22nd March 2015

Do I Have To Have A HACCP Plan?


Question MarkI have increasingly noticed that caterers are being asked for their ‘HACCP Certificate’ by their clients, before they will use their services. The owner of the business then goes off and duly researches and jumps to the very reasonable conclusion that what their customer actually requires is HACCP training, with a certificate at the end; hence the HACCP certificate.

But is this what your customer is really asking for?

Every food business has to have a documented food safety management system by law, which is appropriate for their size and activities.

It is fair to note at this stage that ‘HACCP’ is an acronym which is bandied about as a word, and quite often the person asking for the HACCP certificate, does not fully understand (usually) what they are asking for and sometimes why they are even asking for HACCP certification. It is just a ‘word’ that they have heard and know it has something to do with food safety and so they ask for it. They fully expect you, as the caterer to know exactly what they are looking for, even if they do not!

So let me help clear this up a little:

  1. HACCP is a process which has several stages to it. The outcome of the HACCP process is HACCP Plan. The main point about the resultant HACCP Plan is that the HACCP process is that it is about analysing your food business for where your processes can potentially fail and cause food poisoning or other undesirable consequences. The points at which it can fail will be your critical control points (CCP’s). This means that the HACCP process has to be based on your business and your business alone to be an accurate HACCP plan at the end of the process.
    A full HACCP plan is usually associated with food manufacturers. However, chains of premises may need them for consistency as may larger catering operations.

  2. All food businesses need a documented food safety management system, based on the HACCP principles. This is a law which has been around for over ten years now, so it is not new.
    The purpose of your documented food safety management system is to prove you are making/producing/selling food which is safe to eat.

  3. HACCP training is usually at 3 different levels –
    • Level one is suited to staff who have to fill in record sheets to support the HACCP plan
    • Level two is suited to the supervisors who supervise the staff filling the record sheets so that they can check if they are doing it properly, or perhaps if the HACCP plan has a flaw.
    • Level three is for managers who are tasked with designing the HACCP plan and are going to have to go through the HACCP process.

Training in HACCP is necessary to underpin a HACCP plan, it does not provide you with the HACCP plan itself.

So in conclusion, if this is still not clear: Your customers of your food business need you to be able to prove to them that you are making/producing/selling food which is safe to eat, consistently.

You definitely have to have a documented food safety management system, but whether you need a full HACCP plan or just elements of it, is down to the size and nature of your food business.

Your customers need proof that you have a documented food safety management system, whether it is a full HACCP plan or based around the HACCP principles.

If your instinct is telling you that you need a full HACCP plan, then that is OK. But before you insist on a full HACCP plan, consider the points above in relation to your food business, and no one else’s.

16th July 2013

Refrigerator Wisdom


Fridge TempDid you know that it takes a domestic refrigerator around 3 hours to recover its temperature after the door is opened once? So prepare a meal and keep opening and closing the door to it and this will be increased. And that is normal weather.....

But yet another urban myth is that most people think that refrigerators struggle to keep their temperature cool in hot weathers or environments. WRONG. Refrigerators actually work better in hot environments than cold. But only if you give them opportunity to do so.

Consider your own refrigerator and ask yourself the following questions:

Q: Is the refrigerator overloaded, do I have just too much in it?
A: The cooled air needs to be able circulate within the refrigerator compartments and therefore if it is too stocked up, this will be unable to happen. Over a prolonged period, this will cause your refrigerator to break down.

Q: Is there sufficient space around the refrigerator's exterior? I.e. is it pushed into a tight space or built in?
A: If you have ever looked at the rear of a refrigerator and seen the fins on it? These look like metal plates which are evenly spaced apart. This is where the cooling magic happens and they must have sufficient air space around them to allow this. Refrigerators that are pushed right back to the wall, backed into a corner or are a built in appliance could be struggling to have enough air circulating around them to operate properly allow the cooling magic to happen. So to remedy this where possible, pull the refrigerator out a little and see if it improves its performance. With built in appliances, leaving cupboard door open where the appliance is housed may help.

Q: What do the numbers mean on the dial in the refrigerator?
A: Contrary to some urban myths, the numbers on the dial DO NOT indicate the actual temperature that the refrigerator will operate at. Rather the numbers are arbitrary, and finding the correct number for your refrigerator is trial and error. But, the higher the number, the colder the refrigerator will be. i.e. number 9 = very cold; number 1 is not very cold at all.

