OUR KITCHEN RULES - HACCP Plan

Sunday, 30 August 2015

Incomplete SFBB - The Most Common Cause of Low Food Hygiene Scores in the UK.



One  of the first businesses I ever inspected under the National Food Hygiene Rating Scheme (National FHRS) in the UK was a medium sized restaurant in a small market town.

The owner was very knowledgeable on food hygiene matters, the structure was to an excellent standard and the kitchen was incredibly clean.

Unfortunately, the owner had been in the trade for many years and couldn't see the benefits of having a documented food safety management system. Although he had been provided with a pack by the Local Authority, he had never bothered to complete it as he didn't see the point.

He had been informed by previous officers (on several occasions) that it was now a legal requirement to have such a document, but for many years he ignored their advice and just kept the blank document locked away safely in a cupboard, never seeing any repercussions for his stubbornness.

Unfortunately for him, in 2008 the Local Authority I worked for joined the national FHRS and one of the scoring requirements to achieve a 5* rating was to have "food safety management / procedures in place, appropriate for the size and nature of the business" with "food safety management records (once again appropriate for size and nature) generally maintained"

He had neither.

Although nothing else was wrong and I'd have been more than happy to dine there myself, I had to award him a score of 0* as he had no documented procedures or records whatsoever. 

He was stuck with that score for 3 months. The definition of 0* is "Urgent Improvement Needed" and is not really an enticing descriptor for prospective diners!!

The owner, as is his right, requested a re-score visit 3 months later and with a now, robust and fully completed documented food safety management system in place, with up to date monitoring and records, he scored a 5*.


Sunday, 23 August 2015

5* Home Catering and Mobile Food Businesses



The last few posts have considered the standards a conventional food business is expected to demonstrate if they want to achieve a 5* award on the Food Hygiene Rating Scheme. Things like storing and preparing food hygienically, having a good structure with the right facilities and having an up to date and robust document food safety management system, like "Our Kitchen Rules".


When it comes to running a food business from home or from a mobile structure, you still have to be able to demonstrate that you store and prepare food hygienically and you also have to have an up to date documented food safety management system in place however, the structural requirements are a lot more relaxed as the requirements discussed in previous posts do not apply to mobile and home operations. They are expressly exempted by the headings to both Chapters I and II (See Annex II Chapters I, II and III in Regulation EC (No) 852/2004

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:139:0001:0054:en:PDF

So what are the structural requirements when running a catering business from home or a mobile unit?


  1. The structure must be kept clean and in good repair and be designed to avoid the risk of contamination especially from animals and pests.Chapter III makes no mention of smooth walls nor easy to clean floors etc.
  2. Appropriate facilities are required for the hygienic  washing and drying of hands. There is no mention of the phrase wash hand basin nor running water. It does however, make mention of having somewhere available an adequate supply of hot and/or cold potable (clean and wholesome) water.
  3. Hygienic sanitary arrangements and changing facilities are required.
  4. Food contact surfaces are to be in good condition and easy to clean and disinfect. These do have to be smooth, washable, corrosion resistant and non-toxic.
  5. There must be adequate provision for cleaning and disinfecting utensils and equipment.
  6. If the food you prepare needs to be washed then there must be adequate provision for doing so hygienically. 
  7. Provision must be made for the storage and disposal of waste.
  8. There must be adequate provision for maintaining and monitoring suitable food temperatures and
  9. Food must be placed to avoid the risk of contamination.
These are the requirements that relate to mobile and home catering. You will note that in addition to the omissions already sited, there is also no mention of ventilation, lighting or drainage.

The problem when it comes to being rated is that once again the legislation is very vague and consequently open to inconsistent interpretation and hence reduced food hygiene rating scores.

At least knowing that the requirements for mobile and home catering businesses are more relaxed, gives you a fighting chance should you wish to appeal against an over zealous interpretation of the legislation and a resultant low score.

Tuesday, 18 August 2015

Food Room Structure and Achieving 5* FHRS Award


So what do food safety inspectors expect to see in any food room of a 5* premises?

If you take an in-depth look at Regulation 852/2004 (the last post only gave a brief synopsis) then you will realise that the requirements are quite vague.


Floors
Suitable materials are resin, rubber, vinyl, ceramic tiles and even a fine finish poured sealed concrete. Ideally it should be coved at the junction of walls, such that it cannot accumulate dirt. In reality, there is nothing to stop you using flat sheet vinyl flooring as long as you ensure the joints at walls are adequately sealed with a cleanable sealant. Don't forget, food room floors tend to get wet so ideally the flooring should provided a non-slip surface too.

