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Guests choose a restaurant because they trust and believe that the establishment shall always fulfill their
demands and expectations both the expressed and unexpressed expectations. They trust that the food cooked in
the restaurant is safe to eat and will not make them sick after eating. Providing customers with safe food is not
only important for the success of a business but also mandatory by law.
A Food safety Management Program which is intended to prevent food poisoning by following safe food
preparation practices; this involves taking measures necessary to ensure the safety and wholesomeness of food
during purchasing, receiving, storing, cooking, transporting, reheating and service. A Food safety Management
Program is a program developed to control food safety problems and ensure that the food served is safe to eat.
It is based upon the principles of HACCP. It involves looking at the food preparation and service operation step
by step from the selection of ingredients right through to the service of the food to the customer. By carefully
analyzing each step of the food preparation and service operation anything that may affect the safety of the food
is identified and controlled. Food safety Management Program helps in ensuring that food is safe at all times and
the risk of food poisoning is minimized / prevented
Food safety is very important as stated above. It is a crime punishable by Law to serve food that is unfit for
consumption.
0102. The FSA (1990) is the overarching food safety legislation in England, Wales and
Scotland. It introduced a number of features for the enforcement of food hygiene and
Enabled subsequent regulations to be introduced.
0103. There are a number of offences under the Act:
a. Selling food that is not of the nature, substance or quality demanded by the purchaser.
b. Falsely describing, advertising or presenting food.
c. Rendering food injurious to health.
d. Selling food that does not comply with food safety requirements. This is food that has been rendered injurious
to health (e.g. through contamination with food poisoning organisms) or which is unfit for human consumption.
0104. The definition of selling food includes food that is offered, displayed, advertised by and / or in possession
of and is in the food business.
DUE DILIGENCE
0110. A key concept of the FSA is that of ‘Due Diligence’. This is essentially a defense in the event of
prosecution and requires evidence that the person charged took all reasonable precautions and exercised all due
diligence to avoid committing the offence. In effect, it enables an enforcement authority to “by-pass” an
immediate offender and prosecutes the real offender. The defendant has to prove that due diligence has been
exercised and this is where the importance of keeping records is crucial.
0111. In practice, the due diligence defense will consist of two stages:
a. ‘To take all reasonable precautions’ means that a system is in place to prevent an offence from occurring.
Areas of consideration will include:
(1) Food Safety Policy in accordance with Food Policy Statement.
(2) Hazard Analysis systems.
(3) Staff training programmes.
(4) Available resources, e.g. technical, staffing, financial.
(b) Secondly, exercising due diligence, which concerns day-to-day operation of the system. A court of law
would usually require documented evidence that procedures were carried out at a relevant time and by an
appropriate person. The usual requirements include details of the following:
(1) Cleaning schedules.
(2) Temperature monitoring e.g. dedicated transportation vehicles, temperature at time of receipt, cooking and
service, and monitoring of freezers and refrigerators.
(3) Documentation of any corrective action taken.
(4) Documentation of supervisory checks.
(5) Records kept up to date at all times and available for inspection by local authority enforcement officers.
The Food Standards Agency (FSA) is an independent Government Department and is an enforcement authority
in its own right. It is also responsible for enforcement support, advice and audit of enforcement activity with
respect to local authority food safety and standards controls.
Dubai Municipality Grading System to rate food preparation & Fines imposed to food preparation
premises not complying with the law
Dubai Municipal Food Control Inspectors grade food preparation establishment by using the following criteria.
They use the points systems 90 points and above ensure that the establishment secures “A” grade this means that
the food premises shall be inspected once every 3 months.
A score of 90 and below up to 70 means an inspection every month. This establishment shall receive a “B”
Grade.
A score of below 70 up to 60 means an inspection every week, this establishment shall receive a “C” Grade
Dubai Municipal Food Control Inspectors are authorized to fine establishments not complying with the
legislations, Please find below the checklist that is used by the inspectors for fining establishments not
complying. Attached at the end of this document are The violation sheet of Dubai Municipality, They use the
grading system based on points to grade food establishments A, B and C .Catering establishments here in Dubai
are governed by the Food Hygiene Regulations of 1992 i.e. Administrative order no 20 of 1992 issued on the
3rd of February 1992.
