Food Safety Management Systems

Part 1 '' Food Safety and the Law.

Food safety management procedures

Guests choose a restaurant because they trust and believe that the establishment shall always fulfill their demands and expectations both the expressed and unexpressed expectations. They trust that the food cooked in the restaurant is safe to eat and will not make them sick after eating. Providing customers with safe food is not only important for the success of a business but also mandatory by law.

A Food safety Management Program which is intended to prevent food poisoning by following safe food preparation practices; this involves taking measures necessary to ensure the safety and wholesomeness of food during purchasing, receiving, storing, cooking, transporting, reheating and service. A Food safety Management Program is a program developed to control food safety problems and ensure that the food served is safe to eat. It is based upon the principles of HACCP. It involves looking at the food preparation and service operation step by step from the selection of ingredients right through to the service of the food to the customer. By carefully analyzing each step of the food preparation and service operation anything that may affect the safety of the food is identified and controlled. Food safety Management Program helps in ensuring that food is safe at all times and the risk of food poisoning is minimized / prevented

Why is Food safety Management Program important?
The following are the costs resulting from food poisoning:
• Closure of food premises by local authority.
• Loss of business due to negative publicity or from guests due to poor standards, food poisoning outbreaks and even deaths. The reputation of the establishment is tarnished.
• Fines and costs of legal action taken because of not following hygiene legislations or because of sale of food that is unsafe for consumption. Court cases and law suits taken by food poisoning sufferers or those aggrieved by injury from foreign bodies in food.
• Low employee morale and high staff turnover, as the working conditions are of poor standards.
• Guest’s complaints in regards to food will increase.
• Loss of food, food shall have to be thrown out as it has become unsafe for consumption, thereby increasing costs and reducing profitability.
• Employees will loose their jobs because of closure of the business or because they have become long term carriers of food poisoning organisms especially salmonella.

The benefits of Food safety Management Program are as follows:
• Delighted guests.
• Enhanced reputation as an establishment where food is produced in a hygienic environment and is safe for consumption.
• Increase in business.
• Compliance with food safety regulations.
• Less food wastage and increased shelf life, thereby reduction in food costs and increase in profitability.
• Higher employee morale as they know that they are working in a clean, safe and hygienic environment.

Food safety is very important as stated above. It is a crime punishable by Law to serve food that is unfit for consumption.

Food Safety and the Law:
The constant increase in government regulations has made food safety a critical issue for every organization, and a vital responsibility of management. Widespread media attention has also increased public awareness of food crises and scares, public concern over the effects of major food safety, product recall and food poisoning.
Assuring food safety throughout the chain minimizes the risk of contaminated food entering a establishment. The requirements of food safety legislation are increasingly directed at the implementation of the principles of Hazard Analysis and Critical Control Points (HACCP) within food manufacturing establishments. To comply with food safety requirements it is important to incorporate a system that identifies the food safety hazards and the important controls associated with menu items, the training of food handlers, and the regular audits carried out that will assess current performance as well as identify training needs and corrective actions to be taken.

In the UK, The Food Safety Act (1990) (FSA) Act incorporates most of the previous Food Safety Regulations. It is ‘enabling’ legislation, allowing for the making of new regulations, modifications of existing regulations and the adoption of European Law. It has enabled subsequent regulations to be introduced, e.g.
Food Premises (Registrations) Regulations 1991, Food Safety (General Food Hygiene)
Regulations 1995, Food Safety (Temperature Control) Regulations 1995 and Food Labeling
Regulations1996.

0102. The FSA (1990) is the overarching food safety legislation in England, Wales and
Scotland. It introduced a number of features for the enforcement of food hygiene and
Enabled subsequent regulations to be introduced.
0103. There are a number of offences under the Act:
a. Selling food that is not of the nature, substance or quality demanded by the purchaser.
b. Falsely describing, advertising or presenting food.
c. Rendering food injurious to health.
d. Selling food that does not comply with food safety requirements. This is food that has been rendered injurious to health (e.g. through contamination with food poisoning organisms) or which is unfit for human consumption.
0104. The definition of selling food includes food that is offered, displayed, advertised by and / or in possession of and is in the food business.

FOOD SAFETY (GENERAL FOOD HYGIENE) REGULATIONS 1995
0105. The Food Safety (General Food Hygiene) Regulations 1995 apply to any premises
Where in the preparation, processing, storage or handling of food is undertaken. They detail
key requirements in the following areas:
a. Structure. Premises where food is prepared must comply with a series of structural, maintenance and cleanliness requirements. These are designed to protect food from physical contamination, permit good food hygiene practices and prevent external sources of contamination such as pests.
b. Hygiene. There is a general requirement that any operation involving the preparation, processing, storage or handling of food is carried out in a hygienic way.
c. Hazard Analysis. A manager of a food business shall identify any step in the activities of the food business that is critical to ensuring food safety, and ensure that adequate safety procedures are identified, implemented, maintained and reviewed. This procedure is designed to ensure compliance with Regulation 4(3) of the Food Safety (General Food Hygiene) Regulations 1995.
d. Infected Food Handlers. Food handlers must inform their line manager if they or any member of their household are suffering from, or suspect that they may be suffering from, any infection that may be transmitted through food, e.g. gastrointestinal infection. Infected lesions of skin, eyes, ears and mouth that may directly or indirectly contaminate food with pathogenic micro-organisms are also to be reported. Appropriate exclusion procedures are to be taken pending medical advice.
e. Training. All food handlers must be supervised, instructed and/or trained in food hygiene matters commensurate with their work activity.

FOOD SAFETY (TEMPERATURE CONTROL) REGULATIONS 1995
0106. These regulations contain national provisions relating to the temperature control of food. They detail limits for holding hot and cold food at temperatures designed to reduce the risk of bacteriological activity which may give rise to food poisoning.

