8 CRAFTBUTCHER l MAY 2017 THE TIMES THEY ARE


FOOD HYGIENE


A-CHANGIN' by Paul Hobbs, Principal EHO at Horsham District Council


operator should have implemented the prerequisite food hygiene requirements such as cleaning & disinfection, sound structure and equipment, personal hygiene, staff training, temperatures controls, etc. So long as the prerequisites are supplemented with good safe practices and they achieve the objective of producing safe food there is no need for small low risk businesses to implement and maintain a permanent procedure based on the HACCP principles. Te FSA developed


WE live in challenging times and there can be no doubt that the historic vote to leave the EU has presented the UK with a major challenge. With challenge there comes opportunity and in order to take advantage of opportunity we oſten have to change the way we do things. Central Government


want to change how business is regulated. In order to make the UK an attractive proposition for investors they are determined to tackle the regulatory burdens that hold business back making the UK to be the best place to start and grow a business. Te Food Standards


Agency (FSA) is also advocating change. Tey want to change the way the FSA and local authorities regulate food businesses and ensure we protect people for the future in a modern, global food system. You will have seen from


Richard Stevenson’s article last month that the European Food Safety Authority (EFSA) also recommend change with a proposed simplified approach to food safety management in small retail businesses such as grocery shops, butchers, and bakeries. So where does this leave


Hazard Analysis Critical Control Point (HACCP) so oſten the regulatory burden


for small business? HACCP & BUTCHERS HACCP is seen as a vital food safety and hazard prevention tool within the food industry. It has become the universally recognized and accepted method for food safety. Te World Health Organisation has recognized its importance in preventing foodborne diseases for over 20 years. As a result, the European Union adopted the Hygiene of Foodstuffs Regulation (EC) No 852/2004, which introduced HACCP as a legal requirement throughout Europe for the first time. Tis regulation became mandatory from 1st January 2006 and states that all food business operators should establish and operate their food safety programmes based on the seven principles of HACCP. Tere has always been


flexibility in relation to compliance with the HACCP requirement. Te legislation recognises that small food businesses undertaking low-risk activities do not require a full blown HACCP food safety management system and Annex II of 852/2004 gives guidance on a simplified implementation of the HACCP requirements particularly in small food businesses. Prior to application of HACCP to any business the food business


Safer Food Better Business (SFBB) using this principle to make life easier for business operators. SFBB for caterers and SFBB for retailers were designed to work in most small catering and food retail businesses. Te FSA state however that SFBB is not appropriate to manage food safety in specialist retailers such as butchers, fishmongers and bakers. In butchers premises where raw meat and ready-to-eat foods are handled the FSA recommend HACCP Review and Guidance Manual for Retail Butchers, produced by the Meat Training Council (MTC).


A SIMPLER APPROACH Te European Commission requested EFSA to provide scientific opinion on a simplified approach to food safety management in small retail businesses such as grocery shops, butchers, and bakeries. Te outcome are a suite of formulated guidelines on how to identify the most relevant biological, chemical and physical hazards at each stage of the food production process, the activities or practices that make hazards more likely to occur and appropriate control measures. EFSA have recommended that this approach is adopted, but at this stage it is only a recommendation.


IS CHANGE LIKELY? Whether the FSA choose to adopt this model is uncertain especially given that we have implemented divorce proceedings with the EU. It is important to point out that the examples given in the report seem to relate to a retail butcher handling raw meats only. It is possible that the FSA will stick to its view that a simplified approach is not appropriate for a retail butcher handling raw meats and ready-to-eat foods. When the Government


talk about making the UK an attractive proposition for investors they are of course talking about large international organisations. For those businesses HACCP makes sense and as it is internationally recognised I don’t see much change there. However for small


businesses here is the opportunity to force change. Te FSA wants to change the way food safety is regulated and are currently consulting with stakeholders. It is time for the industry to speak up and tell the FSA that small businesses lack expertise and financial resources when attempting to develop and implement an effective Food safety Management System based on HACCP. It is time to develop a more workable and less burdensome model. In the meantime we have


to work with the current requirement. Te Primary Authority Assured Advice for retail butchers is a great resource and a good place to start. Backed by the Government the advice is free and based on current industry standards. If you follow the Assured Advice your local EHO is legally required to have regard to it and accept it. Food safety must never be compromised and until change comes around this is by far the easiest and affordable way to be compliant. n


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