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Retail Member Stores & Sandwich Bars
Soloist Member Stores & Sandwich Bars
EVENTS
British Sandwich Designer of the Year
SANDWICH INDUSTRY
Code of Practice and Minimum Standards for Sandwich Manufacturers (Producers)
(Revised August 2007)
Introduction
The following Code of Practice has been established by The British Sandwich Association as a guideline to the standards it expects Approved Sandwich Producer Members to meet in order to qualify for the right to display the BSA quality symbol.
Sandwich Producer members are defined for the purposes of this Code as those businesses that manufacture packaged sandwiches for sale by third party outlets. Separate guidelines are provided for sandwich bar operators and retailers.
Those achieving Approved Sandwich Producer Member status are required to:
- Sign a copy of this Code of Practice, undertaking to comply with its requirements and to remove any BSA symbol from product or display within five working days should they cease to satisfy BSA Standards or other membership requirements;
- Undertake to accept inspection at any time, and without prior notice, by BSA inspectors or agents appointed by the BSA to undertake inspection;
Where a member is not found to be complying with the BSA Standards of requirements, the BSA will provide written notice to that member either giving a set time to comply or withdrawing membership, according to the risk assessment of the situation. In such circumstances, Provisional Membership may be granted for a limited time, and generally for no longer than six months, during which time compliance must be achieved (See Minimum Standards below). Subsequently the action taken by the Association will depend on the member’s reaction.
Loss of membership status will also apply if a member in any way draws the BSA or its symbol into disrepute or, in anyway, undermines the reputation of the Association or any of its members.
NOTE: While members’ are entitled to reproduce the BSA Symbol on packs, this does not entitle retail outlets to display the BSA Symbol other than in direct relation to those products. This means that retail outlets stocking products other than from BSA Approved Producers can only display the logo in direct relation to those products carrying the BSA symbol. Producers are responsible for ensuring that this rule is followed by retail customers.
Retail outlets selling branded products supplied “exclusively” by BSA Approved Producers, may, however, apply for retail approval which will entitle them to display the BSA symbol on windows and promotional material.
The BSA will also support branded own-label products retailed through multiple retail outlets, where these are produced by suppliers approved by the BSA and where retailers, or producers, register such brands with the Association.
(Note: The Standard set out in this Code may be subject to variation at any time by the British Sandwich Association. In the event of changes being made to the Code, written notice will be circulated to members and time provided for members to comply with such changes. This time will be a minimum of 28 days.)
Definition of Terms
GMP (Good Manufacturing Practice): The manufacturing and control procedures and disciplines aimed at ensuring that products are consistently made to specification.
RAW MATERIALS: All materials or ingredients, including packaging, used to make products, such as bread, meat, poultry, fish, eggs, vegetables and dairy products.
WORK IN PROGRESS: Materials or Component mixes that are in current use to make products. If partially used, then the unused balance is stored for future use.
HIGH RISK FOOD: A product intended for consumption, either cold or reheated but without further cooking. It is capable of supporting pathogenic, bacterial growth and, if contaminated, has a definite potential for causing food poisoning.
HIGH RISK AREAS: Areas to produce High Risk foods that are physically segregated and designed to a high standard of hygiene and cleanliness. Where operating practices relating to personnel, product and production are controlled to minimise contamination of the product either internally or from external sources.
HACCP (Hazard Analysis Critical Control Point): A systematic approach to identify and assess hazards and risks associated with all stages of a food operation and to define the means for their control.
Minimum Standards
To gain BSA Accreditation, all operators must comply with the minimum standards set down by the Association in terms of food safety. These minimum standards are generally those set out in NORMAL TYPE in this Code. However, the Association encourages all operators to meet the full standards set down by the Code, including additional recommendations set out in ITALIC. Larger manufacturers, whose operations may represent greater risk because of scale, will generally be expected to exceed the minimum standard. This differentiation is accepted within the legal interpretation of food safety legislation.
Provisional Membership
Where it feels appropriate the Association may grant Provisional Membership to applicants. This will usually be in circumstances where minimal work is required to fully comply with BSA Accreditation Standards and the manufacturer will generally be given a timescale within which to comply. Provisional Membership can only apply for a maximum of six months after which businesses must re-apply for membership. Provisional membership may also be granted to existing members in situations where the Association's inspectors require actions to be taken to maintain compliance.
NOTE: While this Code provides the guidelines for BSA Accreditation, the Association's accreditation scheme also assesses broader issues, such as management policy and commitment, and whether this leads to a satisfactory level of competence, responsibility and accountability.
Factory
This section is concerned with factory structure, layout and the general working environment and conditions of the operation.
A factory must be a bona fide manufacturing unit and must comply with all the requirements of current Government food safety and hygiene regulations, in particular the Food Safety Act (1990) and Food Safety (General Food Hygiene) Regulations 1995. The factory must be registered with the local Environmental Health Office and the business must comply with all current legislation, including laws relating to Health & Safety, Employment, and Trading Standards.
