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Ally Tow
Ally Tow,
SENIOR ASSOCIATE - CHARTERED LEGAL EXECUTIVE
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The Food Industry's guide to good hygiene practice: Hints & tips to ensure compliance
10 August 2016

Last updated in 1995, the current version of the Guide to Good Hygiene Practice is intended to represent best practice within the industry in the current market place.

In this article, we set out some hints and tips to ensure that your business is complying with the guide, although readers should be aware that consideration should be given to all relevant Acts and/or Regulations governing the supply of food including, for example, EU Food Information for Consumers Regulation No. 1169/2011.

  1. Don’t forget to register your food premises with your local authority (details can be found on your local authority’s website) and ensure that this information is kept up-to-date – best practice would be to ensure registration is submitted 28 days before the date of opening of the premises.

  2. Ensure you have sufficient space and facilities available within your premises for the safe production of food and that you have measures in place for controlling cross-contamination – best practice is to have separate areas for the storage and preparation of raw and ready-to-eat food. If this is not possible ensure areas and all equipment are fully cleaned and disinfected between use.

  3. Equipment should be moveable to allow effective cleaning and disinfected and of a non-toxic material – e.g. aluminium, tinned copper or ceramic. Consider arranging for regular maintenance checks to be carried out on vital equipment such as dishwashers or fridges.

  4. Arrange for windows and external doors to be screened to prevent contamination from insects. Consider engaging a reputable pest control contractor to carry out regular checks and, where appropriate, remove any unwanted pests.

  5. Ensure your staff are fully trained and comply with best practice personal hygiene standards including, in particular, washing of hands, tying back of hair, covering of cuts/wounds and removal of jewellery and beauty products – e.g. nail varnish, false nails etc. Suitable protective clothing should be provided to all staff for use at the premises only.

  6. Do not use any food which has exceeded its “best before” date. Regular rotation of food should take place to ensure that food with the shortest shelf life is used first. Ensure packaging is checked on delivery of all foods and that part used packages are adequately re-sealed to prevent contamination.

  7. When defrosting any foods which require refrigeration ensure that they are placed in the fridge whilst being defrosted. Ensure any run-off liquid is drained safely into a container which will prevent contamination. Any food cooked in advance must either be kept hot at all times or cooled as quickly as possible – best practice would be to cool from 55˚C to 20˚C within two hours.

  8. In England and Wales, refrigerators should be set between 1˚C and ˚C so as to comply with the law for the maximum allowable temperature for food that has to be kept cold, namely 8˚C – there are some exemptions to this, such as, scombroid fish. When preparing food, minimise the length of time the food is above 8˚C. Generally, a single limited period of up to two hours will not be challenged.

  9. In England and Wales, hot food must be kept at 63˚C after cooking or reheating, although for a single period hot food may be held below this temperature for up to two hours. Thereafter, ensure food is either disposed of, chilled to 8˚C or less or reheated to 63˚C or more and held above that temperature.

  10. Consider implementing an allergen management policy documenting food premises’ policies and procedures on recognising, inter alia, customers’ potential allergies, the need to describe food accurately and to sell safe food and identifying such foods correctly on menus and other documents. Your policy should also identify a recognised procedure for ensuring controls are in place to prevent cross-contamination of allergy free foods including, for example, effective cleaning, separate preparation spaces, separate cooking utensils, spillage management etc. Bear in mind staff themselves may have allergies to certain foods.

  11. Identify critical control points which recognise those areas within your own food premises where food may be more at risk of posing a hazard to your customers. Once identified establish targets to separate food from acceptable and non-acceptable conditions and so as to minimise risk of harm to customers. Once targets have been established ensure they are regularly monitored to check the correct procedures are being followed – for example, regular checks of the temperatures of your refrigerators. Consider keeping written records of any checks carried out.

  12. Finally, don’t forget that you should regularly review and, where appropriate, update all procedures within your food premises to ensure you are as efficient as possible regarding food hygiene safety. Reviews should also be undertaken when there is a specific change in your daily routine – for example, the introduction of a new menu may introduce new ingredients which have new hazards associated with them meriting differing controls or the method of preparation of food may change – a change from a commercially prepared sauce to a “homemade” sauce would introduce fresh critical points for consideration and control.

As a business operator it is your responsibility to ensure compliance with the guide so it is important that you determine the level of training, instruction and supervision that your staff will require to understand the implement the procedures and processes set out therein. We hope that this short article provides some useful tips to assist you with putting your food safety guidelines in place but you should ensure you have a good understanding of the full guide.

The guide is officially recognised by the Food Standards Agency which has responsibility for food safety in England, Wales and Northern Ireland. However, it is not a mandatory guide and food business operators can choose to comply in other ways. However, where the business operator is following the guide, the enforcement authority must take that into account when assessing compliance with legislation. This may afford businesses the opportunity to use the “due diligence defence” to any food safety contravention notices served. In the event of notice of any alleged food safety contravention all owners of food premises would be advised to seek legal advice as soon as possible.

For more information about the issues in this article or to find out more about how the Leisure and Hospitality sector can help you please contact Ally Tow on 0118 952 7711 or email [email protected].

Consistent with our policy when giving comment and advice on a non-specific basis, we cannot assume legal responsibility for the accuracy of any particular statement. In the case of specific problems we recommend that professional advice be sought.

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