FOOD PREMISES (REGISTRATION) REGULATIONS 1991
0107. Food premises must be registered under the Act if they store or serve food. In addition to publicly funded messes, non-public bars and welfare outlets will also be included in the registration process. The
Commanding Officer (CO) is also to appoint an officer to oversee non-public catering facilities. Vehicles used to transport food around unit sites also have to be registered.
0108. The FSA applies to any catering establishment, which, by definition, is ‘an establishment where food is prepared on the premises for delivery to the ultimate consumer and is ready for consumption without further preparation’. Penalties under the Act vary according to the precise nature of the offence. The maximum on summary conviction is a fine of up to £20,000 or 6 months imprisonment, or both. Precautions taken to ensure the prevention of food poisoning i.e. Due Diligence apply in all circumstances.

FOOD LABELLING REGULATIONS 1996
0109. These regulations detail measures required to protect purchasers and consumers from false or misleading information when purchasing food. The two most important provisions from the food hygiene viewpoint are those relating to indication of durability, and storage conditions or conditions of use:
a. Indication of Durability. Most pre-packed foods must be date marked.
There are two types of date mark:
(1) “Use By” Date. Foods that are microbiologically perishable and may pose a risk to health must bear a “Use By” date. This is the more stringent of the two indicators of durability. It is to be noted that it is an offence to sell, or have in possession for sale, food bearing an expired “use by” date and for anyone other than the person originally responsible for applying the date mark to change it.
(2) “Best Before” Date. The majority of foods have a “best before” date, which indicates the period for which it might be expected to retain its specific properties if stored correctly. A “Best Before” date relates to the quality of food rather than safety.
b. Storage Conditions or Conditions of Use. Where particular storage conditions are required to maintain specific properties of food, e.g. “keep refrigerated” or “keep frozen”. These instructions must be stated on the label.

DUE DILIGENCE
0110. A key concept of the FSA is that of ‘Due Diligence’. This is essentially a defense in the event of prosecution and requires evidence that the person charged took all reasonable precautions and exercised all due diligence to avoid committing the offence. In effect, it enables an enforcement authority to “by-pass” an immediate offender and prosecutes the real offender. The defendant has to prove that due diligence has been exercised and this is where the importance of keeping records is crucial.
0111. In practice, the due diligence defense will consist of two stages:
a. ‘To take all reasonable precautions’ means that a system is in place to prevent an offence from occurring. Areas of consideration will include:
(1) Food Safety Policy in accordance with Food Policy Statement.
(2) Hazard Analysis systems.
(3) Staff training programmes.
(4) Available resources, e.g. technical, staffing, financial.
(b) Secondly, exercising due diligence, which concerns day-to-day operation of the system. A court of law would usually require documented evidence that procedures were carried out at a relevant time and by an appropriate person. The usual requirements include details of the following:
(1) Cleaning schedules.
(2) Temperature monitoring e.g. dedicated transportation vehicles, temperature at time of receipt, cooking and service, and monitoring of freezers and refrigerators.
(3) Documentation of any corrective action taken.
(4) Documentation of supervisory checks.
(5) Records kept up to date at all times and available for inspection by local authority enforcement officers.

About food law enforcement in the UK.
The enforcement of regulations on food standards is primarily the responsibility of local authorities.
Who is responsible for enforcement?
Responsibility for enforcement is shared between central and local government bodies. While the making of legislation in the UK is the function of central government, the enforcement of food law is primarily (but not solely) the responsibility of the 499 local authorities in the UK, and more specifically Environmental Health Officers (EHOs) and Trading Standards Officers (TSOs).

The Food Standards Agency (FSA) is an independent Government Department and is an enforcement authority in its own right. It is also responsible for enforcement support, advice and audit of enforcement activity with respect to local authority food safety and standards controls.

Central government role
Where food law enforcement does not rest with local authorities, it is carried out by central Government or its enforcement agencies.
The FSA, acting through its executive agency the Meat Hygiene Service (MHS) in England, Scotland and Wales, and through the Department of Agriculture and Rural Development (DARD) Veterinary Service in Northern Ireland, is the enforcement authority in respect of around 1,700 licensed premises in the UK producing meat for sale for human consumption. Such premises include slaughterhouses, cutting plants and cold stores. Inspection of the meat industry is essential to protect public health and promote consumer confidence. More information about the MHS can be found at the link below. Formal enforcement, including prosecutions and investigations, is the responsibility of the Agency itself.
The Agency aims to ensure that EU wine regulations are enforced in the UK. Our enforcement responsibilities apply to all premises and traders within the production and marketing chain, including wholesalers, warehouses and vineyards. More information about wine standards can be found at the link below.
The Department for Environment, Food and Rural Affairs (Defra) has two executive agencies - the Pesticides Safety Directorate (PSD) and the Veterinary Medicines Directorate (VMD) - which carry out European Union (EU) surveillance programs for residues, and also act as the enforcement agencies for these areas.
Inspectors within Defra enforce areas such as marketing and horticulture, at all but the retail level. There are also separate arrangements for dairy hygiene enforcement, which is the responsibility of Animal Health (an executive agency of Defra).
The Egg Marketing Inspectorate (EMI) is an Inspectorate within Defra responsible for checking standards in egg production, packaging and distribution centers. EMI works throughout England and Wales, wherever eggs are produced, graded, packaged, imported, exported, bought or sold. Scotland and Northern Ireland have their own Inspectors.

