The Food Safety (General Food Hygiene) Regulations 1995 say that a proprietor of a food business must make sure that all stages of food preparation and sale are carried out in a hygienic way.

The proprietor of a catering business must identify any steps which are critical to ensuring food safety and develop adequate safety procedures based on the analysis of potential food hazards. A company that contravenes these regulations may be liable for a fine and individuals face a fine and/or imprisonment for up to two years.

Legal Requirements

The regulations say that all food premises must be kept clean. However, this is not officially defined any further, leaving common sense application to enforcing officers and the courts. The design of the food premises must allow for adequate cleaning and disinfection, protect against the accumulation of dirt and contact with toxic materials and permit good hygiene practices. In addition, the premises must be of a construction that protects against contamination by food stuffs, personnel and other external sources.

Floors, walls, ceilings and windows

There are specific regulations covering those areas which are susceptible to dirt and grime.

• Any rooms in which food is prepared, treated or processed excluding dining areas, must have floor surfaces that are in a sound condition which are easy to clean, and, where necessary, disinfect. The regulations state that impervious, non-absorbent, washable and non-toxic materials should be used.
• The same requirements are stipulated for all wall surfaces.
• Ceilings and overhead fixtures must be of a design that prevents the accumulation of dirt, reduces condensation and the growth of undesirable moulds.
• Windows and other openings must be constructed to prevent the accumulation of dirt and, where necessary, be fitted with insect proof screens.

Keeping floors clean and in good condition can be difficult. From a practical viewpoint, no single finish or covering to a floor can satisfy all the processes that operate within a food business. However, it is essential that the flooring not only satisfies any legislation, but that it is hard-wearing and durable; the financial implications of having to replace the floor can be huge.

Dangerous or dirty floors are some of the most common items reported to Environmental Health Officers.

The floor should be seamless to prevent tripping, hygienic, durable, easy to clean, (but still be resistant to aggressive cleaning methods) and be of a matt finish to prevent slippage. Most food businesses choose seamless resin compounds and slip-resistant heavy duty vinyl as the most appropriate type of flooring.

However, proprietors of food businesses need to analyse the need for a specific flooring for a particular part of the premises depending on traffic and the type of ingredients being used. Each manufacturing process may need a separate type of flooring.

Walls and ceilings are under similar demands. Walls should be easy to clean, impervious and non-absorbent. Often, food businesses use tiles, but it is important to ensure that they do not become broken or cracked as this allows the entry of dirt and bacteria which can be difficult to remove. Most professionals recommend PVC cladding as it has no joints and cannot rip or tear easily. It is also easy to maintain.

Surfaces

All surfaces that come into contact with food must be maintained in a sound condition and be easy to clean and where necessary, disinfect. The regulations stipulate the use of smooth, washable and non toxic materials in this instance. Adequate facilities must be provided for the cleaning of work tools and equipment with a hot and cold water supply. "Sound condition" is not further defined in the regulations.

Equipment

To minimise the risk of contamination, any equipment that comes into contact with food must be kept clean and be constructed in such a way as to reduce contamination. The equipment must be designed to enable thorough cleaning and, where necessary, disinfection. Equipment must also be installed so that the surrounding area can be easily kept clean.

Good Practice

Although the law is not specific, satisfying the requirements of the legislation involves little more than common sense. Here are some examples of good practice.

• Ensure that kitchen surfaces are cleaned after each use;
• Floors should be swept and washed regularly;
• All utensils, equipment and crockery should be washed after use with a strong detergent, and hot clean water, especially when changing to different food types;
• Utensils, equipment and crockery should be dried, preferably by air rather than using towels, and stored away in a clean space;
• Taps and sinks should be cleaned after every use; and
• Cloths and sponges should be reserved for separate tasks and washed thoroughly after use.

The Hazard Analysis and Critical Control Points (HACCP) should be applied in identifying relevant hygiene issues (see HACCP).

Roy Tozer is a Partner in the Regulatory Group of DLA Piper Rudnick Gray Cary UK LLP. roy.tozer@dlapiper.com


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