Food Safety Legislation And The Local Assembly

How many times have we used our Lord’s words ‘Render therefore unto Caesar the things which are Caesar’s; and unto God the things that are God’s.’ Matt. 22. 21, to remind us that we have an obligation before God to obey the law of the land in which we live?

The intention of this article is to give guidance for local churches so that they can obey the law in relation to the provision of food to the public that is safe and hygienic in accordance with the law’s requirements. This article cannot enter into specific details and so advice may need to be sought from the local Environmental Health Officer (EHO) if there is any doubt.

The law that we have to comply with is the Food Safety Act 1990, and in particular two sets of regulations that are very important to food hygiene:

• Food Safety (General Food Hygiene) Regulations 1995
• Food Safety (Temperature Control) Regulations 1995

It has been suggested that the Act does not apply to charities or churches as the food is being given free. This is wholly wrong. The Government’s Food Standards Agency states that ‘The preparation of any food for sale or supply to the public, whether on a commercial basis or not, must comply with food hygiene regulations. This includes food prepared in the home for service at community events. These require that food should be handled, prepared, stored and transported in a hygienic manner’.

Why food hygiene is important

Food poisoning can lead to serious illness, or even death, especially among the very young and the very old. Harmful germs that cause food poisoning can spread very easily so it is the providers’ responsibility to make sure that they do everything to prevent this.

In the kind of catering we are involved with the food is most often prepared at home, transported to the place of the meeting in our cars, set out in one of the rooms, possibly hours before consumption, in uncontrolled conditions and is therefore a cause for concern. A few simple steps will reduce risk considerably.

Let’s highlight six main areas in the defence against food poisoning:

1. Cleanliness of food preparation areas;
2. Personal hygiene standards;
3. Thorough cooking of food;
4. Temperature control of food;
5. Transportation of food;
6. Cross-contamination.

Cleanliness of food preparation areas

Many of these requirements are common practice:

• Ensure that all surfaces that will come into contact with food are clean. Always use clean cloths and clean up spillages immediately.
• An ample supply of hot water and detergent should be available.
• Clean as you go.
• Keep all pets out of the kitchen.
• No smoking in the kitchen.
• Make sure there is sufficient lighting, and that doors and windows are kept closed to prevent the ingress of flying insects.

Personal hygiene

Again many of these are what we do already.

• Wear clean clothes and aprons.
• Wash hands regularly, particularly after touching raw meat, and going to the toilet. Do not use nail varnish and keep finger nails short.
• Cover cuts and abrasions with a waterproof plaster.
• Never prepare food if suffering from diarrhoea, stomach upset or skin infection.
• Keep long hair tied back.

Thorough cooking of food

Food poisoning bacteria multiply particularly well between the temperature of +8°C to +63°C. This is called the DANGER ZONE.

It is an offence to keep food at a temperature that would cause a risk to health; i.e. within this zone.

All raw food must be cooked to above +63°C. The temperatures quoted are core temperatures. It is recommended that meat should reach a minimum of +75°C core temperature.

At its simplest level food is cooked to kill bacteria, and make the food safe for human consumption.

If the food is to be consumed at a later time it must be cooled as quickly as possible and kept refrigerated, below +8°C, if not then it must be kept above +63°C until it is consumed.

Temperature control of food

It is worth pointing out at this stage those foods which require temperature control. These foods are known as ‘High Risk Foods’ and are:

• All dairy products – unless the label states, ‘stable at room temperature’.
• Cooked products – those items that are ready to be eaten, hot or cold, and will include sandwiches, pies, and products containing meat, fish, dairy products, eggs, cereals, (e.g. rice), soups and sauces.
• Smoked/cured ready to eat meat or fish – including cured hams, smoked salmon, salami etc.
• Prepared ready to eat foods – e.g. prepared vegetables, coleslaw, and mayonnaise products.
• Uncooked or partly cooked pastry and dough products – these include pizzas and fresh pasta containing meat.

Transportation of food

The transportation of food must ensure that chilled food is kept under +8°C. This is achievable with the use of cool bags, polar boxes, frozen ice blocks and/or portable chillers, all of which are readily available in the High Street.