❖ Dubai Municipality Grading System to rate food preparation & Fines imposed to food preparation premises not complying with the law

Dubai Municipal Food Control Inspectors grade food preparation establishment by using the following criteria.
They use the points systems 90 points and above ensure that the establishment secures “A” grade this means that the food premises shall be inspected once every 3 months.
A score of 90 and below up to 70 means an inspection every month. This establishment shall receive a “B” Grade.
A score of below 70 up to 60 means an inspection every week, this establishment shall receive a “C” Grade

Dubai Municipal Food Control Inspectors are authorized to fine establishments not complying with the legislations, Please find below the checklist that is used by the inspectors for fining establishments not complying. Attached at the end of this document are The violation sheet of Dubai Municipality, They use the grading system based on points to grade food establishments A, B and C .Catering establishments here in Dubai are governed by the Food Hygiene Regulations of 1992 i.e. Administrative order no 20 of 1992 issued on the 3rd of February 1992.

Dubai Municipalities directive for implementation of HACCP:
All Hotels in Dubai have been given a deadline to implement HACCP in their operations by the end of the year and need to be certified by a third party auditor who has been approved by the municipality. New Hotels are allowed a maximum of 6 months to get their hotels HACCP Certified.

Dubai municipality’s legislations give details on every aspect that of the food chain and what is expected from the Hotel. Non conformance to the Dubai Municipality’s directive results in warning and fines.

Please find attatched the Annexes i.e. grading system and memo’s from Dubai Municipality which provides more insight.

Annexes:
DM Memo on Health Cards.
DM Memo on transport of food stuffs in Dubai.
DM Memo on visitors in food establishments.
DM Excel spreadsheet on Inspection checklist for grading.
DM Violation and Fines sheet.
Local Order No (11) of 2003.

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PART 2 '' Role of Management:

Management needs to formulate a Food Safety Policy detailing the scope, use and purpose of food safety in the establishment. The food safety management system should be based on HACCP and should also take into consideration local legislations. Thus the food safety program, the implementation of which will provide each of the catering operations are adhering to good working practices, guidelines and policies assuring that the food they serve is safe and of good quality. In doing so, each unit will have a reduced exposure to business risks arising from food contamination scares, adverse publicity or brand damage.

How to develop a Food Safety Management System:
The following are the Steps to be taken developing the system. It lists the steps typical in most catering operations, likely hazards to be considered, outlines the controls which apply generally to most catering operations and advises on when and how these should be applied. It also gives advice on the identification of other critical control points, and on practical monitoring procedures, and on the causes of food poisoning. Food Safety Program is suitable for same day service, complex food cook process and No Cook Food step operations.

Food safety policy
Management should define and document a food safety policy, which is supported by measurable objectives and appropriate to the role of the organization in the food chain.
The objectives include the following, and will be assessed on a continual basis:
1. Maximum of 5 food items rejected at receiving per month for food safety related issues.
2. Maximum of 20 food-safety related customer complaints per year
3. Safe working environment, and adequate of suitable materials and equipment.
4. Maximum of 5 equipment or machinery breakdowns in food areas per month.
5. All food handlers will be competent by three months of their employment
6. Minimum of 90% to be scored in both internal and third party food safety audits
7. No major non-conformances identified in HACCP audits.
8. 100% compliance to relevant legal requirements.
The policy takes into consideration the organization’s conformance with both statutory and regulatory requirements, as well as any mutually agreed food safety requirements of customers.
The food safety policy shall be communicated to all staff during the employee orientation training, and by being posted in front of the staff cafeteria, changing rooms and staff notice boards. The management will also ensure that the policy is implemented, maintained and reviewed for continued suitability.

The following steps need to be followed in planning, desining anf implemetation of a food safety management system:

Step 1: Planning
Top Management should first select and hire a Food Hygiene Officer to implement and manage the food safety system. The food hygiene officer could be assisted with an external Food Safety HACCP Consultant to ensure the HACCP implementation and certification of the establishment.
Top Management along with the Food Hygiene Officer and HACCP Consultant must formulate a Food Safety Management policy and formulate a team to implement, overlook and monitor HACCP. Staff will need to be made aware of any changes that may result from its introduction can be kept up to date.
Depending on the size of the business assemble staff into a small team, with a team leader to lead in designing and implementing HACCP. The team should have a good knowledge of the business. Initially, the team will be required to spend a reasonable amount of time and effort to develop and implement the HACCP system. Describe the product(s) and the intended use by consumers and then depending on the size of the business draw up a flow diagram to show each step of the operation. Walk through the operation to confirm that the diagram is correct and check that it covers all the foods your business produces.

The management should have defined objectives to support the food safety policy and which would also provide a measure of the suitability and effectiveness of the management system in place. The following have been taken into consideration while setting the objectives:
1. Food safety policy
2. Customer requirements and expectations
3. Product and process requirements
4. Available resources
5. Statutory and regulatory requirement.

The planning of the Food Safety Management Systems has been carried out over several stages, namely:
• Designing of the Food Safety Management Systems procedures and policies.
• Development of operational prerequisites specific to the operations.
• Development of the HACCP system that takes into consideration the various products and processes as per Codex Alimentarius.
• Development of the Food Safety Management Systems Manual that to ensure consistency in quality and achievement of food safety standard, and to ensure continual improvement of the processes.
Whenever changes to the products or processes are made, the plans shall be reviewed by the top management so as to ensure that the integrity of the food safety management system is maintained.

Step 2: Food Safety Program Team

Depending on the size of the operation, the planning, development and implementation of the system should be undertaken by a team. The members of the team should be able to identify hazards, control measures and critical control points confidently, so an understanding of food hygiene is required, as well as a complete view of each step of the catering operation under consideration.

Responsibility and authority
The top management has defined and communicated the responsibilities and authorities of relevant personnel involved in managing of the food safety management system so as to ensure the effective operation and maintenance of the system.
The overall responsibility of ensuring safe food lies with the General Manager. However, detailed and specific responsibilities and authorities of personnel that have been assigned the responsibility and/or authority to report problems, or initiate and record actions are defined in the job descriptions, as well as in the Prerequisite, HACCP and Food Safety Management Systems manuals. The responsibilities and authorities of relevant personnel involved in managing of the food safety management system will be communicated upon employment, and reinforced during successive training sessions.