Factory - Exterior
a) The external areas must be kept tidy and free from accumulations of rubbish, redundant equipment/pallets and any other obsolete items that could provide a harbourage for pests. Grass, bushes and other areas should be cut back for tidiness and to avoid pest harbourage.
Site boundaries should be clearly defined.
b) Equipment or other materials which have to be stored must be adequately covered and stacked tidily.
c) There must be facilities for the disposal of waste and bins or skips must be kept covered.
d) The waste disposal area must be located away from entrances/exits and production areas. It must also be kept clean and disinfected regularly. A written cleaning schedule must be available for inspection.
Factory - Design
a) Factories must be designed to allow a linear flow of raw material to finished product from one end to the other.
b) The flow line must be clearly defined and points of cross flow must be assessed for potential contamination or hazard and, if possible, eliminated.
c) High Risk areas must be physically separated from Low Risk areas. Preferably these areas should be in separate rooms.
However, in small open plan factories where this is not possible, partitions must be used to segregate activities in order to minimise the risk of cross contamination or these activities separately phased with clean down/disinfection in between.
d) Any cooking of raw materials must be in an independent area and the operation must follow the hygiene and safety disciplines for High and Low Risk control and have an effective extraction system. Cross-contamination risks and temperature implications dictate that cooking must not take place in the sandwich making area.
Factory - Construction
a) Buildings must be of sound structure and repair, and be built to prevent easy access by pests.
b) Floors, walls and ceilings must be sealed and have smooth, impervious, easily washable surfaces. No obvious cracks or other damage to surfaces must exist where bacteriological or other harmful growth could occur.
c) Floor, wall and ceiling junctions should be coved to facilitate cleaning, except for suspended ceilings where this may not be practical.
d) Floors should be sloped to drains to avoid the formation of static, water pools. Drains/gullies must be designed with traps and with grids for easy removal and cleaning. Drainage flow must be away from High Risk areas.
e) Externally opening windows in, or close to, production areas must have effective fly screening. Preferably there should be no windows in production areas but, if so, they must be made from acrylic materials, or, if glass, covered with shatterproof film. Window sills should be sloped.
f) Doors must be tight fitting and together with other service entry or exit points must be adequately pest proofed. External doors opening directly into production areas should be avoided but, where they exist, they must be protected by screens or strip curtains and should be self-closing.
Factory - Environment/Services
a) Adequate ventilation and extraction systems must be in place.
b) For High Risk operations, ventilation systems should include air passing through high efficiency filter systems (to 0.5µ, conforming to BS 5295 Specification) and should maintain positive pressure within the areas.
c) Adequate artificial lighting must be provided in all inspection, manufacturing and packing areas. Where fluorescent type lighting is provided, tubes must be of the shatterproof type or protected by a shatterproof cover/diffuser.
d) Noise levels must not be excessive and disrupt working environment.
e) Good temperature control is essential for High Risk foods and temperatures in production areas must not exceed 12oC. Employees must be provided with suitable warm clothing.
f) For perishable raw materials and finished product, a chill storage temperature range of 0-5oC is recommended.
g) Services must be installed so that they do not cause problems for good housekeeping or hygiene. For example, overhead pipe-work should be accessible for cleaning, ends of ducting should be capped/sealed, and passages through walls should be sealed.
h) Water, steam and ice for use in contact with food must be from potable water - if water tanks are used, they must be covered, regularly inspected and cleaned. Water/ice should be regularly analysed to ensure it is of potable quality.
i) If non-potable water is used for refrigeration, steam generation or other purposes, it must be in a separate system. Such systems must be clearly differentiated, by appropriate marking, from systems using potable water.
j) Prior to use, compressed air should pass through a filtration system which is kept in a clean, hygienic condition.
Factory - Equipment
a) Equipment must be designed and laid out for ease of cleaning and production efficiency as well as safe operation. Good health and safety practices should be observed. A system of planned maintenance covering all key pieces of equipment critical to product safety, quality and legality must be in place.
b) Plant must be kept in good condition, free from rust, flaking paint or excess oil/grease or other lubricants. Paint and lubricants must be approved for use in food manufacturing areas.
c) Refrigeration equipment must be maintained. Catch trays to remove condensate drip during defrost cycles should preferably be removable for cleaning and condensate should be piped into the nearest main drain point.
d) Redundant machinery should be kept away from production areas.
Factory - High Risk Production Areas
a) This must be an area that is physically segregated, maintained to a high level of cleanliness and sanitation where operating practices, including personnel, materials, equipment and environment are controlled to minimise product contamination. Typical examples of High Risk areas are sandwich materials make-up and sandwich production.
b) High Risk areas must include essential services and facilities (eg. wash-up and cleaning) and only essential materials and equipment must be allowed access.
c) Outer wrappings must be removed from raw materials prior to entry and only fully processed or disinfected food components (and inner packaging) admitted, with entry through hatches or other dedicated openings.
d) Surfaces must be constructed of water impervious, easily cleaned materials and equipment hygienically designed to avoid contamination. Wood is prohibited.
e) Personnel must enter high risk areas through a specially designated changing facility and must follow appropriate specified procedures for changing, donning visually distinctive clean overalls, head and footwear and observing GMP in relation to handwashing.
f) There must be thorough cleaning and disinfection according to a laid down programme but the area must be kept as dry as possible.
g) Drainage flow must be from High Risk to Low Risk areas.
h) A temperature of 12oC or less must be maintained.
i) Chill rooms for materials awaiting packing must form part of this High Risk area.
