[important]First, It’s Not ‘Guidance’…[/important]
The 2011 Guidance does have a few grey areas. Let’s look at the FSA’s view with some ‘helpful’ extra comments…
The FSA advice is ‘guidance’ so it’s not compulsory.
Oh yes it is. It’s called ‘Guidance’ so they don’t need an Act of Parliament do change how they enforce. It’s called ‘guidance’ but it’s enforced under HACCP. There is a legal requirement on food business operators to manage food safety using Hazard Analysis and Critical Control Point (HACCP) principles, by ensuring that hazards are identified and that valid critical controls are established, implemented and verified.
The 2011 Guidance clarifies:
- The circumstances in which E. coli O157 cross-contamination hazards should be considered;
- The strict control measures required to effect adequate control of E. coli O157 cross-contamination risks;
…and that a lapse in these controls represents an imminent risk to consumers.
This gives EHOs the grounds to take emergency action to prevent the supply or continued production of unsafe food. If alternative methods of control other than those stated in the guidance are in place they must be supported by robust verification. In the absence of verification the guidance provides an evidenced approach to the control of cross contamination.
In relation to complex equipment, such as vacuum packers, slicers and mincing machines, the FSA considers that the dual use of such equipment for raw and ready-to-eat foods should never be considered safe. Prosecutions and shutdowns can and have happened.
“This doesn’t apply to me”
The guidance applies to food businesses of all sizes and categories where both raw food and ready-to-eat foods are handled. Raw food in this context would include raw meat and any raw ingredients that are potential sources of E. coli O157, such as raw root vegetables, fruit or other vegetables that are likely to have been contaminated by soil.
If a small cafe serving homemade cooked food and freshly made sandwiches has no potential sources of E. coli O157, such as raw meat or root vegetables in addition to ready-to-eat foods, the guidance does not apply but normal statutory hygiene rules still do. The guidance will apply to all relevant food businesses operations where there is an E. coli O157 cross-contamination hazard whether home-based or not.
It should be remembered that the FSA recommendation for killing the E. coli bacteria through cooking is that the food be raised to an internal temperature of 70˚C for two minutes. Where lower temperatures are used the times will be considerably longer, and it would fall to the food business to show that their time/temperature combinations are sufficient to achieve the same decontamination as cooking at the recommended temperature.
Also, the guidance only applies to those parts of an operation where cross-contamination has to be controlled. This includes protection of ready-to-eat food produced by the business from cross-contamination originating from raw ingredients for domestic consumption.
Even a home-based business will need to comply with the guidance, which is for food businesses of all sizes, if both raw food and ready-to-eat foods are handled.
- Raw food in this context means raw meat and any raw ingredients that are potential sources of E. coli O157.
- Ready-to-eat foods are foods that will not be cooked or reheated before being eaten and include foods such as cooked meats, sandwiches, cheese, salads and desserts.
Note that this applies to everyone in the clean environment – not just food handlers.
There are some exceptions: manufacture of speciality cheeses, for example. The processing of raw milk in the manufacture of ready-to-eat foods such as specialist cheeses which are sold as ready-to-eat is beyond the scope of this guidance. Guidance for specialist cheese manufacturers already exists. Other dairy establishments handling raw milk, such as those pasteurising milk, should already have well-established systems to control cross-contamination.
We also need to take care defining ‘handling: ready-to-eat foods that are packaged in such a way that they cannot be contaminated (such as tinned and other hermetically sealed pre-packed foods) should not be regarded as being ‘handled’ for the purpose of the guidance. However, the guidance will apply to any situation where potentially contaminated packaging could spread that contamination into areas where open ready-to-eat foods are handled.
What about salad vegetables, apples and other fruit eaten raw being sold unpacked alongside untreated vegetables that are likely to have been contaminated by soil?
The hazard from E. coli O157 should be treated consistently in all contexts.
- Fruit or vegetables which are sold unpacked and handled directly by consumers should not be considered as ready-to-eat without washing.
- Packaged fruit or vegetables should not be regarded as ready-to-eat unless this is stated on the product packaging.
- Any fruit or vegetables which are sold as ready-to-eat should be protected from potential E. coli O157 cross-contamination risks at all times.
