RAI Legal

FSA 2011 Guidance Summary

The 2011 Guidance was developed in response to the foodborne E. coli O157 outbreaks in Scotland in 1996 and Wales in 2005.

Both outbreaks were attributed to cross-contamination arising from poorly managed food handling practices in a report by Professor Hugh Pennington – a report that resulted in wholesale changes to the inspection regime for FBOs in the UK. Professor Pennington concluded at paragraph 17.40 of the Inquiry Report into the 2005 outbreak in South Wales that: “It is small food producers / processors in Britain that have the greatest difficulty in achieving and maintaining the safety standards that are required to prevent the contamination of ready-to-eat products with E. coli O157. There should be no relaxation of regulation for them. The opposite should be the case.”

The main areas covered in the 2011 Guidance are:

  • It’s called ‘guidance’ but is enforced under HACCP. It’s the law. It’s not optional
  • Surface sanitisers must conform to BS EN 1276 or BS EN 13697
  • The rinse tank of commercial dishwashers must be at a temperature of at least 80°C to assure thermal disinfection
  • ‘Complex’ equipment can no longer be ‘chemically segregated’ – you can’t slice bacon, disinfect, then slice ham (cooked). You need two slicers, one for raw, one for cooked.

EHOs are very focussed on this and have been since it was released. Links to the FSA guidance materials are at the bottom of this page.


If a business handles raw food (which could be contaminated with E. coli O157) in the same establishment as ready-to-eat food, there will be a greater risk. Raw food, such as meat, fruit and vegetables that have been in contact with the soil and are not supplied as ready-to-eat, should be handled as if they are contaminated by E. coli O157.

If there has been a risk of contamination, all work must stop until the surfaces and equipment in the area have been sufficiently cleaned and disinfected, or replaced. Any potentially contaminated food should not be supplied for consumption. If it is suspected that contaminated food has gone to consumers, appropriate action must be taken.

The key control measures involve:

  • Separation of equipment and staff involved in handling raw food from staff that handle ready-to-eat food
  • Effective cleaning and disinfection
  • Personal hygiene and hand washing

Cross-contamination is one of the most common causes of food poisoning. It happens when harmful bacteria are spread onto ready-to-eat food from other food, surfaces, hands or equipment. The FSA mandate that Identifying separate work areas, surfaces and equipment for raw and ready-to-eat foods is the only certain way of preventing E. coli O157 contamination.

Work Areas: Provide separate working areas, storage facilities, clothing and staff for the handling and storage of ready-to-eat food. This is the designated clean area.

Storage: Use separate storage and display facilities, including refrigerators and freezers. Where separate units are not provided, the clean areas should be sufficiently separated and clearly identifiable.

Utensils: Separate chopping boards and utensils must be used for raw and ready-to-eat foods unless cleaned and disinfected in a commercial dishwasher between uses.

Packaging: Packaging materials for ready-to-eat food should be stored in a designated clean area and the outside surfaces of any wrapping materials for ready-to-eat food brought into a clean area must be free from contamination.

Cash Registers: Cash registers and other non-food equipment should not be shared by staff handling ready-to-eat food and staff working in other areas. A single cash register can be used, but staff must ensure their hands and clothing are clean when moving into the designated clean area.

Cleaning Products: Separate cleaning materials, including cloths, sponges and mops should be used for the designated clean area. Use disposable, single-use cloths wherever possible.

Equipment: Use separate machinery and equipment, such as vacuum packing machines, slicers and mincers, for raw and ready-to-eat foods. Where this equipment is used for ready-to-eat food, it should be kept in the designated clean area.

Clean Effectively: Effective cleaning is essential to get rid of harmful bacteria and stop them spreading to food. Work surfaces and equipment should be washed regularly and disinfected between tasks. Single-use, disposable cloths should be used wherever possible.

Cleaning and Disinfecting: Disinfection can be used to destroy bacteria from surfaces. However, chemical disinfectants only work if surfaces have been thoroughly cleaned first to remove grease and other dirt.

Sanitisers that have both cleaning and disinfection properties in a single product, but the two-stage cleaning and disinfecting process must still be carried out as above to ensure the sanitiser works effectively, that is, to first provide a clean surface and then again to disinfect.

This is the two-stage process for effective disinfection:

  • Use a cleaning product to remove visible dirt, food particles and debris, and rinse to remove any residue
  • Apply disinfectant using the correct dilution and contact time, according to the manufacturer’s instructions, and rinse with drinking water

Any disinfectant or sanitiser used must at least meet the official standards of BS EN1276:1997 or BS EN 13697:2001.

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Key food hygiene regulations include:

  • Regulation (EC) No. 852/2004 on the hygiene of foodstuffs
  • The Food Hygiene (England) Regulations 2006 (as amended)
  • The 2011 FSA Guidance
  • The Food Standards Act 1999 (Transitional and Consequential Provisions and Savings) (Scotland) Regulations 2000

These set out the basic hygiene requirements for all aspects of a business, from premises and facilities to the personal hygiene of staff. Comprehensive details of these regulations are contained in the FSA’s ‘Food Hygiene – A Guide for Business’.