Factory - Packaging
a) Cardboard should be avoided for packaging use and any packaging or materials delivered in cardboard outers should be removed in a de-boxing area before entering production areas. Where appropriate, polythene liners should be used.
b) Cardboard must be prohibited from sandwich production areas.
c) Sandwiches for general sale must be packed in tamper evident sandwich packs. All hinged containers must be sealed with a label so they are tamper evident.
d) All sandwiches should be stored at recommended chill temperatures 0-5oC, soon after packing.
e) Packaging must be clearly labelled with the product description, use by date and storage requirements.
Factory - Storage
a) Raw materials must be stored separately from ready-to-use materials/mixes or finished product. Where appropriate, containers should be covered or lidded.
b) There should be separate chill storage areas for incoming perishable raw materials, work-in-progress, High Risk materials and finished product, respectively.
c) Air storage temperatures must reflect the best conditions to suit the product.
The following recommended low temperature storage should be observed:
Refrigeration/chill temperature 0 - 5oC
Freezer minus 18°C
d) Stored products should be kept off the floor and 45cm away from walls to facilitate cleaning and pest bait inspection.
e) Separate storage areas must be provided for non food chemicals.
f) Where external storage is necessary, items must be protected from contamination and deterioration, subject to temperature controls if applicable and be adequately protected against pests.
Factory - Transport
a) Products should be transported under refrigerated conditions and delivered at recommended 5oC. Where 3rd Party Distributors are used these must be approved, with appropriate checks having been made.
b) Deliveries must be made in dedicated refrigerated vehicles. Vehicles with Eutectic plates are generally unacceptable. Cold boxes may only be accepted where they are being used for one-stop bulk deliveries, are unopened from point-of-fill to delivery and where delivery takes place within a timescale where product temperatures will not rise above the accepted limit.
c) Distribution vehicles must be kept clean and the internal storage areas must be regularly disinfected as part of the cleaning schedule.
Production Controls
This section includes production systems and techniques to control key areas relating to food safety aspects, whether physical or microbiological, and quality.
Production - Raw Materials General
a) The producer has a responsibility, under current food safety legislation, to procure safe, sound raw materials.
b) This will involve suitable checks of suppliers to ensure that they maintain appropriate standards and may necessitate sending out supplier self assessments and undertaking inspections of suppliers’ premises/facilities. Generally, letters of warranty from suppliers are insufficient guarantees to satisfy legal compliance.
c) Materials should be purchased from bona fide companies who introduce Good Manufacturing Practice (GMP) and control, preferably those with BSA approval. All materials should be purchased off an Approved Supplier List. Raw materials, intermediate products and packaging should be bought to an agreed specification ensuring compliance to safety and legislative requirements. Where appropriate specifications should be signed by relevant parties. A system of specification review should be in place.
d) Deliveries of raw materials should be tested against the specification standards on arrival and, where appropriate, certificates of analysis should accompany the consignments. Records should be maintained of all tests.
e) All packed products received must be labelled with an appropriate ‘Use by’ or ‘Best Before’ date which must be complied with.
f) Raw materials should be stored under appropriate conditions soon after arrival, and not left outside or uncovered, particular attention being paid to temperature sensitive foods. Good stock rotation must be exercised.
g) Producers must maintain records, registering the actions taken to approve the supplier and records of deliveries.
Production - Raw Materials Specific
Bread
a) All bread must be delivered in suitable containers and/or packaging to avoid cross contamination. Packaging should carry the date of production.
b) Bread should be decanted into High Risk trays and bread trays should be wiped with a sanitised cloth before entry to the sandwich room and, if used for sandwich despatch, should be cleaned and sanitised before being passed back.
Fresh Vegetables and Fruit
a) All vegetables and fruit should preferably be purchased daily and stored in a raw food area upon receipt. The age from picking/preparation should be known.
b) They must be prepared - pre-washed if appropriate - and disinfected in a separate area (Low Risk) before being passed into High Risk.
c) The disinfectant to be used for most salad vegetables (including peeled onions) and fruit is a solution containing 150-250ppm available chlorine. Concentrations should be monitored.
d) The raw products should be immersed (i.e. depressed under the surface) for a minimum three minutes and then thoroughly drained before use.
e) The solutions must be changed for every treatment or as necessary to maintain the required chlorine concentration, which must be regularly checked.
Materials in Cans/Bags/Plastic Containers
a) Containers must be cleaned and dipped in disinfectant solution (containing 100ppm available chlorine) or wiped with a sanitised cloth before being passed into a High Risk area for storage and/or opening.
b) Canned and other products containing liquid must be opened in a suitable area with facilities for decanting/sieving and removal of the liquor.
