I heard it from multiple foodservice professionals just last week: “FDA delayed menu labeling so maybe we should just pick this up again next year.” GULP.
I get it – I do. In the foodservice business we are constantly challenged with competing priorities. When the opportunity arises to delay working on just one of them, it’s hard not to take it. If you have nutrition information ready for each of your menu items, you probably can. If you have experience with menu labeling in a state or municipality that already requires it, you probably can. But if you are starting from scratch I can give you dozens of reasons not to take your foot off the gas. For the sake of brevity, I’ll focus on three.
ONE: Analyzing your recipes will take you longer than you think. Even if you have standardized recipes in play, they don’t necessarily contain all of the information you need for accurate nutrient analysis. Calculated nutrition analysis (using a software program and ingredient data) is generally based on weights – not measures. Scoops, spoodles and sprinkles will need to be translated into weights through weighing and measuring in the kitchen. For some products, pre- and post-cooked weights will be needed to determine a final yield for the analysis to be accurate. These activities are incremental work that can put a strain on your culinary team. Allowing them to plan ahead and stage this work across several months can help control the chaos and decrease the chance of error. And don’t forget, while you can use “standard” USDA data for certain commodity items – like lettuce, tomato and low-fat milk – you’ll need the nutrition data for the proprietary products you use. Because gathering this data from the manufacturer takes time (and you can’t do your analysis without it!), you won’t want to leave it to the last minute.
TIP: Even if you aren’t ready to begin analyzing recipes, consider having an expert evaluate your recipes now to identify 1) additional information, weights or measures that will need to be provided for an accurate analysis and 2) ingredient information that will need to be gathered. This will allow you to build and prioritize a to-do list that can be staged in an organized way in the months ahead, making recipe analysis less daunting when you want to cross that bridge.
TWO: The door for formal guidance from FDA is just about to close. If you’ve been engaged in the regulation (all 350+ pages of it), you know there is a fair amount of ambiguity in the rule. FDA has been busy gathering questions from the food industry and we are hopeful the Guidance Document they are scheduled to publish (this summer, we’ve been told) will answer most of our burning questions. However, it may not address your questions. Even worse – you may find some of FDA’s answers are unworkable for your business. Why is this important? The Guidance Document will be open for public comment before being finalized. This means you have one more opportunity to get formal, written answers that clarify what is needed to be compliant. If you haven’t tried to apply the regulations to your menus, menu boards or self-service foods, you likely don’t know what your questions are or – more importantly – what answers you want. This means you won’t be prepared to engage in this process – either directly with FDA or through your industry association. Having clear, written guidance should not be undervalued. Without it you may be forced to contend with a local regulator enforcing the rule based on their interpretation of unclear guidance. What other choice will they have?
THREE: Use the gift of time to test your way through it. We test everything in the foodservice business – so why not this? Nobody can say with much certainly how menu labeling will change consumer behavior. However, we do know a shift in menu item preference has a ripple effect– with potential to impact margins, par pulls, inventory and more. While most operators can adjust on the fly (it is what you are built to do, after all!), testing in a few locations or a small market may help you project and plan for the impact. And remember, testing calories on the menu shouldn’t be limited to measuring consumer behavior. Use the opportunity to determine what needs to be done to prepare your operators, too. What questions did your customers ask? Are your servers prepared to answer them? Do any improvements need to be made to the staff training materials? Did your process for having “full nutrition information available upon request” work? Ironing out these small details before rolling out on a large scale could help to control the chaos.
December 1, 2016 will be here before you know it. Don’t drag your feet for too long. Instead, use the gift of time to take a thoughtful, organized approach to compliance. www.cldnutrition.com