Danger in waiting

Good temperature control of high-risk foods is probably the most vital step in safe food production, yet Brussels has delayed the implementation of new temperature control requirements in the forthcoming Food Safety (General Food Hygiene) Regulations 1995.

These regulations, which implement the EC Hygiene Directive, are due to be introduced in September this year.

There has been disagreement within Europe as to what temperature levels for food safety should be introduced across the board. The new regulations were set to sweep away all discrepancies and ambiguities.

Under the british submission, the dual system of storing some foods at 8ºC and others at 5ºC, which took effect from April 1993, would be replaced with a single temperature of 8ºC for all foods likely to support the growth of micro-organisms. But Brussels has now rejected this proposal, believing 8ºC to be an inadequate temperature.

So, for the time being at least, the status quo in England and Wales is set to continue. Scotland will maintain its woolly requirements of cold storage - "food to be kept in…refrigerator or refrigerated chamber, or a cool ventilated place" (no temperature mentioned).

If you are confused, it's hardly surprising to find that most enforcement officers are confused as well.

The British Government is keen to press ahead, but we will have to wait and see which way Brussels is going to jump. In the meantime, the uncertainties continue.

Aside from legal requirements, there is the greater issue all caterers should be concerned about: the prevention of food poisoning.

Contamination of food is bound to happen, in even the best catering businesses. Most caterers escape food-poisoning incidents by using refrigeration as the first and foremost measure of preventing harmful bacteria multiplying on food.

It is possible to get away with a bit of contamination providing that contamination is not incubated. High bacteria counts on salad bars are found when enforcement officers take samples, but they certainly don't always cause food poisoning.

You can guarantee as the summer comes on, with long, hot days, the more traditional bacteria will claim their usual number of casualties.

Stories of lovely, ambient wedding buffets contaminated with staphylococcus from food handlers' hands are likely to be hitting the headlines soon. And salmonella from undercooked chicken or cross-contaminated by chefs' hands is likely to be commonplace throughout the summer.

Raw egg mayonnaise and mousses made from shell eggs will still take their toll on those organisations that have not yet decided on a proper policy for the use of these products. And you can bet that the stockpot, attaining an ambient temperature of around 30-40ºC (blood heat) in the kitchen through the summer, will cause plenty of clostridium perfringens (a common form of food poisoning) incidents - the lessons are rarely learnt for long!

These remain the most common causes of food poisoning in the UK. But the one thing that seems to be forgotten is that food poisoning is entirely preventable. It's often down to the negligence or indifference of the food handler.

The whole concept of law these days is about self-regulation, and the only defence under the Food Safety Act is that of due diligence.

You may wonder why "diligence" means, among other matters, taking temperatures every few hours or perhaps monitoring deliveries. Enforcement officers, by advising you to keep these records, are really asking you to check to see if refrigerators or deliveries maintain proper temperatures. Due diligence also means corrective action if temperature tolerances are exceeded.

The new requirement of hazard analysis arrives with the new regulations in September. At that point, all these systems with regard to delivery monitoring and regular temperature checks will not have been wasted.

Now is a good time to see how due diligence and hazard analysis can be combined, perhaps through the concept of a company food safety policy. Look at the whole process of food safety compliance as a logical flow as follows: Food safety risk assessment; development of a company policy; training; implementation of controls; audit and inspection; review of the policy.

This model has been developed for health and safety, and can easily be transferred to food safety, incorporating the new concept of hazard analysis.

This process may seem very technical, but if you think about it, your own company may be carrying out this process subconsciously already. All it needs is the framework.

In the meantime, it is advisable to get the basics right. Here is a summary of the most important food safety rules to impress upon all staff:

• Service of refrigeration twice a year - pre-summer and autumn time.

• Keep all refrigeration below 5ºC - the present dual temperatures only confuse staff.

• All high-risk foods should be kept under refrigeration through storage, distribution and service.

• Keep preparation time short.

• Place small amounts of food out for service and replenish from refrigeration.

• Remember that chilled display units only "hold" food at the temperature it was put in at!

• Keep hot food service above 63ºC.

For small companies the aim will be to keep it simple, for large companies it will be to ensure all aspects of food safety are covered.

Certainly we will all have to do omething this summer about temperature control if we are to prepare ourselves for the new regulations ahead and avoid some of the disasters of previous summers.

Geoff Ward is managing director of Hygiene Monitoring Services (HMS), consultants in environmental health, assisting the trade with food safety and health and safety compliance. HMS is running a series of seminars in May/June on cost effective compliance with new laws, entitled: Rest in Peace with your EHO. Call 01225 858412 if you would like to reserve a place.