St. Michael s, Breaston

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1 Summary Policies and Procedures Key points Food poisoning and allergic reactions are a sad reality of life and can occur anywhere. These are especially dangerous for vulnerable groups like the elderly and those with strong allergies. These notes set out what needs to be done to avoid this. Anyone planning an event or activity including food needs to read this well ahead of time. The key requirements are: Anything beyond Tea and biscuits/toast may need to involve someone with Food Hygiene Training read on! Keep everything (and people) clean Keep hot food hot Keep cold food cold Make any allergens clearly marked Be especially careful over high-risk foods like cooked meats and dairy products Regular catering activities need reporting to the local Council Routine action Undertaken by When Use this document Person responsible for food Any time preparation in H&S Policy; Social Committee Chairman; Office staff; Church members doing food preparation. Review the document Person responsible for food preparation named in the H&S On review date, or as required Policy Legal obligations Accountable role The Food Safety and Hygiene Persons undertaking catering (England) Regulations SMB-HS-120-POL.docx

2 Document control St. Michael s, Breaston Document reference SMB-HS-POL-010 Issue: 5.4 Status Published Issue Date: 01/08/2018 Written by: Bob Crockford Roles principally responsible for compliance with document Person responsible for food preparation in H&S Policy; Social Committee Chairman; Office staff; Church members doing food preparation. Circulation (by job title) The above, plus Standing Committee Review period Annually Next review due 01/08/2019 Table of contents 1 Introduction Legislation and Registration with the Local Council Allergens Summary Durations food can be left out Barbecues... 7 Appendix 1 Legislation notes... 9 Appendix 2 Hygiene requirements Appendix 3 Flowchart Issue 5.4 (Published) Page 2 of 15

3 1 Introduction There has been a lot of press coverage about the issue of the provision of food by churches and village fêtes etc. Unsurprisingly there is confusion over this matter. After research with the church insurers, similar bodies and churches and discussion with the local Environmental Health department, the following is the church's policy on the matter. If you are in any doubt as to the requirements for a certain type of catering or event, please contact the H&S Co-ordinator. This procedure has been shared with the local Environmental Health Department who have confirmed that it deals with the relevant issues. In short, although in strict legal terms some church-related catering may be exempt from food hygiene legislation in that it is not for commercial profit, we are obliged to provide food that is safe under the more general health and safety legislation and the terms of our insurance and the means to achieve this are the same. We would want to do this in any event as a Christian church and not to harm those who we serve. Consequently, it is entirely reasonable and in fulfilment of our legal obligations that we meet good food hygiene standards and practices. Consequently, the requirements stated below in terms of food hygiene training and temperature control must be adhered to. 2 Legislation and Registration with the Local Council Apart from matters of safety, certain types of catering must be notified to the local authority who may carry out inspections as they see fit. Appendix 1 gives more detail on this issue, but in summary, if catering is: "more than tea and toast/biscuits" and "regular" and/or "complex in terms of food safety risks"...it must be registered with the local authority. The church is responsible for advising the local authority of all catering carried out on a regular basis and any "ad hoc" events of its own that fall into the third "complex" category. We are not responsible for non-church events in that category using the hall. Even for food preparation that is not regular (i.e. "ad hoc") such as occasional social events, our insurers require that certain standards of cleanliness, hygiene and temperature control are followed (see Appendix 2) Appendix 1 gives an extract from the FSA guidance with examples of what is likely to be exempt or not from registration with the Local Authority. Appendix 2 gives the hygiene requirements required by our insurers and information regarding handwashing. Issue 5.4 (Published) Page 3 of 15

4 Appendix 3 gives a flowchart to determine the requirements for a given catering activity. The office contacts all regular users of the hall annually to enquire as to the nature of the catering provided (if any), and completes the appropriate form and submits this to the local authority. Even if all activities are "tea and toast/biscuits" or "no catering", this is still a requirement. "Ad hoc" catering at events run by non-church groups (e.g. WI or Playgroup Jumble Sale) is not the church's responsibility and any need to meet food hygiene regulations and/or to advise the local authority etc. is for the event organiser to determine. The most common catering undertaken for church activities tends to be for social events where buffet type food is provided, some form of bring and share or takeaway food is brought in, plus occasional events where cakes and jams are sold e.g. at a garden party. It must be stressed that even these occasions pose food safety risks, especially the times that food is left out for. 3 Allergens The Food Information Regulations 2014 make certain requirements on food outlets regarding the provision of information to customers about the presence of allergens in food. These regulations do not apply to churches and charitable organisations unless these are themselves registered as food businesses under the regulations in Section 2. However, under the more general health and safety legislation we are obliged to control this risk and appropriate measures must be taken to either avoid the presence of allergens or to clearly warn people of their presence. For some people allergic reactions can be very serious and even fatal. For a list of allergens, consult food safety training documents and online information. These include: Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats Crustaceans for example prawns, crabs, lobster, crayfish Eggs Fish Peanuts Soybeans Milk Nuts; namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia (or Queensland) nuts Celery (including celeriac) Mustard Sesame Sulphur dioxide/sulphites, where added and at a level above 10mg/kg in the finished product. This can be used as a preservative in dried fruit Lupin which includes lupin seeds and flour and can be found in types of bread, pastries and pasta Issue 5.4 (Published) Page 4 of 15

