The dramatic increase in the number of pubs offering food over the past decade has given local authority Environmental Health Officers - EHOs - increased involvement with the pub trade.
The Food Safety Regulations 1995, which is the main legislation covering the storage, preparation, handling and serving of food in pubs, made enforcing the law the responsibility of local authorities. This has given EHOs a reputation for fierceness which is probably undeserved - at least in most cases.
Everyone recognises that food safety is important, and no pub is in the business of endangering its customers' health. Where problems have arisen it has often been due to different interpretations of the law by different authorities which has made it difficult to give definitive advice to pubs.
Stuart Kelly, a former EHO who is now operations manager for hygiene consultants RisCo, said: "We often find that people are baffled by regulations and are not sure how much they need to do to comply.
"For pubs offering a limited food menu there is probably no need for a huge and complex system, so don't go over the top. It's all about knowing your needs and interpreting the regulations appropriately."
The situation should improve from April 1 2001, when a common standard of enforcement will be introduced for all local authorities. As guidance only, Kelly suggests the following 10 steps in order to be ready for a visit from the EHO:
Take control - appoint a member of staff who understands and is prepared to oversee health and safety and food hygiene issues.Training - establish regular training to ensure staff understand what they need to do and how, where and when.Due diligence -- time of food storage and cooking temperatures should be checked and recorded at regular intervals.Risk assessment - health and safety hazards should be identified and recorded, the risks evaluated and control measures implemented. Manual handling - hazardous manual handling operations should be identified and safe procedures introduced. Staff should be trained in the correct techniques.Hazardous substances - Catering operations must adhere to COSHH (Control of Substances Hazardous to Health) requirements wherever substances deemed hazardous are used. This might include gas in the cellar and cleaning materials in the kitchen. Pubs should carry out COSHH assessments on all potentially hazardous substances. Where it is not possible to prevent exposure, steps should be taken to control exposure to them.Slips, trips and falls - staff should understand the common causes of these kinds of accidents and know what to do if they occur.Accident book - all premises must have an accident book to record staff accidents. Serious accidents should be reported to an EHO immediately.Records - keep records of all checks, training and routine reviews that are carried out, including details of corrective actions.Ask - if you are unsure about any of your obligations ask your local Environmental Health Department or contact a specialist.
HACCP, or Hazard Analysis and Critical Control Point, is a requirement introduced under the 1995 legislation for all food businesses. Behind this fearsome set of initials is a legal requirement to assess your business, identify any areas of risk, and ensure that suitable controls are in place. In a pub, that means you should:
Look at your food operation - from collection, transport and delivery, via procedures for storing food, preparation and cooking through to storage and serving.Identify any hazards - problems which may arise - during these procedures which could potentially harm your customers.Ensure you have the necessary controls in places, and that these controls are always maintained.
There is currently no legal obligation for staff to receive formal training under the existing food hygiene regulations. The law actually says that employees working in food businesses must be "supervised and instructed and/or trained in food hygiene".
This reflects the reality that newly employed staff are often likely to be handling food and dealing with customers before they are given full training. The law, therefore, places a responsibility on employers from the beginning to ensure that employees are properly supervised.
It makes sense to provide formal training for new staff as soon as possible. The best known entry-level qualification is the Basic Food Hygiene Certificate from the Chartered Institute of Environmental Health (CIEH).
This is widely available through colleges, local authorities and other training organisations, and aims to ensure that anyone working in a business handling food meets the training requirements of the Food Safety (General Food Hygiene) Regulations 1995, as well as being able to understand the practical procedures and methods of applying food hygiene in the workplace.
Food safety issues are rarely out of the headlines, with the recent foot and mouth outbreak following a whole range of scares such as BSE, salmonella and listeria, and concern over GM crops. The press interest is understandable, reflecting public concerns about the way in which farming and food production can affect the food we eat.
For pubs, dealing with these issue means following the same hazard control procedures outlined above. In the event of a problem, you would need to be able to show that you observed due diligence not just by storing and preparing food correctly, but also by sourcing it properly.
In the case of possible food contamination, showing receipts for products sourced from a reputable supplier would be a lot more convincing a defence than a side of pork or salmon bought over the bar from the local poacher.
Since 1999, pubs, in common with other catering operations, are required to state on menus whether dishes contain GM products. However, it seems that as much as 30 per cent of the trade is breaking the law.
In a survey of pubs carried out for The Publican Newspaper's Market Report, it emerged that 70 per cent of menus in managed houses are complying with the law but tenanted pubs are less likely to do so.Forty-nine per cent of licensees said their pub menu did not comply with GM food laws because there was no demand from customers.
Publicans can give a generic statement to the effect of "some dishes may contain GM products - staff will be able to advise". However, all staff must be briefed to answer such questions.
At this time of year, any pub with a garden will be starting to think about ways of maximising the profit potential of the extra space, at least for however long the British weather decides to behave itself.
However, responsibility for food hygiene extends into the garden, and food served outside carries with it particular risks. Publicans will need to consider the following:
Should you offer table service? Food left standing in the sun for customers to collect is an obvious hygiene risk, as are cutlery and condiments left outside.Outside tables and chairs should be cleaned frequently.If necessary, designate a particular area of the garden for eating, which can be easily accessed by kitchen and waiting staffCollect empty plates and glasses regularly.