Food Allergy Policies

Whitsons' Allergens & Special Dietary Needs Policy

SESAME AS NINTH ALLERGEN (Beginning January 1, 2023)

Whitsons Position

Upon the release of the 2021 FASTER Act, Whitsons proactively added sesame as the 9^th allergen call-out in Dine Central. Over the past several months all products containing sesame, or its by-product, have had the allergen called out on the DC allergen report. To further support and address the increased incidents of allergic reactions to sesame, Whitsons continues to minimize the use of products containing this allergen. In addition, we have eliminated the use of sesame oil in all of our recipes and we do not allow sesame seeds in any recipes. However, all of the commercial bakeries we purchase from will begin using sesame flour effective 1/1/23. FD Meal Planner and all associated records will be updated showing bread having a sesame allergen.

Vendor & Product Procurement Standards

Whitsons maintains meticulous records of all food products purchased through its systems companywide, not just in school nutrition. Part of Whitsons' approach to the marketplace is to manage the entire food supply chain, from origination through manufacturing, warehousing and delivery.

Whitsons School Nutrition policy is to procure products that do not contain peanuts or tree nuts as an ingredient. For manufacturers that process peanuts and tree nuts, specifically, Whitsons gives preference to suppliers whose plants use separate equipment and separate rooms to process products that are free of these allergens. Regardless of preference, all suppliers must demonstrate adherence to our stringent vetting process and have Good Manufacturing Practices (GMPs) and effective Sanitation Standard Operating Procedures (SSOPs) in place to eliminate the possibility of cross-contamination from inadvertent allergens during the manufacturing process.

Whitsons thoroughly vets all manufacturer partners prior to receiving their products. The vetting process requires Letters of Guarantee, Certificates of Insurance and a completed Food Safety and Defense Questionnaire. These documents provide information regarding the suppliers’ HACCP plans and allergen handling procedures. In addition, Whitsons requires our manufacturing partners belong to the Global Food Safety Initiative (GFSI), which uses internationally recognized standards for GMPs, the highest safety and quality standards in the world. If not already certified, we provide a reasonable time period for our suppliers to obtain certification.

Periodically our audit team reviews third party audit and QA inspection results and conducts random facility inspections at our suppliers’ manufacturing plants to ensure GMPs are being followed. Manufacturers that do not continue to meet these rigorous standards are prohibited from remaining our partners.

Product specification sheets for each product we source are carefully reviewed by the Purchasing and Nutrition Departments for accuracy. This information is incorporated into Whitsons’ comprehensive recipe database, where we maintain information regarding ingredients, nutritionals and allergens for each menu item we serve.

New FDA food Allergens Effective January 2023 (Top NINE)

1. Milk

2. Egg

3. Fish

4. Crustacean shellfish

5. Tree nut

6. Wheat

7. Peanuts

8. Soybeans

9. Sesame

Students and parents can access nutrition and allergen information easily by visiting their school district website, viewing our online menus and clicking on any day’s menu to see allergens and nutrition information. Detailed ingredient declarations for each product can be obtained from the Food Service Director (FSD). Since Whitsons goes to great lengths to review products from origination through manufacturing and the distribution process, we have developed a strong allergen policy. Considering the sensitivity of the allergen issue in school nutrition today, it is extremely important that you read and understand the policy below.

Allergen & Special Dietary Needs Policy Overview

As your school foodservice provider, Whitsons recognizes the importance of its role in helping to prevent food-related allergic reactions in our school cafeterias. Food allergies and sensitivities can be dangerous or even life-threatening to those exposed. Accidental exposure to foods that trigger allergies or sensitivities can be reduced in the school setting if we work together with students, parents and the district to minimize risk and provide a safe dining environment for students with food allergies and sensitivities.

You are legally required to have a printed list of foods, what we call an “Allergen Report” in each school cafeteria which details the foods on our menus that contain the most common food allergens. Food allergens are listed in the report and are based on the districts monthly menu. The "Allergen Report" should be updated monthly through Dine Central by the Food Service Director based on the monthly menu offerings.

