What new guidance means

Local authorities are all trying to work out what the implications of the new guidance.

In order that the content and significance of the Guidance requirements for the business and enforcement community can be openly discussed SFMTA is encouraging local authorities to call meetings to communicate what they are looking for to food business operators. The first of these will be held in Perth on 20th April 2011 to be held in conjunction with the Scottish Federation of Meat Traders Associations (SFMTA) in Pullar House , 35 Kinnoull Street, Perth at 2.30pm.

The Report of the Public Inquiry into the 2005 E. coli O157 outbreak in Wales recommended that food businesses must ensure that their systems and procedures are capable of preventing contamination or cross-contamination of food with E. coli O157 and that the Food Standards Agency should remove the confusion that exists amongst food business operators about what types of solution should be used to prevent cross-contamination from surfaces and equipment.

The Agency wants food business operators to be absolutely clear about how to meet their generic obligation in law to produce food safely as well as their specific obligations to comply with the requirements of hygiene legislation.

Authorised officers undertaking official controls should similarly be clear about whether food business operators are complying with those requirements and the steps that it would be appropriate to take when faced with non-compliance.

Guidance has been drawn up to address these matters will apply to food businesses of all sizes and types handling raw and RTE foods.

The Guidance sets out ways to comply with obligations to control cross contamination where an E. coli O157 hazard needs to be considered.

The key points in the guidance are:

a. The necessity for separation of raw and ready-to-eat foods and their handling, including describing the circumstances when physical separation is always required

b. The need for dedicated (single purpose) use of complex, equipment such as vacuum packers, mincers and slicers. The guidance stipulates that dual use of such equipment should never be regarded as safe practice.

c. Provision of advice on the selection and use of chemical disinfectants by reference to existing European standards.

d. The critical role of hand washing is reinforced. Existing advice on hand washing technique in the health care sector is applicable to cross contamination control. However, hand rubs should not be used as an alternative to hand washing.

e. Notwithstanding the overriding requirement for physical separation, the guidance emphasises the need for appropriate hygienic design of all food equipment and machinery. Advice is given on the applicable standards for hygienic design of machinery.

f. Failure to follow any procedure to control E. coli O157 cross contamination must always be regarded as a potentially serious incident. The guidance sets out appropriate corrective actions and highlights the need to reconsider and amend control measures that have failed.

g. The actions enforcing officers must consider in order to protect consumers if a food business operator has not identified and controlled hazards appropriately. In particular, they should always consider the use of Hygiene Emergency Prohibition Notices where inadequate control presents a risk of direct or indirect contamination of ready to eat foods by E. coli O157.

As you can see the Guidance is clearly laying down a prescribed standard for the strict physical separation of unwrapped raw meats and ready to eat foods where they are handled on the same premises, in addition to the enforcement approach to be adopted whenever any significant breach of that standard is observed by enforcement officers.