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HACCP and small businesses in the UK

The Commonwealth and State Governments are continuing to consult on how best to introduce Food Safety Programs based on HACCP to the food industry as a whole. This seems likely to occur on a priority basis determined at least in part by cost-benefit studies.

Since 1995, all proprietors of food businesses in the UK have been required to carry out a hazard analysis to identify the food safety hazards within their businesses. This covers five of the seven HACCP principles set down by the Codex Alimentarius Commission. The businesses are not required by legislation to document or formally verify their controls. However some, mainly larger, food businesses have embraced the additional principles for what they perceive as their own advantage. This is likely to be a legislative requirement in the future in the UK as the European Union moves towards this goal.

A study, commissioned by the British Food Standards Agency, has recently been published (Food Control 13 2002 307). This study, conducted by two environmental health officers, compares the standards of food hygiene in 70 food premises operating either documented or undocumented hazard analysis systems within the Derby City Council boundary.

Classification of the 70 food premises included within the survey
Premise category	Documented hazard analysis	Undocumented hazard analysis
Café Restaurant Staff restaurant	10	9
School Nursery	4	4
Nursing home Residential home Day center	7	6
Sandwich bar Sandwich manufacturer	3	3
Takeaway	2	4
Public house	6	6
Hotel	3	3
Total	35	35

The study is titled 'An assessment of the value of documenting food safety in small and less developed catering businesses'. The term catering is used in a fairly general sense (see Table) but the results obtained are of interest for a cross section of the food industry. The criterion used by the investigators for inclusion in the study was that the caterer was carrying out preparation/cooking of open, high-risk foodstuffs.

The 70 food outlets were surveyed by questionnaire. Thirty-five had documented hazard analysis systems and 35 had undocumented hazard analysis systems in place. Of the 35 premises with documented hazard analysis systems, 24 had company produced generic systems and 11 had in-house constructed systems. Those premises with company systems were likely to be subject to regular compliance audits by experienced consultants. On average, these premises received a higher score (better hygiene practices) than those with in-house constructed systems.

Evaluation of production stages
The survey results were used to compare premises' production stages. These included purchase, storage, preparation, cooking, cooling, and reheating. A score closest to 100 per cent indicated a high level of control and lower percentages showed those areas that were not as controlled.

There was little variation in overall compliance for each of the production stages between those premises operating documented and undocumented hazard analysis systems. Those with documented systems scored marginally better in most circumstances but there was a significant difference in favour of documented systems premises in only two production stages: preparation and cooking.

Preparation
This section referred specifically to cleaning of food preparation surfaces and attempted to measure whether detergents and sanitizers were correctly used. Over half of all premises surveyed were not cleaning and disinfecting correctly. Premises with documented systems overall had significantly higher standards of food hygiene for preparation. The exception was in the case of nursing/residential homes where those with undocumented systems scored slightly higher. The authors speculate that this group appreciated the importance of adequate cleaning and sanitizing because of the importance of infection control in their work environments.

Cooking
Although most outlets had methods for checking foodstuffs at cooking, lower scores were recorded where outlets did not verify the checking methods, for example by using food temperature probes to check core-cooking temperatures. Most premises without documented systems relied on visual checks and experience, a procedure which has been shown to be fatally flawed in the past. However, only 57 per cent (20 of 35) of premises with documented systems were using a disinfected probe thermometer to check foods at cooking.

The authors conclude that it has become increasingly apparent that without a requirement for food businesses to perform the latter two steps of HACCP, recording and verification, enforcement officers have difficulty in proving non-compliance with the existing hazard analysis requirement in UK legislation. Nevertheless, the results of their study indicate that further research is needed before the UK Government proceeds with a decision to implement full HACCP across the entire food chain. The study reported 'does not present any compelling evidence that having systems in writing would remedy all food safety problems'.

The authors recommend that all food businesses should be licensed, with the application of HACCP linked to the licensing requirements. The licensing would be in two stages with a provisional licence being granted to those businesses that have the necessary prerequisites in place. A full licence would be granted when the business had successfully implemented HACCP.

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Prepared by Keith Richardson and Rachel Jackson
Food Science Australia
PO Box 52, North Ryde 1670. Tel +61 2 9490 8397 Fax +61 2 9490 8499
Email enquiries@csiro.au