Chris Purslow and Associates was formed in 1985 to offer a range of back up services to the Food Manufacturing and Hotel and Catering Industries. These include

· Auditing and Monitoring in all aspects of Food Safety and Health and Safety.

· Development of Documentation and Systems customised for the individual client to ensure compliance with legislation.

· Liaison as necessary with enforcement authorities.

· Training in both Food Safety and Health and Safety: Registered centre for the Chartered Institute of Environmental Health.

· Supplier Auditing.

· Monitoring contractors and advising on contracts.

Chris Purslow is a fellow of the Chartered Institute of Environmental Health, a member of the International Institute of Risk and Safety Management and a founder member of the Expert Witness Institute. He has had extensive experience throughout the industry, lectures widely and has made a number of appearances in the media.

Chris Purslow and Associates is retained by leading Hotels and Restaurants in the country, and have helped a number of major companies set up their in house facilities.

This is designed to be the first of a regular series of updates to be featured on this Website. It is intended to keep subscribers up to date with trends and legislation as well as providing a readable and idiosyncratic view of the industry, legislation and enforcement. There will be a regular bulletin posted, and if any subscriber needs specific information hopefully this can be included. The first bulletin is as follows.

The Food Standards Agency is now beginning to formulate its policy and to flex its muscles. Sir John Krebs has stated several times that he sees the inspection and enforcement programme as central to maintaining standards. This realistic approach is likely to be mirrored in the inspection programmes that are formulated by local authorities. These are becoming increasingly accountable for the application of a risk based inspection programme.

You can expect a schedule of visits, based upon the size of your operation and the type of food prepared. These inspections are now much more likely to concentrate on the systems for control and the commitment of management.

The recent programme of licensing butchers shops together with the requirement for HACCP and the nationwide training programme, is held to have been successful in raising standards in the wake of the disastrous out break of E Coli (O157) at Wishaw in Scotland. There will undoubtedly be pressure brought for the rest of the food industry to come into line, and compulsory licensing is once again a live topic. Whatever happens however, there is no doubt that enforcement action will continue to be seen as central to the food safety effort, and any organisation that does not realise the need for a sound risk based control system is heading for trouble.

We all acknowledge the structural standards to be met in a food preparation premises and it is fair to say that standards have risen considerably over the years that I have been involved in the industry. Many companies however still fall short in being able to demonstrate their due diligence through accurate and concise documentation. The following are some of the written systems that an EHO may request.

· A list of suppliers together with criteria for selection.

· Records of inspection and temperature checking on incoming goods.

· Temperature checks on all refrigerated storage.

· Temperature probing of cooked items.

· Temperature probing for buffet work.

· Pest control documentation.

· Cleaning schedules.

· Internal inspection routines.

· Training Records.

The above list is not exhaustive but the presence of these records together with a simple statement of a procedure to be met in each case goes a long way to establishing a generic HACCP.

Depending on the size and complexity of your organisation you may also need to consider the production of product specific flow charts and a break down of the risks and controls at critical stages of production. These provisions are of course required by the Food Safety (General Food Hygiene) Regulations.

1. Some companies rely on a centrally produced manual. This can be affective but only if it is adapted to reflect local site conditions and there is evidence that it is actually used.

2. If you set a standard in your documentation it is crucial that you stick by it. I have had first hand experience of prosecutions brought because companies were not following their own systems on the basis that HACCP was not working.

3. Ensure that when your records show a deviation from the standard you can prove action. I have lost count of the number of times that temperature records show a fridge operating way too high sometimes for days at a time without apparent action.

4. Make sure that records are being kept properly and are not just tick lists.

Remember that an EHO is looking for commitment, and one of the judgments they are making is on the reliability of management. You can best demonstrate your own standards of professionalism by your documentation.

A brief note on some worrying cases that have hit the headlines in the past twelve months. There have been two major criminal cases taken because of the use of condemned poultry meat for human consumption. In the one case poultry carcases to be processed for animal feed were being trimmed and portioned, washed in disinfectant, and then used to fill catering contracts. This was no small operation. In the one instance twelve hundred tons of poultry meat was involved which by my calculation means nearly a million portions.

There have also been a continuing number of smaller cases discovered and prosecuted by vigilant EHOs. We should all ask if we can guarantee the quality of our suppliers and press our suppliers to provide traceability in the supply chain.

Next bulletin I will concentrate on Health and Safety matters in the meantime if we can help please contact the Website.