Allergen Management Plan
An Allergen Management Plan is a written document outlining how a business identifies, controls, and declares food allergens to prevent customer harm. It is required to comply with Standard 1.2.3 of the Food Standards Code (Australia New Zealand Food Standards Code).
A written plan that outlines how a food business identifies, controls, and communicates food allergens to ensure consumer safety and meet legal standards.
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About this Document
An Allergen Management Plan is a document for any Australian business involved in the handling, preparation, or sale of food. This includes cafes, restaurants, catering companies, bakeries, and even tradespeople who provide food services on site. The primary purpose of this plan is to protect customers from allergic reactions which can be severe or life threatening. In Australia, food allergies are a significant public health issue. The law requires food businesses to provide accurate information about the presence of allergens in their food. This plan acts as a roadmap for your business to meet those legal obligations consistently and safely. To understand why you need this document, you must look at the Food Standards Code. This code is a collection of standards that govern food safety in Australia and New Zealand. Specifically, Standard 1.2.3 requires food businesses to declare the presence of certain allergens when they are present as ingredients or components of ingredients. The declared allergens include cereals containing gluten, crustacea, eggs, fish, milk, peanuts, soybeans, tree nuts, sesame seeds, and sulphites. If your business fails to declare these, you are breaking the law. An Allergen Management Plan helps you ensure you do not break this law. It creates a system for checking every ingredient that comes into your kitchen and every dish that leaves it. You need this plan before you open your doors to the public. You also need to update it whenever you change suppliers, update your menu, or change your processes. If a customer has an allergic reaction at your premises, the first thing an inspector will ask for is your Allergen Management Plan. Without it, you face severe penalties and potential closure. The document also aligns with broader work health and safety laws. Under the Work Health and Safety Act 2011, a business must ensure the health and safety of workers and others. While WHS laws often focus on physical risks like slips or falls, the duty of care extends to risks posed by the products you create or sell. If a customer suffers anaphylaxis because you failed to manage allergens, this is a breach of your duty of care. , the Australian Consumer Law requires that services be supplied with due care and skill. Serving food containing unlabelled allergens is a failure of due care and skill. Creating the plan involves several steps. First, you must list every ingredient used in your business. You must review the labels of these ingredients to identify which of the nine allergens they contain. Second, you must assess your workflow. You need to look at how food is stored, prepared, and cooked. Cross contamination is a major risk in food handling. You must identify points where allergens could transfer from one food to another. For example, using the same chopping board for nuts and bread is a risk. Using the same fryer for chips and battered prawns is a risk. Your plan must detail how you will separate these items. Third, you must plan how you will communicate this information to your staff. Staff training is a mandatory part of allergen management. Your plan should outline how often you train staff and what that training covers. It should include procedures for staff to follow if a customer declares an allergy. This includes knowing who to ask in the kitchen and how to verify ingredients. Fourth, you must plan how you communicate to customers. This includes menu labelling, signage on display cabinets, and the ability of staff to answer questions accurately. Writing the plan requires careful thought. You must use clear language that your staff can understand. You should avoid jargon. The plan must be a living document. This means you must review it regularly. A good rule of thumb is to review it every six months. You must also review it immediately if you introduce a new product or if a supplier changes the formulation of a product. Common mistakes to avoid include relying on memory rather than checking labels. Never assume that a product is allergen free just because it was last month. Manufacturers change recipes without warning. Another common mistake is assuming that removing an allergenic food, like picking nuts off a salad, makes the food safe. It does not. Trace amounts remain and can cause a reaction. Your plan must explicitly forbid this practice. Another mistake is failing to understand the difference between gluten free and low gluten. Under the Food Standards Code, only foods specially prepared to meet strict standards can be labelled gluten free. You must understand these definitions. You must also be aware of the penalties for non compliance. State and territory food authorities enforce these laws. Penalties can include heavy fines for individuals and corporations. In severe cases, directors can be prosecuted personally. There is also the risk of civil action from customers who suffer harm. The financial and reputational damage from a food allergy incident can destroy a small business. An Allergen Management Plan is your best defence. It shows that you took reasonable steps to prevent harm. When you complete your plan, be specific. Do not write that staff will be careful. Write that staff will use colour coded chopping boards for allergen free food. Write that staff will wash hands for 20 seconds with soap and water after handling eggs. Be specific about who is responsible. Name the manager who will check ingredient labels. Name the chef who will verify special allergy meals. This clarity ensures everyone knows their role. It also makes it easier to enforce the plan. For tradespeople who work in food construction or fit outs, understanding this plan is also vital. You must design kitchens that allow for the separation of allergens. If you install equipment, ensure it is cleanable and does not harbour allergens in crevices. While you may not write the plan for the restaurant, your work must support their ability to implement one. In summary, an Allergen Management Plan is not just paperwork. It is a critical tool for managing risk. It protects your customers, your staff, and your business. It ensures you comply with the Food Standards Code, the WHS Act, and the Australian Consumer Law. It reduces the chance of causing serious harm. It demonstrates your commitment to professional food service. Every Australian food business, regardless of size, must have one. It is the mark of a responsible business owner.