It is vital that food business operators are aware that unwashed vegetables, particularly those which are visibly contaminated by soil should be considered as potential sources of E. coli O157 and stored and presented in such a way that they do not lead to the contamination of ready-to-eat produce. It is also vital that consumers understand whether the vegetables and fruit they are purchasing are intended to be ready-to-eat or require washing, peeling or cooking prior to consumption. The necessity to consider the risk of E. coli O157 contamination of vegetables is particularly significant in light of the recent outbreaks in 2011, where there was a link to consumption and handling of contaminated vegetables.
Control measures to achieve the decontamination of foods are outside the scope of the main guidance. Industry implements controls to minimise the potential for contamination in the field from the seed onward through Good Agricultural Practice. However, it should be recognised that fruit and vegetables are produced in non-sterile environments and while washing cannot guarantee the removal of all bacteria from produce it will help to reduce any bacterial contamination which may be present on the outside. Raw fruit and vegetables should not be stored with ready-to-eat foods until they are ready-to-eat.
Unless they are supplied to the food business as ready-to-eat, it should be assumed that they are not. Washing will help to remove bacteria including E. coli present on the surface of fruit and vegetables. Most of the bacteria will be in the soil attached to the produce therefore washing is particularly important to remove any soil. This can be done effectively by rubbing the vegetables vigorously under water, for example in a bowl of fresh water, starting with the least soiled items first and then rinsing with clean water. Washing loose produce is particularly important as it tends to have more soil attached to it than pre-packaged fruit and vegetables. In general, it is always advisable to wash all fruit and vegetables before you use them as ready-to-eat ingredients to ensure that they are clean and to help remove bacteria from the outside.
Peeling or cooking fruit and vegetables can also remove bacteria. Once these controls have been undertaken, and the food will not undergo another control before being supplied to the customer as ready-to-eat, the food should be protected from any further cross-contamination and stored and displayed in those areas of the premises set aside for ready-to-eat foods. The use of chlorine is not recommended for the washing of fruit and vegetables in catering or domestic kitchen settings. Chemicals such as chlorine are used by the fresh produce industry under strictly controlled conditions, and the main role of such chemicals is to sanitise the water being used to wash produce rather than to decontaminate the produce itself.
Research has indicated that the reduction in microbiological contamination which occurs through the washing of produce appears to be due to the amount of physical agitation rather than through the effect of washing aides such as chlorine. The FSA strongly advises against using general cleaning products or washing-up liquid to wash vegetables etc as these products may not be safe for human consumption, and by using them harmful residues may be left on the food.
Can you use the same food preparation sink for washing raw food, such as salad vegetables, and then for rinsing ready to eat food such as cooked rice?
You can use the same sink for washing dirty vegetables as for rinsing ready-to-eat foods, but a strict system of control to do this safely needs to be in place. After a sink has been used for washing dirty vegetables the sink should be thoroughly cleaned and disinfected (including the taps and any other fittings). The same sink may then be used for ready to eat foods. It is not considered desirable to wash raw meat prior to cooking due to the increased risk of splashing bacteria onto surrounding surfaces. Vegetables and rice should be washed in such a way to avoid contact with the sink both during and after washing e.g. by placing them in a bowl/container or colander.
It is also not necessary to rewash raw foods such as salad items that are already labelled ready-to-eat when purchased.
But ‘chemical separation’ worked. Why do I now need two meat slicers?
Errrmmm… Not really. The kinds of Campy counts they were getting form retail butchery pretty much nailed that one.
The FSA claims its decisions are based on science and many are asking for evidence that separate equipment is the only reliable means of adequately controlling E. coli O157 cross-contamination and for banning the dual use of equipment and machinery, for raw and ready-to-eat foods is excessive and costly.
In fact there are a number of published studies which support the need for separation to facilitate effective cross-contamination control. Research has clearly demonstrated the transference of pathogenic bacteria from raw meat onto surfaces, hands and inanimate objects, and the subsequent spread of these pathogens to ready-to-eat foods. Such indirect cross-contamination has also been shown to be extremely difficult to control when strict adherence to procedures such as hand washing and cleaning is relied upon to prevent the spread of pathogens between raw and ready-to-eat foods.
The evidence shows that it is not possible to manage these procedural controls to ensure that they are carried out adequately on all of the appropriate occasions, particularly in busy environments.
