Photograph by Gecko Studio for Adobe Stock
New food-labeling legislation will force change. But it will not fix the problem of labeling dishes properly on its own. Supply chains shift, products change, and what was accurate last month might not be accurate today. Labels that are not connected to a dynamic, recipe-level system will fail.
And if a serious allergy incident happens at an event, liability won't stop at the kitchen door.
Industry attorney Joshua Grimes, speaking on episode #275 of Eating at a Meeting, noted that in a meeting or conference context, the plaintif (the person with the allergy or suing on their behalf) generally will sue everyone in the chain: the host organization, the independent planner (if there is one), the venue and the brand. His conclusion: Allergen management now belongs alongside force majeure and ADA access as a due-diligence item for planners. Ask about a venue’s capabilities. Ask about their track record. Build indemnification and clear responsibility language into your contracts.
In the same episode, civil-rights attorney Mary Vargas added a harder edge: You cannot contract away basic legal obligations. A hotel email that says, "We can’t be responsible if attendees don’t predisclose their allergies" does nothing for the guest standing at an unlabeled buffet. A knee-jerk "We just won’t accommodate you" response to allergy risk can veer into disability discrimination — and it certainly doesn’t build trust.
The lesson for planners is this: You can’t own the kitchen, but you do own your due diligence, including which venue you choose, what you ask for from the chef, and what you put in writing on buffets and menus.
Planners' biggest risks and what to do
Risk 1: Assuming venue compliance covers your event
Legally, the obligation to comply with allergen-disclosure laws sits with the food facility. Reputationally, the fallout lands on the organizer. If a guest is harmed, your client and your attendees will not split hairs over whether it was the hotel’s label or your banquet event order that failed.
What to do: Require written allergen disclosure for all buffets and plated meals in your contracts now, regardless of whether the law technically compels it. Make it a condition of doing business, not just of passing inspection.
Risk 2: Treating registration data as compliance
Collecting dietary needs at registration is data collection, not compliance. A spreadsheet of allergies that stops at your desk or in the catering office doesn’t protect anyone. If that information never turns into recipes, labels, and clearly marked plates or buffets, it is just a list.
What to do: Map the path from the registration form to the plate. Who receives the data, how is it translated into menus and labels, and how does it reach the guest at point of service? Build allergen communication into BEOs, run-of-show documents and precon meetings. Assign one on-site point person who is empowered to advocate for guests with dietary needs.
Risk 3: Not asking whether your partners have a system
Regulators have said they will look for a consistent process for determining allergen content, such as ingredient-tracking, supplier documentation, recipe databases, and/or internal allergen reference tools. Unfortunately, many operators still rely on ad-hoc memory and last-minute tent cards.
What to do: Ask every venue and catering partner the same question an inspector would: "How do you determine and keep current the allergen information for each menu item? Show me your process." Favor partners who can demonstrate a recipe-level system that flows from purchasing through prep to labeling — not making just day-of labels.
Risk 4: Stopping at the Big 9
The food-labeling laws that are being built in various states require disclosure of the nine major allergens. But more than 170 foods are known to cause reactions, and advocates in Michigan and elsewhere already are pushing to add rye, barley and other triggers to the list. Remember that the legal minimum and your guests’ actual needs are different lists.
What to do: Use the Big 9 as your baseline for labeling. Require your partners to identify and label any additional allergens your attendees have disclosed on their registration forms — whether or not these items are in the statute.