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Is menu labeling in your retailer’s future? FDA’s final rule requires chain restaurants and similar retail food establishments with 20 or more locations to post calories on menus and menu boards and to provide other nutrient information in writing by Dec. 1, 2016.
To prepare, you’re likely investigating the cost of analyzing the nutrition information for your recipes. Depending on the type and number of “restaurant type foods” you offer, hiring an expert could run several thousand dollars—tough news to swallow in the low-margin supermarket industry.
It’s tempting to minimize costs by using the least expensive nutrition analysis software and assigning the work to a staffer with little or no recipe analysis experience. After all, it’s just adding up the nutrition numbers for each ingredient, right? Wrong.
The Risks of Do-It-Yourself Recipe Analysis
With few exceptions, calculated recipe analysis (using ingredient information and a software program) is anything but a simple exercise of addition. Calculated recipe analysis uses accurate nutrient information for exact amounts of specific ingredients and then adjusts for any preparation or cooking technique — an undertaking that requires an in-depth knowledge of food and nutrition.
Consider your deli’s fried chicken. You can’t simply use supplier nutrition information for the raw product because the calories declared must represent the food as prepared and served. Once the chicken goes in the fryer, the nutrient composition changes significantly. The chicken loses moisture and takes on fat. But how much? And what does that mean for the calories declared? Only a knowledgeable food expert can apply an educated calculation that reflects the food as prepared and offered for sale. And that expert knows it’s best to send fried foods to an accredited laboratory for chemical analysis—a best practice in the food industry for getting accurate results.
Fried foods aren’t the only ones that are tricky to calculate. Take pasta salads. It seems like adding up the nutrition information from the Nutrition Facts Panel (NFP) of each ingredient should work, but it doesn’t. The NFP numbers are rounded according to FDA regulations. Some nutrients may be rounded up and some down. Scaling rounded information (for instance, the NFP amount is one tablespoon but your recipe uses 1/3 of a cup), results in an inaccurate nutrient analysis—sometimes significantly so. And what about that the pasta in your recipe? The nutrition information on the NFP is for uncooked pasta when your recipe likely calls for cooked pasta. A skilled nutrition professional can translate uncooked nutritionals into cooked nutritionals, according to your procedures.
The more cooking you do in-house, the more complicated your recipe analysis becomes. How much marinade did the chicken retain and how does that impact sodium values? How much water evaporated from the soup as it cooked and how does that impact total yield and calories? How much sodium does pasta cooked in salted water retain? These are just a few questions that show the complexity of recipe nutrient analysis.
It’s worth noting that any recipe analysis won’t be exact, even by an expert. Calculated recipe analysis is, by design, an estimate. However, it’s incumbent upon you to be as accurate as possible. Hiring an expert to analyze your recipes costs money, but the cost of not doing it right can be exponentially higher. There’s the very real threat of an audit and penalty from FDA—and risk to your reputation from bad PR and the resulting consumer distrust.
Steps for Success
Menu labeling is not a one-time event, but will soon be a routine part of your go-to-market process. These steps can help you establish a method that works long-term for your organization.
- Plan the entire project. Start by developing a complete picture of all your menu items and recipes. Identifying sub-recipes, batches and item variations helps determine the most efficient way to approach the work. Without careful examination of how your recipes are built, you run the risk of creating inefficiencies in time and cost. Make sure your recipes are clear and complete.
- Leverage an expert. Ideally, you’ll utilize an expert with at least two years of experience performing recipe analysis. If you don’t have an expert on staff, contract the work to a consultant or organization that can provide the expertise you need. Fees range from $75 to $250 per recipe, so budget accordingly. If you must assign this work to an inexperienced employee, consider hiring a consultant to teach and mentor your internal staff via an hourly contract or project fee. Consultants may also be willing to spot check or verify recipes for a reduced fee.
- Appoint an internal project leader. This person can establish clear roles and responsibilities for the project and keep it on track. If you’re outsourcing the work, the project leader can organize the work and answer questions. Even if you keep the work internal, designating a project leader will help facilitate the process.
- Organize your documentation. FDA requires specific documentation to show a “reasonable basis” for menu item calorie declarations. Review FDA’s guidance for industry before you begin recipe analysis to make sure you generate the required reports and documentation.
- Send fried foods to the lab. It’s costly, but highly recommended. As discussed, factors such as moisture loss and fat absorption make it difficult to get accurate results from a calculated approach. Lab fees range from $450 to $1,000 per item, so get quotes from several labs. And plan ahead — it usually takes 10 to 21 days to receive the results.