In a domestic setting, you probably don't have an independent temperature probe, so a quick and dirty method is to just place your hand inside the refrigerator and see how cold your hand becomes! Yes really. Does your hand immediately feel colder? If yes, your refrigerator is probably cold enough; if not, turn the setting of your refrigerator up to its highest number (see above for guide). Yes this may be too cold, but partly frozen food can be defrosted and eaten still, whereas spoilt and off food cannot.

More quick tips:

• Refrigerator thermometers can fail and therefore can lie. If yours are over a year old, they are probably not working properly and are unable to be used as an indication of your refrigerator's temperature.

• The same for refrigerator read outs. They can lie also. In addition to this they are probably positioned so that they measure the temperature of the incoming cold air. This is not an accurate guide to the temperature of the food stored in your refrigerator. ( a lot of commercial businesses get this wrong too)

• As I said the only way to accurately measure your refrigerator's temperature is to use an independent temperature probe, but if you don't then feel the hand contact temperature of a piece of food in your refrigerator when it has been in there overnight. i.e. a block of cheese or butter (polyunsaturated fat spreads will not work for this purpose). If it feels cold to the touch and for the butter is a solid block with no hint of melting then your refrigerator is likely to be operating at a cold enough temperature.

Oh for those of you with an independent probe – the air temperature of the refrigerator should be 5 degrees Celsius or less. If its measuring this, your food will be colder so its cold enough.

Remember: Cold food should be just that: Cold.

Coming soon – Refrigerator and Chiller wisdom for commercial businesses.

1st July 2013

Bovine Tuberculosis (mTB) in Beef

Bovine TBBeef burgers and steak took another battering recently during the recent revelations that the government have passed off TB (Tuberculosis) infected beef as safe to eat and thus it has entered the food chain.

This is interesting as just like another expert on infectious diseases Dr Martin Wiselka, at University Hospitals of Leicester NHS Trust, was quoted as saying

"I'm a bit surprised as I thought infected cattle were removed from the food chain"

And so did I.

As a qualified meat inspector, (yes I have personally carried out these checks in the past within an abattoir environment). I was taught that the entire meat inspection regime was to detect TB in cattle (Bovine TB or mTB). Yes, the meat inspection process also detected other issues that could also render the carcass unfit for human consumption; but its main purpose was to detect TB.

There now appears to be a skin test that can detect TB onset in cattle. And I am surmising that following a positive skin test, if a positive testing beast is then sent for slaughter through the usual route, it would be identified from the meat inspection checks which occurred at the abattoir. Potential problem eliminated.

Maybe though, as the Nigel Gibbens, Defra's chief vet, warned recently:

"If we do not maintain and improve our bTB controls… the risk of infection to other mammals and humans will inevitably increase."

Why would this be? The meat inspection check regime that I was taught was sufficient then, so why isn't it now?

Could it be that these checks have also been relaxed, meaning that the reliance is now on the skin test to identify TB in cattle. Therefore, if fraud is at play again (think horse meat scandal just a few months ago) that getting a positive beast into the food chain is easy peasy?

A bit of good news...

Before you all turn vegetarian and all the GENUINE meat producers across the food chain give up. TB in its unabbreviated form stands for: Mycobacterium bovis (mTB) this is the strain found in cattle, and Mycobacterium tuberculosis – the strain (mainly) found in humans. The fuss is because the bovine version found in cattle is zoonotic, which means it can be transferred to humans.

OK the good news is: mTB is currently being reported as a virus. It isn't. It is a bacterium. This cold comfort means that as bacteria are readily cooked out of food, this one can also be cooked out at temperatures 60 degrees Celsius or above.

We were all vaccinated for TB (remember the jab at school) Why, in this day and age, are we still having to be concerned with diseases that were prevalent during the Victorian era, but were all but eradicated during the last 50 years plus? Why are they making not just a come back, but appear to appearing at an exponential rate?

19th June 2013

Horsemeat Scandal Canters On....

HorsemeatA couple of weeks ago, the Food Standards Agency published their findings of the horse meat scandal from earlier this year.  You can read this report here: also download their power-point presentation given on this subject on the same page.

