The document discusses strategies for restaurants to comply with upcoming menu labeling regulations, including creating a timeline to analyze nutritional data, source labeling providers, gather supplier information, and replace menus and educate staff on the new labeling requirements which restaurants will have at least 6 months to implement following the finalization of rules expected in November 2012. It emphasizes being prepared and having a plan to accurately analyze and disclose calorie and nutrient information on menus.
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Menu Labeling Compliance Plan
1. Menu Labeling: Mitigation of Risk
Gillian Dagan, Ph.D. Ivy Cho
Cheif Scienctific Officer Business Developement
ABC Research Laboratories
2. General Menu Labeling Update
• NRA 2012: likely that final rules for
menu labeling will debut in November
2012
• Implementation Period: at least 6
months
• Preparation is Key!
• This is coming--have a plan of attack
3. Create a Timeline
• Examine the implementation period
and work backwards on a timeline
• How long will it take to replace all
menus, menu boards, and drive-thru
menus?
• How long will it take to get a final draft
for all printed materials including
menus, boards, and additional
pamphlets?
4. Create a Timeline
• How long will it take to organize all
data and reportion items if necessary?
• How long will it take to get full lab
analysis on cooked items?
• How long will it take to generate
database nutritional analysis for simple
items like salads and sandwiches?
5. Create a Timeline
• How long will it take to gather
nutritional data from suppliers for items
like sauces and dressings?
• What is the time required to source
labeling quotes and budget for this
work?
Six months is a JOKE!
6. Responsible Sourcing
• What questions should I ask when
looking for a nutritional labeling
provider?
– I’m worried about accuracy—How do I
know the values are correct?
– What if someone questions my nutritional
values? What type of support can I
receive after the analysis is completed?
7. Gathering Information: Suppliers
• Request 100 gram, unrounded
nutritional data from your suppliers
• Prevent rounding errors and omission
of information
• Is zero grams of fat really zero?
8. Proper Use of Database Labels
• In this method, formulations are used
to estimate nutritional value
– Manufacturers’ 100 gram unrounded
nutritional values are needed to create a
database label in your specific serving
size
• This is appropriate for menu items that
will see little to no changes during
preparation or cooking
– Examples are salads, dressings, sauces
9. Full Laboratory Analysis
• Menu items are physically analyzed
using official validated methods by an
ISO 17025 accredited laboratory
• This is appropriate for menu items that
undergo changes during preparation
or cooking
– Examples are any menu item that is
fried, baked, sautéed, or grilled
10. Debating the Type of
Analysis Used
• Hashbrowns and Chicken Wings
– By Database analysis, you will see higher
contributions to calories, fat, sodium
– By Full Laboratory analysis, you will see
accurate values for all nutritional
information
11. Portioning on Your Menu
• Do I want to revise serving sizes based
on data collected?
• Variable Menu Items can be shown as
an average, median, or range caloric
values
– An example is a buffet institution
12. Required Statements and
Optional Text for Menus
• What must be disclosed?
– Calories
– Succinct statement for daily intake
– Statement of additional nutritional
information available
• What is voluntary?
– Allergen declaration
13. Replace Menus and Educate
Your Staff
• Things to consider
– Timeline to educate staff at each of your
20+ restaurants on healthier menu
options, where they can find the
additional nutritional information should a
customer ask for it
– Training of staff to know the answer to the
question: “I’m allergic to peanuts, does
this sauce contain peanuts?”
14. Replace Menus and Educate
Your Staff
• Timeline to replace all menu boards:
drive-thru board, in-house board, take-
out menus, etc.
• New advertisement for the menu items
found to be low in
calories, sodium, etc