CHANGES IN FOOD SAFETY LEGISLATION – 1ST January 2006 GUIDANCE FOR CHURCH OF SCOTLAND CONGREGATIONS A fair amount of publicity has been given to new food hygiene regulations which are due to come into force on 1st January 2006. While on the one hand, they relate to food business operators, on the other they are intended to cover all activities apart from the domestic handling, preparation and storage of food for private domestic consumption. They will therefore apply to Congregational operations no matter how limited. However, in practice, they should not be particularly onerous so far as the bulk of Congregations is concerned. It should be borne in mind that they do not introduce new hygiene requirements as such. Food should be stored, handled and processed safely and hygienically and premises should continue to be kept clean and hygienic. The hygiene principles underpinning the Regulations are as follows * Compliance with microbiological criteria for foodstuffs; * Compliance with temperature control requirements; * Maintenance of the cold chain; * Appropriate sampling of foodstuffs to ensure compliance (e.g. use of temperature probe); * Keeping premises (kitchens and all other accommodation used for the preparation or processing of food) clean and in good condition, with adequate facilities for cleaning food stuffs, washing utensils etc; * Keeping temporary premises such as marquees or stalls clean, with adequate provision for hygienic preparation of food stuffs and washing utensils etc. The principle innovation in the Regulations relates to the managing of food safety in line with what are known as HACCP (Hazard And Critical Control Point) principles. Essentially, these requirements relate to the minimising or managing of risk. HACCP is a food safety management system. Its main aim is to focus attention on critical points in an operation and to take measures to ensure that problems do not occur. The approach should be familiar to anyone with food safety training and should not involve anything unfamiliar to Congregational Food Safety Co-ordinators who have been on a training course. Under the existing law those responsible for any sort of operation where food is prepared and served should carry out risk assessments and, as stated, premises should continue to be operated in a safe and hygienic way, but a more structured approach to managing the operation may be required and records may require to be kept. The requirements will vary depending on the level of operation. Congregations which provide café facilities or the like will be most affected. Congregations who have monthly or fortnightly events such as lunch clubs will be less affected, but nonetheless appropriate procedures will require to be in place and records kept (as detailed below). The Regulations apply in all circumstances where food is brought on to premises but in the case of “low risk” activities, simplified procedures and record keeping should suffice. The basic Food Safety management requirements are as follows:- 1. Identifying risks to food safety which might be present or occur within your operation (“What can go wrong, when and where?”). 2. Putting controls in place which will deal with the risks (“What can I do about it?”). 3. Ensuring that controls are carried out and that if something does go wrong, it is clear to all involved what should be done to rectify the problem (“What is acceptable?”, “How can I check?”, “What can I do about it?”). 4. Ensuring that the procedures are kept up to date (“How do I confirm that the procedures are still working?”). 5. Keeping the documents and records necessary to show health inspectors that the procedure is working and is reviewed where necessary (“What documents and records do I need?”). Guidance should be available from the Environmental Health Department of the relative local authority and it is strongly recommended that such advice is obtained and acted upon. Details of the HACCP documentation are provided in the Food Standards Agency publication which should be available from local authorities. It can also be accessed at the FSA website: http://www.food.gov.uk/foodindustry/regulation/hygleg/hyglegresources/cookretailscotland/cooksafe/ The publication provides detailed advice which is tailored for commercial operations and in most cases “slimmed down” versions of the example documentation should suffice. While references to record-keeping may appear daunting, once the basic documentation (such as flow charts and check lists) is in place, monitoring by the Congregation’s Food Safety Co-ordinator should be fairly straightforward. It is recommended that each Congregation has a Food Safety Co-ordinator with the appropriate level of training and that he or she is responsible for implementing the risk assessment, reviewing the procedures and keeping records. Home preparation The Law Department frequently receives enquiries as to whether or not it remains open to Congregations to allow food which has been prepared at home to be brought to the Church for consumption or sale. It remains the case that there is no outright ban on this. However, assessments as to risk do require to be carried out. While there would normally be no problem with cakes which do not have high risk ingredients, such as fresh cream, there may be a degree of risk with all other foods and, as a general rule, it is safer to avoid bringing in high risk foods which have been prepared at home. Such items should therefore be prepared within the church premises or be bought in from commercial sources. Whether procedures require to be applied and documentation kept in respect of low risk items such as cakes will depend on the circumstances. If “home cooking” is being donated in connection with an event, then it may be appropriate to record the source and, of course, items should then be handled and stored safely. Again, there may be labelling requirements so far as items such as jams and cakes sold at Church fetes and the like are concerned. This circular supplements and updates the more general advice on the Food Safety Act 1990 and relevant Regulations contained in the Circular issued in 1999. A copy of this can be obtained by emailing :- mwilson@cofscotland.org.uk Word- Circulars – Food Safety 2006 update