Key Facts
- Food businesses must declare the presence of nine specified allergens including peanuts, tree nuts, milk, eggs, fish, crustacea, sesame, soy, and cereals containing gluten.— Food Standards Code Standard 1.2.3
- Businesses have a duty of care under the Work Health and Safety Act 2011 to ensure the safety of customers and others.— Work Health and Safety Act 2011 (Cth)
- Sulphites in concentrations of 10mg/kg or more must be declared on food labels.— Food Standards Code Standard 1.2.3
- Failure to declare allergens can result in fines and prosecution under state and territory food Acts.— Food Act 2003 (NSW) - example legislation
- The Australian Consumer Law prohibits misleading or deceptive conduct regarding food content.— Competition and Consumer Act 2010 (Cth)
Sources
Required Sections
Business Details
Basic information about the business and the person responsible for the plan.
Business Details
This section captures the essential information about your operation. You must complete this section accurately. It identifies who is responsible for food safety and provides the location where the plan applies.
Business Name
Write the full registered business name. If you trade under a different name, write both names here. This ensures there is no confusion about which entity holds responsibility for the allergen management procedures.
Business Address
Provide the physical street address where the food handling takes place. You must include the street name, number, suburb, state, and postcode. Do not write a post office box number here. Australian regulators need to know the exact site of the food operations.
Contact Details
List a primary phone number and an email address for the business. You must provide a contact method that allows a food safety officer or authorised council officer to reach you during standard business hours. If you use a mobile phone, ensure you check messages regularly. Clear communication is a legal requirement when an inspector needs to discuss compliance or urgent matters.
Name of Responsible Manager
Write the full name of the person who manages the business on a daily basis. This person is the primary contact for all food safety matters. They must understand the legal obligations under the Food Act 2003 (NSW), Food Act 1984 (Victoria), or the relevant state or territory legislation in your area.
The responsible manager must ensure the business complies with Food Safety Standard 3.2.2A (Food Safety Management Tools) if it applies to your service type. They must also ensure staff follow Standard 3.2.2 (Food Safety Practices and General Requirements). This standard places a specific legal duty on the food business to ensure that food sold or served is safe and suitable.
Under Standard 3.1.1 (Interpretation and Application), a food business must demonstrate that food is not unsafe or unsuitable. Failing to manage allergens correctly is a breach of these standards because allergenic food becomes unsafe to specific consumers. The responsible manager takes ownership of this risk. They must ensure the allergen management plan is up to date and that every member of the team understands their role in preventing cross contamination.
If the responsible manager changes, you must update this form immediately. Accurate records allow environmental health officers to verify accountability during a routine inspection. It also ensures your staff knows exactly who to approach with questions about ingredients or labelling. Keep this information current to maintain high standards of food safety.
Allergen Policy Statement
A general statement of commitment to customer safety regarding allergens.
Allergen Policy Statement
We are dedicated to providing safe products and services for our customers. Our business is committed to identifying all food allergens present in our operations. We will train our staff thoroughly to manage these risks. We promise to protect customers with allergies by preventing cross-contamination and providing accurate information.
Detailed Policy
Our business takes allergen management seriously. We understand that failing to control allergens can cause severe injury or death to our customers. This policy outlines our approach to handling allergens. We operate in compliance with the Australia New Zealand Food Standards Code. We follow the requirements in Standard 1.2.3 regarding the declaration of allergens on food labels. We also adhere to Standard 1.2.1, which mandates that we must not sell food that is unsafe or unsuitable.
Under the Food Act 2008 in our state and the Food Standards Australia New Zealand Act 1991, food businesses have a legal duty of care. We accept this responsibility. We ensure that all food sold or provided is fit for human consumption. We recognise that undeclared allergens are a significant food safety hazard.
Our approach involves three key areas. The first is identification. We maintain accurate records of every ingredient used in our business. We check supplier labels and specifications for the priority allergens declared by Food Standards Australia New Zealand. These include cereals containing gluten, crustacea, eggs, fish, milk, peanuts, soybeans, tree nuts, sesame seeds, lupin, and sulphites. We verify that recipes and menu descriptions match these ingredients.