Materials Chilled/Frozen (e.g. Meat, poultry, fish, eggs, dairy)
a) Chilled products should be delivered at recommended temperature maximum 5oC (product temperature) in refrigerated vehicles and frozen goods in freezer vehicles, at maximum -18oC (product temperature).
b) The vehicle and product temperatures must be checked before the delivery is accepted and results recorded.
c) Stock must be transferred to chilled or frozen storage quickly and not left at ambient temperature for any period of time.
d) Frozen product must be thawed under controlled conditions, preferably in a chiller in the High Risk area or in a separate position from other chilled products.
e) Once the thawing cycle has commenced, the products must not be refrozen.
f) All whole eggs must be purchased pre-boiled from an approved supplier.. Raw eggs must not be used.
g) Mayonnaise either made in-house or bought in must not contain raw egg.
Production Traceability/Coding
a) All raw materials, work in progress and finished products must be traceable during the production, processing, storage, despatch and distribution stages.
b) It is recommended that these materials be given a code, or number, which can be logged and identified throughout their production use, in addition to a ‘use by’ or ‘best before’ code.
c) Materials in progress must be coded, preferably with a Use-by date to facilitate stock rotation and compliance with safe shelf-life.
d) Documentation must be in place so that in the event of a problem with product it can be traced back to the date of production, the raw materials used and their origins can be identified for investigation.
e) Finished product must always be coded with a Use-by date.
f) A documented product recall procedure which can be operated at any time and which is regularly tested must be in place.
Production - Foreign Matter
a) Systems should be in place to remove foreign matter contamination. For example, visual inspection of materials and, if appropriate, sieving of dry powdered ingredients.
b) It should be the aim to prohibit the use of glass within the factory but, if this is not entirely possible in practice, then a log of all glass items should be made and a regular audit carried out to observe any breakage. A written glass breakage action procedure should be in place.
c) Producers are recommended to install metal detection equipment after sealing. Hourly checking of the rejection mechanisms with the appropriate test pieces for ferrous and non-ferrous metal must be carried out and the results logged.
Production - Housekeeping and Cleaning
a) A ‘clean as you go policy’ should be adopted. This must involve regular housekeeping and surface cleaning to avoid gross build up of residues and waste, supplemented by deeper cleaning and disinfection.
b) The cleaning must be carried out according to a programme/schedule which includes structure such as walls, floors and ceilings, overheads, equipment (including service equipment such as refrigeration and ventilation), and utensils.
c) This programme must cover items to be cleaned according to a frequency pattern related to risk. The programme must specify cleaning activity to take place during breaks in production and at the end of shifts.
d) Cleaning chemicals must be approved for use in the food industry and must be suitable for the purpose according to the manufacturer's recommendations. They should include both detergents and disinfectants.
e) Cleaning chemicals usage must comply with COSHH regulations so that containers are clearly labelled, adequately sealed and stored in a lockable situation away from food.
f) Cleaning chemicals must be dispensed by an appointed person and only sufficient quantities kept in secure locations in production areas for use during the shift.
g) Cleaning must be carried out by personnel adequately trained for the job. More difficult cleaning tasks must be tackled by specialists, for example, heavy machinery and high overheads.
h) Only disposable cloths or wipes must be used and other utensils (such as brooms or squeegees) must be cleaned and disinfected after use and kept off the floor until subsequent use. Colour coding of utensils for the various cleaning activities is recommended.
No wooden handled tools or dish cloth type materials should be used.
i) Cleaned and disinfected utensils, containers and equipment must be stored away from those awaiting cleaning and must not pass through areas where re-contamination could occur.
j) Hoses/pressure washers should be used with care and stored off the floor on reel holders or hooks. High water pressure is not recommended as this can produce ‘aerosols’ which spread contamination.
There must be provision for a hot water supply.
k) Cleaning must be monitored both visually and microbiologically, either using conventional swab techniques or approved rapid assessment techniques.
l) Visual monitoring of factory areas must be carried out just prior to production and particularly to assess cleanliness of food contact surfaces and equipment.
Production - Pests
a) There must be an effective programme for the control of pests based on a prevention approach. This is a highly specialised field and is best carried out by persons experienced in the treatment necessary to counter infestation by insects, rodents, birds and other pests.
It is recommended that pest control contractors used should be members of the British Pest Control Association.
b) Risks from adjoining premises must be assessed and rodent baits laid at the location interface, where appropriate.
c) All doors and windows should be close fitting, with no obvious gaps for pest access.
d) Where practical, external doors should be adequately screened and protected with strip curtains. Bristle or plastic strips should be fitted where necessary to cover smaller openings.
c) All openings into main production areas must be screened and all windows, if external, must be fly screened.
f) Production and ambient storage areas must be protected by suitable fly killers with catch trays or other means for catching insects.
g) The fly killer units should be sited at entry points and never directly over areas where food is handled or packed.
h) The units must be switched on constantly and the tubes encased and replaced annually.
i) A site plan of numbered rodent bait points must be available and baits should be laid in ancillary areas around, but not within, the main production areas. Loose grain baits must not be used.