This is supported by the conclusions published in the Public Inquiry report, in which Professor Pennington highlighted that too much reliance was placed on using chemicals to sanitise surfaces in contact with raw and ready-to-eat meats. This was particularly the case in relation to E. coli O157 given its virulence, the low infectious dose, and its ability to survive on metal surfaces. He considered that the use of biocides was not a control measure applied at a critical control point “that can be used to prevent or eliminate a food safety hazard or reduce it to an acceptable level”.
Professor Pennington concluded that a reliance on biocides to reduce the risk from cross-contamination should have been made unnecessary by the use of separate equipment for raw and ready-to-eat meats, particularly in relation to complex equipment such as vac packers. During its examination of the issue, the FSA found no evidence to suggest that Professor Pennington’s conclusion that cross-contamination could not be fully or reliably controlled using biocides on shared equipment was incorrect. Such a regime is subject to a number of complicating factors that would make reliable proof of safety unachievable.
What is ‘Complex’ equipment? Is there a list?
Complex equipment is considered to be any piece of equipment that cannot, in its entirety, be subject to appropriate cleaning, as set out in the guidance. Such equipment cannot be adequately cleaned to ensure complete disinfection over all surfaces and in all its internal components.
Complex equipment and machinery, such as vacuum packing machines, mincers, slicers and so on, are composed of an array of surfaces and components which have the potential to become contaminated either directly (from raw food) or indirectly (from hands or aerosols). In order to prevent indirect cross-contamination, it is important that complete disinfection is applied to all parts of the equipment and not only those which contact the food directly. Given the difficulties in controlling spread of contamination by procedural means, the consequent opportunities for indirect cross-contamination, and the difficulties in reliably implementing adequate disinfection each time a surface is subject to contamination, dual use of such equipment for both raw and ready-to-eat foods is considered to present an unacceptable risk.
Also, if a complex piece of equipment is to be used for ready-to-eat foods that may have been used for raw food in the past – for example due to a change of use in the food business or bought second-hand without a full history of usage – the FSA’s view is that it is not safe.
If it is not known for certain that complex equipment has not been used with raw foods it cannot be used with cooked.
Bacon. Are cured meats raw or cooked??
Bacon is sold as a raw product and although the salting / curing process could have an antimicrobial effect this will not guarantee removal of pathogens. Further processing, usually cooking will be required to achieve this so dual use of vacuum packers for bacon and ready-to-eat foods should not be allowed.
Black pudding may be sold as ready-to-eat or as requiring further cooking before consumption by the customer and it is for the retailer to make a decision on how to treat such products. If they are to be sold as ready-to-eat, they must be stored, displayed and handled in the designated clean areas of the premises. If they are to be sold as raw, then they must be treated as such throughout the product cycle and must not be placed in storage or display with ready-to-eat foods.
The retailer should also make it clear to their customers that the product requires further cooking if it has been handled as raw and have documented controls in place to ensure that, whichever decision is taken standards are consistently applied. An EHO will then make a judgement to decide if these controls are adequate.
Do businesses need to have separate cash registers, chip and pin machines etc. for handling raw and ready-to-eat foods?
The FSA advocates separation, but accepts that there may be examples of where a single cash register may be used with appropriate controls in place, including hand washing either before or after using the cash register. In this case the guidance states that ‘A single cash register can be used if appropriate measures are taken to prevent the spread of bacteria. If the cash register is kept in the clean area, care must be taken to ensure it is not contaminated by staff coming from areas outside the clean area. Similarly if it is kept outside the clean area, staff from the clean area must ensure their hands and clothing are clean after using the cash register before returning to the clean area’.
We have one fridge for raw and cooked. How about the handle?
Where a single fridge is used for storage of raw and ready-to-eat foods, controls must be put in place to ensure that the door handle does not become a source of indirect contamination for those staff handling ready-to-eat foods. In practice, if staff handling raw foods wash their hands before touching the door handle, this will ensure that it is kept clean for staff handling ready-to-eat foods.
What is a ‘clean area’?
A designated clean area is an environment within which freedom from E. coli O157 contamination is assured by having suitable control measures in place. The clean area includes the space above the work surface. No raw foods, or equipment that may be contaminated by raw food, should be carried over the top of the work surface or stored above it, as this would compromise the clean area.