What struck us most about this report, is that it's just a report on the role (perceived or actual) played by the stakeholders in the horse meat scandal. It considers how well the situation was handled by all relevant stakeholders and includes the FSA themselves, the media, the food industry and also local authorities. And concludes how they could handle this type of situation and work better together next time. These are all very valuable insights, for them.

But with all the information that was provided in the report and power point presentation; What it doesn't appear to answer or even discuss are the main public and industrial interest points of the scandal.

We would say these are:

Until these kinds of questions can be answered, the public faith and belief in the safety of our food will not be restored which means that the repercussions for the meat industry, whether at fault or not, will continue to reverberate.

What does this mean for the average food business owner, whether they are a manufacturer or smaller retailer? Well we think that this means an extended period of uncertainty for these markets. Even though many players in the industries were not a part of this scandal, they would have been and will continue to be affected by it. This section of industry are probably the ones who have invested in their food business, have played by the rules, have robust and demonstrable food safety management systems in place and also comprehensively audit their suppliers. But they have followed all the 'rules' but still suffer. It could see why many would think 'why bother?'

But as auditors and specialists in food safety management systems, I defer to HACCP UK's previous blog post about the horse meat scandal (Horse Play) in that this particular scandal was fraud on a very large scale. I still am of the opinion that comprehensive auditing of the suppliers would have found it, or at least sensed that all was not well and searched further. Also, what about financial audits that all limited companies have to undergo? I think there was widespread conspiracy and fraud for this to have happened on such a large scale.

So maybe the FSA will have another meeting and put together a package of measures that protect them from criticism, and may also in fact help them in the prompt investigation of another incident of this magnitude. But in the meantime, the industry still need to survive and we as humans still need to have food to eat and we won't all become vegetarians. Therefore, we can't afford to wait for the FSA to act the good players in the industry need to react now to prove over and over again that most of them can in fact be trusted to produce not just safe food, but also that the food they produce is exactly as they say it is.

18th June 2013

To freeze or not to Freeze

FreezeFood waste seems to be topical at the moment and both Sainsbury's and Tesco have made moves to reduce it and the Co-op declaring that they will have their stores waste free by 2016.

Sainsbury's 'answer' is to change the freezing advice on the label from freeze on day of purchase to freeze before the use by date.  Their reasoning for this is that because people look in their fridge and see the advice 'freeze on day of purchase' on some products that are several days beyond the day it was purchased, that they conclude that the item is now 'no good' and as they won't get around to consuming it before its use by date, and that they may as well throw it away.

A few months ago, I would have thought that this notion was ludicrous and people were not so guided by labels.  But, not so, I received a phone from a friend 'who knew I knew about food' asking the very same question.  She had purchased some raw chicken fillets intending to freeze them, but they had ended up at the back of the fridge and was now at its use by date.  She was now concerned that she had wasted her money and would have to throw that product away.

Tesco have decided to tackle food waste by intending to stop offering bulk buy incentives I.e. buy one get one free.  Their theory behind this is that customers buy more and then are faced with the scenario outlined above.

Have The supermarkets have created this issue themselves?  What once was intended as good advice to stop people inadvertently poisoning themselves with food which was so old it was dangerous to eat, now appears to have gone overboard and no single item of packaged food (I challenge you) can now be found which does not have a use by or best before label on it.  Personally, this particularly annoys me when we are talking about grocery items like lettuce and fruit.  And the supermarkets have created their own waste food mountain because only 'perfect' looking fruit and veg is displayed for sale, the rest is consigned to the waste bin.

Whether or not relaxing the labelling from 'freeze on day of purchase' to 'freeze before the use by date' will have any effect on food wastage remains to be seen. HACCP UK's view on this is that they (Sainsburys) have decided to alter the wrong part of the label.  As far as we can see as food safety specialists; the length of time that is advised that a particular food can remain frozen for – these are used to be displayed as the freezer stars on products – are entirely for food quality purposes and heralds back to when domestic freezers were far less effective at freezing than they are today and people like my late grandma had a larder freezer only.  It's all to do with the size of the ice crystals that freezers create during the freezing process of a product.  Domestic freezers freeze more slowly and therefore the ice crystals formed are larger than during a commercial freezing processes.  Bigger ice crystals damage the structure of the foods during freezing leading the foods to, theoretically, decompose quicker.

