RAW MEAT COLD STORES AND CUTTING PLANTS - ALLEGED SCANDAL

IS THE FOOD STANDARDS AGENCY’S ENFORCEMENT ACTION PROPORTIONATE TO THE RISK?

A lack of transparency and information forthcoming from the Food Standards Agency is fuelling speculation on the exact nature of the issues identified during recent audits of meat cutting plants and cold stores. When the concerns first came to light the information released from the FSA was limited to the fact that “they had uncovered serious non-compliance that related to a number of issues including concerns about procedures and processes around use by dates.” Since the communication no further clarification has been circulated which has catalysed the media into searching for whistle blowers and hypothesising that meat suppliers might have also been caught changing use by dates and country of origin labelling.

The requirement to label foods with a minimum durability (best before date) declaration is mandatory except for a few exemptions under Regulation (EC) No 1169/2011. Within the regulations, the date of minimum durability of a food is defined as the “date until which the food retains its specific properties when properly stored.” The best before date relates to the quality of the food and is not an indication of when the food becomes unsafe to eat.

The regulation then continues to state that “In the case of foods which, from a microbiological point of view, are highly perishable and are therefore likely after a short period to constitute an immediate danger to human health, the date of minimum durability shall be replaced by the “use by” date. After the “use by” date food shall be deemed to be unsafe.” Thus the use by date relates to the safety of food.

The terms “highly perishable” and “short period of time” are not defined within the regulation, which makes it problematic for both food producers and regulators to assess whether some types of food should be marked with a use by or a best before date. The responsibility of setting a durability date lies with the food business operator however the chosen durability chosen can be challenged by the enforcing authority.

With regard to the durability marking of raw meat, there are two schools of thought amongst food safety professionals. It is a well-known fact that raw meat is highly likely to be contaminated with bacteria which, if the shelf life is too long will have time to multiply. Therefore raw meat should have a use by date. However, a handful of food safety professionals argue that raw meat should be given a best before date and consequently they were mystified by the claim that any alleged non-compliance related to use by dates at all.

Most raw meat sold on the open market, is intended to be eaten only when it has been thoroughly cooked, although it has got to be said that there are a handful of meat establishments that have official approval for the production of speciality raw minced meat and raw meat preparations which are intended to be eaten less than thoroughly cooked. These establishments have to be able to prove that their products will not present a risk to health if served lightly cooked, for example pink burgers and they usually sell directly to catering outlets only. That aside, if standard raw meat cooking is undertaken correctly then any food poisoning bacteria present, should be eliminated or at the very least, be reduced to a safe level.

 But food poisoning bacteria are not the only microorganisms found on raw meat. The surface of meat is teeming with spoilage bacteria. Most food poisoning bacteria do not compete well with other microorganisms and consequently spoilage bacteria will proliferate thus controlling the growth of pathogens. Consequently the meat will noticeably spoil before food poisoning bacteria could reach a level that might compromise the safety of the meat. This hypothesis is the reasoning behind the belief by some food safety professionals that raw meat should be allotted a best before date. Obviously this supposition relies heavily on the competence of the person cooking the food and this might explain decisions made by food business operators and why use by dates are so commonly found on prepacked raw meat.

One major area of concern among food safety professional regarding pre-packed food arises when it is packed in a reduced Oxygen atmosphere, for example vacuum packed or food packed under a modified atmosphere. The potentially fatal food poisoning bacteria, Clostridium botulinum will happily grow under such conditions even when under refrigeration, producing a deadly toxin. For this reason guidance has been issued by the Food Standards Agency limiting the shelf life of chilled vacuum packaged foods etc. to a maximum of 10 days. However, Clostridium botulinum will not grow at temperatures below 3°C and the guidance expressly exempts foods that are held at such low temperatures. The majority of cutting plants and cold stores will be provided with walk in chiller units capable of maintaining temperatures at just above freezing and consequently if they vacuum pack the meat for cold storage, then their major issue with regard to durability will be to do with the quality of the product rather than the safety. The hazard of the growth of Clostridium botulinum only becomes a real issue when it leaves the control of the food business operator and the product is in the hands of the retailer or the final consumer. To reduce food waste, maybe the recommended 10 day shelf life clock should start ticking once the pre-packed meat is dispatched.

