A questionof waste
THE attention focused on the due diligence requirements of the Food Safety Act 1990 has tended to overshadow environmental legislation which is potentially just as onerous for many caterers.
Separate duty of care legislation lays responsibility for safe disposal of waste squarely on the shoulders of the businesses which generate it. Basically, every caterer must ensure that all waste materials are stored securely and disposed of by a legally registered contractor. Failure to do so can result in unlimited fines.
Since it is intended to be self-regulating, duty of care works in a similar way to due diligence - caterers must be able to demonstate that they have taken all reasonable care to meet the requirements. That means maintaining records that specify the nature of the waste, which company and driver was employed to remove it, and when and where it was dumped.
LOW AWARENESS
Just how many catering establishments are documenting their waste management to this level of detail is open to conjecture. A survey last year of 454 businesses found two-thirds of respondents had not heard of duty of care. Of those who had, only 3% appeared to fully understand their obligations under it, according to Barbara Leach of MEL Research Waste Management Unit, which undertook the survey on behalf of the Department of the Environment. Around 50 of the respondents were in the hotel and catering sector.
Why such low awareness? Leach suggests that, because duty of care is intended to be self-regulating, policing has yet to receive high priority from local council waste authorities. This is confirmed by Peter Bayliss, executive chef at Leicester's Holiday Inn. Bayliss points out that although there are supposedly "horrendous" fines imposed on anyone using unlicensed removers and/or fly-tipping, he has yet to encounter any active checking-up. "It is all a bit hit-and-miss at the moment," he says.
response
Location in what is vaunted as Britain's first "green city" has encouraged the Holiday Inn Leicester to respond vigorously to the legislation. As well as developing staff procedures and a detailed paperwork system to comply with duty of care, the hotel checks all detergents used in warewashing and laundry to ensure they are biodegradable and do not contain nitrates or caustic soda.
Overall, Bayliss has found that food waste disposal demands most attention. For example, companies contracted to dispose of waste cooking oil and also deliver new oil must use appropriate vehicles. With pigswill, the necessary Ministry of Agriculture, Fisheries and Food (MAFF) licences now required by removers cost £1,200 a year. The result? Few people will do the job at all. Bayliss knows of just three in Leicestershire. It is now necessary to pay them, whereas in the past they would happily take it away free of charge.
The hotel has kept in line, Bayliss believes, with expectations in both duty of care and due diligence areas. "With all the new legislation, plus the recent apparent U-turns in the Food Hygiene (Amendment) Regulations 1990 & 1991 in respect of food storage temperatures, Bayliss sees the past couple of years as a period of "near-turmoil".
Apart from new training programmes to ensure all food handlers have a basic food hygiene certificate, the hotel has invested heavily in new servery equipment capable of meeting the under 5ºC holding temperatures - now being questioned by the Government - and also in changing to polypropylene chopping boards. In the latter instance, Bayliss says he has since heard suggestions that wood, as previously used, may actually be safer.
His conclusion: too many changes have been pushed through by bureaucrats, with scant concern for the people who have to make them work. As a part of a giant multi-national organisation, the Holiday Inn can cope, but Bayliss points out that a private hotel given a bill for £20,000 to replace its cutting boards and refrigeration might find things very difficult.
CONFERENCE VENUE
The new legislation has forced Birmingham International Convention Centre to employ a full-time hygiene manager specifically to deal with demands arising from the due diligence and duty of care requirements.
According to deputy catering services manager John Lander, the essence of both sets of legislation is to be able to track every single item purchased and disposed of at the centre. With the ability to serve up to 4,000 people a day at its various banqueting facilities, setting up the requisite paperwork was a mammoth undertaking.
"But once you have got it in place it simply becomes part of the way you do things, and only minor modifications are needed to reflect any changes in the way the business works."
DECLARATION
John Forte, director of environmental services at Forte, agrees. "In our industry we are talking about non-hazardous material for the vast majority of the waste we handle, so it comes within the household waste category," says John Forte. "So provided you can get a good waste disposal contractor, the paperwork should not be that onerous, with one declaration counting for the majority."
The main exception comes if, say, asbestos is found when refurbishing part of the building. In such cases specialist removal arrangements must be made.
With pigswill, John Forte has found that so few companies now want to take it away that caterers are generally better off investing in leak-proof containers for any matter which cannot be dealt with through in-sink waste disposers.
At catering sites operated by the Compass group, pigswill removal is now discouraged altogether on hygiene grounds, according to hygiene and safety adviser Jenny Farr. Food waste either passes through in-sink disposers or is mixed in with the usual kitchen waste for removal by regular contractors. In most respects, duty of care is, according to Farr, similar to due diligence. "If you are managing the system correctly in the first place there should not be any surprises."
FRANCHISEES
The challenge has been rather different for Wimpy International, with its high street outlets owned and operated by a diverse mixture of independent franchisees. Managing director Max Woolfenden says that briefings to franchisees explaining aspects of the health and safety regulations seem like "an almost weekly occurrence".
With its table service operation, the chain does not have the same volume of waste disposal as other hamburger brands, in the sense that the only disposable packaging used at Wimpy is taken away from the premises. However, a large amount of delivery packaging and items such as cooking oil must be disposed of. Wimpy has, as far as possible, arranged for nationally nominated contractors to serve groupings of franchised units centrally, for both general waste and oil removal. But some units are outside such networks and need to negotiate with an approved local disposer.
INCINERATION
What about caterers who dispose of their own waste? Barnsdale Lodge in Leicestershire incinerates much of its waste packaging and material such as disposable paper towels. With two hotels close to each other on Rutland Water, both in non-urban locations, planning permission for installing the £650 incinerator was straightforward and it has, according to proprietor Robert Reid, halved waste disposal charges to save about £150 a year.
The incinerator is in a field across the road from the hotel, so it is discreet and free from vermin problems, Reid claims. The only complication has been the need to transport waste to the incinerator, for which registration was sought from the local council. o
