Group Inc.

EHA Consulting Group, Inc. (EHA) offers comprehensive public health consulting, epidemiology and food safety services before, during and after a crisis. We provide these services to Retail Food, Food Service, Food Processing, and Contract Food Service Management companies.

Need our Services? Call us today at 800-969-1441.

Visit us at www.ehagroup.com. Follow us on Twitter @EHAConsultingGp.
Introduction

“The proper control of food allergens in a food processing plant presents numerous challenges. The ubiquitous presence of allergens in the human food supply, coupled with increased awareness of food allergies, warrants undertaking appropriate preventive measures to protect sensitive consumers from unwanted exposure to offending food allergens. Food processors must have an allergen prevention plan to determine potential sources of contaminating allergens and create appropriate controls to prevent allergen introduction into food products.”

The proper control of food allergens in a food processing plant presents numerous challenges. The ubiquitous presence of allergens in the human food supply, coupled with increased awareness of food allergies, warrants undertaking appropriate preventive measures to protect sensitive consumers from unwanted exposure to offending food allergens. Food processors must have an allergen prevention plan to determine potential sources of contaminating allergens and create appropriate controls to prevent allergen introduction into food products.

The following guide from EHA Consulting Group, Inc. (EHA) contains information, best practices, and tools for a food processing company to avoid allergen-related recalls. Key factors in allergen control include poor identification, poor handling, poor storage, improper product matrix, improper labeling, poor sanitization, and inadequate testing. The purpose of this guide is to educate you and your staff on the proper steps to protect your brand and your business from the negative ramifications of an allergens incident and potential recall.
Allergens and Food Processors

“Up to 15 million Americans have food allergies, 1 in every 13 children under the age of 18.”

When it comes to food allergens, what you don’t know could hurt you - as a customer and as a business owner. Up to 15 million Americans have food allergies, including one in every 13 children under the age of 18. Ensuring that a large number of potential customers can safely consume your food is a vital business practice.

Allergens affect people in various ways. Allergens are substances, usually protein in nature, that illicits a reaction that is generically termed an allergic reaction. Allergens do not have to be proteins; they can be chemical, such as sodium bisulfite or MSG (monosodium glutamate) and in non-food settings, they can be dust. Food allergens are an improper reaction of someone’s immune system that most of


 surface of the storage and dispensing portion is shaped substantially like the inner surface of a drinking cup.

[0018] In still other preferred embodiments, the storage and dispensing portion is cooperative with a sealing cap.
In other preferred embodiments, the storage and dispensing portion is shaped so as to accommodate storage of a closed cylindrical container.

In yet more preferred embodiments, the storage and dispensing portion includes a plurality of drinking cups.

In still more preferred embodiments, the drinking cups each bear a trademark.

Another general aspect of the invention is a bottle for containing a beverage, and for storing and dispensing cups useful for consuming the beverage. The bottle includes a cup storage and dispensing portion formed into a surface of the bottle, an inner surface of the cup storage and dispensing portion including a cup retaining element capable of resisting removal of a cup from the cup storage and dispensing portion. The bottle also includes a plurality of cups stored within the cup storage and dispensing portion.

In preferred embodiments, the cup storage and dispensing portion is formed into a bottom of the bottle. In other preferred embodiments, the cup storage and dispensing portion is formed into a side wall of the bottle.

In still other preferred embodiments, the cup storage and dispensing portion is sealed by a cap.

In further preferred embodiments, the cup storage and dispensing portion is shaped to accommodate a cup, while maximizing the volume of the bottle.

In still further preferred embodiments, the bottle also includes at least one sample within the cup storage and dispensing portion.

In other preferred embodiments, the cup retaining element, capable of resisting removal of a cup from the cup storage and dispensing portion, includes a plurality of resistance regions.

In still other preferred embodiments, the resistance regions are circumferentially disposed.

In preferred embodiments, the cup retaining element is formed from a wall of the cup storage and dispensing portion.

Another general aspect of the invention is a method of providing promotional items with drink containers. The method includes providing a drink container with integral storage formed into a wall of the container, the storage forming an externally accessible cavity extending into the drink container. Then, placing one or more promotional items within the externally accessible cavity, and sealing the promotional items within the externally accessible cavity with a removable lid.

FIG. 5 is a cut-away view of an alternate preferred embodiment of the invention storing promotional items.

DETAILED DESCRIPTION OF PREFERRED EMBODIMENTS

FIG. 1 shows a cut-away perspective view of the drink storage and dispenser portion of a preferred embodiment of the invention with details of key features and elements. This portion of the preferred embodiment of the invention includes concentric cylinders joined at the top with the inner cylinder closed at the bottom. The shape of it is essentially that of a sleeve that can accept a plurality of cups within the sleeve such that only the bottom surface of the last cup inserted into the sleeve is exposed.

