The FSA has concluded that the best solution is to issue new approved guidance and it is now consulting on the approach that this guidance should take and the principles that should be applied. Naturally the Association will be taking a leading role in this exercise and will be seeking an early meeting with the officials involved.
It is worth repeating some of the key recommendations of the Pennington Report 2009:
1. All food businesses must ensure their systems and procedures are capable of preventing contamination or cross-contamination of food with E.coli 0157
2 The principles underpinning the Butchers' Licensing Scheme should guide food hygiene measures in businesses processing raw meat and unwrapped ready-to-eat foods
3. The FSA should review its current guidance and should be proactive in generating new guidance where needs are identified
4. The FSA should remove the confusion that exists among food business operators about what solution(s) should be used to prevent cross-contamination from surfaces and equipment
There are a number of proposals and policies underpinning the FSA guidance proposals, which are in line with basic FSA principles and also the Pennington recommendations. They have made it clear, however, that their key intentions with the eventual guidance can be summarised as follows:
1. Ensure effective cleaning by removing the confusion that exists among FBOs about what cleaning solutions should be used to prevent cross-contamination from surfaces and equipment. The guidance will include advice on the standards that disinfectants/sanitisers should meet. They will also confirm that cleaning is a two-step process initial cleaning to remove dirt and grease etc then a disinfection process to ensure destruction of bacteria.
2. Ensure the physical separation of the raw and ready-to-eat food preparation process. This will be a key area for discussion and will look at the use of dedicated (single-purpose), complex, hard-to-clean equipment, such as vacuum packers, mincers and slicers.
3. Ensure those who handle food are aware of effective hand hygiene techniques to prevent cross-contamination.
HACCP will, of course, continue to play a major part in the proposals and the Association will argue the new guidelines should not detract from the importance of effective HACCP procedures.
The seven HACCP principles:
1. Identify any hazards that must be prevented, eliminated or reduced to acceptable levels.
2. Determine the critical control points (CCPs) identify the step at which control is essential to prevent, eliminate or reduce a hazard to acceptable levels.
3. Establish critical limits at CCPs which separate acceptability from unacceptability for the prevention, elimination or reduction of identified hazards.
4. Establish a system of effective monitoring procedures at CCPs
5. Establish corrective actions when monitoring indicates that a CCP is not under control.
6. Establish checks that verify the measures are working effectively
7. Establish records to demonstrate effective application of the measures.