Dubai municipality’s legislations give details on every aspect that of the food chain and what is expected from
the Hotel. Non conformance to the Dubai Municipality’s directive results in warning and fines.
Please find attatched the Annexes i.e. grading system and memo’s from Dubai Municipality which provides
more insight.
Annexes:
DM Memo on Health Cards.
DM Memo on transport of food stuffs in Dubai.
DM Memo on visitors in food establishments.
DM Excel spreadsheet on Inspection checklist for grading.
DM Violation and Fines sheet.
Local Order No (11) of 2003.
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Management needs to formulate a Food Safety Policy detailing the scope, use and purpose of food safety in the
establishment. The food safety management system should be based on HACCP and should also take into
consideration local legislations. Thus the food safety program, the implementation of which will provide each of
the catering operations are adhering to good working practices, guidelines and policies assuring that the food
they serve is safe and of good quality. In doing so, each unit will have a reduced exposure to business risks
arising from food contamination scares, adverse publicity or brand damage.
Step 1: Planning
Top Management should first select and hire a Food Hygiene Officer to implement and manage the food safety
system. The food hygiene officer could be assisted with an external Food Safety HACCP Consultant to ensure
the HACCP implementation and certification of the establishment.
Top Management along with the Food Hygiene Officer and HACCP Consultant must formulate a Food Safety
Management policy and formulate a team to implement, overlook and monitor HACCP. Staff will need to be
made aware of any changes that may result from its introduction can be kept up to date.
Depending on the size of the business assemble staff into a small team, with a team leader to lead in designing
and implementing HACCP. The team should have a good knowledge of the business. Initially, the team will be
required to spend a reasonable amount of time and effort to develop and implement the HACCP system.
Describe the product(s) and the intended use by consumers and then depending on the size of the business draw
up a flow diagram to show each step of the operation. Walk through the operation to confirm that the diagram is
correct and check that it covers all the foods your business produces.
The management should have defined objectives to support the food safety policy and which would also provide
a measure of the suitability and effectiveness of the management system in place. The following have been
taken into consideration while setting the objectives:
1. Food safety policy
2. Customer requirements and expectations
3. Product and process requirements
4. Available resources
5. Statutory and regulatory requirement.
In the absence of The Food Hygiene Officer, The Executive Chef will be acting as the Food Safety team leader.
The following would be members of the Food Hygiene Management Team:
General Manager, Food Hygiene Officer, Food and Beverage Manager, Executive Chef, Director of
Engineering, Executive House Keeper, Purchasing Manager, Food and Beverage Cost Controller, Store
Supervisor, Training Manager & Human Resources Manager.
Roles and Responsibilities should be given to the members to ensure that implementation of the Food Safety
Management Systems has been successfully integrated in the Hotels culture.
Purchase High risk foods Buy from reputable supplier only. Specify temperatures required at
contaminated with food delivery. Supplier quality assurance program, Supplier Audits.
poisoning bacteria or toxins.
Receipt High risk foods Visual / sensory checks. Temperature checks. Transportation
contaminated with food vehicle checks, delivery personnel personal hygiene checks, separate
poisoning bacteria or toxins. weighing scales for frozen & chilled meat products, non chilled / low
risk items and separate for ready to eat products.
Storage Growth of food poisoning High risk foods stored at safe temperatures. Store wrapped. Rotate
bacteria, toxins on high risk stock & use before expiry. Chilled products storage below 5 deg C,
foods. Further Frozen items stored at -18Deg C and dry foods stored at below 22
contamination. Deg C and less than 60% Humidity.
Preparation Contamination of high risk Limited exposure to ambient temps. During preparation. Prepare
foods. Growth of with clean equipment, used for high risk foods only. Separate
pathogenic bacteria. cooked and raw foods. Wash hands before handling foods.
