Two years

The food hygiene regulations introduced in September 1995 were revolutionary. For the first time, food businesses were required to analyse potential food hazards and to train staff in food hygiene.

Unlike most other regulations that tackle the physical aspects of food handling, the Food Safety (General Food Hygiene) Regulations 1995 include the management of food hygiene. So, two years on, how has the industry reacted?

Reaction to hazard analysis

Most have found the training requirement fairly easy to comply with because any business can send its staff to the local college for courses in food hygiene.

But the hazard analysis requirement has not been quite so straightforward. One way of complying with the new regulations is by operating a system of Hazard Analysis and Critical Control Points (HACCP). But for many businesses this formal management technique requires resources that are not available.

Moreover, although the Department of Health advises that records of analysis and monitoring procedures may be helpful to demonstrate compliance, there is currently no legal requirement for written documentation.

Andrew Shilton, who owns Horton Grange, a 60-seat restaurant with nine bedrooms at Seaton Burn, near Newcastle-upon-Tyne, confesses to an initial misunderstanding of the regulations - something not uncommon among independent operators. "I thought hazard analysis was to do with accidents and sharp knives," he explains.

Having gone on a training course with his heads of department, Shilton says he then found implementation of hazard analysis "fairly easy".

Shilton says he does not run a written hazard analysis system, but insists on a high standard of hygiene, adding "we don't employ the calibre of staff who would make fundamental mistakes".

"We try to work with the local health and safety people and meet their requirements - but I'm sure someone could find more paperwork for us to do."

He adds: "Any good operator, restaurateur or hotelier will take on board much of what is in the new regulations. But the fact that we don't write it down on a specific form doesn't mean we're running an unsafe environment."

Detailed manuals

By contrast, large organisations have produced detailed manuals and HACCP systems. The approach of Granada Food Services is typical.

Mike Batchelor, quality systems director, says that in the past year a large number of environmental health officers (EHOs) have been specifically looking for information from the company on hazard and risk analysis.

He says: "Since 1991 we have had a very comprehensive hygiene and safety management manual, but last year we completely revised it and added a couple of new chapters specifically headed Hazard Analysis and Risk Analysis.

"The previous version fully addressed the issues anyway, but this was for the sake of clarity."

More control

At Marriott Food Services, Mike Chubb, director of environmental services, explains the company has an assured safe catering system linked to its ISO 9002 quality standard.

He says the regulations have led to more control and he likes the fact that caterers are now legally required to review their hazard analysis. "It means you have a live system," he explains.

Chubb adds: "The requirements have allowed us to demonstrate to our clients that we've got things under control."

At Compass Group UK, technical services director Clive Wadey explains that the contract companies within the group use a food safety management system developed by his 18-strong department.

"It's a workbook which is replaced every year and updated if there's a particular issue like E coli. It enables our unit staff to carry out hazard analysis with suitable training.

"The workbook is appropriate to all areas because the contract business has to fit every eventuality. It is audited by the operating companies and my team will also look at it a minimum of once a year."

Wadey is on advisory committees of the HCIMA and British Hospitality Association, as well as the food committee of the Chartered Institute of Environmental Health Officers. He is also a member of the general food hygiene working group of the Local Authority Co-ordinating Body on Food and Trading Standards. As a result he has widespread experience of how the industry is reacting to the requirement for hazard analysis.

"I think a lot of caterers aren't doing it and a lot of local authority EHOs aren't sure what they want to see from a business," he says.

Wadey stresses that effective training and retraining in food hygiene is essential. But he adds: "The fact that you've got a basic food hygiene certificate doesn't mean that you can do hazard analysis.

"It's particularly difficult for smaller businesses. I hope local authorities will be approachable. Otherwise it means paying for a consultant, which a lot of businesses won't do or can't afford."