The location of insect pheromone trays should also be known.
j) The control scheme must cover service plant and waste storage areas.
k) An on-site record must be kept of the on going situation, the treatments and follow up action by all concerned.
Personnel
This section is concerned with staff behaviour in the workplace and the facilities associated with good personal hygiene and staff welfare.
Personnel must be trained for their work tasks and must adopt appropriate hygiene practices and safety disciplines to keep product risks to a minimum.
Personnel - Flow
a) Staff and visitors to production areas must enter the factory by a specific entrance leading to dedicated changing areas/rooms. Visitors may use offices for this purpose.
b) They must first remove external clothing in a separate area/room and store it, together with personal belongings, preferably in lockers.
c) Staff must then proceed to dedicated High or Low Risk changing areas/rooms which connect directly to their relevant work areas.
d) The change into protective headwear and clothing, together with washing of hands, must take place before entry to these areas.
Personnel - Hygiene
a) All personnel involved with the preparation and production of sandwiches must strictly observe the principles and practices of good hygiene.
b) Clean protective headwear and clothing must be worn in production areas by staff and visitors. Coats must be without button fastenings or outside pockets and hats should include a hair net to cover the hair completely.
c) Protective clothing must not be worn outside production areas (e.g. rest rooms) or outside the factory.
d) Protective footwear (dedicated to High Risk areas) or overshoes should be used. High-heeled shoes must be avoided.
Footbath and /boot washers can be contaminated by bacteria unless regularly cleaned and boot washing by cleaning staff is preferred.
e) The changing procedure for staff or visitors entering High Risk areas should be:
- Remove Low Risk clothing, if relevant. Put on mob cap.
- Remove shoes, swing over bench onto high risk side, put on protective footwear or overshoes.
- Wash hands (using nail brush if appropriate) with anti bactericidal soap, drying with paper towels.
- Put on protective clothing.
- Wash hands and use a hand disinfectant.
- Put on disposable gloves, if required
- Enter High Risk
f) Personnel moving out of High Risk areas must wash hands and remove protective clothes.
g) A daily change is required for High Risk workers and at least three times a week for Low Risk workers. High and low risk clothes should be stored separately.
(This frequency may be increased if clothing becomes soiled more quickly.)
Different coloured clothing for the different risk categories is strongly recommended.
h) Protective coats/overalls must be laundered by external laundry services and not by staff. High Risk clothing should be handled and laundered separately and the external laundry approved for cleaning food factory garments.
i) Hand wash facilities must have taps operated by elbow, knee, foot or sensor systems and not by hand . Water should be premixed to a temperature of 45-50oC. Handwashing must be performed at appropriate intervals.
j) Dedicated hand-wash facilities must be provided in changing rooms, at appropriate entry points to production and in toilets. Nailbrushes and non-scented liquid bactericidal soap must be provided together with paper hand towels and waste towel bins which, preferably, are lidded and operated by foot pedals. Other towelling material or air-drying units must not be used.
k) Rubber or plastic gloves used in High Risk areas must be disposable and colour coded. They should be disposed of after each application/session and not used for multipurpose preparation. Hands should be washed before gloves are changed.
l) Other types of heavy-duty gloves used in production areas must be disinfected regularly and washed both internally and externally.
THE USE OF GLOVES DOES NOT AVOID THE NEED FOR HAND WASHING.
m) Personal jewellery (including watches, rings, chains, wrist bands/bangles, and earrings) must not be worn with the exception of plain wedding bands and ‘sleeper’ earrings.
n) Nail varnish, all other cosmetics or perfume/aftershave must not be used.
o) All cuts, sores or other skin abrasions must be covered with blue coloured waterproof dressing, containing a metal strip (if metal detectors are in use). Staff must not work in production areas if they have sceptic wounds.
p) There must be a reporting/recording system for any skin disorders/accidents. A reporting/recording system for accidents is a legal requirement.
q) Operatives must not cough or sneeze over food or touch the mouth, nose or hair when handling food.
r) Smoking, eating and drinking must be restricted to designated areas and never in production areas. Hands must be thoroughly washed afterwards.
s) Staff handling waste/refuse must wash hands thoroughly afterwards.
t) All staff must be made aware of these hygiene requirements either through induction for new employees or briefing sessions for existing employees.
Personnel - Hygiene Signs
a) Prominent signs must be displayed setting out required procedures at all points where Personal Hygiene Rules apply.
b) Procedures for entering and leaving high and Low Risk areas must be clearly displayed on signs, including protective clothing and hand washing requirements.
c) All restricted areas - such as High Risk - must be clearly signed and the restrictions displayed at the entrance.
d) Hand washing requirements must be displayed in all factory wash areas and toilets.
e) Signs prohibiting smoking and eating must be displayed in non permitted areas, including changing rooms and toilets.