The durability labelling of raw meat can be seen to be a contentious issue and other nations in the developed world set a variety of standards. In the U.S.A food business operators are allowed to store vacuum packed raw meat for a maximum of 30 days if it is held at 5°C or below. However, perceived poor food safety standards in America are the subject of much media attention at the moment, so maybe they are not the best example to follow. In Australia vacuum packed raw meats are usually labelled with a best before date and can have a recommended shelf life of 3 to 6 weeks for beef and 2 to 5 weeks for lamb, dependent on whether the raw meat is a whole primal cut or sliced. The Australian guidance on choice of durability date labelling and recommended shelf life has been established by The Commonwealth Scientific and Industrial Research Organisation (CSIRO) which claims that “under normal circumstances of hygienic handling and storage, uncooked meat and meat products will be spoiled before an unacceptable food-safety risk arises.”

Reducing food waste is high on many a governments’ agenda and back in November 2017 the Waste and Resource Action Programme (WRAP) released a document entitled Labelling Guidance – Best Practice on Food Date Labelling and Storage Advice. The document carries the official logos of both The Food Standards Agency and The Department for Environment Food and Rural Affairs (DEFRA), although the document clearly states that “the content has not been endorsed by the organisations and individuals featured within it.”  

Although the guidance does bring a level of clarity to the durability labelling requirements, it does contain some ambiguity with regard to the labelling of raw meat. On one count it claims that a use by date is normally applied to raw (“fresh”) meat. However, it then goes on to ask the question in a decision tree scenario, “Is the food ready to eat (i.e. is intended by the producer or manufacturer for direct human consumption without the need for cooking or other processing, effective to reduce to an acceptable level or eliminate microorganisms of concern)?” On answering “no” to this question, the decision tree then asks “Could any microbiological hazard remain after the intended cooking or other processing?” As thorough cooking of raw meat will eliminate or reduce any food poisoning bacteria to safe levels, then the answer to this should be “No”, therefore raw meat should have a best before date.

The first vacuum packer was invented in the 1940’s and the technology started to be utilised by the food industry from the 1960’s onward.  Vacuum packaged raw meat has an excellent track record with regard to food safety and there have been no reported outbreaks of Botulism poisoning associated with the practice of the vacuum packaging of raw meat. However, available guidance from the Food Standards Agency clearly indicates that the policy stance is that raw meat, even though intended to be cooked must be allotted a “use by” date and if stored chilled in a reduced Oxygen atmosphere, then that “use by” date must not extend to more than 10 days from the date of packaging.

Maybe it is time that the Food Standards Agency reviewed the guidance that it uses as a base line for judging the degree of compliance with the food hygiene regulations.

Charcuterie HACCP Plans Delivered To A Food Business.

Earlier this year, we were contacted by a food business owner, who was struggling to convince his food safety officer, that his food safety management system would produce a safe product.

It wasn't that the Owner was doing anything wrong, it was more a case of the officer having a fear of the unknown, as she did not understand the products nor the science behind what made them safe.

The products in question were cured, fermented and air dried meats which were classified as ready to eat, although they had never received a heat treatment.

As the saying goes, "There are more ways to skin a cat" and indeed, there are also more ways of killing pathogenic bacteria than heat alone....

Fermented and air dried meats have been safely produced for centuries, particularly in regions where the climate is warmer than the UK. They could almost be classified as "Safe by Tradition"

The procedures being used by the food business owner were pretty much ideal for producing a safe product, however this needed to be justified in the HACCP plan.

And that is what we did. We didn't specifically change any of the processes, we merely described in the HACCP plan, how the processes controlled the risk.

Although this work was very specialised, don't forget, we have also prepared a generic HACCP plan which is ideal for catering establishment. Its is easy to use and is robust proof of Due Diligence It is entitled "Our Kitchen Rules" and is always available to purchase by emailing artisanfood.angel@gmail.com

CHARCUTERIE - How should it be stored and displayed

Charcuterie Displayed at Ambient Temperatures

One common complaint that I hear from retailers of fermented and air dried meats is that when their local food safety officer pops his head in, he expects to see such products under chilled temperature control.

