Paperwork

Importance of paperwork

As a food business operator, you have a lot of pressure on your time. Over complicate food safety and it will quickly fall apart leaving you in trouble. Here are the top reasons why food businesses get food safety paperwork wrong:

1. Too much paperwork! Food businesses can often get bogged down in thinking lots of documentation is what the EHO wants to see, piling up folders and folders of information. The problem is how do you find the time to oversee all that paperwork, making sure it is up-to-date and being followed by staff? The truth is a good system is a succinct system.
2. No idea what your own food safety paperwork even says! The paperwork that sits on the shelf collecting dust for two years, until an EHO walks in and wishes to look at it, is utterly useless to everyone. You have no idea what it says and therefore no idea how accurate it even is anymore.
3. Too many daily checks! Businesses that overdo the daily monitoring records find themselves struggling to keep up with them, and then ultimately falling behind on them, or giving up on them entirely. Once a system is in place and working smoothly, it shouldn't take more than five minutes a day to maintain.
4. Lack of understanding why you have to do something! Using a food safety documentation system that you do not understand will quickly fall apart. You have to understand and appreciate your own personal system in order for it to work.

Why do you need food safety paperwork?

Thinking through your entire business to identify any possible hazard that may make your food unsafe is you managing food safety.

Now then, let’s say you do this entirely in your head. What if something goes wrong? Can you explain in detail every single hazard you have considered, how you control them, what has gone wrong and when, what changes you carried out to resolve these problems? Can you also do all of this in court being cross-examined by a Barrister? If so, then great. You are a smart person and may be able to have no paperwork at all.

But what if you employ any staff? If so, can you remember exactly what training you have given them and when? Are you absolutely confident the staff will remember everything you have told them? If they have been properly trained and have a good enough memory to confidently remember everything you have told them, what they do and what action they have taken when things go wrong then amazing! You can probably have no paperwork at all.

If you do not fit into one of these two categories, then you will need some paperwork. To be clear, the second category doesn’t even exist and the first only exists for a very select number of individuals.

So, you may need some paperwork. Why? Because you can’t possibly remember everything, and your staff certainly can’t. Documentation enables you to keep a record of how you are keeping your food safe. It creates a "Bible" for you to give to your staff to follow. It gives you something to show the EHO so they can see how you are running your food business. If things do go horribly wrong, it can give you a written, documented defence in court, which may just save you from a huge fine and possibly even prison.

What to include in your paperwork

You therefore need to have paperwork in place to demonstrate how you manage each section of your business. A lot of this is covered across this website. By going through each section, you could write a system as you go.

But each food business is different, so you will need to assess each part of your own business to make sure everything is covered. Let us look at how we can do that.

Identifying your hazards

To serve your customers safe food, you need to identify anything related to the food that may cause them harm. These are called hazards. Hazards can be broadly separated into three categories:

1. Microbiological contamination: These are any micro-organisms that cause food poisoning or spoil the food. We control microbiological contamination by keeping foods at the right temperature, not keeping them past their use-by date, cooking them, managing cross contamination, etc.
2. Physical contamination: Any physical objects that may contaminate the food are not supposed to be there! For example, hair, plastic, glass, metal, wood, insects, animal droppings. We control this by having a clean kitchen in good condition, by keeping foods covered, by using undamaged utensils and equipment, etc.
3. Chemical contamination: Most chemical contamination issues will centre around cleaning chemicals, but this may also include heavy metals such as lead or mercury which may seep into food from your equipment or structure. Thinking about how we use and store our chemicals, and what materials we use in our equipment and structure, will ensure we control chemical contamination.

Identifying your controls

Once you have identified the hazards, you need to establish how you will control them. Controlling a hazard is ensuring that the hazard is eliminated or reduced to a safe level. A lot of hazards will be controlled through general practice, such as cleaning, laying out the premises correctly, using disposable cloths, having clean clothes, training staff, using fridges, etc.

By implementing these measures, you will go a long way to having a safe food business. These measures are sometimes called prerequisites. They are precautionary control methods that prevent food safety concerns arising.

There are some controls however, that are critical and cannot be achieved though general practice. They are critical as without specific controls being in place, food safety will be compromised. These are known as critical control points.

Identifying your critical control points

The critical control point is the final opportunity to eliminate the hazard or reduce it to a safe level. Critical control points will always be very precise, for example, cooking to 75°C for a minimum of 30 seconds, or keeping high risk foods in fridges at or below 8°C.