Personnel - Toilets
a) Toilets must be provided within the requirements of appropriate legislation, they must not open directly into production, packaging or storage areas.
b) They must have hand-washing facilities and be separated from the process areas by a lobby.
c) They must be adequately ventilated and must be supplied with toilet paper. Hand-wash basins must be supplied with non-scented liquid bactericidal soap, nail brushes, disposable paper towels and waste towel bins.
d) Toilets must be cleaned and disinfected daily.
e) Personnel must not enter toilets wearing protective clothing.
f) Toilets shared with other businesses are to be avoided. If this is the case, then the producer must be responsible for cleaning and maintaining the area.
g) Smoking, eating or drinking are not permitted in toilets and must only take place in designated areas.
Personnel - Canteen/Rest Room
a) Employees must take breaks and meals away from production and storage areas; a suitable canteen/restroom must be provided. Protective clothing must not be worn in any canteen or rest rooms.
b) Eating, drinking and smoking must not be allowed in any production area or toilets/cloakroom areas.
c) If vending machines are employed, then these must be serviced and cleaned as appropriate.
d) If meals are prepared, good hygiene practices must be observed. Perishable foods brought in by staff must be kept in a refrigerator which should be regularly cleaned.
It is strongly recommended that different colour coded preparation boards are used for raw and cooked foods respectively and that separate fridges or distinct separation in one fridge is used for storing raw and cooked foods. If one fridge is used, cooked foods should always be stored above raw.
In practice, the canteen can be the most likely source of food poisoning outbreak among staff.
e) If a refrigerator is provided, temperatures in the refrigerator should be checked regularly.
f) If smoking is allowed, then ash trays should be provided and scraper mats used at the entrance.
g) Operatives must not be allowed to take their breaks outside the factory buildings without removing their protective clothing. When they re-enter, they must comply with the procedures applicable to personnel flow and hygiene.
Personnel - Training
a) All food handlers must undergo a course of training in basic food hygiene and safety. This must particularly apply to High Risk personnel.
b) There must be induction training for new employees with refresher training thereafter.
c) It is also recommended that managers and supervisors with food safety responsibilities undergo appropriate training.
d) Hygiene courses run by institutes such as the Chartered Institute of Environmental Health Officers (CIEHO), Royal Society of Health (RSH) and the Royal Institute of Public Health and Hygiene (RIPHH) are recommended.
e) Any training should be work-place and task specific as well as covering general principles of safe food handling.
e) Training records must be kept for all personnel concerned.
Personnel - Health
a) All new employees must complete a medical questionnaire. This should also apply to contractors/outside workers. It is advised that visitors should also complete a health questionnaire.
b) All employees must complete a medical questionnaire annually.
c) Operatives, contractors or visitors suffering from any infectious illness or infections must not be permitted to work in contact, or come into contact, with food. This applies to gastro-intestinal disorders, skin infections, nasal or ear discharges or boils.
d) There must be a procedure for medical screening of employees following gastro-intestinal disorders, especially on return from foreign visits.
e) All cases of food poisoning relating to food handlers must be reported to the local Environmental Health Officer as soon as they arise and to the BSA. Some infectious diseases, such as typhoid and smallpox, must also be reported.
Technology
This section covers technical systems and methods necessary to comply with legal requirements and BSA Standards. It uses the risk assessment approach to food safety (based on certain HACCP principles) which is now the basis of both EC and UK food hygiene legislation.
Technology - General
a) Control systems must be in place that enable the producer to manufacture safe, sound products that comply with all relevant food legislation and customer specifications.
b) Particular legislation that applies includes the Food Safety Act (1990), the Food Safety (General Food Hygiene) Regulations 1995, the Food Safety (Temperature Control) Regulations 1995, the Food Labelling Regulations 1996 and the Food Labelling (Amendment) Regulations 1996.
c) To take all reasonable precautions to avoid the commission of an offence, which is the underlying principle of any statutory defence of Due Diligence, control systems must specifically address all areas of activity, involving:-
- Raw Materials - including packaging and temperature control
- Production process - including temperature control
- Finished products - including specifications, recipe/labelling and compositional standards
- Trace-ability and shelf-life coding
- Packaging and storage - including temperature control
- Transport and distribution - including temperature control
- Hygiene of personnel, premises and plant
- Staff training
- Pest control and foreign matter
- Customer Complaints Monitoring
- Product recall
(NOTE: Refer to booklet on Guidelines on the Statutory Defence of Due Diligence, drawn up in collaboration by the National Consumer Council, LACOTS, the Institution of Environmental Health Officers, National Farmers Union, Retail Consortium and the Food and Drink Federation).
d) Where a company makes specific product claims (e.g. nutritional) analytical checks, including independent analysis, should be carried out as part of the company's due diligence defence.
e) The control results, and any subsequent reaction, must be clearly recorded on specific documents that are co-ordinated to cover the total operation from raw materials to finished product.
f) Records must be available for inspection at any time during audits.
g) It is strongly recommended that staff are employed who have a depth of knowledge and experience of the technical issues involved in sandwich production. Such staff should be given the responsibility for implementing technical systems and for monitoring their effectiveness and practice.