Cooking Survival of pathogenic Cook rolled joints, chicken and reformed meats e.g. burgers to at
bacteria. least 75°C in the thickest part. Sear the outside of other meats (e.g.
joints of beef, steaks) before cooking).
Cooling Growth of any surviving Cool foods quickly as possible. Do not leave out at room temps cool
spores or pathogens. Toxin unless cooling period is short (e.g. place stews, rice etc in shallow
production Contamination tray and cool to chill temperatures quickly).Blast chill products to
with pathogenic bacteria. below 4 Deg C from 90 Deg C within 90 Minutes.
Hot holding Growth of pathogenic Hot hold food in hot cabinets above 65°C.
bacteria. Toxin production.
Chilled storage Growth of pathogenic Temp. Control; Stock rotation. Keep items below 5 Deg C.
bacteria.
Service Growth of pathogens. Cold service – serve high risk foods as soon as possible after
Toxin production. removing from chiller. Hot foods – serve high risk foods quickly.
Contamination.
The following questions can be used to help to determine critical control points at each step:
(1) Question: Is it necessary to control the hazard at this step, or will a subsequent step reduces or eliminate the
hazard?
For example: At the purchase or preparation step
Raw ingredients may contain food poisoning bacteria but the cooking step will, if carried out correctly, reduce
these to safe levels.
* Therefore in this case the purchase and preparation step is not a Critical Control Point.
* If a subsequent step (e.g. cooking) will control the hazard, then that step is the Critical Control Point.
(2) Question: Can the hazard be eliminated or reduced to acceptable levels at all, at this step or any step?
If the answer is ‘no’, consideration should be given to whether the food is served at all. Different ingredients or
changes to be preparation / cooking method may need to be considered so that the food is safe when served to
the consumer.
Step 3d: Decide how to monitor and, if necessary, record that the controls have been applied.
Critical Control Points must be monitored. The frequency of monitoring will depend upon the nature of the
control, practicality, and the level of confidence the monitoring procedure gives.
Monitoring
The methods used should be kept as simple as possible, for example:
• On delivery, visual check of packaging, expiry dates
• The measurement of the temperature
• checking that all equipment is cleaned before use
RECORDING
Wherever possible, records should be kept as these will help the manager check that food safety measures are
adequate and working.
Records will also provide useful information if there is a query from the Municipality officials. The type of
equipment available to monitor some critical control points may automatically give records, e.g. automatic
logging devices connected to all chiller and freezer units, giving a printed read-out.
Where manual checks are taken at a critical control point and the manager decides that it is necessary to keep
records, consideration will need to be given to the type of recording sheets needed. These should be kept as
simple as possible, and training must be given to staff to ensure that records are completed correctly.
STEP 3E: IMPLEMENTATION AND HOW TO MANAGE THE CHANGE TO FOOD SAFETY PROGRAM?
1. Prepare, print and if necessary copy any record sheets.
2. Consider developing working instructions for the controls, and monitoring procedures for staff to refer to,
particularly where a critical control point is identified. These should be simple and clear.
3. Procedures and work instructions should include:
• What is to be done?
• How it is to be done
• When it is to be done
• Where it is to be done
• Who is to do it
4. Tell staff why checks or measurements need to be taken.
5. Train staff as necessary in the basic principles of the Hotel Food Safety Management System approach.
6. Ensure staff understands their responsibilities so that the system can be implemented successfully.
7. Ensure that instructions, procedures and training cover what to do if a critical control point is not achieved.
For example: place food back into the oven and inform the manager immediately, throw the food away.
Important note – control measures may involve taking temperatures using a probe thermometer. Training
should be given so that this is done properly including giving instructions on cleaning the probe between uses.
Probes should be accurate and checked frequently.
MANAGEMENT COMMITMENT
Management Commitment is essential to the effective food safety system implementation and execution and this
must be demonstrated by establishments Food Hygiene Team. This is judged by the number of Food Hygiene
team meetings held, the frequency with which the Management / Hygiene Team Members attend these
meetings, the control exercised by Management to ensure that Internal Audits of the policies are undertaken
with the correct frequency. This will ensure that the staff will apply the Food Safety Management Systems
policies to minimize Food Safety Risk. The top management should be committed to the development and
implementation of the food safety management system and to continually improving its effectiveness.
