Facilities managers should be aware of new food safety laws, whether they have direct responsibility for their firm's catering facilities or not. Peter Phillips reports on the latest updates
09 September 2005
Until now firms have not been required by law to provide much written information to prove compliance with hygiene and safety legislation. For example, only if a business has five or more employees is there a requirement for a written policy statement. But this is changing.
In January next year, the new Food Safety Regulations will require all food and drink businesses to demonstrate their food safety management systems in writing. There are no exceptions, but the detail and complexity of the written system should reflect the size of the business and the nature of potential hazards and risks identified.
In producing its written system any food business must go through the following stages:
Before starting, certain prerequisites must be satisfied. All staff must be adequately trained and premises and equipment must be hygienic
Identify every activity that involves the purchase, storage, preparation, cooking and sale or service of food
For each activity or stage, identify any potential hazards. In other words, things that could put the consumer at risk or adversely affect the quality or safety of the product. Typically, hazards fall into the categories of contamination from micro-organisms, foreign bodies or chemicals and growth of micro-organisms
Design and implement controls for each of the hazards identified so that the hazard is eliminated or the risk from it is reduced as far as is practicable. For example, correct cooking temperatures ensure the destruction of many harmful micro-organisms and correct storage temperatures ensure that any that are still in the food do not grow
Consider how you the controls can be monitored. This might be in the form of simple opening and closing checks each day. Opening checks might include the temperatures of fridges, checking that staff are clean and correctly dressed, making sure that the premises and equipment is clean and checking that hand washing and cleaning materials are available. Closing checks might include ensuring that all food is put away correctly, all cleaning has been done and all refuse has been removed
Record all of the checks that you regard as critical to food safety. Some businesses choose to keep separate records for such things as temperature and cleaning checks and others prefer to keep a day diary where all checks are recorded on one page per day. Its more important to record when things go wrong and what you do to correct it
Ensure that there is a system of corrective action for every foreseeable break down in control. It is essential that all food handlers know what to do when things go wrong
Review the whole system at adequate intervals to ensure that any changes in activity are dealt with. This could include new products and recipes, new equipment, and confirmation that new staff are adequately trained in the requirements of the system
The amount of written information required will vary depending on the size and nature of the business. A sole proprietor might have very simple reference material to refer to. They might only keep records that prompt them to check the controls that are critical to food safety. A larger firm might need detailed recipes and procedures so that everybody works to a consistent standard.
There are several models that can be used to provide an approach to the design of a food safety management system. The British Retail Consortium has a model. Another is the forthcoming international standard, ISO22000.
Help in creating food safety management systems can be obtained from a number of sources. Small catering businesses can probably get all the information they need directly from their own environmental health department. The Food Standards Agency is currently developing a hygiene management pack called Safer Food - Better Business, which is again suitable to the small caterer. Some local authorities are also participating in the Fitness for Purpose project which helps small businesses create management systems for food safety, health and safety, fire and trading standards.
Attending formal food hygiene courses is a great way of gaining the skills necessary to write your own hygiene management systems. A one-day basic course will provide the hygiene information essential to any food handler. The intermediate food hygiene certificate course is aimed at additional skills to those who manage or supervise others. The advanced food hygiene certificate course provides knowledge not only useful to management but also develops skills in teaching others in the workplace and in creating management systems.
For those who require additional guidance in the design and maintenance of their food safety management systems, especially if they run a substantial food and drink processing business, it may be appropriate to call in the services of an environmental health or food safety management system consultant.
Quite apart from the legal requirement to have a written system for food safety management in the near future, the benefits of having one are enormous and forms a major part of your "due diligence" defence should something go wrong.
If you sell food to other commercial organisations the "due diligence" defence has another effect. In order to preserve their defence many organisations will only buy from firms where adequate food safety management systems exist. Remember that civil claims are now a much bigger threat to most firms than statutory enforcement. Good management systems not only prevent incidents leading to civil claims but, should the need arise, also provide sound defence against them.
Peter Phillips is a consultant for Handley-Walker Services