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Managing your food safely

A guide to developing your documented Food Safety Management System

Introduction

From 2006 the introduction of new food hygiene regulations (EC No 852/2004) made it a legal requirement for all food businesses to have what is known as a HACCP (Hazard Analysis Critical Control Point) based Food Safety Management System. This MUST be documented; however the extent and detail of documentation will depend on the nature and size of the business.

Once you have completed your documented Food Safety Management System it will:

  • show that you have taken account of this important requirement
  • serve as an important training reference for your staff
  • ensure that the inspecting officer will have greater confidence in you and your business, possibly resulting in fewer inspections
  • providing that your documented Food Safety Management System is satisfactory and all
  • requirements are met hopefully allow you to achieve a good food hygiene rating.

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The law requires you to:-

1. Identify any hazards that must be prevented, eliminated or reduced to an acceptable level to ensure food safety in your premises.

2. Identify which of these steps are critical to food safety (the critical control points).

3. Decide how these risks will be eliminated or otherwise managed (the ‘controls’).

4. Establish a system to regularly check that your controls are working (the ‘monitoring’).

5. Establish corrective actions when your monitoring shows that food safety at critical points is not being controlled.

6. Establish procedures which shall be regularly carried out to verify (make sure) that the measures outlined in points 1-5 are working.

7. You will need to establish documentation and records to prove the effectiveness of your Food Safety Management System, the level of documentation and record keeping will however depend on the nature and size of your business.

8. Where there is any change in your products, process or any step in your food business operation you will need to review your procedures and make any necessary changes.

This information has been designed by our Environmental Health team to help small to medium sized businesses comply with the law. The pack is intended as a starting point. It is not a definitive
guide as in many cases it gives examples rather than all the answers.

Please contact our Food and Safety Team or call 01803 208025 for further advice and information.

This pack is not the only way to comply with the requirement for a documented Food Safety Management System. The Food Standards Agency have produced Safer Food Better Business packs (SFBB pack) to help you comply with the law 

There are different versions of the SFBB pack, such as one for Caterers and a different one for Retailers. Make sure you if you use SFBB you chose the right one for your type of business. SFBB is not suitable for more complicated menus or cooking techniques (such as sous vide or large scale caterers).

You can also draw up your own system. The important thing is, that whichever way you choose to do it, it is written, it works efficiently, and that it is understood and kept up to date by you and your staff.
This pack has been developed as a simple, easy to use guide. As every food business is different it needs to be tailored to your own business.

Please remember that it is no good just having a written system in place - you will need to make sure it is being put into action.

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The eight steps

To develop your documented Food Safety Management System you need to complete the following eight steps:

STEP 1 - What steps are there in my processes?

Think about all the foods that you sell/and or produce and list all the steps in the process, or things that you do to the food. It may be very simple such as purchase, store, display, and sell on, if you retail food, or there may be more steps if you prepare and cook foods. It may help to draw a simple flow diagram of what you do.

STEP 2 - What are the hazards?

For each step in your process, think about everything that could reasonably present a hazard to food. Write all of these thoughts down. Look around your premises, concentrating on areas where food is stored and prepared and note down any hazards identified. Consult your employees, if any, as these may have a different perspective of the hazards. It is also beneficial to consider any complaints that may have been received from customers which may identify a problem.

STEP 3 - What control measures are required?

A decision must be taken on each hazard identified as to how it can be removed and/or controlled wherever possible.

Your first question should always be:
Can I remove the risk to food safety? If so, how?

If not, the next question is:
How can I control the hazard to reduce its effects?

Look at what controls, if any, are in place at present and ask yourself:
Are the controls in place adequate?
Can I improve on these controls?
What new controls are required?
Are the controls to the standard recognised by my particular industry?

Consider the examples of controls given on pages 7 -9. Do they apply to your business? Remember,
the more specific the control procedures are, the easier it will be to monitor whether that the control
is adequate.

STEP 4 - What monitoring procedures are required?

These procedures are designed to ensure/check whether the control measures are working. Monitoring may include temperature recording for refrigerators and food temperatures, stock rotation checks, visual and supervisory checks. Each control should have a specific monitoring frequency, for example, ‘temperature readings will be taken twice on a daily basis’.

Safe limits also need to be applied to these procedures, for example, ‘a temperature range of 0oC to 8oC will be accepted for food stored in refrigerators’.

STEP 5 - What corrective action should be taken?

If your monitoring checks reveal situations where the safe limits are not met, you must identify what action should be taken to correct this and maintain food safety. Staff must also know what action to take. For example, if a check revealed a refrigerator temperature of 10oC, high risk foods should be discarded, and the temperature lowered until it reaches 0 to 8oC.