If you breach a critical control point, food is deemed unsafe for consumption and must be removed from the food chain. Establishing critical control points will enable you to clearly identify when a control has been breached and you will be able to take immediate corrective action.

Don’t get confused by critical control points; the vast majority of businesses will have very few of them. Cooking raw foods is the most obvious one.

Monitoring your critical control points

You need to make sure you are meeting your critical control points, as if you are not, then food safety will be at risk. The only way you can do this is by monitoring and making sure your control measures are working correctly and being implemented as required.

You do not need to check everything every second of the day, but you do need to carry out enough checks to be satisfied your system is working correctly. If any issues are identified, you must take immediate corrective action to put things right.

Corrective actions

Where monitoring shows something is going wrong, do something about it immediately. It may be that food hasn’t been cooked correctly, or a fridge temperature is too high, or an area is dirty when it should be clean. Decide what action you need to take to ensure no food is sold that is potentially unsafe and decide what action you need to take to stop the same thing happening again.

Make a documented record of it (for example, in your daily diary) and make sure you follow through on your actions.

Verification and review

Monitoring can take various different forms. You may probe a food to check it has reached temperature, you may check a print-out of the chilled delivery van to make sure it is less than 8°C. You may check your staff members are using the sanitiser correctly. The list is endless. Monitoring is vital to identifying if something is going wrong.

Documentation

As previously alluded too throughout this section, all of this process is your food safety management system. This is whatever you’ve identified and decided must be written down; this is your paperwork.

It shouldn’t be complicated, and depending on what you are doing as a food business it may be remarkably short once refined.

Your monitoring and corrective actions are your daily records. These will be usually be kept in a daily diary. They are important as they allow you to check everything is working correctly and to give an overview to identify any patterns of problems.

If things go wrong and the EHO is investigating you, your daily monitoring records will be vital in demonstrating that you are complying with food safety law. If you are not carrying out any monitoring (or you just sign to say everything is great every day when it is not), then you are going to be in big trouble.

Remember, daily monitoring should take on average no more than five minutes a day! If it takes longer something is wrong!

Training

Food safety training is really covered in every section of food safety, as food handlers need to be trained in all aspects of food safety! Nonetheless, it is included under paperwork as you will want to have a record of who has been trained in what.

No member of staff needs a piece of paper to say they are trained. In fact, it is fairly common for food handlers to have received training and have a certificate but their food safety knowledge is still poor. So the certificate becomes meaningless.

So you do not need a certificate, but staff members must be adequately trained commensurate to their responsibilities. It is acceptable for an untrained member of staff to work under the supervision of someone who is adequately trained, but the supervisor must be able to oversee what they are doing and take action if they do something wrong.

Food handlers must be trained in the food safety management system in use at your food business. As such, they should be familiar with the paperwork and what control measures are used, what the critical control points are and what monitoring needs to take place.

It’s not just food handlers who need adequate training. Managers who are responsible for overseeing food safety or developing the food safety management system paperwork, must have appropriate training as well.

Now, I said you do not need a certificate, but obviously if you are carrying out food safety training it makes sense to keep a record of it. Otherwise, how will you prove it was done, or remember how long ago the training occurred, or keep a check on which staff members have had training and which one’s haven’t? Keep a record of food training as part of your paperwork. If staff members carry out formal training, keep a copy of their certificates too.

Refresher training

There are no legal requirements for refresher training, but again, individuals must always be adequately trained in food safety commensurate to their activities.

What does this mean? Well, in reality it means some form of refresher training will always be required. Menus change, food safety advice changes, chemicals change, kitchens are developed and updated, and people develop bad habits!

You can never stop learning and nothing ever stays still. So, if you think you did a food safety course and that’s it for life, you are dangerously mistaken. Keep staff members knowledge up-to-date to ensure you don’t get yourself into trouble.

Allergen management

Allergen management is now one of the largest, most complicated areas of food safety. People will say it’s simple to manage allergens, but experience with businesses every day shows that it is not.

There are many reasons for this. There is the lack of understanding from manufacturers, food handlers and the customers themselves. This is combined with busy businesses often working at peak capacity and the chaotic nature of most small business kitchens. All together this makes allergens a dangerous area to manage.

Nonetheless, there is no excuse. If you are serving food, you must meet the needs of your customer’s allergies so that the food they are given is safe to eat.

Refusing a customer should only really be done if you do not feel you can provide them with safe food. To refuse every customer with an allergy doesn’t make very good business sense, but at this stage it is up to you as the food business operator. The legality of this is evolving quickly, so make sure you keep up to date with any changes.

