What’s Cooking?

15 October 2005

Hazard Analysis and Critical Control Point (HACCP) procedures, training and industry guidelines must
become everyday compliance tools in the catering industry in the wake of new European Food Safety
regulations, as Graham Sheppard explains

FOR 30 YEARS THE UNITED KINGDOM happily worked within the Food and Drugs Act of 1955 and its limited powers. From 1985 progressive changes were made, but January 2006 will see a dramatic revolution in the responsibility for those involved in the food business, including caterers, meaning more exacting demands will have to be met.

The EEC Hygiene of Foodstuffs Regulation 852/2004 seeks to pursue a ‘high level of protection of human life and health’ whilst ‘including the aim of achieving free movement of food within the (European) Community.’ The Regulation demands that there is an integrated approach by all food business operators in the food chain to ensure that food safety is not compromised along the way.

In harmony with this, the new Food Hygiene (England) Regulations 2005 also come into force on 1 January 2006. These deal principally with enforcement and legal provisions as well as temperature control requirements.

The 852/2004 Regulation applies to all food business activity from primary production right through to sale to the end-user. It contains the hygiene rules originally put forward in the 1993 Directive, along with a few subtle changes. These same rules were incorporated in the UK General Food Hygiene Regulations of 1995 (to be repealed) so the actual requirements for premises and general hygiene practices in existence remain virtually unchanged. However, a lot has altered in the verification process.

New documentation
The significant new measure for caterers is that they must now have written Hazard Analysis and Critical Control Point (HACCP) documentation in place. HACCP is effectively a formalised verification process, which aims to attain a higher standard of food safety. The open-ended references to identifying hazards and points of critical control in the old Directive have now been stitched up very tightly and it will be an offence not to have any documentation showing how hazards and risks have been dealt with. The Regulation specifies that training in the principles of HACCP, to employees as appropriate, is a legal requirement.

HACCP is a system originally devised for food for NASA astronauts in space. The principles of this system demand thoroughness and have therefore been adopted ahead of time by many of the major caterers, including Compass Group. In fact, in 1996 Compass adopted its own food safety management system along HACCP lines, and many other companies have since followed suit.

The Food Standards Agency (FSA) has launched an abbreviated system for small businesses called ‘Safer Food, Better Business’. By comparison Compass has developed on-line manuals, rather than printed copies, to enhance reporting procedures and access to the guidelines for its staff.

There are indications in the Regulation of scope for flexibility, provided that it does not compromise food hygiene. For example, they allow for continued use of traditional methods, and take account of special geographical constraints.

It is obviously a huge task to bring harmonised food safety standards throughout the now-enlarged European Community, especially among the newer members, but this is what the new Regulation seeks to do, albeit with a little ‘give and take’ and under the watchful eye of the European Food Safety Authority.

Tracability
The Regulation is also very clear on the continued responsibility for food businesses to be able to trace the origin of their ingredients and products. This will, of course, form part of the HACCP process and will thus need to be documented and recorded.

Microbiological limits for categories of food (e.g. cooked meats, dairy produce etc) have been on the horizon for some time - the Health Protection Agency published guideline limits in September 2000 but without any legal backing. The new Regulation now gives that backing in specific terms so we can expect to see higher levels of purity, especially for ready-to-eat foodstuffs in the very near future.

Whilst the 852/2004 Regulation provides for the chill-chain to be upheld, it is the England Regulations that set the actual temperature requirement (i.e. 8º for chill, four hours maximum at ambient, and 63º for hot holding, or a maximum of two hours if it falls below 63º and so on). There is no requirement for a core cooking temperature. The former relaxation, stipulating that food that had fallen below 63º could be reheated provided that it was within two hours of original cooking, has now been removed.

Guides to good hygiene practice for many of the sectors of the food industry have existed for a decade, and Compass was actively involved in producing the original Catering Guide. In essence these guides endeavoured to provide a user-friendly format, setting out the legal requirement, the means of compliance, and information on good practice. The guides had no legal force but enforcing authorities were required to give them due consideration.

The new Regulation now formally recognises these Guides. In turn, the FSA has determined that the Industry Guides will have quasi-legal status and has contacted all sectors of the industry to draft or review the guide for their sector. For catering, the British Hospitality Association Technical Committee, which has representation from all the major caterers, is rewriting the original Guide to tighten up any loopholes and bring it fully up to date. There will be wholesale changes and much greater use of graphics to cope with language barriers. Safer Food, Better Business will be given prominence.

This Guide has to become every caterer’s bible on food safety. It will effectively quote the requirements of the Regulation and advise on how to comply with them, especially on the complex issue of HACCP and its associated documentation.

A point worth noting is that the Regulation clearly sets out that authorities have the power to demand documented proof of the safety of an operation, and there is clear reference to the need to retain documentation for as long as necessary in order to satisfy any retrospective enquiry.

Menu for action
In a nutshell – don’t wait until 1 January 2006 as your HACCP compliance needs to be installed by then. Here is a checklist to get started on now.
1. Review your current operation, its processes, practices, documentation and record keeping. Are you a safe business from top to tail? Is it currently documented?
2. Decide what improvements need to be made and implement them. Assess the degree of documentation and record keeping now needed to comply and compare it to what is currently in place. If necessary, seek advice from your local authority or a private consultant. (If you are a single small business, you will probably be well served by the FSA’s “Safer Food Better Business”, available free from your local authority)
3. Make sure that management is involved and that all staff are well informed as soon as possible about the new requirements
4. Review your food safety training programme
5. Decide who needs to be trained in HACCP and research the courses (for example providers such as local authorities, Campden FRA, Leatherhead FRA etc)
6. Obtain a copy of the new Industry Guide for Caterers as soon as it becomes available
7. Keep your HACCP documentation up to date, review your methods frequently (and record those reviews) and make changes where necessary.

Don’t let your documentation gather dust! Do all this and 2006 could indeed be a Happy New Year compliance wise!

● Graham Sheppard is head of health and food safety for the UK & Ireland division of Compass Group, the world’s leading foodservice organisation; he is a Fellow of the Chartered Institute of Environmental Health and is a member of the Campden FRA Scientific and Technical Committee and the British Hospitality Association Food & Technical Committee, through which he is currently engaged in updating the Industry Guide to Good Hygiene Practice for Catering to comply with HACCP guidelines.