The catering industry is experiencing the biggest changes in food safety laws for 15 years. When you consider other recent legislation on disabled access, liquor licensing and fire safety, it all adds up to quite a headache for the industry, and most of it comes into operation at the turn of this year.
The food law framework we knew in the 1990s has been totally swept away and is now unrecognisable with the introduction of new rules from Brussels.
Caterers are about to experience the bureaucratisation of their kitchens, with the compulsory requirement to keep records and paperwork as part of a documented food-safety management system.
There is a new requirement to train supervisors of such systems and also a new procedure enabling officials to close kitchens on the spot, without recourse to the courts - an extremely controversial measure which is still being debated. Environmental health practitioners (EHPs), formerly called environmental health officers, will have the power to do this where they find unsatisfactory standards of hygiene which might cause a health risk.
The basic rules that govern the design, layout, fixtures, fittings and management process within kitchens have been updated by the introduction of a new European regulation, EC 852, on the hygiene of foodstuffs. It is difficult to see immediately what's changed from the existing law, but certainly the basic rules of hygiene have been beefed up in the light of experience over the past 10 years. There are clearer requirements on thawing and cooling of foods, with a new requirement to keep chemical storage out of the kitchen. There is an emphasis on "disinfection" of food equipment and the general kitchen environment. Waste now has to be dealt with in an "environmentally friendly way".
The key points in the new requirements are those of ensuring segregation and the maintenance of the chill chain throughout the operation, together with the monitoring of temperatures when necessary. Many of the existing requirements remain the same. They are, though, transferred into the new legal framework.
These include the need for food organisations to continue to register with the local authority and tell it of any material change in their business activity. All staff must continue to be trained "commensurate with their work activity". EHPs can still serve improvement, prohibition and emergency prohibition notices where they find issues. They still have the power of entry at "any reasonable time", and it is an offence to obstruct them.
The temperature-control limits of 8°C and 63°C, with Scottish difference, remain the same, and cheeseboards and sweet trolleys are still OK, as the four-hour rule for placing food out on display is maintained.
In reality, there are key changes, and there will be new guidance notes to help the industry comply. Millions of pounds are being given to local authorities so that they can undertake local initiatives to get the message out. The Food Standards Agency has produced and has been testing a compliance diary for small caterers called Safer Food, Better Business. This is freely available and can be ordered through the website, www.food.gov.uk/catering, or by calling 020 7276 8000.
Tips on complying with the new rules
- Reduce the clutter and remove any old equipment in your kitchen in order to improve basic cleanliness. Inspectors hate cluttered
kitchens and tend to look deeper.
- Identify areas where you can segregate raw and cooked processes, and make a "Raw prep only" sign to demonstrate you have got the message.
- Improve "disinfection" with easy availability of sanitiser and disposable paper cloths.
- Ensure hand-washing availability with bactericidal soap and paper towels.
- Improve personal hygiene appearance with clean, ironed whites and crisp hats - first impressions count.
- Make a simple records system which identifies key critical areas such as delivery, storage, preparation, thawing (you might need cooling too), cooking and service. Monitor these in terms of temperature, date codes, times, weights, etc - that's HACCP - and you have to find simple ways of showing that you know what you are doing.
- Keep bulk chemicals out of food rooms.
- Review your training status so you are up-to-date and can talk the environmental health practitioner's language.
- Get a decent probe thermometer and probe wipes.
- Sort out your waste arrangements to reduce risk of pests.
Legal changes and new requirements
- Fully documented food safety management system based on HACCP (hazard analysis, critical control points) principles.
- Keep records on all food safety activity.
- Train the person responsible for the management system in food safety management and HACCP.
- New enforcement measure for inspectors - the Remedial Action Notice. This can close premises or a process on the spot without any recourse to the courts.
- Need to achieve and demonstrate traceability of foodstuffs.
- New emphasis on the basic standards of premises:
Layout to promote segregation of raw and cooked foodstuffs.
The chill chain not to be interrupted, and temperatures to be monitored.
Premises of sufficient size and design to allow for cleaning.
Emphasis on "disinfection" of premises and equipment.
New rules on thawing.
Clear rules on cooking with sufficient time and temperature.
Clear rules on keeping cleaning product storage away from food production.
Waste management must be "environmentally friendly".
- It is still illegal to sell or process food which is unfit or injurious to health or is not of the "nature, substance or quality the customer demanded".
Geoff Ward is managing director of Hygiene Monitoring Services, whose consultants undertake policy development, risk assessments, HACCP training, audits and inspections throughout the UK and Ireland. Contact 01225 858412.