STEP 6 - Is this point a CRITICAL control point?

Whilst all control measures are important, a critical control point (CCP) is one which is ESSENTIAL to ensure the safety of the food you handle. Identify any stage within production and/or retail which MUST be controlled in order to ensure that food is safe, i.e. any stage where:

  • ready to eat food can become contaminated,
  • bacteria have the potential to grow on ready-toeat food, and
  • the process relies on killing harmful bacteria to ensure that the food is safe.

A critical control point should be looked on as the ‘last chance to get it right’.

Aim to have as few CCPs as possible, without compromising food safety. You can then put more effort into them to make sure that you get them right. If there are too many CCPs, they may not be addressed thoroughly. CCPs help you to concentrate on the most vital areas of your business.

STEP 7 - Verification and Review

It is important that your documented food safety management system remains a WORKING DOCUMENT. It is never ‘complete’ as control systems are rarely perfect and require constant updating and improvement. For this reason, periodic review of your working systems is vital to ensure that the controls in place are adequate and are achieving their intended purpose.

For example, staff may be recording daily temperature readings, but are not taking appropriate action when readings are too high; or you may identify a simpler, less onerous, method of control which does not compromise food safety.

The review process may also identify gaps in knowledge of staff. Ways of bridging that gap may be to discuss food safety issues at a staff meeting, refresh staff’s knowledge with in house training, to consult your local enforcement officer for advice, or to attend an approved formal food hygiene training course.

The following are examples of what should trigger your food safety management system review:

• change of menu/new product,
• introduction of new equipment,
• structural alterations,
• changes in key members of staff.

In any case, it is recommended that you carry out an annual review or when something changes in your business.

STEP 8 - Documentation of procedures and record keeping

It is a legal requirement to document your Food Safety Management system. The level of documentation will however vary depending on the nature and size of your business but may include:

  • a documented copy of your Food Safety Management System
  • training records
  • cleaning schedules
  • temperature monitoring records
  • pest control contract and/or reports
  • personal hygiene rules and other similar procedures and documentation
  • list of suppliers and customers
  • maintenance / service records for equipment, e.g. ventilation ducting cleaning certificate
  • records of your checking problems and action taken
  • Allergy information – procedures and allergen product references/ matrices

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Potential food hazards in your business

Examples of hazards that can threaten the safety of the food in your business

Purchase and delivery

  • Chilled or frozen food delivered out of temperature control, i.e. higher than 8 oC (5oC or less recommended) for chilled foods; or warmer than –18oC for frozen foods.
  • Food contamination
    - Micro-biological (food poisoning bacteria) e.g. due to poor temperature control
    - Chemical e.g. pesticides
    - Foreign body e.g. rodent droppings, glass, paper, wood etc.
  • Food purchased very close to or beyond the ‘use by’ or ‘best before’ date.
  • Defective packaging on delivered food e.g. dented tin.
  • Food purchased from dubious or unfamiliar sources.

Storage

  • Chilled or frozen food stored out of temperature control or not in line with the manufacturer’s instructions.
  • Contamination & Cross Contamination

- Microbiological e.g. raw meat juices dripping on to ready-to eat food, or open food stored in WC, or not protecting high risk food in the refrigerator.

- Chemical e.g. cleaning materials coming into contact with food.

- Foreign Body e.g. staples, pins, tape, flaking paint, rodent droppings etc.

  • Food stored in damp or humid conditions leading to mould growth or rusting of tins.
  • Defective racking systems/storage conditions which may cause damage to fragile packaging.
  • Inadequate stock rotation, e.g. food past its ‘Use by’ date still in the fridge and available for use.
  • Inadequate refrigeration provision.
  • Inadequate pest proofing of storage areas, e.g. opening external doors to improve kitchen
  • ventilation without insect screening.

Preparation

  • Inadequate thawing/defrosting of foods prior to cooking.
  • Leaving food out at room temperature unnecessarily.
  • Food preparation rooms which are excessively hot due to poor ventilation.
  • No continuous supply of running hot water, soap and hygienic hand drying materials to all wash hand basins.
  • Poor personal hygiene practices, e.g. not washing hands between handling raw and cooked foods; not washing hands after eating, handling rubbish, using mobile phone, drinking, sneezing and/or smoking etc.
  • Food handlers suffering from vomiting, diarrhoea, fever, abdominal pains etc. (symptoms of food poisoning), handling food which can potentially pass food poisoning bacteria through that food to the consumer. (All staff have a responsibility to report illness to their manager who then has the responsibility to take appropriate action)
  • Using the same cloth for cleaning surfaces used for both raw meat/ poultry and ready-to-eat foods.
  • Infrequent use of a sanitiser (a combined cleaning and disinfecting agent) on work surfaces and chopping boards. This is critical where equipment is used for both raw and cooked foods, in particular meat and poultry.
  • Poor cleaning regime which can lead to contamination of food through attraction of bacteria and pests.
  • Physical contamination from, e.g. flies, jewellery, broken glass, worn equipment etc.

