An Introduction to Creating a Food Safety Management System

Under EC Regulations 852/2004 and 853/2004, all business premises where food and drinks are manufactured, processed, prepared, handled, stored, distributed, sold or served (including mobile or temporary premises such as delivery vehicles) must be registered with the environmental health department of the local authority in the area where the business is located. The business proprietor must submit an application form for registration at least 28 days before they begin trading.

Under the EC Regulations, as part of the registration process, proprietors must produce a written FSMS. The FSMS must be based on Hazard Analysis Critical Control Point (HACCP) principles, which require the proprietor and any staff who prepare, handle, store, distribute and serve food to follow procedures that ensure food is safe to eat. Go to www.food.gov.uk/business-industry/food-hygiene/haccp for further information about HACCP.

Following registration, a local authority environmental health enforcement officer will inspect the business premises and any proposed food preparation, serving and display areas, as well as the storage areas where food supplies are kept. They will continue to inspect the premises and any statutory documentation systems such as an FSMS on a regular basis to ensure adequate systems are in place and are being followed.

It is the responsibility of the business owner to ensure that the FSMS is implemented and maintained, but anyone who works in a food business and whose actions could affect food safety must follow the processes laid out by the FSMS. In most cases, it will be necessary to involve a range of employees in the creation, implementation and monitoring of the FSMS, including managers, cooks, food preparation staff, cleaners and other members of staff. In some cases, it will be useful to form an FSMS or HACCP team to enable staff to contribute to the FSMS. All staff will need to be suitably trained in the use of the FSMS and HACCP principles.

An FSMS provides a breakdown of a food business's processes, such as making, preparing, serving or selling food, and identifies potential hazards and suitable control measures. An individual FSMS must be created for each separate activity if the business carries out more than one food-related operation, for example making sandwiches and selling them to customers via a mobile delivery service.

An FSMS is a written document that must be kept up to date and available for inspection by the local authority's environmental health enforcement officers. As part of the FSMS, a food business operator must create and maintain a monitoring and record-keeping system.

The FSMS should be based on the seven HACCP principles, which provide a system for identifying and preventing potential food safety hazards. The seven HACCP principles are:

1. Identify hazards. This requires a risk analysis in order to identify any biological, chemical or physical hazards that may cause food to become unsafe.
2. Identify Critical Control Points (CCPs). These are specific points in business procedures and processes where steps can be taken to remove or reduce any potential hazards to an acceptable level.
3. Establish limits for CCPs. The limits are the maximum and minimum thresholds at which potential hazards must be controlled at each CCP. Examples include minimum frequency of cleaning, or minimum heating and storage temperatures.
4. Establish CCP monitoring procedures. Each CCP must be suitably monitored in order to ensure CCP limits are being met and processes are safe and under control.
5. Establish corrective actions. These are steps that need to be taken if the CCP monitoring procedures reveal that any limits for hazard control are not being met.
6. Validate and verify the FSMS. This involves putting checks in place to ensure the FSMS is working as intended, for example by checking CCP limits and records, or by microbiological testing of food.
7. Keep records. All food operators must keep written records, including records of the hazard analysis, FSMS, CCP limits, monitoring of CCPs, handling of corrections and any checking and verification activities.

The format of an FSMS should be appropriate for the individual business and easy to use. Some food business operators use flow charts to map out business processes and printed worksheets to document monitoring and corrective actions. Others use more detailed computer-based systems to record their FSMS. There is no specific format required, although many local authorities do provide their own templates and guidance documents. A food business operator should contact their local authority's environmental health department for more information about this.

For general assistance with producing an FSMS, small food manufacturers (with 50 or fewer employees) can use the MyHACCP web tool provided by the Food Standards Agency (FSA, https://myhaccp.food.gov.uk). This provides a step-by-step guide to producing an FSMS, and includes relevant resources and assistance to enable users to use the tool.

The FSA has also developed a range of schemes and guidance packs for different food sectors to help food business operators across the UK create FSMS plans. Go to www.food.gov.uk/business-industry/food-hygiene/haccp for further information. Schemes include:

• The Safer food, better business (SFBB) scheme, which provides various information packs and training materials to help different types of food business operators comply with food safety requirements (www.food.gov.uk/business-industry/sfbb).
• Safe Catering, which is a similar scheme operated by the Food Standards Agency in Northern Ireland (www.food.gov.uk/northern-ireland/safetyhygieneni/safecateringni).

Although the regulations do not stipulate any specific schedule, an FSMS must be reviewed regularly, and certainly whenever there is any change in food operations or processes. When a change occurs, relevant hazards and CCPs should be identified, with limits and monitoring procedures established. All relevant staff should be kept up to date with changes to the FSMS.

The FSMS is a working document designed to help a food business operator maintain food safety, so it should be readily available to all staff that are required to follow its procedures. Buyers and other suppliers in the business supply chain can ask to see the FSMS in order to confirm that systems and processes are safe.

When a food business is inspected by local authority enforcement officers, the enforcement officers will need to be provided with the FSMS, along with records detailing the checks that have been carried out to ensure that the system is working and being followed. In most cases, inspections by enforcement officers will be carried out without prior notice, so it is important that records are continually kept up to date.

• An FSMS/HACCP team should be set up that includes key supervisors and staff in order to create and implement an effective FSMS.
• Efficient record keeping is essential to the implementation of an effective FSMS, and HACCP procedures should be documented for the benefit of staff, customers and local authority environmental health enforcement officers.
• An individual FSMS must be created for each separate food-related operation, if the business carries out more than one.
• The level of documentation should be appropriate to the size of the business; for example, completion of paper-based worksheets may be sufficient for a very small business, while larger firms may require computer-based records.
• Establish good practice, such as food hygiene precautions, before applying the HACCP principles.
• Creating a flow chart of business processes can be a useful first step when setting up an FSMS.
• Validation and verification of processes should be carried out by someone other than the person responsible for monitoring a CCP, and, if necessary, by a qualified external person.
• Ensure staff are properly trained in HACCP principles so they can follow the FSMS.
• Review the FSMS regularly to ensure it is up to date and covers any changes in business operations or processes.
  
  

Useful contacts

The Food Standards Agency (FSA) is a Government agency responsible for protecting the public's health and consumer interests in relation to food. It provides guidance and information on food safety. There are three national FSA offices in England, Wales and Northern Ireland, in addition to a separate Food Standards Scotland:

FSA England
Tel: (020) 7276 8829
Website: www.food.gov.uk

Improve is the Sector Skills Council for the food and drink manufacturing and processing sector. It sets standards and provides training relevant to the food industry.
Tel: 0845 644 0448
Website: www.improveltd.co.uk

The Chartered Institute of Environmental Health (CIEH) offers a wide range of food safety courses and qualifications.
Tel: (020) 7928 6006
Website: www.cieh.org