The Food Standards Agency has released a communication concerning some common sense controls to avoid risk. The main points are targeted towards the consumer who does not need, of course, to follow mandatory food safety procedures and hence can be a source of their own risk.
I wonder whether we are just possibly over-reacting to risk in this case?
The recall of Lloyd Grossman sauce has, according to the latest from the FSA, affected only one jar of the entire batch.
The toxin that causes the illness is very easily destroyed by normal cooking and again that can be verified by the a linked article issued by the FSA. Now if we had a water supply problem, which was a microbiological issue, a boil order would most likely be issued. So should we simply issue a warning that the consumer should thoroughly heat the sauce, as they should anyway?!
I’m interested to hear comment.
In a positive move forward, the British Sandwich Association, the trade association which runs a food safety certification scheme for sandwich and sandwich mix manufacturers, has adopted a minimum 3 out of 5 score as a mandatory requirement for its retail members. The scheme awards score of 0 to 5 where 5 is excellent and 0 indicates urgent attention to food safety controls and /or site standards. Read about it here
So how do sandwich manufacturers, food factories, restaurants, pubs, hotels and takeaways achieve a 5 score? By having commitment to food safety in these primary areas:
And so on……it’s all of course laid out in the Food Hygiene Regulations
And can easily be monitored and improved through the process of internal checks and external hygiene audits.
On another, but related note, it has been suggested to me in the past that, in exercising these controls, we are living in a falsely sterilised environment and have opened ourselves up to immunological weakness. Well consider two things: Have you ever had full blown Salmonella food poisoning from a food establishment? If so you probably would never want it again and you possibly lost valuable work days as a result – all because someone else didn’t care or take the time enough to think of you and minimise the risk! And just by ensuring good food safety we aren’t living in a sterile world. If you go out, as you probably do, every day, into a number of different situations, and if you eat “natural” food (i.e. non processed), such as fruit and salad, then you are presenting a challenge to your system that is just fine.
This recent and very serious Listeria outbreak in the US has been reported by Food Quality News as the worst in modern history with a death toll of 29.
Listeria can, once it takes hold within the food area, be very difficult indeed to eliminate. The organism is associated with areas of wet and standing water, such as floors and drains. Using very high pressure hoses can exacerbate the problem causing micro-aerosols which spread far and wide around the food room, contaminating other surfaces and food equipment.
A higher risk of Listeria within raw materials and ingredients needs to be highlighted within the assessment of hazard significance as part of the HACCP Plan. Then the risk to the food stream and factory can be appreciated and effective controls proposed and implemented. Those controls will centre around the key pre-requisites of selection and maintenance of materials used in construction of the food room, design and hygiene of equipment, and effective, validated cleaning and disinfection procedures using clean and well designed cleaning equipment and chemicals.
Following our last post we continue our guidance on implementing a BRC Global Standard Issue 6 compliant HACCP Plan.
I’m often asked about the “point” of this, in a HACCP Plan. The answer is simple. It makes the HACCP Team consider the impact of the attributes of the product on the credible food safety hazards. For example:-
A product with near neutral pH, much available water (Aw 0.95 or more), packaged in normal atmosphere packaging will be prone to rapid microbial spoilage, or worse, the growth of pathogens and the formation potentially of bacterial toxins.
A product with low pH (acidic), or very low available water (<0.95), and that is vacuum packed or tinned, represents a much lower risk of microbial growth and consequent microbial spoilage.
And so describing the product or groups of products helps to ensure that the hazard analysis which will follow is appropriate – that is – credible hazards are not missed and unlikely hazards are not considered unnecessarily.
Defining the target customer identifies whether the food is likely to be eaten by those who may be more prone to food poisoning or food borne disease. It is important to identify if, for instance, your products are targeted to consumers in hospitals, care homes or infants.
Then look at intended use of the product. If you target the elderly consumer and your product is ready to eat (straight out of the pack) then you potentially have some more credible microbial hazards than if the product is intended to be cooked and you do not target those who may be less healthy. Again, as for section 2.3, this provides you with information about how you should consider the credibility of hazards within the hazard analysis.
Almost certainly the auditors will be looking for a lot more detail that demonstrates that the HACCP Team understand where and how the processing steps interact and where those processes occur within the factory / food unit. This requirement is, to a degree, visited again in clause 4.3.1 (Lay-out) which we’ll cover later.
We need to know whether a process step in one particular area of the premises gives rise to more hazards compared to it being situated in another area. Hence the BRC requirement to consider the option of covering a plan of the premises and equipment lay-out when producing the flow diagram. Then add in: waste routes; utilities introduction; water, gas, compressed air or steam inputs; packaging inputs, delay steps, rework steps, processing aid inputs, and so on.
Again this is the way in which the HACCP Team, in performing the hazard analysis will not forget to consider all credible hazards perhaps arising from sources that they wouldn’t have thought of were the flow diagram not to be detailed enough.
And then don’t forget to verify the flow diagram. Really do have the team walk the line, talk to operators, consult plans, take into account shift patterns etc. Once satisfied get everyone to sign and date the flow diagram. You can create an nice little verification table somewhere in the corner for this if you value tidiness of course.
Next time – we’ll look at hazard analysis, managing CCP’s and HACCP review.
The BRC Global Standard for Food Safety is clear in Issue 6 – it wants processors to truly manage their food safety using their HACCP plan. The key word here is “manage”. This is a live document that should be at the forefront of the minds of all operators, shift leaders, managers and directors. Not just the HACCP Team.
If you think this is getting a bit tricky and you would value some expert input, you know where we are!