Walls
Suitable materials are stainless steel sheets, ceramic tiles or plastic cladding. However, there is nothing to stop you having a smooth plaster and washable paint finish as long as the surface is easy to clean and disinfect. It's useful to remember that the requirement for smooth, easy to clean walls only applies up to a certain height (as long as the remaining wall area is in good condition). So in a room with a really high ceiling, it wouldn't be absolutely necessary to provide cladding from floor to ceiling, you could just install the appropriate wall covering to a level where cleaning is critical for example 7 feet above floor level.

When it comes to what type of floor and wall coverings to have the 4 key words are impervious, non-absorbent, washable and non-toxic. The word smooth also applies to the wall finish.

Washing Facilities
For hand washing there is no set number of wash hand basins that are required. However, every food room is expected to have at least one wash hand basin. In larger food rooms more than one may be required, especially if food handlers have to travel between areas where raw and ready to eat foods are prepared, to wash their hands. Wash hand basins must have hot and cold running water (or running water at a suitably controlled temperature) and a hygienic means of washing and drying hands. Liquid soap and paper towels are recommended. 

The regulation then goes on to say that "where necessary", the facilities for washing food are to be separate from the hand washing facility. The use of the phrase "where necessary" implies that separate hand and food washing facilities may not always be required. However, if you proposed to use a large sink for both washing hands and food you would have to prove how you are controlling any risk of cross contamination. For example, it might be possible, depending on your food offer, to argue that at the start of the day, your hands are washed and then the sink is cleaned and disinfected and immediately used to wash all the food you need for the entire service. Once all the washed food required has been prepared, the sink would then revert back to being the dedicated hand wash station whilst in service. To be successful on these grounds, you would always have to be able to demonstrate that this procedure is being followed. In reality if you need to wash food then it will probably make your life easier if you have separate facilities, but the point is that  a food safety officer cannot require one unless you absolutely need one, and the absence of a food wash sink shouldn't result in a lowered FHRS score unless the sinks absence is creating a risk to food safety. NB Food wash sinks are not required to have a hot water supply unless they are used for other purposes too, the regulation requirement is "an adequate supply of hot and/or cold potable water" (Potable water is clean wholesome drinking water.)

Any food business that has to wash utensils or equipment must have adequate facilities provided for doing so, with a supply of both hot and cold water. The phrase "where necessary" is used once again but it is unlikely that any food business actually exists that doesn't need to wash, on occasion,  the odd bit of cutlery etc. 

In general, when it comes to washing facilities the legislation is quite vague. You might be able to argue that you can still be compliant with only one sink in a food room. However, this argument would be quite flimsy and not easy to justify. In reality, most food rooms will need 3 separate facilities for the washing of hands, food and equipment.

Other Matters
Obviously, always keep the structure clean, disinfected and in good repair and ensure all surfaces in areas where food is handled are easy to clean and disinfect.

It must be noted that much of the above does not apply to food businesses that operate in movable structures or out of domestic premises. They are covered by a separate chapter and will be discussed in a future post.




Thursday, 13 August 2015

Food Room Structure and Facilities - What is Required for 5* Rating

Rooms Where Foodstuffs are Prepared Treated or Processed
Regulation (EC) No 852/2004





Surfaces
  1. Floors must be maintained in good condition and must be easy to clean and disinfect. Consequently they must be impervious, non-absorbent, non-toxic and washable. They might also require effective drainage. (Annex II Chapter II para 1a)
  2. Walls must be maintained in good condition and must be easy to clean and disinfect. Consequently they must be smooth, impervious, non-absorbent, non-toxic and washable. (Annex II Chapter II para 1b)
  3. Ceilings /open  internal roofs must not allow the accumulation of dirt, condensation or mould growth and they must not shed any particles. (Annex II Chapter II para 1c)
  4. Windows must not accumulate dirt. If necessary they should be fitted with an insect proof covering which is removable for cleaning and must be kept closed if there is a risk of contamination from the outside. (Annex II Chapter II para 1d)
  5. Doors must be easy to clean and disinfect. Consequently they must be smooth and non-absorbent. (Annex II Chapter II para 1e)
  6. Surfaces (including surfaces of equipment) in areas where food is handled and in particular food contact surfaces must be maintained in good condition and be easy to clean and disinfect. Consequently they must be smooth, washable, corrosion resistant and non toxic. (Annex II Chapter II para 1f)
Washing Facilities
  1. Where necessary, adequate corrosion resistant facilities for the cleaning, washing and disinfection of utensils and equipment with an adequate supply of hot and cold water. (Annex II Chapter II Para 2)
  2. Where necessary, adequate provision for the washing of food, with hot and/or cold potable water. This facility must be kept clean and disinfected. (Annex II Chapter II para 3)
  3. Adequate number of suitably located, designated wash hand basins, with hot and cold running water and materials for the hygienic washing and drying of hands. (Annex II Chapter I para 4)
Some Other General Structural Matters
  1. Food rooms must be kept clean and maintained in good condition. (Annex II Chapter I para 1)
  2. The design must permit adequate cleaning, minimise air-borne contamination and provide adequate work space to avoid contamination and permit good food hygiene practices. (Annex II Chapter I para 2a and 2b)
  3. Food Rooms must be pest proof. (Annex II Chapter I para 2c
  4. Food rooms must have adequate natural or mechanical ventilation and the system must be capable of being cleaned. Airflow from a contaminated area to a clean area is to be avoided. (Annex II Chapter I para 5)
  5. Food rooms must have adequate natural and/or artificial light. (Annex II Chapter I para 7)
  6. Lavatories are not to open directly into rooms in which food is haHndled. (Annex II Chapter I para 3)
  7. Food rooms must have adequate drainage facilities and open channels must not flow from a contaminated area to a clean area. (Annex II Chapter I para 8)
  8. Cleaning chemicals are not to be stored where food is handled. (Annex II Chapter I para 10)
Next time, further guidance will be provided on what is considered satisfactory provision for meeting these requirements.

