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Module 4: Enforcement issues

Section 1: General advice for enforcement officers

This section gives general advice to food law enforcement officers on how to make sure food business operators understand the inherent hazards associated with vacuum packing and modified atmosphere packing as well as the control factors they should be using to prevent growth and toxin production by Clostridium botulinum in chilled foods.

General advice for enforcement officers

The key elements of FSA guidance

How should a food business operator establish the appropriate shelf-life for products with respect to Clostridium botulinum?

What food hygiene legislation is applicable to a business using vacuum packing and modified atmosphere packing?

How much information should be contained in a HACCP plan that covers vacuum packing and modified atmosphere packing?

Would a Safer food, better business (SFBB) approach to HACCP be appropriate?

What level of process validation might be appropriate for a HACCP plan?

Who is responsible for undertaking the validation process?

What steps should the local authority take to ensure that validation is carried out correctly?

What action can the local authority take if evidence of the validation process is not provided?

How should the local authority satisfy itself as to whether a business is appropriately applying a shelf-life of more than ten days?

What further investigation or action might be necessary?

What should the local authority do if a business continues to apply a shelf-life of more than ten days without supporting evidence?

What should the local authority do if, contrary to advice, a business continues to apply a shelf-life more than ten days?

Under what circumstances might a local authority consider the use of a hygiene emergency prohibition notice?

A business uses vacuum packing and modified atmosphere packing for chilled foods but doesn't appear to understand the associated inherent hazards. What should the local authority do?

Do all vacuum packed and modified atmosphere packed products present the same inherent risk?

A business is repacking products. What should the local authority do to satisfy itself that this activity is ‘safe’ and appropriate?

What is the Agency's advice on the dual use of equipment for raw and ready-to-eat foods, and the cleaning of that equipment?

Under no circumstances should it be considered safe to use the same complex equipment, such as vacuum packing machines, slicers and mincers, for both raw and ready-to-eat foods.

The Agency has produced guidance, ‘E. coli O157: Control of Cross-Contamination – Guidance for food business operators and enforcement authorities’, that details the steps that food businesses need to take to control cross-contamination between raw foods and ready-to-eat foods where E. coli O157 is a hazard. The guidance includes advice on the dual use of equipment and machinery (including vacuum packing machinery), cleaning and disinfection procedures, and additional disinfection considerations for equipment and machinery, including vacuum packing machines.

The Agency’s advice is that there is a major risk of cross-contamination where the same item of equipment, such as vacuum packers, slicing machines and mincers, are used to process raw food and ready-to-eat food. E. coli O157 may contaminate the food contact surfaces of such equipment after use with raw foods. This contamination may not be adequately removed during the cleaning and disinfection process, which can result in any ready-to-eat foods, subsequently processed with the equipment, becoming contaminated.

The Agency’s guidance states that:

'Under no circumstances should it be considered safe to use the same complex equipment, such as vacuum packing machines, slicers and mincers, for both raw and ready-to-eat foods. Where, for example, vacuum packing of ready-to-eat foods is carried out, the vacuum packing machine for this purpose should be located in a designated clean area where there is no risk from cross-contamination via splashes, hands, clothing, packaging or other equipment, and should never be used for packing raw foods. Dual use of complex equipment for raw and ready-to-eat foods should never be regarded as a safe practice.'

The following is guidance on cleaning and disinfection of vacuum packing machines, and other machinery and equipment:

  • Chemical disinfection – effective cleaning must use a combination of physical cleaning, i.e. using a detergent to physically remove all visible dirt, food debris, solids and grease from surfaces followed by a disinfectant used at the correct temperature, contact time and dilution. If a sanitiser is employed, it must be used in both stages of the cleaning and disinfection process, i.e. in general cleaning, to provide a clean surface, and then again to disinfect the surface. Single use of a sanitiser is not sufficiently effective to ensure thorough disinfection to microbiologically safe standards.

    There are two officially recognised laboratory standards for assessing the effectiveness of disinfectants and sanitisers against a range of microorganisms.
    These are BS EN 1276:2009 (or its predecessor BS EN 1276:1997) and BS EN 13697:2001. These standards demonstrate that a disinfectant is capable of reducing the levels of a range of bacteria, including E. coli, under a set of specified conditions (e.g. at a particular temperature, dilution and contact time).
  • Non-chemical disinfection – the application of heat (thermal disinfection) is one of the most reliable ways of killing bacteria such as E. coli O157, but is not always practical, particularly in small food businesses. Where heat disinfection is being used, food businesses should ensure that the temperature and contact time is sufficient to destroy harmful bacteria. For instance, in certain non-retail establishments that require approval (such as meat cutting establishments), a water temperature of 82°C is legally required for the disinfection of tools (see Annex III, Section I, chapter II para 3 of Regulation (EC) No 853/2004).

The above guidance is suitable for smooth surfaces in good condition that can be fully inspected to ensure that they are visibly clean.

An additional disinfection consideration for all food equipment and machinery is that they should be hygienically designed.

Machinery supplied in 1995, or any time after that, for use at work should be CE marked to indicate that it was designed to comply with the European Machinery Directive. This includes requirements for hygienic design. Detailed guidance on hygienic design requirements of the Machinery Directive can be found in BS EN 1672-2:2005+A1:2009 Food Processing Machinery-Basic Concepts Part 2: Hygiene Requirements, BSI.

Additional requirements for some particular types of food machinery and packaging machinery are set out in more specific standards. Lists of type-specific standards are available for:

Further advice

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