Our hygiene audits can sometimes make for tough reading, as they do not necessarily pull punches, and even though they are only being used internally by the owners of a food outlet, or those responsible for the food safety and hygiene of the site, they are not much use if we don't say what needs to be said in the audit report.

This can often lead to a sense of panic, when it is reported that key data is not recorded, even though the actions which need to be undertaken might in fact be happening as they should. This often leads us to have the conversation about the difference between food which is likely to be safe, and food which is demonstrably safe. It is one of those principles which underpins food hygiene legislation, and regularly reported on during our hygiene audits.

Record Keeping

You may of course be absolutely certain that your freezer has operated at the right temperature, every day for the last year.  You may equally be sure that your supplier is maintaining the right systems in order to supply you with safe food for you in turn to serve your customers.  These things are good to know, and of course mean that in those two particular circumstances you are not endangering your customers.  However, it is a world away from being demonstrably safe - and that means you are failing in the law and your duty of care to your customers.  It arguably does not actually increase the risk to your customers, not having records to back up your good practices, but forgetting to fill in the paperwork, or not having the paperwork available and ready to hand when you need it, is an absolutely essential piece of your food hygiene puzzle, and one which our audits often find in less than perfect condition.

The Burden of Proof

It is incredibly important, not because the records themselves make your food any safer, but because you have a duty not just to implement a food safety system with all of the component risk assessments and hygiene procedures, but also to demonstrate that your system is functioning.  The only way to effectively do this is through diligent application of the procedures and recording the results as you go.  This is the difference between safe and demonstrably safe, and often the difference between legal and otherwise.  It is one thing for us to find this sort of information during what we term a 'friendly but critical' hygiene audit, but obviously not something a food business wants their local enforcement to identify, so we always suggest that in order to ensure complete compliance with the standard you have chosen for your food safety system, it has to be supported by every member of the business, with every member of the team taking responsibility.

Management Commitment

This means that it is not only food handlers who have a responsibility, but everyone from the most senior management to the newest recruit.  The importance of record keeping and regular review of data can not be overstated.  You must have a system that not only records the right data, but then includes the facility for checking that data on a scheduled basis to ensure accuracy.  And of course, it can then be supported by a third party hygiene audit to cast that fresh set of eyes over the data which you should now have in abundance, not just assuming your food is safe, but demonstrating it.

Written by Tom New