Tuesday, 11 August 2015

STRUCTURE MATTERS If you want a 5* Rating


When a food safety officer undertakes an inspection and awards a FHRS score one of the factors they consider is the standard of the structure and the available facilities. The requirements that are considered satisfactory are detailed in Regulation (EC) No 852/2004 


As with all things legal, these requirements are not that straight forward and can be dependent on what type of food business you run and what each part of the food premises is used for. If you look at the above link, you will find a document that is quite lengthy. When it comes to structure, the parts that apply are chapters I, II and III and these can be found in Annex II.

Chapter I applies to the premises as a whole and includes quite general requirements.

Chapter II is more specific and prescriptive and applies to any "room where foodstuffs are prepared, treated or processed"

Chapter III applies to "movable and/or temporary premises and premises used primarily as a domestic dwelling-house" so mainly applies to things like mobile catering, market stalls preparing/selling food and home caterers etc.

It must be noted that the regulation expressly excludes any premises that come under Chapter III from the requirements of both Chapters I and II. Consequently different rules apply to mobile and home caterers as compared to static catering establishments such as restaurants, cafes and pubs.

More on this, on the next post.

The easy to use HACCP plan - Our Kitchen Rules can be purchased by emailing

artisanfood.angel@gmail.com





Sunday, 9 August 2015

How To Get 5* on the Food Hygiene Rating Scheme (FHRS) - Continued



The Structure Matters Too

In addition to controlling the "four C's" and having an effective and up to date documented food safety management system, the condition of the structure and the availability of facilities at the premises can also affect the rating score you are awarded during a food hygiene inspection.

If there are only one or two minor defects in the structure and they are unlikely to affect food safety then you might just scrape a 5* rating as long as everything else is in order. An example of such a scenario is maybe one or two damaged wall tiles that are remote from a food preparation surface. When the defect can directly impact on food safety, that's when points start to be lost, for example a damaged work surface that is no longer easy to clean and disinfect, poor standards of cleanliness or some pest proofing works required.

The structural requirements of a food premises are covered by 
Regulation (EC) No 852/2004 and is available to download here:-


In future posts the content of 852/2004 will be unscrambled into normal speak!!

Our Kitchen Rules, the easy alternative to Safer Food Better Business can be purchased directly, by contacting 
artisanfood.angel@gmail.com




Friday, 7 August 2015

How to Get a 5* on the Food Hygiene Rating Scheme Continued.



Assessment of your Food Hygiene Arrangements

In addition to developing and maintaining a documented food safety management system (discussed in the last post), to achieve a 5* rating you need to be able to demonstrate that you have excellent food hygiene standards too. Generally speaking, when food safety officers assess food hygiene standards they look at what are known as the "Four C's"

  1. Cleaning and the standard of cleanliness.
  2. Cross contamination risk from raw foods to ready to eat foods.
  3. Cooking and hot holding - is the food reaching a high enough temperature for the correct amount of time and when hot holding is the food kept at 63 degrees Celsius or above.
  4. Chilling and cold storage - is hot food cooled quickly enough and are high risk foods kept at 8 degrees Celsius or below. 
If you can demonstrate you have control of the "Four C's" and the structure of the premises is satisfactory and your documented food safety management system is effective and up to date, then your business should be awarded a 5*

Our Kitchen Rules is available via artisanfood.angel@gmail.com