The designated clean area would not include the floor surface as a floor can never be regarded as clean. All surfaces that could come into contact with food – hands, utensils wrapping materials etc. must not be a possible source of contamination.
Is storage and display equipment required to be labelled so that clean areas are readily identifiable as being for ready-to-eat foods?
The guidance does not require this, it just requires adequate separation within such equipment and – critically – that food handlers know where it is safe to store ready-to-eat foods and to ensure that raw food is kept adequately separate from these locations at all times. Separation should form part of the food safety management procedures plan and these must be effectively communicated to staff. While not a strict requirement it is good practice to use labelling to help with the implementation of the food safety management procedures e.g. “This refrigerator to be used for cooked meats only”.
The Guidance says I need two chefs to fry a steak – one for when it’s raw, one when cooked. Or if I have one he needs to change clothes?
No. Where staff are cooking raw food to order in a catering operation, the business should ensure that the raw ingredients are kept in a separate location from the clean plates and the ready-to-eat foods.
Separate utensils, from those used for raw foods, should be used to plate cooked foods from the cooking range and these must be clean at all times. One way of maintaining clean hands will be to ensure that raw ingredients are only handled using tongs, forks or other utensils that are kept between uses in such a way that the handles are not exposed to risk of contamination.
This would mean that hands would not be contaminated when these utensils are used. Hands should nevertheless still be washed on a regular basis by staff handling food. Is a probe thermometer complex equipment? A probe thermometer must be treated the same as any other piece of equipment, and must not be a vehicle for cross contamination. Any probe thermometer that cannot, in its entirety (including any base unit), be subject to heat disinfection (in the dishwasher) would be regarded as complex equipment and would not, therefore, be considered safe for dual use between raw and ready-to-eat foods.
In most cases, where the probe thermometer is being used to check the temperature of partially cooked food, we would expect that the initial use of the probe would take place after the outside surface of the food had been raised to a sufficient temperature to kill any bacteria found on the surface of the food such as E. coli O157. Therefore, the initial use of the probe would not introduce contamination from surface to the centre or, importantly, from the food to the rest of the probe equipment. In this case there would be no requirement to use a different probe to subsequently check that the food has finished cooking or to probe other ready-to-eat food, although we would recommend cleaning the tip between uses, either with a probe wipe, or in boiling water.
The exception to this would be when the probe is being used to monitor the temperature of partially cooked products made from minced or ground meat. In this case, the bacteria would not be limited to the surface of the product and there is, therefore, a greater risk of cross-contamination. The tip of any probe that has been inserted into partially cooked food made from minced or ground meat, must be appropriately heat disinfected, for example in boiling water, before it can be used again to subsequently check that the food has reached the required temperature.
I clean with an antibacterial sanitiser so why do I need to do two-stage cleaning?
Sanitisers combine both cleaning and disinfection properties in a single product, usually as a spray. The FSA recommends that chemical disinfection can only be reliably achieved on a visibly clean surface and hence the need for a first stage cleaning process to remove visible dirt, food particles and debris before using the sanitiser for disinfection.
When used in a single stage process these products are only suitable as an interim ‘clean-as-you-go’ measure and never as a disinfection control for controlling E. coli O157 cross-contamination.
Do I need separate floor scrubbers?
An area of floor may be within a room or designated clean area but the floor itself can never be regarded as clean and any food or surfaces of food equipment that come in contact with any floor must be considered as potentially contaminated. So, you don’t need a separate machine but floor cleaning equipment will need to be separated from any equipment used to clean other surfaces such as worktops in clean areas. It is essential that floor cleaning is carried out in such a way that it does not contaminate surfaces in a clean area that will be treated as safe to contact without the risk of spreading E. coli O157.
I wash my cloths by hand and steep them in bleach overnight. Is this acceptable?
Ick. Cloths. Ick. Bleach. Ick. Separate cloths for cleaning should be provided for use in raw and ready-to-eat areas to prevent cross contamination. The FSA does not consider steeping in bleach to be an effective method of control for E. coli O157 contamination. This is because any organic matter, such as grease, dirt or food, left on the cloths can stop the disinfectant from working properly. The guidance indicates that cloths previously used outside the clean area that are to be re-used in the clean area should be laundered using a standard boil wash, which typically operates at 90°C.