GMOs
The Food Labelling (Amendment) Regulations 1999 introduced compulsory labelling of certain genetically modified (GM) foods by caterers and food manufacturers. They came into force on 19 March 1999 and respond to consumer concerns about the influx of GM foods, their safety and possible adverse effects on the environment. You are required to label foods that contain GM maize or soya, you do not have to label foods that are free from GM maize or soya ingredients. Indeed, because there are several exemptions from labelling for a number of additives or other ingredients from GM sources, caterers and manufacturers should be very careful about ‘GM’ free claims. Caterers have the same obligation as retailers of pre-packed foods to provide information about whether a food does or does not contain any GM maize or soya. A policy regarding the use of GM organisms should be in place.
Food Allergens
The term ‘food allergy’ describes an unusual sensitivity to a food which is harmless to most people. Customers need to know the exact ingredients of foods that they eat, for caterers it may mean the description on the menu or a customer may ask about the ingredients of a certain product, for manufacturers it means providing information on labels. If customers enquire about nuts and seeds you must take the question seriously, as their life could be at risk. Another food which has been cross contaminated with nut traces could also be potentially dangerous. Where nuts or materials of similar allergenic properties are handled there should be a system of segregation in storage, production and retail. At the present time there is no legal requirement to label food with allergen information but this is considered good practice, and is recommended by the BSA.
Technology - Process Control (HACCP)
This is a very important aspect of food safety
a) Safety controls should be applied using hazard analysis systems, such as HACCP.
b) The HACCP (HAZARD ANALYSIS CRITICAL CONTROL POINT) system, as part of the risk assessment requirement of the EC Hygiene of Foodstuffs Directive, is based on the following principles:-
- Analysing the potential food hazards in a food operation.
- Identifying the points in these operations where food hazards may occur.
- Deciding which of the points identified are critical to food safety.
- Identifying and implementing effective control and monitoring procedures at those critical points.
- Reviewing the above periodically and wherever operations in the business change.
c) The process is usually initiated with the formation of a multi-disciplinary team who draw up a detailed flow diagram of the process. This is followed by identifying the essential characteristics of the product and its use, which help determine the hazards which will threaten the consumer or product (or deviate from the agreed specification).
d) Each operation of the manufacturing process should then be assessed with respect to identifying any hazard for that stage. In this way, the critical stages in the process can be identified.
e) These points need to be controlled adequately and are, therefore, Critical Control Points (CCP's).
f) The various control options should then be considered and the most effective chosen and implemented. Their effectiveness can then be checked over a period of time.
g) The design of the system can be adapted to suit the particular circumstances and requirements of the company, but it must be backed by appropriate documentation and monitoring to verify any relevant corrective action taken. Records must be maintained.
h) Appropriate training of staff must be undertaken to fulfil their role in implementing the risk management system.
i) It is relevant to any size of company and the format can vary according to the particular needs and practicality for the situation. The scale and resources of the company will, to some degree, dictate the manner in which the system is drawn up and the various stages involved in its implementation. Within the scope of this flexibility, the essential principle remains that it is a systematic approach to quality and safety risk control.
(NOTE: Refer to Campden Technical Manual ‘HACCP - A Practical Guide’ 2nd Edition 1997)
Technology - Temperature Checking
a) Product temperatures are an essential factor, although they are necessarily interlinked with environment temperatures. Both measurements must be taken. The BSA recommends 5°C for chilled product temperature but it is the manufacturer's responsibility to work within the temperature regulations and to distribute sandwiches in a safe condition.
b) Temperatures should be monitored at least three times per shift or form part of the HACCP checklist. A standard form should be used for this purpose and records kept for at least six months.
c) Chill rooms must be equipped with accurate recording thermometers (± 0.5oC) . A damped probe or thermal stimulant should be considered for small chill rooms where frequent door openings are unavoidable.
d) Autographic recorders/controllers can be used and ideally equipment should be linked to give a central, digital read out of all chill areas.
e) An alarm system is recommended when temperatures exceed the maximum required.
f) If refrigeration equipment fails then product temperature must be checked and appropriate action taken if temperatures exceed the maximum tolerances.
g) Accurate manual thermometers (±0.5oC) must be used for product and also as an additional check against thermometer dials/gauges for the environment. Probes must be sanitised before and after insertion into product.
h) Delivery and despatch vehicles and their products should also be checked for temperature.
i) Temperature recording equipment should be regularly checked and calibrated. Manual thermometers must be checked at least every week for accuracy (e.g. in iced water). Self-calibration thermometers are recommended.
Technology - Microbiological Aspects
General
a) It is a requirement of the BSA accreditation that manufacturers undertake systematic microbiological analysis of their products by an appropriate laboratory. This should be accredited by a suitable authority (e.g. UKAS).
b) The analytical programme should include key High Risk raw materials, environment and equipment, and finished product.
c) It is important that a person is employed who understands the significance of the results and can react accordingly. Assistance from consultant laboratory microbiological experts should be sought in this respect and they should be required to provide action comments on the results obtained.
