allergen-and-food-hygiene-training-record

---
name: allergen-and-food-hygiene-training-record
description: Builds the training record that proves staff were supervised, instructed or trained in food hygiene commensurate with their work, and that allergen information on anything prepacked for direct sale meets the labelling law that followed Natasha Ednan-Laperouse's death. It works out who handles food and who does not, logs the FSA's own free allergen course against named staff rather than a generic "allergen trained" tick, and keeps the record separate from the labelling fix, because training staff and labelling food are two different legal duties. Use before a new starter handles food unsupervised, and before you assume last year's induction covered this year's menu.
---

# The record that proves who was trained, on what, and when

You give this the staff list with start dates and roles, what training each person has done and when, and whether the venue sells anything prepacked before a customer orders it. You get back a training record per person against Annex II Chapter XII's own wording, a separate labelling check for anything prepacked for direct sale, and a list of anyone handling food with no training record at all.

## What it does

1. **Ground the duty in the regulation that actually creates it, not in a Level 2 certificate nobody is legally required to hold.** Retained EU Regulation (EC) No 852/2004, Annex II, Chapter XII, paragraph 1 requires "that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity." The duty is supervision, instruction or training fitted to the job, not a named qualification. A kitchen porter and a chef preparing allergen-sensitive dishes unsupervised do not need the same thing, and the record says why each got what they got.
2. **Use the FSA's own free course, and record exactly what it is.** The Food Standards Agency's allergy training site states the training was "developed by the Food Standards Agency (FSA)" and runs to "six Modules which include a knowledge check at the end of each one." It is free and online. But the FSA is explicit about its limits: completion "does not constitute accreditation, approval, endorsement, authorisation, licensing" and "should not be relied upon as evidence of competence" on its own. The skill logs it as what it is, one input to competence, not a certificate that ends the conversation.
3. **Separate the training record from the Natasha's Law labelling fix, because they are different duties with different triggers.** The Food Information (Amendment) (England) Regulations 2019 inserted regulation 5A, requiring that prepacked for direct sale (PPDS) food carry allergen labelling under "Article 9(1)(c) (labelling of certain substances or products causing allergies or intolerances)", in force from "1st October 2021." That law is about what goes on the label; it says nothing about staff training. A venue can have perfect labels and untrained staff, or trained staff and no labels on a new sandwich line. The skill checks both and never lets a pass on one stand in for the other.
4. **Weight supervision toward new, agency and temporary staff, not evenly across the team.** The commensurate test in Chapter XII means a new starter awaiting formal training needs closer supervision than someone three years in, and the record names who is on heightened supervision and until when, rather than treating "trained" as one flag that is either on or off.
5. **Record the 14 major allergens against the menu, not against a generic poster.** The labelling duty traces to Article 9(1)(c) of retained Regulation 1169/2011, which lists the substances causing allergies or intolerances that must be declared. The skill checks the current menu against that list dish by dish, because a new special added last Tuesday is not covered by a laminated poster printed two years ago.

## Then it checks

1. Every person who handles food has a training record naming what supervision, instruction or training they received and when, matched to their actual role.
2. New, agency or temporary staff awaiting formal training are flagged as such, with the date that status ends.
3. The FSA course, where used, is recorded as what it is, not relabelled as a qualification or certificate.
4. Anything sold prepacked before the customer orders it is checked against the PPDS labelling rule separately from the training record.
5. The current menu, including anything added since the last check, is matched against the 14 major allergens, dish by dish.
6. Nobody on the food-handling staff list has a blank training record.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never state that a Level 2 food hygiene certificate is a legal requirement, because the regulation requires training commensurate with the role, not a named qualification.
- Never treat the FSA's free course as a substitute for competence, and never present it to the owner as accreditation.
- Never confirm an allergen is absent from a dish without a supplied recipe or supplier spec to check it against; "probably doesn't have it" is recorded as unverified, not as clear.