When transporting food ensure that it is well sealed, and covered so there is no risk of contamination or spillage.

Once at the place of service the food should be kept under refrigeration till the time of consumption.

Food for serving hot should not be heated untill it is required to be served. The regulations state that all food for reheating must achieve a core temperature of +75°C (+82°C in Scotland) and be kept above +63°C.

There is a time element in which food can be left out of temperature control for the purpose of food service for one occasion only:

• Hot foods can be kept below 63°C for a maximum of two hours;
• Chilled foods can be kept above 8°C for a maximum of four hours.

Cross-contamination

Cross-contamination is one of the major causes of food poisoning in this country. It is the transfer of bacteria from foods (usually raw) to other foods. The bacteria can be transferred directly, when one food touches another, or indirectly via hands, equipment, work surfaces, knives or other utensils.

It is very easy for cross-contamination to happen. Some of the most common causes are:

• Storing raw and ready to eat food together;
• Storing raw food above ready to eat food;
• Not washing hands after touching raw food;
• Using the same utensils (chopping boards, knives) for raw and ready to eat food.

Training

Part of the Law requires all food handlers be trained in food hygiene matters. The simplest way to achieve this is for all those who prepare and/or handle food, to do the Basic Food Hygiene Certificate, either via the local EHO, or the local College of Further Education.

In the provision of food to the public the provider must be able to demonstrate that every reasonable care has been taken. This is called Due Diligence. The only way Due Diligence can be proved in a court of Law is by monitoring and recording practice, and if necessary supplying the proof as evidence in defence that the regulations are being applied.

How do we know the refrigerator is operating at 8°C? – the temperature was taken, recorded, and kept.

How do we know the sausage rolls were served at +63°C? – the temperature was taken at service time, recorded and kept.

Remember your local EHO will be only too pleased to help and advise in proper practice and what records should be kept and for how long.

Useful address:

Food Standards Agency, Aviation House, 125 Kingsway, London WC2B 6NH. Web site is: www.food.gov.uk.

In conclusion

It would be difficult for specific advice to be given as no two local assemblies are the same, have the same facilities or the same catering requirements. Some assemblies have a ministry of outreach through food. Other assemblies only provide tea once a year at conference time, and others for monthly meetings.

Advice should therefore be sought. Before this is done, make a list of the questions you want answered. The list below might, I hope, help:

• Contact the local EHO and invite him to the assembly meeting place. Explain what catering is done, or envisaged to be provided. Ask your questions. Act on the advice given. EHO’s will usually classify church catering as fairly low on the risk scale as long as the above is followed. However it is dependent on frequency and type of food served (e.g., hot meals, compared to coffee and biscuits).
• Get some thermometers. A probe thermometer for checking the temperature of hot food, and a refrigerator thermometer for any refrigerators. Record the temperatures of any hot food served (see above) and of the refrigerator.
• If necessary keep separate chopping boards (different colours) for raw food, raw vegetables, ready to eat foods. This will help to reduce the risk of crosscontamination. This is of particular importance for assemblies that cook on site.
• If you cook food or do a lot of preparation you will also require a double sink for washing equipment and a separate sink for hand washing with soap, hot and cold running water and a means of drying hands, ideally paper towels.
• Do not make sandwiches, cut pies, or leave sausage rolls, etc. out in the morning for a late afternoon tea. This does not apply to cakes, scones, biscuits, and tray bakes etc.
• Food served cold must be kept cold for as long as possible. Bring it to the meeting place as near to service as is practicable – remember the four-hour rule above. (If a conference tea is to be served between 5-6 pm, and the conference starts at 3:30 pm, then the food should stay under refrigeration till 2 pm at least, later if possible.
• When buying ready to eat food (high risk food), buy the longest possible shelf life; keep it sealed until preparation time. Once prepared (e.g. into sandwiches), keep under temperature control.
• Wear protective clothing, a clean apron will do.
• If possible use disposable plates, cutlery and cups, practically it saves with the washing up and the requirements for sterilising by hand, and the difficulties that come with it.