Management must ensure that food safety is supported by the business objectives of the organization by:
1. Including hygiene as a performance indicator, obtained from customer feedback
2. Business is driven by revenue management instead cost cutting.
3. No compromise is undertaken on any issues that may affect the safety of products.
4. Marketing its commitment to food safety when selling and organizing catering events.
5. Budgeting for resources, investments or costs related to food safety.
6. The top management will ensure that staff at all levels in the company are communicated of the importance
of meeting the requirements of this International Standard, any statutory and regulatory requirements, as
well as customer requirements relating to food safety through.
To reduce the risk of unsafe food by taking preventive measures to assure the safety and suitability of food at an
appropriate stage in the operation by controlling food hazards.
Establish procedures for the conduct of internal and external hygiene audits, which shall verify the level of
hygiene activities and determine the effectiveness of the food safety management system in place. The audits
shall be scheduled at a frequency deemed necessary for the activities being audited.
o The following audits shall be conducted:
1. Daily Departmental Self Audit.
2. Monthly Internal Audit by Hotel’s Food Hygiene Team Members.
3. Quarterly Internal Audit by a Panel of the Hotel’s Food Hygiene Team.
4. External 2nd Party Audit by an External company minimum once every 6 months.
o The audits should cover all food areas and any other areas that are likely to affect the safety of the
operations and that of the food.
o The results of the audits shall be recorded and brought to the attention of the employees responsible for the
area audited.
o Appropriate and timely corrective measures shall be taken to address any non-conformances raised during
the audits.
o Any new information regarding hazards or processes that are likely to affect the effectiveness of the
HACCP system in place shall also be taken into consideration and the HACCP plan shall be revised
accordingly.
CONTINUAL IMPROVEMENT
The top management will ensure that the Hotel continually improves the effectiveness of the food safety
management system through the use of: Communication ,Management review, Internal audit, Evaluation of
individual verification results, Analysis of results of verification activities, Validation of control measure
combinations & Corrective actions and Food safety Program policies are updated.
System updating activities will be recorded and reported, in an appropriate manner, as input to the management
review.
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Part 3
Investigation into Food Safety Controls in a Food Business
The hotel has 3 restaurants with 3 kitchens where in food is cooked in these kitchens and food and beverage is
served in these restaurants. There are currently 60 Chefs, 70 Waiters, 25 Stewards, 2 in Purchasing, 3 in
Receiving and 4 storekeepers.
The hotel has a food safety program in place and is undergoing HACCP Certification with the consultancy stage
over, HACCP Manual in place and HACCP Implemented. The preliminary certification HACCP Audit revealed
the following:
Audit Findings:
1. Finding: Hazard Analysis has not been done for live Crabs and Lobsters in Fish Tank.
• A fish tank was found in the Fish Preparation Kitchen located in the Main Kitchen (The fish section
area is where all the raw fish is cut etc). The fish tank contained live Crabs and Lobsters. The tanks was
owned and maintained by the suppliers. Whenever there is an order for crabs and lobsters, they were
taken out of the tanks cut, cleaned and used for cooking and served. The audit inspection revealed that
Hazard analysis was not done for the live Crabs and the Lobsters in the Fish Tank in Fish Preparation
Area.
Recommendations:
• Hazard Analysis requires to be done for the live seafood and lobsters. This would be a Control point in
the operations. The supplier requires sending Health Certificates for the live seafood being delivered
along with Certificate of Analysis.
• The receiving staff requires requesting the supplier’s delivery personnel and checking the Health
Certificates and Certificate of analysis. They need to check the cleanliness and temperature of the
delivery vehicle (Below 8 Deg C for transporting live seafood).They need to check the personal
hygiene of the driver and the loading helper. They need to check the seafood that it is delivered in a
clean and thermo cool box. The crabs and lobsters are alive and healthy and there is no awful smell and
most importantly that they are not injured or damaged.