However, when visiting the continent it is typical to see such products displayed openly at ambient temperatures and nobody seems to bat an eyelid.

Are there different laws across Europe you might wonder. Well there are a few exceptions but generally speaking food safety law is pretty standard across the continent and is formulated by the EU commission with the intention of creating a level playing field for trade. 

Fermented and air dried meats are not native to the UK and therein lies the problem.

In countries where Charcuterie has been traditionally made for centuries, there is a deeper understanding of the physical and chemical qualities that result in a safe product.

Fermented meats such as salamis have a very low pH, creating an acidic environment within which pathogenic bacteria find it it hard to survive and grow. Salamis are also dried to some extent and this further inhibits the growth of bacteria as there is very little water available, and without an adequate supply of water bacteria cannot multiply.

Similarly, air dried meats such as Serrano or Prosciutto hams contain high levels of salt and have  minimal amounts of water available to promote the growth of pathogens.

In reality, the safety of these products rely heavily on dryness and the use of refrigerated storage might compromise safety, especially if condensation were to form on the surface of the meats. 

Generally speaking, most continental style air dried and fermented meats do not support the growth of pathogenic bacteria and this is why it is safe to store and display them at ambient temperatures.

Further information on artisan food safety is available here 
http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail … … … … … … …

ARTISAN AND SPECIALITY FOOD PRODUCTION - FOOD SAFETY ESSENTIALS

http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail

"ARTISAN & SPECIALITY FOOD PRODUCTION" explains the food safety essentials for the safe preparation of - JAM, CHUTNEY, VINEGAR PICKLES, FERMENTED PICKLES, CHEESE, FERMENTED SAUSAGES, BILTONG & JERKY, SALTED & SMOKED FISH, CEVICHE, FLAVOURED OILS and foods cooked SOUS VIDE. 
The book is ideally suited to both the novice and experienced Artisan or Speciality Food Producer. 
Essential food safety controls are simply explained in a way that does not require too much prior food safety knowledge. 
Everybody knows that temperature controls both the growth and survival of unwanted bacteria in food. That is why we cook food and why we keep food in the refrigerator. But there are other methods of controlling the growth and survival of micro-organisms too. 
What gives jam its extended shelf life? What makes salami safe to eat when the meat is still raw? How much salt should you use when preparing smoked fish? 
The physical controls that are discussed are salt, sugar, acidity, pH, moisture content and water activity. 
If you are contemplating starting a food business then "Artisan & Speciality Food Production" is an essential read for getting started. It can be used to inform the content of a documented food safety management system. These systems are frequently known as a Hazard Analysis Critical Control Point (HACCP) systems and are a legal requirement for all food producers in many countries.

Keeping Food Safe - Continued

The most common technique used to make and keep food safe is temperature control. We all know excessive heat will kill most bacteria and we all prolong the shelf life of perishable foods by storing them in the refrigerator / freezer.

However, temperature control is not the only technique employed by food manufacturers when ensuring safety and durability. They may use one or more of the following controls either in addition to temperature control or sometimes as an alternative.

1. Removing water from the food by drying it or by adding salt and / or sugar etc.
2. Reducing the pH of the food by adding an acid or using natural fermentation techniques.
3. Smoking the food.
4. Using curing salts such as Sodium Nitrate and Sodium Nitrite.
5. By using other chemical preservatives such as Sulphur Dioxide,Sorbates and Benzoates.
6. Packing the food to exclude air or by replacing the air with a mix of inert gases.

When they use a combination of any of these techniques this is known in the trade as using "Hurdle Technology."

You can find out more about Artisan Food Safety here 

http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail … … … … …

And an easy to use catering HACCP plan can be sourced by emailing 

artisanfood.angel@gmail.com

 

Keeping Food Safe

Throughout history, man has endeavoured to find ways of making fresh food last longer by preventing it from becoming inedible or rancid. Whilst doing so they have inadvertently developed mechanisms that keep it safe too. Many of the methods used today were discovered accidentally many years ago, but with the advent of knowledge and technology food preservation has become a science in itself.