Food safety team leader & Food Safety Team Members:
The Food Hygiene Officer has been appointed by the top management as the food safety team leader who, irrespective of other responsibilities, shall have the responsibility and authority to:
1. manage a food safety team and organize its work,
2. ensure relevant training and education of the food safety team members,
3. ensure that the food safety management system is established, implemented, maintained and updated
4. report to the organization’s top management on the effectiveness and suitability of the food safety management system, and liaison with external parties on matters relating to the food safety management system

In the absence of The Food Hygiene Officer, The Executive Chef will be acting as the Food Safety team leader. The following would be members of the Food Hygiene Management Team:
General Manager, Food Hygiene Officer, Food and Beverage Manager, Executive Chef, Director of Engineering, Executive House Keeper, Purchasing Manager, Food and Beverage Cost Controller, Store Supervisor, Training Manager & Human Resources Manager.

Roles and Responsibilities should be given to the members to ensure that implementation of the Food Safety Management Systems has been successfully integrated in the Hotels culture.

Designation: - Executive Chef
• To ensure that food being cooked is cooked safely according to the food safety regulations.
• Update status on policies relating to the Food Preparation (Implementation, training & follow up).

Designation: Purchasing Manager
• Report and share with team members on visitation to supplier’s premises.
• Report on Supplier quality Assurance program, Names of approved suppliers etc.

Designation: Facilities Manager
• Update on status on policies related to Engineering Division (Implementation, training & follow up).
• Update team with planned Preventive Maintenance for coming weeks.
• Provide feedback on water testing, tank cleaning and equipment calibration.
Designation: - Food & Beverage Manager.
• Update on status on policies related to F&B Division (Implementation, training & follow up).
• Update on Large Function challenges in regards to food safety, Food Borne Illness if any, Expiry Items, Guest complaints in regards to food illness, Bar Hygiene and Dishwashing cleanliness.
• Share with team on overall staffs grooming standard.

Designation (s): - Cost Controller & Stores Supervisor
• Update on status on policies related to Receiving & Stores Department.
• Update team with data collection report spot check conducted on suppliers’ truck, Supplier concerns, Summary of Items rejected etc at receiving area.

Designation: - Executive Housekeeper.
• Update team on cleaning & sanitation of Loading Dock, Restaurant Cleanliness, Food and Beverage Public Area Cleanliness status directly related to Food Hygiene and Food Safety.
• Update team on Pest situation, Bait maps, and treatment date by Pest operator.

Designation: - HUMAN RESOURCES Manager
• Report and share with team on issues of Medical Facilities & First Aid.
• Report and share with team status of Dubai Municipality Health Cards for Food Handlers.
• Report and share results of Medical Health Spot Check and Food Handlers Hand Swab Test Results carried out by the Hotel Nurse
• Report and Share with team on issues of Medical Examination being conducted for staff who have returned from Vacation.
• Share with team on the consistency of training and hours clocked by individual department in relation to food hygiene.

STEP 3: HAZARD ANALYSIS AND RISK ASSESSMENT.
In most cases this will mean that the first step will be to look at the purchase of ingredients or other foods used in the business and carry out the following tasks:
• Identify hazards.
• Identify control measures
• Determine critical control points (CCP’s)
• Implement the system for the purchase part of the operation before moving onto the next step.

Step 3a: List ALL HAZARDS

List the hazards associated with food at the first step of the operation. This may require help from professional food safety consultants.
Hazard means a biological, chemical or physical property that may cause an unacceptable public health risk. The potential to cause harms. Hazards may be biological, chemical or physical e.g. Salmonella specifies in a chicken burger (Biological Hazard), detergent in milk (chemical hazard) or glass in breakfast cereals (Physical Hazard). A number of things may constitute a food hazard, for instance the contamination of food with food poisoning bacteria or other micro-organisms or their toxins (poisons which they produce) foreign bodies chemical contaminants

Step 3B: IDENTIFY CONTROL MEASURES.

List the measures which can be used to eliminate or reduce to safe levels the identified hazards. Control measures may be very simple, e.g. when looking at purchasing: The hazard may be the multiplication of food poisoning bacteria in foods because the temperature is too high.
The control measure may be having purchasing specifications which asks for temperature controlled deliveries (which can then be checked or monitored). Some hazards do not need to be eliminated when they occur as they may be controlled later, e.g. in the preparation or cooking of the food. In this case they can be dealt with at the step. However, this does not mean that good hygiene standards should not be maintained throughout all steps in the catering operation. Make sure that control measures are actually feasible in the business / kitchen where they are to be operated, or they may not be used.

Step 3c: Critical Control Points

Critical Control Points (CCP’s) should be identified. The critical control point is the step in the preparation of the food which has to be carried out correctly to ensure that a hazard is eliminated or reduced to a safe level.
The following actions need to be taken at these Critical Control Points. They are likely to be other critical control points in a given operation which will need to be considered.