Sampling Plan
a) Producers must establish a sampling plan. It is recommended that this is done in consultation with their consultant laboratory microbiological experts.
b) Raw materials analysis should be concentrated on High Risk products, such as poultry and eggs.
c) An environmental swabbing programme should be used to check the microbiological effectiveness of the cleaning programme.
d) For final product, every main component/ingredient type should be tested at least every two months.
e) As a minimum, samples should include one of a meat, poultry, fish, cheese and egg variety. Additionally, the sample should include at least two sandwiches containing salads.
f) Samples must be delivered to the laboratory under chill conditions (<8oC) and the arrangements for the samples time/temperature conditions prior to analysis agreed with the microbiologist concerned.
g) Samples should be put under test at a time to match their declared 'Use-By' date coding.
Guidelines for Analytical Standards
a) The BSA guidelines for microbiological standards of finished product are based on counts per gram, unless otherwise stated, and are based on the condition of samples at use-by-date (production + 2 days).
b) The standards, which are considered achievable targets under Good Manufacturing Practice, are set out in the chart below. Note: Sandwiches containing cheese will invariably have higher TVC counts.
c) If higher counts occur than those recommended, then advice should be sought from the consultant microbiologist or the BSA.
d) High counts in individual samples are not necessarily a cause for major concern unless pathogens are involved but should, nevertheless, be investigated. Trends over a period of time are a more practical guide to microbiologically associated situations.
e) Producers should plot graphs on which microbiological results are recorded in order to establish and log trends.
Technical Control - Minimum Product Specifications
a) Sandwiches/rolls displaying the BSA logo must comply with all relevant legislation, including provisions in the Food Safety Act 1990, Food Safety (General Food Hygiene) Regulations 1995, Food Safety (Temperature Control) Regulations 1995, Food Labelling Regulations 1996 and subsequent amendments, and the Trades Description Act 1968 with regard to the composition, description and labelling of products.
b) In addition such sandwiches/rolls should be made from good quality ingredients so that they conform to a quality image associated with BSA recognition.
c) The following minimum specifications are set out for sandwiches where the BSA ‘Mark of Quality’ symbol is used.
Bread - Must be minimum 66 grams
Meat based - Minimum 40 grams meat
Poultry based - Minimum 40 grams poultry
Fish based - Minimum 30 grams fish
Cheese based - Minimum 35 grams cheese
Egg based - Minimum 40 grams egg
d) Fillings must cover the full surface area of the sandwich bread.
Conditions of Sale
All suppliers must issue conditions of sale that stipulate that the product must be kept under refrigerated condition whilst on sale and that the ‘Use By date’ must be observed. The Association recommends that the ‘Use By date’ should be production plus two days. Where shelf-life is extended beyond two days, manufacturers must be able to substantiate by analysis that their products are safe to consume at retail. Generally, evidence of independent shelf-life tests will be expected.
At point-of-sale the Association recommends that cabinet temperatures should be held at 5°C.
Security and Food Tampering
a) Adequate security must be provided at the premises, including a suitable alarm system, to minimise the risk of illegal entry and food tampering when premises are vacated.
b) Appropriate measures must be enforced to ensure that raw material entering the premises, and finished product leaving the premises, is only handled by authorised employees or agents of the company.
c) Delivery vehicles must be secured by drivers at all times when they are left unattended.
Customer Complaints
a) All customer complaints should be recorded, actioned and monitored for trend analysis, information gained should be used to implement ongoing improvements to food safety.
b) Complaint summaries will be checked as an integral part of any BSA Audit covering this Code of Practice.
Insurance
All businesses must be adequately and currently insured. Insurance must include:
Public Liability - Minimum £1,000,000
Product Liability - Minimum £1,000,000
BSA Recommended Microbiological Test Standards for sandwich type products (cfu/g)
With Salad
Target Acceptable Reject
Total Viable Count (TVC) at 30°C <10**** 10**** >10 Coliforms at 37°C <10** 10** >10*** E. coli at 44°C <10 10 >10* Staph aureus (coagulase +ve) <10 10 >10* Salmonella Absent in 25g Absent in 25g Present in 25g Listeria Monocytogenes <10 cfu/g n/a 100 cfu/g
No Salad
Target Acceptable Reject
Total Viable Count (TVC) at 30°C <10*** 10*** >10**** Coliforms at 37°C <10* 10* >10** E. coli at 44°C <10 10 >10* Staph aureus (coagulase +ve) <10 10 >10* Salmonella Absent in 25g Absent in 25g Present in 25g Listeria Monocytogenes <10 cfu/g n/a 100 cfu/g
Notes:
cfu/g = colony forming units per gram
* It is not recommended that tests are done for Total Viable Count (TVC) on products containing cheese.
** Fresh herbs or cultured dairy products may inherently produce a high TVC due to their nature.
***. Limits stated are for end of life. (p +2)
****. The presence of Listeria Monocytogenes in product should be investigated.