FSA 2014 Guidance Summary

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The 2014 Guidance

This is an update to the 2011 Guidance which was developed in response to the foodborne E. coli O157 outbreaks in Scotland and Wales. Both outbreaks were attributed to cross-contamination arising from poorly managed food handling practices. Rather than reproduce the bits that are the same this should be read in conjunction with the notes on the 2011 Guidance.
Big Change

The biggest single change is that the guidance on thermal disinfection in commercial dish wash machines has been replaced by ‘follow the manufacturer’s instructions’. Given many machines are built to a DIN standard the chances of something being cleaned reaching 82ºC for 15 seconds at the surface is effectively zero – this is the requirement under EU law for utensils used on raw food. The 2011 Guidance referred to rinse tank temperatures and was in need of clarification but this isn’t really any clearer. The challenge will be in how Environmental Health Officers enforce this; there is a risk many will default to 82ºC for 15 seconds but technically this only applies to utensils used on raw foods, not – for example – crockery that has been in contact with ready-to-eat foods. They also make nebulous references to steam but give no detail; wet steam at 65ºC will give a 4 log reduction (that’s 99.99%) in E. coli in 8.4 seconds but if it’s dry heat it’s 547 minutes at the same temperature.
Fine Details

What is cross-contamination? (p6: 1.2)
This is a pretty vague definition. It is defined differently in the Glossary but a far clearer version would be:
Cross-contamination is a common cause of food poisoning. It is the process by which potentially harmful bacteria are transferred from raw meat or soiled vegetables to ready-to-eat food. This process can be direct (for example by touch or blood dripping onto ready-to-eat foods) or indirect ( by hands, surfaces or equipment).
Also the diagram is misleading because it suggests only direct contamination as the arrows only go from the source of cross contamination to the ready to eat (RTE) food. There really should be lines from the raw meat or soiled fruit to other cross contamination routes such as hands, equipment, and clothing before it reaches the RTE food. Routes of cross contamination can be complex and this oversimplifies it.
Raw Meat (p7: 1.4)
They confuse species and meats here. For example ‘beef, lamb, goat and deer’ should be ‘beef, lamb, goat and venison’ for consistency and ‘it has also been found in pork, poultry and the offal of all the mentioned species’ – but the those are not species, they are the meats from the species! In the footnote regarding washing of veg there should be a caveat regarding lettuce – it is standard practice not to rub the leaves because it would bruise and discolour them. It is accepted practice to plunge them repeatedly in to cold water to push out the sand and soil often found on them because rubbing bruises and discolours sensitive leaves.
Premises (p8-9)
There is no mention of the importance of direct workflow from raw to RTE foods yet this is fundamental to how a kitchen operates and how chefs should work to avoid cross contamination.
Time Separation (p10)
When time separation is used, it is recommended, where possible, to prepare RTE food first in a designated area before undertaking preparation of raw foods.
What? By preparing the raw meat or soiled veg nearer the service time you increase the risk and – more practically – you usually have to prepare raw food first to cook it. Chefs are always under pressure to prepare food to a set time and as service approaches things get rushed and people tend to be less attentive to hygiene rules. It is better for chefs to prepare raw meat and veg first when they have the time to be more careful with cleaning and disinfection and because that is the way it is when preparing food from raw.
Complex Equipment(p12: 2.5)
While the stance appears to have softened here from ‘separate complex equipment for raw and cooked’ it hasn’t in practical terms. What this section says is ‘IF you can ENTIRELY dismantle a mincer, slicer or vac packer and completely disinfect the parts then that’s OK‘.  It is then made clear this is not something that can be contemplated mid-service. This was always the case: if you could entirely dismantle complex equipment used for raw foods and disinfect all the parts you could change its use to RTE foods. But this wasn’t something you could do ‘on the fly’ and sill isn’t. To all practical intents and purposes they are still saying ‘separate complex equipment’ but are being mealy-mouthed about it. This will lead to confusion and different interpretations by different EHOs. Again.
Sinks (p13: 2.7)
It is not recommended to wash raw meat (eg poultry) due to the increased risk of splashing bacteria…
’This is too general and simplistic. Sometimes you do have to wash chicken in water either to remove blood deposits before deep frying or for religious reasons. For this separate, dedicated bowls and colanders / sieves solely for this purpose should be used so chicken can be washed without risk of splashing. This is normal practice in many large fast food operations.
Protective Clothing, (p21: 4.2)
When same staff handle raw and RTE food… there is no need to change protective clothing for different activities but care is required to ensure that clothing does not become contaminated, or pose a risk of contamination in which case it will need to be changed
In situations such as butchers’ shops this is unhelpful. A better solution in such situations would be to take off their apron or coat used for raw meat when going to the RTE counter. No matter how careful you are there is a significant risk serving RTE food while wearing the same clothing you were when preparing raw meat, for example.
Glossary - Detergents
Products used for general cleaning (to dissolve grease and remove dirt, debris etc
This lacks clarity: ‘debris’ is loose material left on a surface which would be wiped off before the first stage of cleaning, not treated with detergent. You should remove loose soiling or debris before the two-stage cleaning process mandated by the FSA (clean then disinfect – and if one product does both you still need to do it twice).

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