The storage and dispenser portion of the invention in this embodiment includes two cylinders, an outer cylinder 120 and an inner cylinder 130 which is smaller in diameter and shorter in length than outer cylinder 120. Additionally, the inner cylinder 130 has a closed end 140. The inner cylinder 130 is located concentrically within the outer cylinder 120 such that the open end of inner cylinder 130 is aligned yet opposed with respect to an open end of outer cylinder 120. The aligned open ends of the cylinders 120, 130 are attached by an annular seal 110 to maintain the cylinders 120, 130 in stable relative position, and to close off one end of the space between the cylinders, thereby creating a storage space 150 between cylinders, thereby providing space for a plurality of stacked drinking cups. A circumferential retaining ridge 160 provides a barrier that resists removal of each of the cups, as explained further below.

FIG. 2 shows a cut away view of a preferred embodiment of the invention where the bottom of a large beverage container, such as a soda bottle, includes a storage and dispensing portion 100. The storage and dispensing portion 100 of FIG. 2 is very similar to the structure described in FIG. 1, differing only in the relative slant of the cylinder walls, and that the plastic is formed as a continuous structure that is integral to the wall 210 which descends to form the bottom of the large beverage container 220, which includes the storage and dispensing portion 100. FIG. 2 also shows a cross-sectional view of a circumferential retaining ridge 160, which is essentially the same as the circumferential retaining ridge 160 of FIG. 1. This storage and dispensing portion 100 of the large beverage container 220 can accept a plurality of cups that can each be inserted by a person or by a machine situated outside the large beverage container 220.

The storage and dispensing portion 100 of the invention is made from the same material used to make standard beverage containers. For example, in the case of a two-liter soft drink container, the invention is made from PET plastic, which is relatively hard and transparent. In the case of a one-half or one gallon milk container, the invention is made from partially translucent or opaque plastic. The invention can also be made from glass, such as when included in the bottom or the side of a large glass milk jug. The invention could also be included in the side or the bottom of a very large plastic water cooler bottle, for example.

The storage and dispensing portion 100 can store and dispense a plurality of cups, each cup having a cup rim 260 sized to lightly contact the inner wall of the storage and dispensing portion 100. When a cup is moved past the circumferential retaining ridge 160 to add or remove a cup from the portion 100, it applies a compression force to a cup rim 260, temporarily deforming it slightly, as it moves past ridge.
The force applied to cup rim 260 is sufficient to prevent the cup 230 from falling out of the storage and dispenser portion 100 under its own weight, but is not enough to permanently deform the cup rim 260. Retaining ridge 160 can be a continuous structure, or it can be a plurality of segments interspersed with voids along the inner circumference of outer ring 120 so as to reduce the compression force on cup rim 260.

FIG. 3 also displays how the invention takes advantage of the fact that drinking cups 230 can be stacked to provide maximum drinking cup storage with minimum volume being taken away from the interior volume of a drink container.

To keep drinking cups 230 from being exposed to dirt and germs outside the drink container, a lid 310 can be placed over the open end of cup storage portion 100. The lid 310 can be constructed and attached in a way similar to the plastic or foil-backed lids used to seal many liquid storage containers. These peel-off, single use lids provide protection to the contents during manufacture, distribution, and retail handling. Alternatively, the lid 310 can be made of rigid plastic, and formed in the shape of a thin stopper to allow the lid 310 to be reusable.

With reference to FIG. 4, the storage and retaining portion 100 of the invention can be formed into any wall of a drink container. FIG. 4 shows a side-wall embodiment of the invention integrated into the side wall of a plastic bottle or glass jug.

FIG. 4 also shows an alternative embodiment of the invention without an inner wall similar to the inner cylinder 130. Instead, there is only an outer wall similar to the outer cylinder 120, and a flat back wall 410 instead of a cup-like wall 332. This embodiment provides storage for drinking cups, as well as anything else that one might want to include inside the inner-most cup, such as packets of sugar, drink flavoring, or collapsible drinking straws, for example. However, this embodiment also takes up a larger volume from drink container interior 220 than the other embodiments described herein.

FIG. 5 shows an alternate embodiment of the invention with storage and dispenser portion 100, which can be accessed by removing lid 310. The storage and dispenser portion 100 here is shown NOT storing cups, but instead being used for storage of promotional items such as game cards, key rings, a coupon 510, or a product sample 520, as the manufacturer or bottler may choose to provide. Thus, the shape of storage and dispenser portion 100 could be other than cup-shaped, and could therefore be smaller or larger than a set of cups so as to accept such promotional items. In this embodiment, storage portion 100 could be used by the retail consumer to store an item or items of their choosing such as non perishable food.

Alternatively, storage portion 100 could be used to store a different drink in its own small container, a trial sample 520 of a complimentary food, or other item offered by the manufacturer.

Storage portion 100 could also accept similarly sized cups provided by the retail consumer, or another party, independent of the consumption of the drink container contents. In this way, the storage and dispenser portion of the invention can function solely as a cup storage and dispensing apparatus.

Other modifications and implementations will occur to those skilled in the art without departing from the spirit and the scope of the invention as claimed. Accordingly, the above description is not intended to limit the invention except as indicated in the following claims