In today’s world we use various combinations of historical and modern technology to ensure that food is safe to eat. Before discussing the most common techniques there are a few facts about bacteria that you need to know:-

Most Bacteria Like

1. A warm environment between 8°C and 60°C
2. A certain degree of available moisture known as water activity
3. A food source that is rich in nutrients, for example meat, fish, eggs, milk or starchy foods such as rice and pasta
4. Plenty of time.

If all or some of the above are available then bacteria can multiply at an alarming rate. The number present can double in as little as 10 to 30 minutes, consequently it only take a few hours for one bacteria to multiply to more than one million.

Generally speaking, most modern day methods for keeping food safe rely upon taking bacteria out of their comfort zone by removing one or more of the environmental factors that they thrive on or by adding things that slow down their growth.

It must be noted that some of the controlling factors described below are not usually used in isolation, as this would result in foods that are unpleasant to eat at the levels described. They are purely mentioned to demonstrate the extremes of the controls required if they are to be used in isolation.

More information on Artisan Food Safety can be sourced here http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail … … … … …

And the easy to use HACCP document Our Kitchen Rules is available to purchase by emailing 

artisanfood.angel@gmail.com http://http://www.ebay.co.uk/itm/OUR-KITCHEN-RULES-EASY-ALTERNATIVE-TO-SAFER-FOOD-BETTER-BUSINESS-SFBB-HACCP-/161937202759?hash=item25b4359e47:g:LmUAAOSwDNdVz19
l?ViewItem&ite

RAPID COOLING OF FOOD IS IMPORTANT TOO

You might well wonder why cooling food as quickly as possible is considered so 
important when considering food safety. After all, if you've cooked the food thoroughly then you should have killed all the bacteria that are present.

Generally speaking this is true, but there are a few crafty food borne bacteria that have the ability to protect themselves from harm when threatened with an environment that is to hot for them. When the food cools down again they can start to grow and in doing so produce food poisoning toxins.

To explain further, these types of bacteria, under normal conditions, reproduce by replicating their DNA, which they encapsulate within spores inside the bacteria themselves. They then release the spores which subsequently germinate into active bacteria. The spores created are resistant to heat and chemical attack and this cycle is known as sporulation. It is during sporulation, particularly when the spore is being released, that toxins are produced.

When heat is applied to food containing spore forming bacteria, the bacteria are automatically thrown into the sporulation cycle to ensure survival, thus many spores are created which then go on to survive any heat treatment. When the food cools down, they germinate and if conditions are favourable the cycle starts again and toxins are produced.

Consequently, a thoroughly cooked food is not always a safe food and other control measures are needed to keep it safe for longer. The main spore forming bacteria are:-

Bascillus Cereus

Found in foods that have been in contact with the soil or of vegetable origin e.g. rice.

Clostridium Perfringens

Widely distributed in the environment and foods, and forms part of the normal gut flora in man and animals.

Clostridium Botulinum

Found in foods that have beenin contact with the soil or of vegetable origin e.g. garlic, herbs etc.

Further information on food safety controls can be found in "Artisan & Speciality Food Production - Food Safety Essential" available via Amazon.

http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail … … …

Information on cooling is also available in "Our Kitchen Rules" the generic catering HACCP plan, formulated by an experienced food safety officer, which is simple to use and an easy alternative to using "Safer Food Better Business"

It's available to purchase by emailing 

artisanfood.angel@gmail.com

FOOD SAFETY ESSENTIAL - CORE TEMPERATURE & TIME

When considering food safety, it is generally accepted throughout the UK, that there is a target temperature that the core of most raw, high risk food should reach to guarantee it is safe to eat and this is normally around the 75 to 80 degrees centigrade mark.

There are many micro-organisms present in food that can cause illness and they all behave slightly differently when heat is applied. Food safety is not only dependent on target core temperature but time too.

To ensure food safety across the board, food safety scientists set the target temperature at a level that they believed would guarantee food safety in the worst case scenario and the following temperature / time combinations are widely accepted as safe targets. 

80 C  for  6 seconds

75 C  for  30 seconds

70 C  for  2 minutes

65 C  for  10 minutes

60 C  for  45 minutes

These targets were set with conventional cooking in mind however, over recent years, there has been a rise in the popularity of low temperature / long time cooking techniques and consequently the scientists have revised these targets.