The second area is staff training. We train all employees during their induction. We provide regular refresher training. Staff learn how to read labels, store ingredients separately, and clean equipment effectively. We ensure our team knows that they must never guess an ingredient. If a staff member cannot verify the ingredients of a product, they must not serve it to a customer with an allergy. We instruct staff on how to handle customer enquiries regarding allergens safely and honestly.
The third area is control measures. We have strict procedures to prevent cross-contamination. We designate specific areas and utensils for preparing allergen-free meals where practical. We follow colour-coding systems for chopping boards. We ensure cleaning schedules address the removal of allergen proteins from surfaces. We also manage packaging. We ensure pre-packaged foods we sell display the correct allergen warnings.
We review this policy and our allergen management plan annually. We also review it immediately if we change our menu or suppliers. This ensures our practices remain current and compliant with Australian law. Our goal is to ensure every customer feels safe and informed when consuming our food.
Ingredient and Supplier Control
Procedures for checking incoming goods and maintaining ingredient lists.
Ingredient and Supplier Control
Managing ingredients at the loading dock is the first step in preventing allergen contamination. Under the Australia New Zealand Food Standards Code (Standard 1.2.3), you must declare certain allergens on food labels. Your business must verify these declarations before a product enters your store or kitchen.
Receiving Deliveries When a delivery arrives, check the driver and vehicle are clean and suitable for transporting food. Check the temperature of refrigerated or frozen goods immediately. Reject any delivery where the temperature is in the danger zone or if the packaging is damaged. Damaged boxes can lead to cross-contact between allergens.
Checking Labels You must inspect every label on every delivery. Do not assume the product is the same as the last order. Manufacturers often change ingredients without notice. Look for the allergen summary box or the ingredient list. Check specifically for the nine allergens declared under the Food Standards Code. These are cereals containing gluten, crustacea, eggs, fish, milk, peanuts, soybeans, tree nuts, and sesame. You must also check for sulphites in concentrations of 10mg/kg or more. Compare the label against your current product specification sheet. If the information does not match, do not accept the goods.
Recording Allergen Status You need a reliable system to record the allergen status of every ingredient. This is often called an Ingredient Specification Table. When a new product arrives, record the product name, supplier, batch code, and the specific allergens it contains. If a product is free from a specific allergen, record that as well. Keep a copy of the supplier label with your records. If a supplier changes a recipe, you must update your records immediately. This process is essential for complying with Standard 1.2.1 and ensuring you can provide accurate information to customers.
Supplier List Maintain an approved supplier list. Only purchase food from reputable suppliers who comply with food safety laws. If a supplier cannot provide an ingredient specification or allergen information, find a new supplier. Keep this list updated and accessible to staff.
Supplier List
| Supplier Name | Contact Person | Phone Number | Primary Products | |
|---|---|---|---|---|
Storage and Handling Procedures
Steps to prevent cross contamination during storage and preparation.
Storage and Handling Procedures
Effective storage and handling stops allergens spreading to safe food. You must prevent cross-contact. This happens when tiny particles of an allergen transfer to a food that does not contain it. Under the Australia New Zealand Food Standards Code (Standard 3.2.2), you must take all practicable measures to process only safe and suitable food.
Fridge Storage Store food in sealed containers. Label every container clearly with the product name and a ‘contains allergens’ list. Never store allergenic ingredients above other foods. If a container leaks or spills, it must not drip onto food below. Ideally, dedicate a specific shelf for high-risk allergens like nuts or eggs. If you cannot allocate a shelf, store allergens at the bottom of the fridge. This acts as a physical barrier against leaks.
Dry Storage Keep dry goods like flour, nuts, and seeds in airtight containers. Loose packaging creates a high risk of dust and spillage. Place these containers on lower shelves. This prevents heavy containers from falling and spilling onto other items. When using scoop bins, ensure staff use dedicated scoops. Never use a scoop used for a nut mix in a flour bin.
Colour Coded Chopping Boards Use a colour coding system for chopping boards and preparation equipment. This system creates a physical separation between tasks. Use specific colours, such as red or yellow, exclusively for preparing allergenic foods. Use a separate board, often white or green, for preparing allergen-free meals. Staff must know which colour corresponds to which task. Clean boards thoroughly between every use. If you are unsure if a board is clean, wash it again.