|Step |Hazard |Action |
|Purchase |High risk foods contaminated with |Buy from reputable supplier only. Specify temperatures required at delivery. |
| |food poisoning bacteria or toxins. |Supplier quality assurance program, Supplier Audits. |
| | | |
| |High risk foods contaminated with | |
|Receipt |food poisoning bacteria or toxins. |Visual / sensory checks. Temperature checks. Transportation vehicle checks, delivery|
| | |personnel personal hygiene checks, separate weighing scales for frozen & chilled meat|
| | |products, non chilled / low risk items and separate for ready to eat products. |
| |Growth of food poisoning bacteria, | |
| |toxins on high risk foods. Further |High risk foods stored at safe temperatures. Store wrapped. Rotate stock & use |
|Storage |contamination. |before expiry. Chilled products storage below 5 deg C, Frozen items stored at -18Deg |
| | |C and dry foods stored at below 22 Deg C and less than 60% Humidity. |
| |Contamination of high risk foods. | |
| |Growth of pathogenic bacteria. |Limited exposure to ambient temps. During preparation. Prepare with clean equipment,|
| | |used for high risk foods only. Separate cooked and raw foods. Wash hands before |
|Preparation | |handling foods. |
| | | |
|Cooking |Survival of pathogenic bacteria. |Cook rolled joints, chicken and reformed meats e.g. burgers to at least 75°C in the |
| | |thickest part. Sear the outside of other meats (e.g. joints of beef, steaks) before |
| | |cooking). |
| |Growth of any surviving spores or | |
|Cooling |pathogens. Toxin production |Cool foods quickly as possible. Do not leave out at room temps cool unless cooling |
| |Contamination with pathogenic |period is short (e.g. place stews, rice etc in shallow tray and cool to chill |
| |bacteria. |temperatures quickly).Blast chill products to below 4 Deg C from 90 Deg C within 90 |
| | |Minutes. |
| |Growth of pathogenic bacteria. Toxin| |
|Hot holding |production. |Hot hold food in hot cabinets above 65°C. |
| | | |
| |Survival of pathogenic bacteria. | |
|Reheating | |Reheat to 82°C. |
| |Growth of pathogenic bacteria. | |
| | | |
|Chilled storage | |Temp. Control; Stock rotation. Keep items below 5 Deg C. |
|Service |Growth of pathogens. Toxin |Cold service '' serve high risk foods as soon as possible after removing from chiller.|
| |production. Contamination. |Hot foods '' serve high risk foods quickly. |

How to determine Critical Control Points

The following questions can be used to help to determine critical control points at each step:
(1) Question: Is it necessary to control the hazard at this step, or will a subsequent step reduces or eliminate the hazard?
For example: At the purchase or preparation step
Raw ingredients may contain food poisoning bacteria but the cooking step will, if carried out correctly, reduce these to safe levels.
* Therefore in this case the purchase and preparation step is not a Critical Control Point.
* If a subsequent step (e.g. cooking) will control the hazard, then that step is the Critical Control Point.

(2) Question: Can the hazard be eliminated or reduced to acceptable levels at all, at this step or any step?
If the answer is ‘no’, consideration should be given to whether the food is served at all. Different ingredients or changes to be preparation / cooking method may need to be considered so that the food is safe when served to the consumer.

Targets and critical limits
For each CCP, a target should be set which gives the required control. Variations from that level which are considered acceptable before corrective action is taken are the critical limits.
For example, in the instruction:
Reheat precooked dishes to 75°C or hotter (if the food has reached 73°C the food may be served, allowing a 2°C tolerance.)
* The target value is 75°C
* The critical limit for reheating is 82°C or above.

Step 3d: Decide how to monitor and, if necessary, record that the controls have been applied.

Critical Control Points must be monitored. The frequency of monitoring will depend upon the nature of the control, practicality, and the level of confidence the monitoring procedure gives.
Monitoring
The methods used should be kept as simple as possible, for example:
• On delivery, visual check of packaging, expiry dates
• The measurement of the temperature
• checking that all equipment is cleaned before use

Recording
Wherever possible, records should be kept as these will help the manager check that food safety measures are adequate and working.
Records will also provide useful information if there is a query from the Municipality officials. The type of equipment available to monitor some critical control points may automatically give records, e.g. automatic logging devices connected to all chiller and freezer units, giving a printed read-out.
Where manual checks are taken at a critical control point and the manager decides that it is necessary to keep records, consideration will need to be given to the type of recording sheets needed. These should be kept as simple as possible, and training must be given to staff to ensure that records are completed correctly.

Step 3e: Implementation and How to manage the change to Food Safety Program?
1. Prepare, print and if necessary copy any record sheets.
2. Consider developing working instructions for the controls, and monitoring procedures for staff to refer to, particularly where a critical control point is identified. These should be simple and clear.
3. Procedures and work instructions should include:
• What is to be done?
• How it is to be done
• When it is to be done
• Where it is to be done
• Who is to do it
4. Tell staff why checks or measurements need to be taken.
5. Train staff as necessary in the basic principles of the Hotel Food Safety Management System approach.
6. Ensure staff understands their responsibilities so that the system can be implemented successfully.
7. Ensure that instructions, procedures and training cover what to do if a critical control point is not achieved. For example: place food back into the oven and inform the manager immediately, throw the food away.
Important note '' control measures may involve taking temperatures using a probe thermometer. Training should be given so that this is done properly including giving instructions on cleaning the probe between uses. Probes should be accurate and checked frequently.

Step 3f: Checking the system
Once the Hotel Food Hygiene Management System for the first step is in operation, it may be necessary to check it to ensure:
1. That it is running as originally planned and / or that the monitoring of CCP’s is satisfactory
2. The revised system should follow the one that was originally devised with changes being made only after careful consideration.

Step 4: Repeat step 3 for each catering step
The manager or the Food Safety Program team can now attend to the next step on the flow chart (e.g. receipt of food). For this next step on the flow chart, the same processes (3a to 3f) as before are carried out:
• listing hazards
• Identifying control measures
• deciding upon critical control points
• deciding upon adequate and suitable monitoring and recording procedures, as necessary
• implementing and checking
This process is then repeated until the Food Safety Program is running for all steps of the catering operation.

Step 5: Full system check
The full system will need to be checked to ensure that it is working as was originally intended.
This will mean ensuring Critical Control Points identified during the development of the system are:
• Being applied correctly
• Being adequately monitored
• Accompanied with adequate work instructions
• In addition, check to ensure that:
• The system is understood
• That all parts of the system are working compatibly
• This can be carried out by the team leader or manager by means of an internal audit.