The guidance quotes BS EN 1276:1997, but the BS site states that this has been withdrawn and replaced by BS EN 1276:2009?
The differences between the two standards are procedural rather than technical. This has had the effect of strengthening the test method and harmonised it with other European disinfectant standards, but has not changed the requirements for the disinfectant to pass the test so disinfectants that passed the test before the change in standard would, therefore, have met the same, current pass criteria. A sanitiser complying with BS EN 1276:1997 remains suitable for use and does not need re-testing to BS EN 1276:2009.
Why are there two test procedures for killing E. coli O157?
Both standards are adequate in terms of outcome but the method of assessment in each is different. BS EN 1276 is a suspension test whereas BS EN 13697 is a surface test.
BS EN 13697 has a wider scope because it includes fungicidal action, which is not relevant to the control of E. coli O157. Therefore, if products meet BS EN 13697 there is no need to demonstrate compliance with BS EN 1276.
What formal action is deemed appropriate if a food premises is found to not be using a British Standard bacterial detergent?
Where disinfection is critical to food safety, a food business operator must have a valid procedure in place and use a product complying with one of the BS EN standards set out in the guidance. They also need to use it in accordance with the manufacturer’s instructions for it to be considered as valid. It is for the food business operator to demonstrate that procedures are valid and EHOs must consider the use of a Hygiene Emergency Prohibition Notice where disinfection is critical to food safety and a valid procedure has not been demonstrated by the food business operator.
Chemical disinfection should not be used as a substitute where the guidance stipulates that physical separation is required.
[important]Dishwashers / Thermal Disinfection[/important]
How should I clean my utensils if I do not have a commercial dishwasher?
Ideally, a separate sink should be used to wash utensils that have been in contact with raw foods from one used to wash utensils in contact with ready-to-eat foods. However, the guidance acknowledges that this is not always possible and advises the utensils used for ready-to-eat foods be washed first, followed by anything used for raw foods. The most important control is to ensure that the sink is properly washed and disinfected following contact with any utensils that have been in contact with raw foods. It is also recommended that utensils washed in this way should be air dried to avoid the risk of contamination with cloths that may have been in contact with raw foods.
If a food business is not decontaminating with heat disinfection, they must have separate chopping boards/utensils for use with raw and ready-to-eat foods.
Can I use a steamer to disinfect utensils / chopping boards that have been used for raw foods and then use them with ready-to-eat foods?
Any method of temperature disinfection that allows for the temperature of all surfaces of the utensils / chopping boards to reach 82˚C may be an acceptable control for utensils / chopping boards, once they are clean of actual food debris etc. The food business operator would need to demonstrate to the satisfaction of an inspecting officer that the method was an effective control as part of the business’ food safety management system.
[important]You Need Hands…[/important]
Do I have to wash my hands if I handle cash at a ready-to-eat counter before serving the next customer?
The guidance would apply where the cash is likely to be contaminated by sources of E. coli associated with raw foods handled in the food operation. This is not likely to be the case where cash is handed over by customers. In such cases, existing advice applies. Tongs and other utensils are used in most ready-to-eat serving areas to avoid any contamination of food from the general environment.
Do hand sanitising products need to comply to British Standards too?
The FSA says that ‘for extra protection against cross-contamination it is recommended that a liquid hand wash that has disinfectant properties conforming to the European standards BS EN 1499:1997 is used’. if only the Dept of Health were so sensible the nation’s hospitals might not be so minging. Never go into a hospital unless you’re unconscious. Seriously. Anyway, it also says that hygienic hand rubs ‘can provide an additional level of protection and are recommended following hand washing where there is an increased risk of cross-contamination (e.g. when raw foods have been handled prior to hand washing)’. It also recommends that hygienic hand rubs ‘should conform to standard BS EN 1500’. I’d suggest a moisturising bactericidal hand foam; alcohol dries out your skin, as does soap, so working in food you need to wash / sanitise your hands lots. They will dry out and get sore if you don’t watch it.
Technically ‘Guidance’ needs to be complied with and is enforced under HACCP so the BS EN 1276 / BS EN 13697 ‘Guidance’ for sanitisers is compulsory. The BS EN 1499 / BS EN 1500 advice, however is described by the FSA as ‘best practice’ and compliance with the advice on best practice is not required by law. That said, we would always recommend FBOs use hand sanitisers that comply.