Anyone running a catering business has a legal obligation to train their staff in the basics of food hygiene. This obligation is detailed in the Food Safety (General Food Hygiene) Regulations 1995.

The amount of training depends on the job each individual member of staff does and whether they are classified as "high" or "low" risk.

A guide, published by the Chartered Institute for Environmental Health, offers advice for caterers on complying with the regulations.

Enforcement officers must assess whether a catering business has complied with the regulations and give "due consideration" to the guide when assessing compliance. While there are other ways to show that a business has complied with the regulations, the guide provides an excellent benchmark.

Industry guide
The Catering Industry Guide to Good Hygiene Practice suggests that food handlers should be trained beyond the legal requirements, especially as their careers develop and they take on additional responsibilities.

All staff, not just those who handle food, should be properly supervised and instructed to ensure they work hygienically. Greater supervision is suggested for new staff, staff handling high risk foods and less experienced staff. The proprietor should evaluate the competency and experience of the individual food handler in order to establish what level of training is best for them.

Categories of staff
The Good Practice Guide classifies three categories of staff, namely A, B and C, and each must be supervised and trained to a certain level.

Category A
The Good Practice Guide defines category A staff as those handling low risk or wrapped food only. All category A workers should be trained in food hygiene essentials and understand what needs to be done to comply with the regulations. It is good practice to carry this out before they start work for the first time.

The code of practice outlines the instructions a food handler should receive on the essentials of food hygiene whether verbally or in writing.

Category A food handlers are likely to include waiters, bar staff, delivery staff and counter staff as they are not directly involved in preparation and personal handling of high risk open food.

Category B
These are food handlers who prepare open, "high risk" foods. All category B workers must be instructed on the food hygiene and hygiene awareness in the same way as category A workers.

In addition, they should receive formal training. The Good Practice Guide splits this training into three different levels. Category B staff must have formal training in food hygiene to at least level one. This training must be received within three months of appointment or as soon as possible afterwards.

The overall aim of level one training is to develop an understanding of the basic principles of food hygiene. The categories that should be covered are listed in the code of practice.

Larger organisations may prefer to carry out this training in-house. Many organisations run courses on food hygiene that are accredited and of the appropriate standard.

Category B workers are likely to be cooks, kitchen assistants, commis chefs or bar staff who prepare food.

Category C
Category C workers tend to be food handlers who also have a supervisory role. In addition to the requirements of category B workers, it may be good practice for staff in these grades to take further training to level two or three as their career and management responsibilities progress.

Levels two and three are more advanced training courses dealing with food hygiene, cover management and systems. Typically, level two will involve a one or two day course and level three will involve courses covering two to three days. However, the code of practice provides no outline to training content of levels two and three.

Category three workers are likely to be chef managers, proprietors, unit managers and bar/pub managers.

Assessment and records
Anybody handling food should be tested after any formal training in hygiene, using for instance, a multiple choice paper or verbal test.

It is good practice, but not a legal requirement, to keep records of the training and assessment completed by every member of staff. Written records of the training, however may be excellent evidence that the proprietor of the food business has complied with the regulations and may assist companies in establishing a due diligence defence.

Ideally, owners and managers should review the level and quality of training being received by their staff on a regular basis. It is important that each employee is evaluated on his or her own ability and level of experience. This will help decide what level of training is best for their current job title and to help in their future development.

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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