Inadvertent Allergens, GMPs and SSOPs

Please note that we only list the Top 8 Allergens that are actually present as an ingredient in the foods we serve. We do not list manufacturers who may also process allergens such as peanuts and tree nuts in other products they produce in the same facility or on shared equipment. This is because we require all our manufacturers to have GMPs and SSOPs in place to eliminate the possibility of cross-contamination from inadvertent allergens in the manufacturing process. For more information regarding inadvertent allergens please click here to view our Allergen Policy Memo.

Whitsons does all it can within to ensure the wholesomeness of the products that arrive into our schools daily. From the point of delivery on, it is the foodservice director’s job to ensure that all the proper HACCP controls are in place with the team. Furthermore, we run allergen-training classes to educate food service workers on the sensitivities of handling allergens to prevent cross-contamination inside the kitchen and on the serving line.

Whitsons does all it can to ensure the wholesomeness of the products that arrive into our schools daily. From the point of delivery on, it is the FSD’s job to ensure that all the proper HACCP controls are in place with the team. Furthermore, we run allergen-training classes to educate Food Service Workers (FSWs) on the sensitivities of handling allergens to prevent cross-contamination inside the kitchen and on the serving line.

Cautionary Recommendations for Cross Contamination in Schools

Even with all these controls already in place, Whitsons cannot guarantee that all food products will be completely 100% allergen-free at the time of consumption. Although Whitsons has implemented proper handling procedures and protocols within the areas it controls (including HACCP and Food Defense Plans), Whitsons cannot control and cannot be held liable for potential cross-contamination occurring in areas outside of its control.

Such inadvertent cross-contamination could occur while food products are transported by third party carriers or due to the presence of allergenic particles in the ambient air within the food preparation or dining areas, where other students may be consuming allergen-containing foods. However, we take every precaution within our control to reduce that risk. Whitsons’ recommended course of action to ensure the safety of students with food allergies and sensitivities is for the on-site manager to collaborate directly with students, parents and district nutritional staff to create an individual meal plan to accommodate students with dietary restrictions or special dietary needs. If a student has a food allergy and does not see the item he/she wishes to consume listed in the allergen report, DO NOT ASSUME IT IS SAFE TO EAT WITHOUT FIRST CHECKING WITH THE WHITSONS ON SITE MANAGER AND/OR THE PRODUCT MANUFACTURER DIRECTLY. MANUFACTURERS ROUTINELY CHANGE INGREDIENTS AND ARE NOT REQUIRED TO ALERT US! To help FSDs better manage food allergens, sensitivities and cross-contamination in their districts, supplies may be ordered through the Sam Tell. It is important that our allergen policy is made available in the cafeteria.

Procedures For Accommodating Student with Food Allergens and Special Dietary Requests

Schools that participate in the National School Lunch Program (NSLP) and School Breakfast Program (SBP) must make reasonable meal or food substitutions/modifications, at no additional cost, for students whose allergies are considered disabilities or which may substantially limit a major life activity. Additionally, a school district (and its food service operation) may be required to make food substitutions for students with allergies or other medical conditions that may substantially limit a major life activity when medically necessary and prescribed by a licensed physician. A non-life-threatening allergy may also be considered a disability and require a meal modification if it impacts a major bodily function or other major life activity (such as digestion, respiration, immune response, skin rash, etc.). Disabilities and special dietary needs like these can be difficult to manage in a hectic school environment. Whitsons has created the Food Allergy and Special Dietary Needs Manual to address the policies, procedures and practices of Whitsons School Nutrition to address allergens and special dietary needs, to control the presence of allergens in the food products it serves, and to prevent allergic reactions by the students who consume its food.

Included in this manual is information regarding texture modifications, Whitsons' food allergen policy and standard operating procedures for managing students with food allergies and special dietary needs. It provides the FSD with guidance on how to manage texture modifications, how to identify if a student has a documented disability or an intolerance, (for example, a milk allergy vs. lactose intolerance), and how to handle accommodations for this student. It also goes into further detail regarding Whitsons' allergen policy and responsibilities of the school nutrition staff to prevent cross contamination and/or allergic reactions