Step 6: Full system review / MANAGEMENT REVIEW.
The top management will review the organization’s food safety management system at least once yearly to ensure its continuing suitability, adequacy and effectiveness. However, in order to provide continual improvement to the system, the food safety team representing the top management will meet at least once monthly to review audit findings.
Review input
The input to management review shall include, but is not limited to, information on
• Follow-up actions from previous management reviews,
• Incident reports from observations of daily operations, and records review
• Analysis of results of verification activities,
• Changing circumstances that can affect food safety,
• Emergency situation, accidents and withdrawals or recalls,
• Reviewing results of system-updating activities,
• Review of communication activities, including customer feed-back, and
• External audits or inspections.
• The data presented from these meetings shall enable top management to relate the information to stated objectives of the food safety management system.
➢ Review output
The output from the management review shall include decisions and actions related to the following:
• Food safety,
• Improvement of the effectiveness of the food safety management system,
• Resource needs, and
• Revisions of the organization’s food safety policy and related objectives.

Management commitment
Management Commitment is essential to the effective food safety system implementation and execution and this must be demonstrated by establishments Food Hygiene Team. This is judged by the number of Food Hygiene team meetings held, the frequency with which the Management / Hygiene Team Members attend these meetings, the control exercised by Management to ensure that Internal Audits of the policies are undertaken with the correct frequency. This will ensure that the staff will apply the Food Safety Management Systems policies to minimize Food Safety Risk. The top management should be committed to the development and implementation of the food safety management system and to continually improving its effectiveness.

Management must ensure that food safety is supported by the business objectives of the organization by:
1. Including hygiene as a performance indicator, obtained from customer feedback
2. Business is driven by revenue management instead cost cutting.
3. No compromise is undertaken on any issues that may affect the safety of products.
4. Marketing its commitment to food safety when selling and organizing catering events.
5. Budgeting for resources, investments or costs related to food safety.
6. The top management will ensure that staff at all levels in the company are communicated of the importance of meeting the requirements of this International Standard, any statutory and regulatory requirements, as well as customer requirements relating to food safety through.
7. Regular Hygiene Team and Top Management meetings.
8. Internal staff notices boards and posters.
9. Hygiene Training and workshops.

Internal Audits & Verification:
To ensure that Food Hygiene Program Policies are:
1. Kept up to date and effective by regularly reviewing the hazards and the processes.
2. The hotel is complying with implementing the regulations of the Dubai Municipality.
3. Hygienic conditions and facilities are evaluated.
4. Hazards to food and safety are determined and controlled.

To reduce the risk of unsafe food by taking preventive measures to assure the safety and suitability of food at an appropriate stage in the operation by controlling food hazards.
Establish procedures for the conduct of internal and external hygiene audits, which shall verify the level of hygiene activities and determine the effectiveness of the food safety management system in place. The audits shall be scheduled at a frequency deemed necessary for the activities being audited.
o The following audits shall be conducted:
1. Daily Departmental Self Audit.
2. Monthly Internal Audit by Hotel’s Food Hygiene Team Members.
3. Quarterly Internal Audit by a Panel of the Hotel’s Food Hygiene Team.
4. External 2nd Party Audit by an External company minimum once every 6 months.
o The audits should cover all food areas and any other areas that are likely to affect the safety of the operations and that of the food.
o The results of the audits shall be recorded and brought to the attention of the employees responsible for the area audited.
o Appropriate and timely corrective measures shall be taken to address any non-conformances raised during the audits.
o Any new information regarding hazards or processes that are likely to affect the effectiveness of the HACCP system in place shall also be taken into consideration and the HACCP plan shall be revised accordingly.

❖ Validation of control measure combinations
The food safety team has planned and implemented the processes needed to validate control measures and/or control measure combinations, and to verify and improve the food safety management system
o Prior to implementation of control measures to be included in operational prerequisites programs and the HACCP plan and after any change therein, the Hotel has validated that:
1. The selected control measures are capable of achieving the intended control of the food safety hazards for which they are designated, and
2. The control measures are effective and capable of, in combination, ensuring control of the identified food safety hazards to obtain end products that meet the defined acceptable levels.
o If the result of the validation shows that one or both of the above elements cannot be confirmed, the control measure and/or combinations thereof will be modified and reassessed.
o Modifications may include changes in control measures (i.e. process parameters, intensities and/or their combination) and/or changes in the raw materials, manufacturing technologies, end product characteristics, and methods of distribution and/or intended use of the end product.

❖ Continual improvement
The top management will ensure that the Hotel continually improves the effectiveness of the food safety management system through the use of: Communication ,Management review, Internal audit, Evaluation of individual verification results, Analysis of results of verification activities, Validation of control measure combinations & Corrective actions and Food safety Program policies are updated.

❖ Updating the food safety management system
The top management will ensure that the food safety management system is continually updated. In order to achieve this, the food safety team will evaluate the food safety management system at planned intervals.
The team will then consider whether it is necessary to review the hazard analysis, the established operational prerequisites programs and the HACCP plan.
The evaluation and updating activities will be based on:
o Input from communication (external as well as internal).
o Input from other information concerning the suitability, adequacy and effectiveness of the food safety management system.
o Output from the analysis of results of verification activities and Output from management review.

System updating activities will be recorded and reported, in an appropriate manner, as input to the management review.