Cooking

  • Not achieving adequate internal cooking temperatures, i.e. greater than 75oC core temperature in thickest part of food (particularly for high risk foods, e.g. poultry, meat and rice dishes), which may lead to the survival of harmful bacteria.
  • Poor protection against cross contamination (see definitions) of cooked products by raw foods, particularly raw meats and poultry.

Further storage

  • Hot holding: Food stored at a temperature below 63oC, so allowing bacteria to multiply.
  • Cooling: Cooked foods not being cooled to below 8 oC as quickly as possible. It is recommended that this is achieved within 90 minutes.
  • Reheating: Not achieving a core temperature of greater than 75oC.

General

  • Lack of training and/or instruction or supervision of staff may very well compromise the safety of food.

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Control and monitoring options

Examples of rules for a business to follow to ensure food hygiene and safety

Purchase and delivery

  • Check temperature of foods on delivery. For example, temperature readings can be written on the invoice on delivery. On occasions staff may have to refuse delivery because the temperature is unacceptable, for example, delivery of defrosted products.
  • Check ‘Use by’ and ‘Best before’ dates.
  • Check packaging to ensure intact and in good condition.
  • Use only reliable suppliers.
    Set specifications for food delivered by supplier
    – for example, specifying long, thin joints of meat or specifying that custard tarts should be made using pasteurised eggs only.
  • Consider actually visiting your supplier. This is not unusual, particularly where large volumes of food are purchased.

Storage

  • High risk foods should not be kept at room temperature for longer than absolutely necessary. They should be stored below 8oC (preferably below 5oC), or below –18oC if frozen. Take temperature readings using an appropriate thermometer and record findings and any action taken.
  • Date codes on foods to be checked (specify frequency), e.g. every day for chilled foods and once a month for dried and frozen foods, dependant upon the type of business.
  • All ready-to-eat foods will be kept covered in the refrigerator at all times in order to protect against cross contamination and stored high up in the refrigerator or in a separate area, away from raw meat products and raw eggs.
  • Raw meats will be stored at the bottom of the refrigerator in trays which prevent meat juices dripping onto other foods.
  • In catering establishments eggs will be stored under refrigeration in order to reduce the growth of salmonella. Always check date code before using. Treat raw shelled eggs as a raw product so store below ready-to-eat foods.
  • No foods will be stored on the floor.
  • No cleaning materials will be stored where they may come into contact with open food. Separate storage provision shall be made.
  • Dried foods will be decanted into sealable containers in order to protect from physical and chemical contamination. Date codes will then be transferred onto containers. Consider storing allergens separately and well sealed to prevent contamination of other products.
  • Defective racking systems and the food room structure will be repaired as necessary in order to reduce the risk of physical contamination. Staff to report disrepair to manager.
  • Items which are not directly connected with the food business will not be stored in food rooms, in order to enable effective cleaning and to prevent physical contamination.

Preparation

  • Ensure that all foods which require thawing/ defrosting are completely defrosted before cooking, in particular, joints of meat and poultry.
  • Staff must wash their hands frequently and when required, particularly before preparing food, after handling raw meats and raw shell eggs, eating, drinking, coughing or visiting the WC. All wash hand basins shall be checked daily for cleanliness, soap and means of hand drying.
  • Staff with food poisoning symptoms will not be permitted to handle food.
  • All equipment and surfaces will be cleaned and sanitised regularly and as required.
    Separate cloths (different colours) will be used for cleaning surfaces used to prepare raw and ready-to-eat foods.
  • External doors will be kept closed at all times during food preparation to prevent ingress of pests, particularly flies.
  • Staff will be permitted to wear only a wedding ring during food handling and must wear appropriate protective clothing.
  • Thawing of frozen foods, such as poultry, must take place in areas away from high risk foods, and all equipment and utensils must be regarded as being contaminated. Defrost within a fridge in a temperature controlled environment.

Cooking

  • The centre of high risk foods will be cooked to a temperature above 75oC.
  • Ready-to-eat foods will continue to be separated from raw meats and unwashed vegetables prior to service.

