Allergens — what Ohio requires you to know, and what it requires your staff to be able to say

Allergens sit in an odd place in most kitchens. Everyone knows they matter, the knowledge lives with whoever happens to have it, and nothing about the arrangement is written down until someone asks.

Ohio’s code is more specific than that, and in two separate places.

Two duties, not one

The person in charge has to be able to identify them. Identifying major food allergens is listed among the things a person in charge must demonstrate knowledge of.¹ That is a competency an inspector can ask about, in the same category as the other things the person in charge is expected to know on demand.

Employees have to be trained to talk about them. The rule requires that employees are properly trained in food safety, including food allergy awareness, as it relates to their assigned duties — and then defines what that covers:

Food allergy awareness includes describing foods identified as major food allergens and the symptoms that a major food allergen could cause in a sensitive individual who has an allergic reaction.¹

Read the second one carefully, because it is more demanding than it first looks. The standard is not “staff know we have a nut dish.” It is that they can describe which foods are major allergens and describe the symptoms a reaction produces. Those are two different pieces of knowledge, and the second one is the piece almost nobody trains.

“As it relates to their assigned duties” does real work too. A server taking the question and a cook plating the dish need different things from this — but neither of them needs nothing.

The list, and the item people miss

Ohio defines a major food allergen as:

Milk, egg, fish (such as bass, flounder, cod, and including crustacean shellfish such as crab, lobster, or shrimp), tree nuts (such as almonds, pecans, or walnuts), wheat, peanuts, soybeans, and sesame²

Plus any food ingredient that contains protein derived from one of those.²

Crustacean shellfish is the trap. Count the items in that sentence and you get eight, and shellfish does not appear to be among them — it is folded inside the fish entry. Shrimp is a major allergen in Ohio; it is simply not listed on its own line. Anyone building an allergen matrix by transcribing the list in order will produce one with a hole in it exactly where shrimp goes, which in a Cleveland kitchen is not a hypothetical hole.

Sesame is on the list. If your training material, your allergen chart or your recipe tags predate its addition, they are out of date. This is the single most common way a kitchen’s allergen documentation quietly falls behind.

What is not covered

Two exclusions, both in the definition:

• Highly refined oil derived from one of the listed foods, and any ingredient derived from such oil.²
• Ingredients exempted through the petition or notification process under the federal Food Allergen Labeling and Consumer Protection Act of 2004.²

The refined oil exclusion is the one that comes up in practice — highly refined peanut oil is treated differently from peanuts. Note the qualifier doing the work: highly refined. Cold-pressed, expelled or extruded oils are not the same product, and a guest asking about peanut oil is usually asking a question you should answer specifically rather than from the general rule.

Cross-contact is not cleaning

The code obligations above are about knowledge. The part that actually protects a guest is procedural, and it is the part most easily confused with sanitation.

Washing removes soil. It does not follow that every surface, tool and hand that touched an allergen is free of allergen protein by the time the next dish is made — and unlike a pathogen, the answer is not temperature. You cannot cook out an allergen.

Which means an allergen order needs its own procedure rather than a more careful version of the normal one:

• Dedicated or freshly washed tools, not the ones in the current rotation
• Fresh gloves, and hands washed between
• Order of preparation — the allergen-free plate made first, before the station is contaminated, rather than fitted in wherever it lands
• A named person who confirms it, so the responsibility does not dissolve between the server who took the order and the line that made it
• The fryer question, which is the one that catches people: a shared fryer is shared, and breaded shrimp and french fries out of the same oil is a cross-contact issue regardless of how clean the oil looks

Fitting that into a service depends entirely on your layout — see where things go in a commercial kitchen if you are still designing, because a station with no clean landing space makes the correct procedure physically awkward, and procedures that are awkward do not survive a Friday.

Where this shows up

In an inspection, through the person in charge being asked what they know and employees being expected to have been trained.¹ The inspection checklist covers the wider picture of what is being assessed.

In food safety certification, which is the formal route by which the person in charge acquires the knowledge the rule expects.

And in the ordinary run of service, where the actual question is whether the server who takes an allergy at table nine can describe what happens if it goes wrong. The rule says they should be able to.¹ It is worth finding out, before someone else does.

The short version

• The person in charge must be able to identify major food allergens.¹
• Employees must be trained in food allergy awareness — describing the allergens and the symptoms of a reaction.¹
• Ohio’s list: milk, egg, fish including crustacean shellfish, tree nuts, wheat, peanuts, soybeans, sesame.²
• Highly refined oils and FALCPA-exempted ingredients are excluded.²
• Cross-contact is a procedure problem, not a cleaning problem, and no temperature fixes it.

This page describes the code requirements as they read on the date at the top. It is not medical guidance, and a guest telling you about a severe allergy is describing a risk to their life rather than a preference — treat the conversation accordingly.