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Part 3
Investigation into Food Safety Controls in a Food Business

The hotel has 3 restaurants with 3 kitchens where in food is cooked in these kitchens and food and beverage is served in these restaurants. There are currently 60 Chefs, 70 Waiters, 25 Stewards, 2 in Purchasing, 3 in Receiving and 4 storekeepers.
The hotel has a food safety program in place and is undergoing HACCP Certification with the consultancy stage over, HACCP Manual in place and HACCP Implemented. The preliminary certification HACCP Audit revealed the following:

Audit Findings:

1. Finding: Hazard Analysis has not been done for live Crabs and Lobsters in Fish Tank.
• A fish tank was found in the Fish Preparation Kitchen located in the Main Kitchen (The fish section area is where all the raw fish is cut etc). The fish tank contained live Crabs and Lobsters. The tanks was owned and maintained by the suppliers. Whenever there is an order for crabs and lobsters, they were taken out of the tanks cut, cleaned and used for cooking and served. The audit inspection revealed that Hazard analysis was not done for the live Crabs and the Lobsters in the Fish Tank in Fish Preparation Area.
Recommendations:
• Hazard Analysis requires to be done for the live seafood and lobsters. This would be a Control point in the operations. The supplier requires sending Health Certificates for the live seafood being delivered along with Certificate of Analysis.
• The receiving staff requires requesting the supplier’s delivery personnel and checking the Health Certificates and Certificate of analysis. They need to check the cleanliness and temperature of the delivery vehicle (Below 8 Deg C for transporting live seafood).They need to check the personal hygiene of the driver and the loading helper. They need to check the seafood that it is delivered in a clean and thermo cool box. The crabs and lobsters are alive and healthy and there is no awful smell and most importantly that they are not injured or damaged.
• The water tank requires maintenance to be carried out at least once a week by the fish supplier. Records of the following need to be maintained by the fish preparation chef of the work carried out by the supplier i.e. cleanliness, water filter cleaning, PH Checking and Salinity testing.
• Calibration of the thermometer displaying the temperature of the tank should be carried out at least once a year. The chef requires checking that the seafood is alive every 6 hours and notes the temperature of the water in the tanks on the recording form.
• Water tests should be carried out and send for laboratory analysis.

2. Finding: During the audit it was found that the room service toaster was dirty. There was no cleaning and disinfection procedure in the manual for this equipment. The cleaning schedule was not update to include this machine on the list.
Recommendations:
• There should be a cleaning and disinfection policy for toaster. The cleaning schedule needs to be updated to include the toaster with details on when to clean, how to clean & disinfect safety precautions and who should clean.

3. Finding: There were no labels for expiry date on Small bottles of Tabasco.
Recommendations:
• The small miniature bottles of Tabasco do not have on them the date of production and expiry.
• The small miniature bottles come in a cardboard box which packs 100 bottles in a pack. Now this box has on it the date of production and expiry. Since de-boxing is a hygiene policy to prevent pests from entering into a premises that could have been in the cardboard. This outer box is discarded.
• It is recommended that the date of production and expiry from this box is written / mentioned / stuck on the polycarbonate container in which these miniature bottles are transferred to and stored in. This shall ensure stock rotation and FIFO.
• For items from another box or another batch, they need to be placed in a separate container with the details of the production and expiry on them.

4. Finding: The infrared and probe thermometer being used by the receiving clerk was found to be having a 4 Deg C Variance. This is huge especially when receiving chilled products. No Calibration was done of this thermometer. There was no additional thermometer for the receiving clerk.
Recommendations:
• A second infrared and probe thermometer should be purchased with immediate effect.
• All Equipment calibration of thermometer should be done; the thermometer should be calibrated according to international standards.

5. Finding: Temperature of cooked rice in hot holding was 41.5 c. in Kitchen. Food was kept at ambient temperature ready to be transported to another venue (out of the Hotel).This food was kept out for 45 minutes at ambient room temperature and was to be placed in a hot box to be maintained at a temperature of above 65 Deg C and then reheated to a internal temperature of 82 Deg C before service. The Hot boxes are few and hence it could not be placed immediately. The HACCP Manual did not state how long food could be kept out at ambient temperature.
Recommendations:
• The HACCP Manual requires to be updated and it should be mentioned that food that is cooked could be kept at ambient temperature for a maximum period of 90 minutes.
• Additional Hot Boxes required to be purchased to ensure that all food that is cooked and to be hot held could be placed in hot boxes immediately.

6. Findings: The Hotel has a vegetable washing and sanitizing room located near the receiving area. The unwashed and dirty vegetables that are received in their polycarbonate containers from the suppliers are placed in a designated area. Batch by batch the fruits and vegetables are washed and sanitized and then placed in a color coded green hotel containers. The cold kitchen to which these are being transported too is located on the 4th floor. These containers pass through the receiving area and the designated area where the dirty unwashed fruits and vegetables are placed. This could result in cross contamination as the Cleaned Vegetables were going to the Kitchen without being covered with Cling Film.
Recommendation:
• The HACCP Manual requires to be updated and it should be mentioned that the cleaned and sanitized fruits and vegetables that are placed in the Hotels clean Green Color Coded Fruits and Vegetables Containers require to be wrapped with cling film before being transported out of the vegetable washing room to prevent cross contamination.
• Staff requires training on this procedure and monitored.

How Will I communicate the findings to the staff?
To be successful and to ensure that the incident is not repeated again, the organization will require communicating its policies and objectives to all levels of management and staff. Only through communication the desired levels of cleanliness and sanitization standards shall be achievable. Failure to communicate the Hotels Hygiene Program policies, will lead to inefficiency and ineffectiveness in implementing the Food Hygiene Program policies culture.
The Food Hygiene Program policies are aimed at to provide Hotel with the guidance for implementation, monitoring and reinforcement of food safety in the day-to-day operation. Furthermore, it is an important tool to implement the Food Hygiene Management System culture.