5 Molluscs like clams, mussels, whelks, oysters, snails and squid These requirements apply to both food served for eating or sold as produce (jams, cakes etc). it is not an easy task in churches to control allergens, especially when many things like cakes are made by multiple individuals and by several people. Where all allergens in a given food are known, this shall be displayed. If they are not known, a general warning must be shown such as this... If you suffer from any food related allergy, please note that any of the food provided may contain allergens. 4 Summary In short, all catering provided in situations run by the church or done in its name (beyond simple tea and biscuits/toast) needs to consider the risks associated with food hygiene and to comply with this document. See the flowchart in Appendix 3 Where "takeaway" food e.g. fish and chips is brought in, the temperature requirements still apply, although the requirement for those handling/serving to all be food hygiene trained may be reduced provided normal standards of cleanliness etc. are observed. For events like occasional jumble sales, garden parties etc. where things like cakes and jams are sold, registration with the local authority is not needed (see Appendix 1), however, appropriate care is needed regarding hygiene and cleanliness and warnings about allergens. An appropriate distinction can be drawn between foods that are "lowrisk" and "high-risk" in terms of whether Level 2 food-hygiene training is needed by those preparing them or managing their serving, display or sale. The following is taken from the University of Warwick Safety website and amended in discussion with the local Environmental Health Department. 4.1 High-risk foods - needing food hygiene training for preparation and serving cooked meat and poultry such as; beef, pork, ham, lamb, chicken, turkey, duck cooked meat products such as; meat pies & pasties, pate, meat stock & gravy, cook-chill meals dairy produce such as; milk, cream, artificial cream, custards, products containing un-pasteurised milk, ripened soft & moulded cheeses egg products such as; cooked eggs, quiche and products containing uncooked or lightly cooked eggs, for example; mayonnaise, mousse, homemade ice cream Issue 5.4 (Published) Page 5 of 15

6 shellfish and other sea-foods such as; mussels, cockles, cooked prawns, raw oysters smoked fish fermented products such as; salami, pepperoni flour/starch type dishes including; cooked rice, pasta, couscous 4.2 Low-risk foods Low-risk foods are ambient-stable such as; bread, biscuits, cereals, crisps and cakes (not cream cakes). Such foods are unlikely to be implicated in food poisoning and include: foods that have been preserved, for example salted fish dry goods, those that contain minimal amounts of moisture, such as; bread, flour, biscuits acidic foods, for example; pickled foods, vinegar, fruit foods with high sugar/fat content for example; jam & chocolate tinned food, whilst unopened Food hygiene training is not onerous and is usually by completing a simple online training course, typically an hour or so. The cost may be reimbursed by the church if necessary. Level 1 covers handling pre-prepared foods (i.e. just serving ), Level 2 covers food preparation and cooking etc. It is acceptable for people without such training to be involved provided someone suitably trained is directly and continually supervising them Issue 5.4 (Published) Page 6 of 15

7 5 Durations food can be left out Assuming the hygiene requirements are met (See Appendix 2), the main point of concern is the temperature that food is kept at in between preparation and serving (see Appendix 3). Food safety guidance has maxima of 4 hours for "cold" food and 2 hours for "hot" food, assuming that all other requirements were met up to the point of "sale/serving". However, given that the food preparation typically done in church circles will not be in rigorously controlled conditions (e.g. how many of us have or use fridge thermometers or temperature probes?), the limits for St Michael's will be: HOT FOOD COLD FOOD ONE HOUR TWO HOURS These times are from when the food is removed from the cooker or fridge to the time when serving finishes. If "cool boxes" are used for cold food with plenty of ice packs, one extra hour (in the cold box) is permitted plus the above time. NOTE Once these times have been used up, hot food must be disposed of. Cold food may be returned to the fridge but any subsequent use must be immediate. 6 Barbecues Significant care is needed regarding BBQs as there is a higher instance generally of: People with no/little food safety training People with less experience at cooking Poor or no handwashing facilities Difficulty of controlling cooking temperatures due to being a BBQ often insufficient heat over the full time of cooking (the max temperature falls with charcoal after a while yet the pressure is on to keep going) Poor standards of cleanliness on BBQs The need to separate raw and cooked meats including implements in a small area Burgers being a higher risk than usual of E-COLI Children/elderly people are often eating the food (vulnerable groups) Customers wanting food a.s.a.p. and the pressure to deliver By following the flowchart in Appendix 3 it is clear that BBQs will require person(s) with Level 2 Food Safety Training either doing the work or directly and continually supervising others, BBQs pose a significant food safety risk and following discussion with the Environmental Safety Officer, the following measures should be borne in mind especially: There needs to be good handwashing facilities reasonably close to the cooking area. If the kitchen is too far, then some hand basin with hand soap and hot water, regularly replenished and paper towels are needed. Issue 5.4 (Published) Page 7 of 15

