Food business operators have the prime responsibility for food safety in law by ensuring materials and products supplied to them are safe and their processes and products are safe for the consumer. Food processors don’t just have to produce safe products, they have to be able to prove to the relevant authorities that their procedures, processes and facilities can ensure food safety and comply with legislation, through effective management, monitoring, action and documentation.
This has to start with commitment from top management, as required in ISO 22000, with a ‘fundamental statement of intent’:
putting food safety as a business objective;
communicating to staff the requirement for food safety;
establishing a food safety policy, signed by the person with overall responsibility;
conducting regular reviews of safety;
allocating sufficient resources.
Relevant measures must be put in place to ensure safety is maintained at all points in the production process. This involves achieving a series of ‘prerequisites’ that the company should establish, following established Good Manufacturing Practice (GMP) and standard operating procedures (SOPs).
The US FDA has put more emphasis on prerequisite programs because these have been the source of most food safety hazards and product recalls in the US. Rentokil’s own research shows that the main reason for non-compliance with food safety standards is lack of attention to basic hygiene in the operating environment, including:
basic sanitation measures;
cleaning and hygiene program;
pest control; and
8 Steps for Prerequisites
For each prerequisite there are eight steps in the process for ensuring hygiene and safety are maintained and any lessons learned are fed back into carrying out improvements.
Responsibility: assign a qualified person to be responsible for implementing the steps required;
Develop: develop the procedures for carrying out a programme, monitoring it, and taking corrective action;
Document: produce the documentation that describes the procedures, the tasks required to carry them out in detail, and forms used for monitoring;
Train: staff should be trained to carry out the procedures and tasks described in the documentation, including monitoring and documenting activities;
Implement: actual practices should follow the documented procedures;
Monitor and record: accurate monitoring and recording provides evidence that procedures are being followed;
Verification and audit: verification checks that when the system is running it is working as designed, documentation is being carried out properly and competencies are up to date. This is done through procedures such as validation of critical control points, calibration of equipment used for monitoring, sampling and testing. This should be done by trained personnel, whether they are internal staff or from an outside agency.
Review and update: top-level management should review each program at regular intervals to assess how well it is performing, develop protocols to improve processes, allocate sufficient resources to implement any changes and document the process.
The prerequisites below are based on the Codex Alimentarius and GFSI recommendations, which are followed by regulating and standards bodies worldwide.
The first requirement for food processing facilities is the location, design and construction of the facility. This gives a basic foundation for controlling external risks to food safety and improves the ability to maintain hygiene, store materials safely, and remove waste effectively.
The facility should be located to reduce the risk from:
environmental and industrial pollution;
waste accumulation, allowing removal of solid and liquid waste from the site.
Design and construction
The design and layout internally and externally should enable maintenance, cleaning, and hygienic practices. It should prevent physical, chemical and biological contamination of stored and processed food and during the food production process.
Surfaces of walls, partitions and doors should be made of durable materials suitable for use in food preparation and storage areas and that are easy to clean and maintain.
Floors should be constructed of material that is easy to clean, safe to walk on and constructed to allow adequate drainage without puddling.
Drainage systems should be adequate for the facility, easy to clean and maintain, and designed to prevent contamination, including from pests.
Ceilings/internal parts of roofs, windows, piping, cabling, lighting and other fittings should be designed to prevent accumulation of dirt, condensation and risk of contamination.
Equipment and containers
Equipment, working surfaces and reusable containers coming into contact with food should be made of food-safe material and designed and constructed so that they can be cleaned and disinfected, are safe to use with cleaning and disinfecting chemicals and maintained to ensure food safety.
Hygiene facilities in food production
There should be suitable facilities for cleaning food, utensils and equipment with an adequate supply of potable water.
Personnel hygiene facilities
Personnel should be provided with adequate facilities for maintaining personal hygiene in a suitable location:
adequate number of flush toilets with an effective sewerage system;
washing facilities including hot and cold water, soap and hygienic drying equipment/ materials;
changing facilities for staff to put on hygienic clothing;
hygienic facilities for eating and drinking.
Air handling and ventilation
Ventilation and air conditioning systems should be adequate for the facility, to control aerosols, condensation, temperatures, odours, humidity or dust. They should prevent contamination and be easily cleaned and maintained.
The facility should have adequate supplies of water for food processing, cleaning and fire control. Potable water should be of suitable quality (eg as specified in WHO guidelines or higher) and have suitable facilities for storage and distribution.
Non-potable water should have a separate system that prevents contamination of potable water systems and be easily identifiable.
Cleaning and hygiene
The business should establish effective procedures and methods to prevent contamination of food through systems for cleaning of food production areas and equipment, pest control and waste management.