Of particular concern is E-coli. At temperatures above 70 degrees centigrade, 

E-coli dies at more or less the same rate as most other food poisoning bacteria so the above temperature / time combinations are considered satisfactory at 70 C or above, but at temperatures below 70 C their death rate is significantly slower.

The recommended temperature / time combination for food that is likely to be contaminated with E-coli are now set at 

65 C  for 14 minutes

60 C  for 93 minutes

See the FSA - Advisory Committee on the Microbiological Safety of Food report here:-

http://www.food.gov.uk/sites/default/files/multimedia/pdfs/acmsfburgers0807.pdf

More information on food safety is available via this link:-

http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail

Our Kitchen Rules copies are available to purchase by emailing 

artisanfood.angel@gmail.com

WARNING - BEWARE OF FREEZING FOOD WITH USE BY DATES

Everybody knows that when it comes to food wastage, one of the greatest food preservation techniques ever invented was the freezer.

When fresh, high risk, perishable food is frozen the deterioration stop watch grinds to a halt. The shelf life significantly increases as the act of freezing stops the growth of both spoilage and food poisoning organisms.

As a member of the public, you wouldn't think twice about popping a piece of fresh meat in the freezer, if you thought you weren't going to use it by the given use by date. It makes sense to freeze it rather than throw it away. But if you do freeze fresh food with a use by date and you are a food business owner and you intend to use the frozen food as part of your business and you keep the frozen food on your premises then BEWARE!!!!

In 2011 a meat processing company based in Wales was prosecuted by a local trading standards officer for having at his premises meat, with an expired use by date, that had been frozen. To cut a long story short, the case was heard and appealed at various courts and a final decision was made in 2013. The upshot of it being that the case on behalf of the prosecution was successful and the company was heavily fined.

Trading standards officers and court officials are trained in "fact" and there were two facts in this case:-

Fact 1. Regulation (EC) No 178/2002 states at Article 14 (1) "Food shall not be placed on the market if it is unsafe"

Fact 2. Regulation (EU) No 1169/2011 states at Article 24 (1) "After the use by date a food shall be deemed to be unsafe"

Food safety officers are also trained in fact but they are also trained in risk and when they undertake a food hygiene inspection they assess the risk your business presents to your customers.

Although a food safety officer could initiate legal proceedings for the possession of "frozen" food beyond its use by date found on a premises it is probably unlikely that they would do so if you can prove when the food was frozen. Food safety officers recognise both the economic value and food safety benefits of the act of freezing food. Indeed, the most commonly used and nationally prepared generic catering HACCP plan, Safer Food Better Business states:-

"If you find that you have more food in stock than you need and you do not think you will use it all before the ‘use by’ date, you could freeze some of it to be used in the future. Follow the manufacturer’s instructions on freezing and label the food as appropriate."

Alternatively in OUR KITCHEN RULES it states at rule 17 on Hazard 3

     "  When we freeze fresh food with a use by date we label it with a “frozen on date” without obscuring the original use by date. When taking out of the freezer we label it with a “defrosted on date” and ensure it is used well within the remaining shelf life."

If you use either of these approaches then hopefully a food safety officer won't be seeking to take you to court BUT REMEMBER although your HACCP plan might be robust and you can demonstrate through it's use, that the food you sell is safe, you could still end up landing yourself in litigation  if you freeze fresh food with a use by date.