## Built from
- Regulation (EC) No 852/2004, Annex II, Chapter XII, paragraph 1 (as retained in UK law), https://www.legislation.gov.uk/eur/2004/852/annex/II/chapter/XII, read 4 November 2026: the supervision, instruction and training duty behind steps 1 and 4.
- Food Standards Agency, food allergy and intolerance online training, https://allergytraining.food.gov.uk/, read 4 November 2026: the course's structure, audience and accreditation limits behind step 2.
- The Food Information (Amendment) (England) Regulations 2019, SI 2019/1218, https://www.legislation.gov.uk/uksi/2019/1218/made, in force 1 October 2021, read 4 November 2026: the PPDS labelling duty and its Article 9(1)(c) basis behind steps 3 and 5.

# allergen-and-food-hygiene-training-record

## You are given
The staff list with start date, role, and whether the role handles food. For each person: training completed, provider, date, and whether it was the FSA's free online allergy course, an external Level 2 or 3 course, or in-house instruction. Whether each new, agency or temporary starter is still under heightened supervision and the date that ends. The current menu list with each dish's recipe or supplier spec where held. Whether the venue sells anything prepacked before a customer orders or selects it (PPDS).

## Produce
Write into a `./allergen-and-food-hygiene-training-record-output/` folder:

1. `training-record.csv` with columns: `staff_name`, `role`, `handles_food`, `start_date`, `training_type` (exactly one of `fsa_free_course`, `external_level_2`, `external_level_3`, `in_house_instruction`, `none`), `training_provider`, `training_date`, `heightened_supervision`, `supervision_end_date`. `handles_food` and `heightened_supervision` are `yes` or `no`.
2. `untrained-food-handlers.csv` with columns: `staff_name`, `role`, `start_date`, `days_since_start`. One row per person where `handles_food` is `yes` and `training_type` is `none`.
3. `allergen-menu-check.csv` with columns: `dish_name`, `recipe_or_spec_supplied`, `allergen_checked`, `allergen_present`, `allergen_status`. One row per dish per each of the 14 major allergens (celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide/sulphites, tree nuts). `recipe_or_spec_supplied` is `yes` or `no`. `allergen_status` is exactly one of `confirmed present`, `confirmed absent`, `unverified - no recipe or spec supplied`.
4. `ppds-labelling-check.csv` with columns: `product_name`, `is_ppds`, `label_shows_food_name`, `label_shows_ingredients_list`, `label_emphasises_allergens`, `verdict`. `is_ppds` is `yes` or `no`, decided from the supplied description of when the food is packaged relative to the customer's order. `verdict` is `compliant`, `not compliant`, or `not applicable - not PPDS`.
5. `gaps.md` - a numbered list of: every row in `untrained-food-handlers.csv`; every dish in `allergen-menu-check.csv` with `allergen_status` of `unverified - no recipe or spec supplied`; every `ppds-labelling-check.csv` row with verdict `not compliant`; and anyone on heightened supervision whose `supervision_end_date` has already passed.

## Rules
- Codex counts, checks and records. It never decides whether a dish actually contains an allergen without a supplied recipe or spec, never writes a recipe, and never tells the owner a named qualification is legally required.
- Never mark `allergen_status` as `confirmed absent` without a supplied recipe or supplier spec showing it. No supplied document means `unverified`, never assumed safe.
- Never record the FSA free course as `external_level_2` or any other qualification type; it is logged as `fsa_free_course` and nothing else.
- `days_since_start` is counted, not estimated, from the supplied start date to today.
- Use British English, GBP and DD Month YYYY dates. No em dashes in any file you write.
- Every file ends with this line: this is a working document prepared for the owner to check against their own training records, recipes and supplier specifications, and for their environmental health officer or solicitor to check any disputed allergen or labelling question. It is not legal or food safety advice.

## Return
The absolute path of each file written and the row count of each CSV. The number of food handlers with no training record, named individually. The number of dishes with an unverified allergen status. The number of PPDS products marked not compliant, named individually. The `gaps.md` item count.