Cleaning of facilities
Building exteriors and interiors should be maintained and cleaned to prevent biological, chemical and physical contamination of raw materials, ingredients, processing and storage areas, equipment, storage containers, packaging materials, vehicles, food products and personnel.
Grounds and surrounding areas should be maintained and kept free of vegetation, waste materials and debris to prevent contamination and remove harbourage and food for pests.
Food production areas and equipment should be kept clean and hygienic by applying appropriate standards of cleaning through all production stages.
Raw materials, ingredients, packaging materials and finished products are stored in a clean and sanitary environment.
Cleaning and disinfection products are used according to manufacturers’ instructions and stored safely to prevent contamination of food and packaging.
Many species of pest are attracted to the food and shelter present in food production facilities and can enter the food supply and production facilities at many points, contaminating surfaces, materials, equipment and food products. Pest control is maintained by:
Implementing an integrated pest management programme (IPM) under the control of a competent person;
Inspection of incoming materials: raw materials, ingredients, packaging, containers and vehicles;
Preventing access to food and water:
food stores and containers should be pest-proof;
spills cleaned up quickly;
remove standing water;
waste stored in pest-proof containers and storage areas kept clean.
Preventing access: regular inspections and maintenance of facilities to prevent pests gaining access through windows, drains, vents, screens, doors, piping, roofs, etc;
Preventing harbourage near buildings: clearing of grounds of vegetation and debris;
Monitoring, detection, reporting and documentation of pests;
Taking appropriate pest elimination measures and documenting activities as required by best practice and legislation;
Storing pesticides according to regulations to ensure safety and prevent contamination.
Waste management is essential to prevent contamination, infection, harbourage of pests, and pollution. Provision for the safe handling of waste includes:
Establish effective and legally compliant procedures and facilities for storage and disposal of waste off site;
Waste storage capacity should be appropriate for the needs of the facility;
Establish effective procedures for waste removal from delivery, storage, food processing and other working areas;
Waste containers are designed for waste storage, constructed of suitable materials and are pest resistant eg to flies, rodents, birds;
Implement cleaning practices for waste storage areas and containers;
Waste management complies with legal requirements.
Personnel hygiene & health
The food business shall ensure that all staff and visitors follow appropriate hygiene practices that ensure safety of food processing, including:
Health status: people known to be suffering from or carrying an infectious disease, through medical diagnosis or suspected from showing symptoms, must not be allowed to enter a food handling or processing area. This applies to food handlers, other staff and visitors.
Infectious diseases: conditions that should be reported by staff and visitors to the responsible person, and monitored and recorded by the company include:
jaundice (an indicator of hepatitis);
sore throat with fever;
discharges from ear, eye, nose.
Injuries: cuts and skin abrasions should be covered with suitable dressings and catering glove, if on a hand;
Personal hygiene: food handlers should maintain a high level of personal cleanliness, including:
Hand hygiene at appropriate times: before entering the food handling area, after using the toilet, after handling raw food, after handling contaminated materials. [see handwashing facilities; guide to washing]
Control of personal habits that could result in contamination of food: spitting, sneezing, coughing, chewing;
Remove wearable personal effects before entering the food handling area: jewellery, watches, pins, etc.
Eating, drinking and smoking only in designated places.
Hygienic clothing is worn to protect the food from the handler: every person entering a food handling area is required to wear clean and appropriate clothing. This can include: hair covering, beard covering, footwear, various types of glove.
Hygienic clothing should be clean and undamaged before use, and handled, cleaned and stored to maintain its hygiene;
Hygienic clothing should be made of appropriate material and of suitable design;
Ears, eyes and nose may require protection in some circumstances, for instance, from dusty material, irritant liquids, noisy machinery.
Transportation affects food products before and after the manufacturing process. Therefore measures should be implemented to ensure raw materials, ingredients, packaging, semi-processed and finished products are transported in conditions that protect them from contamination, damage and spoilage. These include:
Vehicles, containers and packaging are suitable for the products and conditions of transport, to maintain the integrity of the products and prevent pests and human interference;
The temperature, humidity, atmosphere and other conditions can be maintained at suitable levels to prevent spoilage, deterioration; and these are also recorded;
Vehicles and containers do not contaminate the product from materials used in their construction, dust and fumes;
Vehicles and containers are maintained in a good state of repair and cleanliness;
Vehicles and containers are effectively cleaned between transporting batches of products, where necessary eg raw materials in bulk;
Vehicles, containers, packaging and products are inspected on arrival at the food processing facility eg for contamination, pests, transport conditions;
Empty vehicles and containers are inspected before loading, eg for cleanliness, pests, mould, dust, odours;
Loading and unloading areas are of appropriate construction and design to protect the transported product during loading/ unloading.
Loading and unloading areas are kept clean and spills removed quickly.
Codex Alimentarius. General principles of food hygiene.