8 The person handling the raw meat especially must keep hands clean and keep any apron away from cooked meat Food must be thoroughly cooked (obvious but pink burgers are extremely dangerous for ECOLI) The middle needs to have juices running clear, be visibly cooked and steaming. Ideally the temperature should be measured (a minimum of 75 degrees for 30 seconds or if 80+, no time period) with a probe. If a probe is used, need to clean it in between measurements with a food-grade disinfect wipe or spray/paper towel wipe, or boiling water. If feasible, pre-bake the meat and minimise risks It is absolutely essential that raw meat is separate from cooked. On a BBQ, best to move things across from raw to cooking to cooked and never the twain shall meet. If one person does raw, one does cooking and one does serving that makes separation much easier. Separate tools must be used for raw meat and cooking/cooked meat and kept apart. Issue 5.4 (Published) Page 8 of 15

9 Appendix 1 Legislation notes St. Michael s, Breaston From the Food Standards Agency guidance document "Community and charity food provision -guidance on the application of EU food hygiene law": 11 All food supplied outside of the domestic and family setting is required by law to be safe to eat. This is regardless of whether the operation supplying or selling the food is doing so to make a profit. This means that food must not be injurious to health or unfit for human consumption 12. EU law also requires that certain operations supplying food are registered with the competent authorities (in the UK this will be local authorities). For an operation to require registration it must have a certain continuity of activities and a certain degree of organisation. Operations such as the occasional handling, preparation, storage and serving of food by private persons at events such as church, school or village fairs are not covered by the scope of the Regulation. This is made clear in recital 9 of Regulation (EC) No 852/2004. The second sentence states that: Community rules should only apply to undertakings, the concept of which implies a certain continuity of activities and a certain degree of organisation. The FSA s views on the terms a certain continuity of activity and a certain degree of organisation and examples of food provision that the FSA considers require or do not require registration are set out below and in Appendix 1. These two terms should both be considered when deciding whether an operation requires registration. In short, if the catering is regular ("continuity") or organised it needs to be registered with the local authority. "Regular" is intended to mean more than about once per month. However, catering which is less frequent may still need registering if involves complex food safety controls or is for vulnerable consumers. In terms of "organisation" (or "complexity"), the following should be considered: Foodstuffs and risk. Consideration should be given to the risk presented by the food provided and the controls needed for safe food supply. Low-risk food provision such as tea and biscuits, packaged foods, and foods which can be kept at room temperature are all low-risk and do not require a significant degree of organisation. Operations with more complex safety controls, such as those serving hot foods or food which otherwise require temperature control to remain safe will require more organisation. Vulnerable consumers. If vulnerable consumers are being catered for (i.e. the elderly, infants under 5 years, expectant women or the chronically sick) then food providers must consider these risks and put suitable controls in place. This can be said to increase the level of organisation. Nature of event. Infrequent large-scale community events, perhaps organised by the same community group where a wide range of consumers can walk in off the Issue 5.4 (Published) Page 9 of 15

10 street are considered to require more organisation than events occurring to more restricted groups of consumers such as at private or closed events. Types of catering needing registration (taken from the FSA Guidance) Issue 5.4 (Published) Page 10 of 15

11 Issue 5.4 (Published) Page 11 of 15

12 Appendix 2 Hygiene requirements Extract from the Ecclesiastical Insurance Guidance Premises which are only used occasionally for food preparation The Food Safety and Hygiene (England) Regulations 2013.require that premises which are used occasionally for food preparation, and moveable or temporary premises such as marquees, follow the guidance for temporary premises. The Food Standards Agency Guidance Food Hygiene A Guide for Business advises that: (temporary) premises must be positioned, designed, constructed, kept clean and maintained in good repair and condition to avoid, as far as reasonably practicable, the risk of contamination, particularly from animals and pests appropriate facilities must be provided to maintain adequate personal hygiene, including hygienic hand washing, toilet, and, where necessary, changing facilities. See additional notes below. food preparation surfaces must be well maintained and easy to clean and disinfect adequate facilities must be provided for cleaning and disinfection of work utensils and equipment there must be an adequate supply of hot and/or cold water, including drinking water there must be adequate arrangements for the storage and disposal of waste there must be adequate arrangements for the storage of food at suitable temperatures and the monitoring of those temperatures food must be placed in a way that avoids contamination, so far as is reasonably practicable if you wash or clean food there must be adequate facilities to do this hygienically. care should be taken to warn potential allergy sufferers of ingredients used - e.g. nut allergies, lactose intolerance etc. Personal hygiene Every person working in a food handling area must maintain a high level of personal cleanliness. Suitable clothing must be worn, hair should be covered using a hat or hairnet whilst preparing food, and jewellery (except wedding rings) should not be worn. People suffering from, or suspected of carrying a disease transmittable by food, or with open wounds, skin infections, sores, or with diarrhoea must not handle food or enter a food handling area. Issue 5.4 (Published) Page 12 of 15

13 Information regarding handwashing supplied by Erewash Borough Council Environmental Health Department Issue 5.4 (Published) Page 13 of 15

14 Issue 5.4 (Published) Page 14 of 15

15 Appendix 3 Flowchart St. Michael s, Breaston Issue 5.4 (Published) Page 15 of 15

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