Allergen management goes beyond getting a five star food hygiene rating, as it is also covered by Trading Standards due to the importance of labelling and informing customers of what is in your food.

As it is such a serious topic, we will firstly look at what allergen ingredients are, then we will look at what is needed to get a five rating. Finally, we will look at what else you need to do to comply with the law from a Trading Standards point of view – because most small food businesses will be interested in this too!

Common allergens

Any food can cause an allergic reaction, but there are 14 common foods that cause an allergic reaction. Everyone who handles food has to be aware of these 14 food types, so that they can make sure they handle them with relevant caution. They are:

1. Celery: This includes celery stalks, leaves, seeds and the root called celeriac. You can find celery in celery salt, salads, some meat products, soups and stock cubes.
2. Cereals containing gluten: Wheat (such as spelt and Khorasan wheat/Kamut), rye, barley and oats is often found in foods containing flour, such as some types of baking powder, batter, breadcrumbs, bread, cakes, couscous, meat products, pasta, pastry, sauces, soups and fried foods which are dusted with flour.
3. Crustaceans: Crabs, lobster, prawns and scampi are crustaceans. Shrimp paste, often used in Thai and south-east Asian curries or salads, is an ingredient to look out for.
4. Eggs: Eggs are often found in cakes, some meat products, mayonnaise, mousses, pasta, quiche, sauces and pastries or foods brushed or glazed with egg.
5. Fish: You will find this in some fish sauces, pizzas, relishes, salad dressings, stock cubes and Worcestershire sauce.
6. Lupin: Yes, lupin is a flower, but it’s also found in flour! Lupin flour and seeds can be used in some types of bread, pastries and even in pasta.
7. Milk: Milk is a common ingredient in butter, cheese, cream, milk powders and yoghurt. It can also be found in foods brushed or glazed with milk, and in powdered soups and sauces.
8. Molluscs: These include mussels, land snails, squid and whelks, but can also be commonly found in oyster sauce or as an ingredient in fish stews.
9. Mustard: Liquid mustard, mustard powder and mustard seeds fall into this category. This ingredient can also be found in breads, curries, marinades, meat products, salad dressings, sauces and soups.
10. Nuts: Not to be mistaken with peanuts (which are actually a legume and grow underground), this ingredient refers to nuts which grow on trees, like cashew nuts, almonds and hazelnuts. You can find nuts in breads, biscuits, crackers, desserts, nut powders (often used in Asian curries), stir-fried dishes, ice cream, marzipan (almond paste), nut oils and sauces.
11. Peanuts: Peanuts are actually a legume and grow underground, which is why it’s sometimes called a groundnut. Peanuts are often used as an ingredient in biscuits, cakes, curries, desserts, sauces (such as satay sauce), as well as in groundnut oil and peanut flour.
12. Sesame seeds: These seeds can often be found in bread (sprinkled on hamburger buns for example), breadsticks, houmous, sesame oil and tahini. They are sometimes toasted and used in salads.
13. Soya: Often found in bean curd, edamame beans, miso paste, textured soya protein, soya flour or tofu, soya is a staple ingredient in oriental food. It can also be found in desserts, ice cream, meat products, sauces and vegetarian products.
14. Sulphur dioxide (sometimes known as sulphites): This is an ingredient often used in dried fruit such as raisins, dried apricots and prunes. You might also find it in meat products, soft drinks, vegetables as well as in wine and beer. If you have asthma, you have a higher risk of developing a reaction to sulphur dioxide.

Allergens and a 5 star rating

When a customer informs you or a member of staff that they have an allergen, this must be made a priority. All staff members must be made aware of the importance of this. You should have a person on site at all times who is responsible for taking ownership of allergen customers.

It will usually be the business owner or a chef. Unless you are working alone, you will need more than one person trained in this role to account for holidays, sickness and/or days off. Everyone else must know who these people are and to take any allergen request to them immediately.

The allergen expert will be able to assist the customer by knowing what all the ingredients are in each food, or whether any of the ingredients have warnings such as ‘may contain…’ If foods have already been prepared in the kitchen, is there a risk it was prepared near any other ingredients?

The only way the allergen expert will know this is by having access to all of the ingredient’s packaging and a complete awareness of what the chef is putting in the food. It is OK to provide the original packaging to the customer so that they can decide, but be aware if any changes to that product may have occurred.

If products are decanted, you must keep a record of all the ingredients used in it, so it can be referred to at a later date if needed.