OUR KITCHEN RULES can be purchased by emailing 

artisanfood.angel@gmail.com

Regulation (EC) No 178/2002

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:031:0001:0024:en:PDF


Regulation (EU) No 1169/2011

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32011R1169&from=EN

http://www.amazon.co.uk/kindle/dp/B00K34H650/ref=rdr_kindle_ext_eos_detail

"ARTISAN & SPECIALITY FOOD PRODUCTION" explains the food safety essentials for the safe preparation of - JAM, CHUTNEY, VINEGAR PICKLES, FERMENTED PICKLES, CHEESE, FERMENTED SAUSAGES, BILTONG & JERKY, SALTED & SMOKED FISH, CEVICHE, FLAVOURED OILS and foods cooked SOUS VIDE. 
The book is ideally suited to both the novice and experienced Artisan or Speciality Food Producer. 
Essential food safety controls are simply explained in a way that does not require too much prior food safety knowledge. 
Everybody knows that temperature controls both the growth and survival of unwanted bacteria in food. That is why we cook food and why we keep food in the refrigerator. But there are other methods of controlling the growth and survival of micro-organisms too. 
What gives jam its extended shelf life? What makes salami safe to eat when the meat is still raw? How much salt should you use when preparing smoked fish? 
The physical controls that are discussed are salt, sugar, acidity, pH, moisture content and water activity. 
If you are contemplating starting a food business then "Artisan & Speciality Food Production" is an essential read for getting started. It can be used to inform the content of a documented food safety management system. These systems are frequently known as a Hazard Analysis Critical Control Point (HACCP) systems and are a legal requirement for all food producers in many countries.

RARE BURGERS - Can You Now Serve Them With Impunity?

As with all things food safety the answer is well sort of, but you'll have to jump through numerous hoops to be able to demonstrate that the product you are serving is safe to eat.

Generally speaking, when you use heat treatment (cooking) to make a food safe, if you can achieve a core temperature (at the thickest part) of 70 degrees centigrade for 2 minutes, then you know it is safe to eat and you don't have to prove this fact any further as it is recognised in the UK that this is a safe cooking temperature / time combination.

In food safety speak, this temperature / time combination achieves what is know as a 6 log reduction in harmful bacteria. To but this simply, log means 10 and 6 log is 10 x 10 x 10 x 10 x 10 x 10 = 1,000,000 (1 million (or 10 to the power 6))

If you use the above mentioned cooking regime, and there are a million bacteria present in the food, then by the end of the cooking time you should have reduced the population to just one.

Over recent months, the Food Standards Agency have been discussing the rise in the popularity of burgers that are served "pink" They are due to hold a board meeting next week and it is highly likely they will propose that burgers can be served pink but only under certain conditions. The discussion paper can be found by following this link :-

http://www.food.gov.uk/sites/default/files/fsa150904.pdf

If you want to serve lightly cooked burgers (defined as those not achieving a 6 log reduction) you will have to be able to prove to your food safety officer some or all of the following:-

1. That you source your meat / mince from a supplier who can guarantee that they have procedures in place during slaughter, cutting and mincing which are as hygienic as possible.
2. That the the meat /mince you use has a low bacterial load and is safe to eat only lightly cooked.
3. That you have a set a specification for the raw mince they supply e.g absence / low levels of certain bacteria and you check it is compliant.
4. How you ensure that the meat they supply meets your specification (your own sampling)
5. That any surface treatment undertaken by you supplier are effective at reducing bacterial load e.g. lactic acid wash.
6. How temperature abuse is controlled throughout the supply chain.
7. How you control the temperature of the meat during processing if you mince it yourself.
8. That in house surface treatments (e.g. sear and shave) are effective and reintroduction of contamination is prevented.
9. That your cooking regime achieves at least a 4 log reduction in bacterial load (10,000 bacteria reduced to 1).
10. That if you serve burgers pink (less than a 6 log reduction), you warn customers (in writing at the point of sale) of the potential risk especially the risk posed to the elderly, very young or those with weakened immune systems.

SIMPLE REALLY!! And finally:-

Good luck with your negotiations with your food safety officer if you want to serve burgers any less than fully cooked.

OUR KITCHEN RULES - It Really Takes the Hard Work Out Of HACCP

"Our Kitchen Rules" 

It covers all the potential hazards that can exist or occur during the preparation, handling and service of food and suggests simple rules that can be followed that will guarantee to eliminate or reduce any risk to acceptable levels. 

The rules are not arduous and are mainly procedures that you already follow in the day to day running of your food business. They are backed up by world wide government guidance on the safe handling of food.

The simplistic logo of "Our Kitchen Rules" is an indication of how easy they are to follow.

All you have to do is:-

1. Learn the rules.
2. Train your staff in the rules.
3. Ensure your team follow the rules.
4. Ensure the monitoring and recording is done.

There no:-

1. Printing costs.
2. Templates to complete.
3. Loose sheets to misplace.

You can order a copy directly by emailing 

artisanfood.angel@gmail.com

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*.

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.

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.

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

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.

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.