The organization communicates food safety information with personnel through both informal and formal communication channels, such as:
• Regular management meetings
• Notice boards and posters
• Training and workshops
• Communication sheets or logbooks
• Communication meetings between Events, Culinary, Food & Beverage, stores, purchasing, stewarding departments
• Emails between concerned parties
• Snapshots sent to all staff by the Communication department
• Management reviews

1. Cleanliness Posters: The following posters shall be required to be stuck on the walls, the posters should be laminated stuck with double sided tape, easily washable or should be put in frames which are washable and easy to clean and maintain. some examples of posters are as follows:
• Clean as You Go.
• Wash your hands.
• Pot Wash Station
• Dish wash Station.
• Chemical Stores Only.
• Do Not Mix Cleaning Chemicals.
• Cleaning instructions on cleaning Meat Slicers, Deep Fat Fryers, and Ovens.
• Cleaning Schedule and Checklist.
• Cleaning Posters showing the Kitchen Layout with Chemicals and Cleaning Equipment Required to be cleaned.
2. Pocket Cleaning Guide: This is a small pocket size booklet that easily fits into ones pockets. This is part of the uniform the stewarding team members. The guide contains the list of cleaning chemicals used, precautions to be taken while using them, safety tips for their usage, Various Equipments are mentioned and standard operating procedures on how to clean them is written given complete information on who is to clean them, when it is to be cleaned, frequency of cleaning, how to clean , what is used to clean them, monitoring and record keeping of the cleanliness.
3. Briefings: Stewarding, Culinary and Food and Beverage service must emphasize on cleanliness and sanitization topics and mention about the standards of cleanliness in their sections, the supervisor on duty must allocate staff and ensure that their area is maintained in a clean, hygienic manner at all given times. Stewarding should include a 5 minute training program in their daily shift briefings focusing on various cleaning equipment and how to clean them. Audit results, supervisory or managerial comments on cleaning and sanitization need to be communicated to employees through briefings and departmental communication books.
4. Hygiene Bulleting Board should be placed in the staff cafeteria, Staff Locker Room and Other Prominent Areas where all Food Handlers could read them. The bulleting Board should contain the following information: The minutes of the Hygiene Committee Meeting, Audit Scores and Audit Reports. Thus creating awareness on cleanliness and sanitization and the Hotels Official stance on cleanliness.
5. Cleanliness Monitoring & Recording: Cleaning Schedules should be in place in which the stewarding shifts supervisors recording and monitoring all cleaning activities. One of the major daily job tasks for the Chief Steward and executive Chef is to walk around the food preparation areas and check the levels of cleanliness. They should have hand held PDA’s where in they could do daily audits on cleanliness, this is then automatically recorded in the computer and reports are generated with to do actions for the stewarding supervisors. Computer linked PDA’s go a long way in providing corrective actions that are required to be taken to rectify issues, provide dates of audits, auditor names, audit findings and emails could be send to all members required to ensure that the cleaning and sanitization programs are functioning smoothly. Since this computer generated reports and electronically saved they cannot be tampered with and reports for various areas could be viewed by all levels of management who have access to a computer.
6. Area Cleanliness Monitoring Logs: Each and Every Area should have a Area Cleanliness Rating and Comment Log Book, This log book should be filled by the Chefs and the Food and Beverage Restaurant staff where in the rate the cleanliness and sanitization of the various premises and also put in their remarks. This record form should be read by the stewarding supervisor daily. In this way the persons working in that area also take active interest in ensuring that the stewarding department maintains their area clean and sanitized and this pushes the stewarding department to also clean the premises and is actually a quality improvement tool.
7. Bonus linked to cleanliness results: Audit results, corrective actions taken, audit scores shall all have a bearing on individual and departmental performance monitors and shall affect bonus paid to them. Good Audit results ensure the departmental employees receive the bonus, poor audit results in lower bonus paid to the employees. Employees not meeting the regular set targets on cleanliness will have disciplinary actions taken against them and this could also cost them their jobs due to poor performance and failure to maintain and adhere to the required set standards. Staff to be communicated about this during their orientation and induction process also during departmental briefings and when they are under going a performance review.
8. Trainings :
Food Handlers to attend the following trainings:
• Rank and file grades:
'' Basic Food Hygiene.
'' HACCP Awareness.
'' Cleaning and Sanitization Trainings.
'' Chemical Trainings.
'' Hotel Food Hygiene Polices Trainings.
'' Staff to be trained on How to use the various tools provided by management for reporting issues relating to non compliances or lapses in cleaning and sanitization.
• Supervisory staff to be trained on:
'' Intermediate Food Hygiene Training
'' HACCP Awareness.
'' Cleaning and Sanitization Trainings.
'' Chemical Trainings.
'' Hotel Food Hygiene Polices Trainings.
'' Supervisory Skills.
• Management and Hygiene Committee Members need to be trained on:
'' Advance Food Hygiene.
'' Intermediate HACCP Training.
'' How to conduct Internal Audits on Cleaning and Sanitization.
'' Cleaning and Sanitization Trainings.
'' Chemical Trainings.
'' Hotel Food Hygiene Polices Trainings

In order to maintain the effectiveness of Hotel Food Hygiene Program, the organization will ensure that the food safety team is informed in a timely manner of changes, including but not limited to the following
• Cleaning equipment, Cleaning Chemical and Cleaning Techniques.
• Production premises, location of equipment, surrounding environment;
• Cleaning and sanitation programmes;
• Personnel qualification levels and/or allocation of responsibilities and authorizations;
• Statutory and regulatory requirements;
• Knowledge regarding food safety hazards and control measures;
• Customer, sector and other requirements that the organization observes;
• Complaints indicating food safety hazards associated due to failures in cleaning and sanitization.
• Other conditions that have an impact on food safety.

References:
• Dubai Municipality Administrative Order No 20, 1992.
• Dubai Municipality HACCP Guidelines & Requirements for Retail operators 2005.
• The Food Safety (General Food Hygiene) Regulations 1995
• Food Standards Agency (FSA) website.
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