• The water tank requires maintenance to be carried out at least once a week by the fish supplier. Records
of the following need to be maintained by the fish preparation chef of the work carried out by the
supplier i.e. cleanliness, water filter cleaning, PH Checking and Salinity testing.
• Calibration of the thermometer displaying the temperature of the tank should be carried out at least
once a year. The chef requires checking that the seafood is alive every 6 hours and notes the
temperature of the water in the tanks on the recording form.
• Water tests should be carried out and send for laboratory analysis.
2. Finding: During the audit it was found that the room service toaster was dirty. There was no cleaning and
disinfection procedure in the manual for this equipment. The cleaning schedule was not update to include
this machine on the list.
Recommendations:
• There should be a cleaning and disinfection policy for toaster. The cleaning schedule needs to be
updated to include the toaster with details on when to clean, how to clean & disinfect safety precautions
and who should clean.
3. Finding: There were no labels for expiry date on Small bottles of Tabasco.
Recommendations:
• The small miniature bottles of Tabasco do not have on them the date of production and expiry.
4. Finding: The infrared and probe thermometer being used by the receiving clerk was found to be having a 4
Deg C Variance. This is huge especially when receiving chilled products. No Calibration was done of this
thermometer. There was no additional thermometer for the receiving clerk.
Recommendations:
• A second infrared and probe thermometer should be purchased with immediate effect.
• All Equipment calibration of thermometer should be done; the thermometer should be calibrated
according to international standards.
5. Finding: Temperature of cooked rice in hot holding was 41.5 c. in Kitchen. Food was kept at ambient
temperature ready to be transported to another venue (out of the Hotel).This food was kept out for 45
minutes at ambient room temperature and was to be placed in a hot box to be maintained at a temperature of
above 65 Deg C and then reheated to a internal temperature of 82 Deg C before service. The Hot boxes are
few and hence it could not be placed immediately. The HACCP Manual did not state how long food could
be kept out at ambient temperature.
Recommendations:
• The HACCP Manual requires to be updated and it should be mentioned that food that is cooked could
be kept at ambient temperature for a maximum period of 90 minutes.
• Additional Hot Boxes required to be purchased to ensure that all food that is cooked and to be hot held
could be placed in hot boxes immediately.
6. Findings: The Hotel has a vegetable washing and sanitizing room located near the receiving area. The
unwashed and dirty vegetables that are received in their polycarbonate containers from the suppliers are
placed in a designated area. Batch by batch the fruits and vegetables are washed and sanitized and then
placed in a color coded green hotel containers. The cold kitchen to which these are being transported too is
located on the 4th floor. These containers pass through the receiving area and the designated area where the
dirty unwashed fruits and vegetables are placed. This could result in cross contamination as the Cleaned
Vegetables were going to the Kitchen without being covered with Cling Film.
Recommendation:
• The HACCP Manual requires to be updated and it should be mentioned that the cleaned and sanitized
fruits and vegetables that are placed in the Hotels clean Green Color Coded Fruits and Vegetables
Containers require to be wrapped with cling film before being transported out of the vegetable washing
room to prevent cross contamination.
• Staff requires training on this procedure and monitored.
The organization communicates food safety information with personnel through both informal and formal
communication channels, such as:
• Regular management meetings
• Notice boards and posters
• Training and workshops
• Communication sheets or logbooks
1. Cleanliness Posters: The following posters shall be required to be stuck on the walls, the posters should be
laminated stuck with double sided tape, easily washable or should be put in frames which are washable and
easy to clean and maintain. some examples of posters are as follows:
• Clean as You Go.
• Wash your hands.
• Pot Wash Station
• Dish wash Station.
• Chemical Stores Only.
• Do Not Mix Cleaning Chemicals.
• Cleaning instructions on cleaning Meat Slicers, Deep Fat Fryers, and Ovens.
• Cleaning Schedule and Checklist.
• Cleaning Posters showing the Kitchen Layout with Chemicals and Cleaning Equipment Required
to be cleaned.