Be very aware of ‘product substitution’. Different brands have different ingredients. So, for example, if you run out of your usual Pesto sauce and decide to top it up with a jar from the local supermarket, make sure you are aware of the what the ingredients are in the new jar – they will likely be different and may introduce a new allergen ingredient!

The best way to manage this is to prepare all allergen requested foods from scratch. These can then be prepared in a pre-cleaned section of the kitchen, with each ingredient checked for the relevant allergen(s) on the label. This may slow the kitchen down a bit, but it is worth it to make sure things do not go wrong.

Complying with Trading Standards

You must display some form of signage to let customers know how they can find out which allergens are present in your food. You may do this with a sign directing customers to ask a member of staff, you may place the information on your packaging, display it on the menu, or list the allergy ingredients on a display board.

An example of suitable wording would be: “Food Allergies and intolerances: Please ask a member of staff if you require information on the ingredients in the food we serve.”

As a food business, you cannot say that you do not know whether a food contains an allergen ingredient, nor can you say that all your food contains allergens; you are legally required to provide specific allergen information about any of the foods you are selling.

If you buy open food from a supplier, for example, bread, pies, cakes, etc., you must request the allergen information from the supplier for these foods. They are legally required to provide this information to you. If they refuse or are unable to do so, report them to Trading Standards so that this can be investigated.

What you must do

Once you have decided how you will manage the service of food to customers with allergens, you should write this process down. It forms an important part of your food safety management system and is a documented safe method of how you will operate your food business. Staff, the EHO, and Trading Standards can read it and understand clearly how you manage allergens safely.

Your documented safe method for allergen control will include answers to the following questions:

1. Who deals with allergen queries? What training have they had? Who covers for them if they are not working?
2. What training do all of your staff have? Allergen awareness is vital for all members of staff and all must know your procedure in responding to customers with allergies. It only takes one disinterested waiter to break your entire system with tragic consequences; make sure all staff are trained and understand your procedure. Keep a record of who had the training and when. Implement a scheme of refreshing training on a periodic basis.
3. How do you manage allergen information from your suppliers? Ensure all products are supplied with a list of ingredients in English, with allergen information included. Pay particular attention to any products supplied from third countries and any loose products you are supplied with.
4. Do you accept or use substitute ingredients? Will your suppliers substitute products that are unavailable, or do you supplement supplies with trips to the local supermarket when you are running out of something? Different manufacturers use different ingredients and therefore may have different allergen ingredients present. How will you manage this risk?
5. Where is the information stored on allergen content in your food products? Do you use an allergen checklist/matrix or are labels consulted for all ingredients in a product? Remember, manufacturers are always “improving” their recipes and changing ingredients. You cannot be confident that the ingredients in last week’s tomato ketchup are the same this week, so you need to consult the label of the product being used at that point in time to be confident.
6. How do you store ingredients safely so that you prevent cross contamination of ingredients with other ingredients containing allergens? How do you manage spillages? If you decant foods from their original containers, how do you keep the allergen information with the product?
7. How is the kitchen alerted that a food they are about to prepare is for someone who is allergic to an ingredient? How does your allergen champion work with other members of staff to ensure there is not a breakdown in communication? Ensure you consider how the procedure will be maintained in busy periods when it is most at risk of going wrong. Being busy is not an excuse in any way, shape or form.
8. How are foods prepared safely so that the risk of cross contamination is controlled? Some allergenic ingredients are easily spread around the kitchen, such as nut powders and flour. It is best to use a separate preparation area where no other food is handled. It must be clean, with clean pots, pans, chopping boards, utensils, surface, etc. Consider any complex equipment that you may be using that cannot be adequately cleaned of allergen ingredients between uses, for example vacuum packers. If you cannot be confident the equipment is free of allergen ingredients, do not use it to prepare the customer’s food.
9. How do you communicate to your customers how they can find out about allergens? Do you display a sign or an allergen menu? Do your waiting staff members ask each table if they have any allergen requirements at the time of booking and when they sit down? A belts and braces approach is strongly recommended.
10. How will you respond to customer complaints over allergen concerns? These should be dealt with by a senior member of staff. It is important staff members are aware it is not acceptable to just remove the offending item from a dish and return it on the same plate; remember the risk of cross contamination! Even a trace of an allergen ingredient can be fatal. A record should be kept of the complaint, whether it was justified, what went wrong and how it has been corrected so that it will not happen again.

Finally, drawing on our knowledge from other sections of this food safety guide, ensure: everyone is implementing appropriate hand washing, two stage cleaning is in use, clean protective clothing is being worn, and cloths are not creating a cross contamination risk.