So the two pieces of advice on a package of raw chicken breast fillets to freeze on day of purchase and then consume within one month is, to us is therefore, nonsensical. The advice to freeze on day of purchase is good quality advice, as the product will be as fresh as its going to be, and freezing effectively puts that product in stasis.  Once it is frozen in domestic chest or upright freezer, it now looks like a solid flesh coloured block, it is as hard as a brick and could in other circumstances be used as an effective weapon.  Exactly why shouldn't I use this food if it remains in this frozen solid brick like state I.e. the freezer doesn't break down and defrost, two months after freezing it?  Bacteria don't breed at this temperature, enzymes are inactivated and any parasites would also be deactivated too.

So the two pieces of advice on a package of raw chicken breast fillets to freeze on day of purchase and then consume within one month is, to us is therefore, nonsensical.  The advice to freeze on day of purchase is good quality advice, as the product will be as fresh as its going to be, and freezing effectively puts that product in stasis.  Once it is frozen in domestic chest or upright freezer, it appears as a solid flesh coloured block, it is as hard as a brick and could in other circumstances be used as an effective weapon.  So, our question is, exactly why shouldn't this food be used if it remains in this frozen solid brick like state and the freezer hasn't broken down and defrosted, two months after freezing it?  Bacteria don't breed at this temperature, enzymes are inactivated and any parasites would also be deactivated too. (also proven by the recent sushi advice)  So exactly what is going to happen to it whilst it is frozen solid?  And why is it so important to consume it within that golden one month!

We would love to hear your comments on this.  Do you agree?  Have you thrown out food because of its advisory labelling?  Anyway, if you do happen to know a sound scientific explanation as to why you should only keep raw chicken breast fillets frozen and consume them within one month, I would love to know!

3rd June 2013

Food Allergy Alerts

Allergy AdviceThere have been 24 allergy alerts and since the beginning of 2013 which equates to roughly one per week. And all of them are due to inaccurate or mislabelling of the ingredients in the product. Each one of these allergy alerts has occurred because the product has made it all the way to the shelf available for a consumer purchase.  Now these are all subject to a product recall. I.e. where the product is withdrawn from sale and recollected by the manufacturer.

These are not all small time producers that have found that their products are mislabelled. No, these include manufacturers making for all the big retail names. Therefore if the likes of Asda, Tesco and Waitrose labels can be caught off guard, do you think your food company could be too?

What has gone wrong? Well, the ingredients that are on the label do not match those that are actually in the product. One of them actually declares itself to be 'dairy free' and actually contains milk protein!

The first thing is these are not 'one offs'. These companies are not making a couple of products for the corner shop, they are producing thousands of products per batch. So how is this happening?

Products made in these quantities are made to a specification (like a recipe) to make sure that all the ingredients on the specification actually go into a product, they will be recorded on a batch control sheet. To get to this stage, someone or an automated system must have ordered the components of the specification or the product would be unable to be made. Therefore someone knew.

Even in the most automated of systems, there is human input and either at the ordering stage or the adding the specification components together for the product, someone must have known that 'we put milk protein in this one'.

What about the extensive Quality Departments that these large companies have? Cross checking the specifications against the batches and labels should be happening routinely and before any of the product is made. What checking systems (validation) do these companies actually have in place? And if they do have auditing (verification) Do they undertake to check for obvious mistakes such as this?

This isn't fraud like the horse meat, its either pure incompetency or plain old complacency.

12th February 2013

Horse Play

How good is your due diligence defence?

Horse Play

When the likes of the large multiple retailers (you know the ones) get caught out with a food issue, like recent headline news. It shows that no food business is immune from being caught unawares. If not by their own actions, by those of a ‘rogue’ supplier.

As a responsible food business, you are responsible for ensuring that the raw materials coming into your business are suitable for use. The word suitable encompasses legal, safe and hygienic. It is your responsibility. If your business is accused of misdemeanour's in respect of your food, could you defend yourselves and prove otherwise?

No doubt, those large multiples have systems in place; but if they are not being properly managed, they will not protect them when it matters most.

HACCP-UK can help with ensuring you have an effective and robust food safety management system in place which is regularly audited to ensure legal compliance and best practice. We can train your staff how to operate the system properly so you can avoid being ‘caught out’.