2. Pocket Cleaning Guide: This is a small pocket size booklet that easily fits into ones pockets. This is part of
the uniform the stewarding team members. The guide contains the list of cleaning chemicals used,
precautions to be taken while using them, safety tips for their usage, Various Equipments are mentioned and
standard operating procedures on how to clean them is written given complete information on who is to
clean them, when it is to be cleaned, frequency of cleaning, how to clean , what is used to clean them,
monitoring and record keeping of the cleanliness.
3. Briefings: Stewarding, Culinary and Food and Beverage service must emphasize on cleanliness and
sanitization topics and mention about the standards of cleanliness in their sections, the supervisor on duty
must allocate staff and ensure that their area is maintained in a clean, hygienic manner at all given times.
Stewarding should include a 5 minute training program in their daily shift briefings focusing on various
cleaning equipment and how to clean them. Audit results, supervisory or managerial comments on cleaning
and sanitization need to be communicated to employees through briefings and departmental communication
books.
4. Hygiene Bulleting Board should be placed in the staff cafeteria, Staff Locker Room and Other Prominent
Areas where all Food Handlers could read them. The bulleting Board should contain the following
information: The minutes of the Hygiene Committee Meeting, Audit Scores and Audit Reports. Thus
creating awareness on cleanliness and sanitization and the Hotels Official stance on cleanliness.
5. Cleanliness Monitoring & Recording: Cleaning Schedules should be in place in which the stewarding
shifts supervisors recording and monitoring all cleaning activities. One of the major daily job tasks for the
Chief Steward and executive Chef is to walk around the food preparation areas and check the levels of
cleanliness. They should have hand held PDA’s where in they could do daily audits on cleanliness, this is
then automatically recorded in the computer and reports are generated with to do actions for the stewarding
supervisors. Computer linked PDA’s go a long way in providing corrective actions that are required to be
taken to rectify issues, provide dates of audits, auditor names, audit findings and emails could be send to all
members required to ensure that the cleaning and sanitization programs are functioning smoothly. Since this
computer generated reports and electronically saved they cannot be tampered with and reports for various
areas could be viewed by all levels of management who have access to a computer.
6. Area Cleanliness Monitoring Logs: Each and Every Area should have a Area Cleanliness Rating and
Comment Log Book, This log book should be filled by the Chefs and the Food and Beverage Restaurant
staff where in the rate the cleanliness and sanitization of the various premises and also put in their remarks.
This record form should be read by the stewarding supervisor daily. In this way the persons working in that
area also take active interest in ensuring that the stewarding department maintains their area clean and
sanitized and this pushes the stewarding department to also clean the premises and is actually a quality
improvement tool.
7. Bonus linked to cleanliness results: Audit results, corrective actions taken, audit scores shall all have a
bearing on individual and departmental performance monitors and shall affect bonus paid to them. Good
Audit results ensure the departmental employees receive the bonus, poor audit results in lower bonus paid
to the employees. Employees not meeting the regular set targets on cleanliness will have disciplinary
actions taken against them and this could also cost them their jobs due to poor performance and failure to
maintain and adhere to the required set standards. Staff to be communicated about this during their
In order to maintain the effectiveness of Hotel Food Hygiene Program, the organization will ensure that the food
safety team is informed in a timely manner of changes, including but not limited to the following
• Cleaning equipment, Cleaning Chemical and Cleaning Techniques.
• Production premises, location of equipment, surrounding environment;
• Cleaning and sanitation programmes;
• Personnel qualification levels and/or allocation of responsibilities and authorizations;
• Statutory and regulatory requirements;
• Knowledge regarding food safety hazards and control measures;
• Customer, sector and other requirements that the organization observes;
• Complaints indicating food safety hazards associated due to failures in cleaning and sanitization.
• Other conditions that have an impact on food safety.
References:
• Dubai Municipality Administrative Order No 20, 1992.
• Dubai Municipality HACCP Guidelines & Requirements for Retail operators 2005.
• The Food Safety (General Food Hygiene) Regulations 1995
• Food Standards Agency (FSA) website.