Further storage

  • Hot holding
    Food will be stored above 63oC in the hot display unit. Temperatures will be checked at least once during service period or every 2 hours. (Be confident that your equipment can maintain food at safe temperatures.) All food will be protected from contamination during hot holding by enclosing in a unit separated from customers and by keeping covered if possible.
  • Cooling
    Hot food will be cooled as quickly as possible by either decanting into shallow containers or cutting into smaller pieces, where possible, and by placing in a cool area (below 20oC) or in an ice/cold water bath to be transferred finally to the refrigerator within 90 minutes. Aim to get the food core temperature down to 8oc within 90 minutes. A blast chiller would help for large scale catering.
  • Cold service
    Cold foods will be displayed below 8oC (preferably 5 oC) and kept covered where possible.
  • Reheating
    The core temperature of all reheated foods must be above 75oC. This is recommended as a CCP

General

  • All foods handlers should be trained to at least a Level 2 (Basic) Food Hygiene Course level. Managers, or those with supervisory responsibilities, may require additional training, e.g. Level 3 intermediate Food Hygiene Training.
  • In addition the person or people responsible for developing and maintaining your business food safety management procedures must have received adequate training to enable them to do this.

Please Note:

1. All options are given purely as examples and are not intended as an exhaustive list. Some items may go beyond the legal requirements of the retained Regulations EC852/2004, EC853/2004 and EC854/2004 but are included as they are recognised as good practice within the food industry.

2. Core cooking time/temperatures combinations which are equivalent to those stated will apply for different foodstuffs.

Allergens

It is a legal requirement for food businesses to provide accurate information about the allergenic ingredients used in the food and drink they serve. You need to consider allergens within your documented food safety management system and have a procedure and provide staff training on allergens.

Consider how you communicate allergies to your customers (e.g. signage), in house allergy references (e.g. a completed matrix), compulsory labelling on prepacked foods for direct sale (PPDS requirements) and how to avoid allergy cross-contamination when preparing/storing foods in your written procedures. For more information on allergens and what needs to be covered visit allergen guidance for food businesses.

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Definitions

Word Explaination
Hazard

The potential to cause harm/endanger the safety and quality of food

Risk

The likelihood of a hazard to occur.

Hazard Analysis

The process of identifying food hazards, the steps at which they could occur, and the introduction of measures to control them.

High Risk Foods

Ready-to-eat-foods. Those which readily support the growth of food poisoning bacteria, e.g. cooked meats, prepared salads, soft cheeses, cook-chill and cookfreeze dishes.

Cross Contamination

The transfer of bacteria from contaminated (usually raw) foods to other, ready-to-eat foods. This may be by:

  • direct contact, e.g. raw stored next to ready-to-eat food.
  • food handlers who handle raw then ready-to-eat food without hand washing.
  • equipment and work surfaces, used first for contaminated food.
Control

A step/procedure/measure which eliminates or reduces the effects of a hazard.

Critical Control Point

Point or procedure at which a control is applied to prevent, eliminate or reduce an identified food safety hazard, without which there may be a real risk of hazardous food being consumed.

‘Use By’ Date

Mark required on microbiologically perishable, pre-packed foods. (Food Labelling Regulations 1996. It is an offence to sell food after the ‘Use By’ Date)

‘Best Before’ Date

Mark required on longer life foods that are NOT subject to microbiological spoilage. For example, canned or frozen foods. (Food Labelling Regulations 1996). This date mark relates to food quality rather than safety.

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Now it’s time for you to have a go!

Don’t be daunted, take things one step at a time.

You will find here some blank hazard analysis charts that you can use. You will also find some example flow charts and hazard analysis charts for a retailer and a caterer that should help to point you in the right direction. We suggest that you use a photocopy for a first draft, as it is likely that you will need to make several changes as you go. You may also require several tables, one for each section of your business. You can choose how many or how few tables you need.

It is a good idea to discuss your first draft of the table with staff and get their input. Once you’ve finalised it, you may wish to display it on your premises. When you get inspected by your Environmental Health Officer they will want to look these and associated monitoring records.

Once you have developed your documented Food Safety Management System, we have provided you with some example monitoring record sheets, that will help you to demonstrate whether your controls are working. Monitoring is an essential part of any food safety management system based on HACCP
principles and you are encouraged to photocopy these forms as you need and use them as recommended. These records will enable you to demonstrate to your inspector all the checks that you take to ensure food safety.

So good luck and remember you can always contact us for assistance.

Download documents

Download Hazard Identification Charts
Download Monitoring Forms