A clean sweep

27-Aug-2007 - Last updated on 13-Mar-2017 at 17:34 GMT

Manufacturers have their work cut out to keep pace with new developments in European hygiene legislation. But help is at hand, with new independent advice and training on the cards, says Rod Addy

Until recently, manufacturers were deprived of high quality, comprehensive and consistent training that covered all the issues that those responsible for hygiene and cleaning would face. Large detergent firms still offer to train companies in the use of their products, but independent training has been thin on the ground.

Until now. Enter the Food Standards Agency (FSA), which is working with Asset Skills, the sector skills council for the property, facilities management, housing and cleaning industries. "We are reviewing the underpinning document on qualifications in the sector," says Chris Pratt, head of the FSA's food hygiene policy and legislation unit.

"We have asked them [Asset Skills] to consider standards for cleaning of food premises. There will be a training unit in the revised standards on this and one on deep cleaning in food."

Pratt says the revised standards will be completed this autumn and syllabi will be developed for cleaning courses in the six to nine months after that. "Companies who don't want to send employees on external courses because of lack of time can adopt the standards internally for their own training."

Not content with focusing exclusively on this project, the FSA is also working with BSI Group, which provides several training guides on best practice for the food and drink industry. These guides have had to account for the new Food Hygiene Regulations 2006 and are under review in consultation with a wide variety of stakeholders.

Four to five of these guides will be on line this year and up to 12 will be put together next year, says Pratt. "We have tried to keep the price down (we have a publishing contract with Her Majesty's Stationery Office), but industries are free to publish themselves." The FSA is providing input for new guides covering the bottled water, dairy and fisheries industries.

Get qualified

That's in addition to working with food and drink sector skills council Improve to develop competency-based food safety qualifications specifically for food and drink manufacturers. This work follows the launch of manufacturing- orientated National Occupational Standards for food safety training qualifications at the end of last year. Courses had previously been offered purely for the catering and service industries. A four-stage framework is now in place, providing an induction in manufacturing and further teaching aimed at providing operational-, supervisory- and management-level food safety knowledge.

"Some awarding bodies are further contextualising [courses], so they could cover bakery, meat and poultry and dairy, using different terms for equipment depending on the sector," says Derek Williams, Improve development director.

The courses will provide standalone qualifications, but can also contribute to food safety modules for NVQs or SVQs. In addition, competency-based qualifications have just been launched. Full NVQs in the area will be showcased in September.

The need for up-to-date training and guidance is vital, not least because of the swathe of legal changes affecting hygiene and cleaning that have occurred over the past year and others expected in the next few years.

The core changes have been imposed in the wake of European Regulation 852/2004 on the hygiene of foodstuffs. This has filtered into law in the form of the Food Hygiene (England) Regulations 2006 and equivalent legislation in Scotland and Wales, followed by the Food Hygiene (Amendment) Regulations 2007, introduced in February.

"Food businesses need to work through these European regulations for all their activities to find out how their entire business may be affected," says Tom Stocker, senior associate in the health and safety team at law firm Pinsent Masons. "For example, there are differing requirements for the registration or approval of premises with the relevant authority depending on the type of food business. One of the difficulties for businesses is keeping up to date with the volume of EU legislation in this area."

Regulatory uncertainty

Areas of continuing uncertainty don't help. For example, the proposal to exempt businesses of 10 or fewer employees from hazard analysis critical control point (HACCP) requirements has been made at EU level. However, a strong blocking minority has so far prevented this from developing.

Not only do manufacturers face considerable regulatory uncertainty, they also have to contend with over-zealous enforcement of regulations by some local authorities.

Companies falling foul of hygiene rules are frequently prosecuted for multiple offences based on each section of the EU guidelines on Regulation 852/2004 breached. "Local authorities can pick out as many sections as possible and prosecute for a high number of offences," says Katharine Vickery, associate in the regulatory team at Eversheds. "In one case there were 70 offences. Instead of being prosecuted merely for dirty premises, the company faced separate charges of having dirty walls, dirty floors, dirty equipment and so on."

Another significant forthcoming regulatory change will be the European Biocidal Directive, according to Stuart McNeil, vice chairman and head of media for the Society of Food Hygiene and Technology.

This will limit the number of permitted products currently on the market for use in the food and feed sectors considerably. The BSI Group is separately working on developing best practice guidelines for the use of disinfectants.

It goes without saying that the technology and methods used for cleaning are constantly evolving as well. "There are various systems of sanitising water without chemicals using some form of electrolysis and I'm seeing more of these systems now," says independent consultant Dr Slim Dinsdale.

McNeil says there's a drive to cut the use of chlorine, especially at sites dealing with products such as fruit, vegetables and salads. "The man in the street doesn't want bleach on his food. Of course, many detergents aren't strictly bleach - they are chlorinated products, but it's psychological and the media has stirred things up a bit."

He says people looking for alternatives are sometimes opting for using peroxides. Another option, which can be used in premises processing organic products is Citrox, which is composed of fruit-based, natural compounds. "One of the areas it's more effective for is fruit washing," says McNeil. "But it's very expensive in comparison to bleach and that's where many people will see the difference."

He also cites the rise of thin film detergents. "Foam is sometimes difficult to rinse off, whereas thin film is a lot more effective. It's very economical to use half an inch of thin film on a surface."

Inadequate plant design

Of course, up to date knowledge of the latest legal changes and the best training in the world is no substitute for experience. It helps to know where problems commonly arise. Inadequate design of equipment is one major issue, says Dinsdale. "In one case I know there was a lack of hygienic design and because of that, machinery couldn't be properly dismantled and cleaned. That said, I'm seeing more hygienically designed equipment now.

"Conveyor belts in particular can be difficult to clean and one could say anti-microbial coatings would help as an additional layer of defence."

However, he cautions against seeing such coatings as a replacement for adequate hygiene controls. And he warns that they may lead to bacteria building up a resistance to the substance used.

Aside from design problems, another issue is improper use of chemicals. Gill Palmer, food safety management consultant at Reading Scientific Services (RSSL), says: "It's making sure people use the right dosage. The instructions may require 5% dilution of the chemical, but how do you achieve that? A lot of people are cleaning without understanding why they are doing what they do. If they don't, they won't necessarily do the right thing in a particular instance."

But it's not just inadequate understanding that causes a breakdown in hygiene and cleaning procedures, says Pratt. Often, it can be a break in routine. "People going on holiday can cause problems. People are used to doing things in a certain way and all of a sudden, things change."

Vickery says: "Changes in management can be an issue or if the key person who enforces hygiene and cleaning is off sick or is away, procedures slip." FM