Cleaning Protocols Cleaning removes allergens. You must wash, rinse, and sanitise all benches and equipment after handling allergens. Use warm water and food-grade detergent. Sanitiser must meet the requirements of Food Safety Standard 3.2.2. Pay attention to shared equipment like mixers, toasters, and blenders. Wipe down handles and knobs. For deep cleaning of shared equipment, clean it after every use if you use it for both allergenic and non-allergenic foods. Keep a dedicated cleaning cloth for the allergen preparation area to avoid spreading allergens to other surfaces.
Customer Communication
How the business informs customers about allergens on menus and displays.
Menus and display boards must clearly identify all food products containing priority allergens listed in the Australia New Zealand Food Standards Code. You must use the specific allergen names, such as milk, egg, peanut, or tree nut. Avoid vague terms like "seasoning" or "spices" unless the full ingredients are listed nearby. If you use pictures or symbols to highlight allergens, ensure you also include the written word so there is no confusion.
Staff must know how to answer customer questions correctly. Under the Food Standards Code, a food business must provide accurate information regarding the presence of allergens when asked. Train your team to never guess. If a staff member does not know the answer, they must stop and check the product label or ingredient sheet. If they cannot verify the ingredients, they must tell the customer they cannot guarantee the item is safe. Encourage staff to listen carefully and take allergies seriously. It is often safer to say "I do not know" than to guess and cause a reaction.
Special orders require extra care. When a customer asks for a meal without a specific allergen, communicate this request to the kitchen staff clearly. Use a distinct method to mark the order docket, such as writing "ALLERGY" in red ink or using a specific allergy flag system. This ensures the chef and preparation staff see the alert immediately. Designate a specific area or separate coloured chopping board for preparing allergen-free meals to stop cross-contamination. Use clean gloves and wash hands before starting the special order. If you cannot make the dish safely due to shared equipment or ingredients, tell the customer honestly and offer an alternative option.
Keep a copy of ingredient labels for all pre-packaged items used in your kitchen. Store these in a binder accessible to all staff. This allows anyone to check the ingredients for a pre-made sauce or mix quickly if a customer asks. Review your menu and ingredient sheets regularly to ensure the information is up to date. Suppliers sometimes change recipes without notice, so you must check your labels every time you restock. Accurate communication protects your customers and helps you meet your legal obligations.
Staff Training
Requirements and records for staff allergen training.
Staff Training
Every person handling food in your business must understand how to manage allergens safely. Under Food Standard 3.2.2A, a food handler must have the skills and knowledge they need to handle food safely. This specifically includes knowing how to identify the nine declared allergens in Australia and preventing cross-contamination.
You cannot assume staff know how to handle allergens just because they have worked in food before. You must provide specific training and keep records to prove it. Food safety auditors and local councils will ask for these records during an inspection.
Training must cover the following topics in plain English.
Mandatory Training Topics
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The Priority Allergens Staff must be able to identify and name the nine allergens declared by Food Standards Australia New Zealand (FSANZ). These are peanuts, tree nuts, milk, eggs, fish, shellfish, sesame, soy, and lupin. Staff must also understand that gluten containing cereals (wheat, barley, rye, and oats) are a key allergen management risk.
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Reading Labels and Information Staff need training on how to read supplier labels and ingredient specifications. They must check for hidden allergens in pre-mixed sauces, marinades, and garnishes. If a product does not have a label, staff must know they cannot use it.
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Preventing Cross-Contamination This is critical for tradespeople and small businesses using shared vans or equipment. Train staff on how to store allergen-free meals separately. They must understand colour coding systems for chopping boards and containers. Staff must know to wash hands thoroughly with soap and warm water and change gloves between handling different meals.
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Serving Customers and Communication Front of house staff and kitchen hands must know how to communicate. If a customer declares an allergy, the order process must be clear. Deliver drivers must check the docket for special allergy stickers or alerts and ensure allergen-free meals stay sealed and separate from other food during transport.
Keep a record of every training session. The table below helps you track who has been trained, when they completed it, and what topics you covered. Update this register every time you hire a new staff member or change a menu item.
Training Register
| Staff Name | Role | Training Date | Topics Covered | Trainer Signature | Staff Signature |
|---|---|---|---|---|---|
Frequently Asked Questions
What is a Allergen Management Plan?
When do I need a Allergen Management Plan?
Is a Allergen Management Plan legally required in Australia?
What are the 9 allergens that must be declared in Australia?
How do I handle cross contamination in my kitchen?
What should staff do if a customer has an allergic reaction?
Can I say my food is 'may contain' nuts?
How often should I review my Allergen Management Plan?
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This document involves significant legal or financial considerations. Professional review is strongly recommended.