How to manage due diligence in food safety with the HACCP App
As the owner of a food service business, you have the power to implement a strategy that counters the challenges of food and service costs, market competition and economic growth.
Managers with the most attractive concept at the right price point in the most desirable location are better equipped to get through the notoriously difficult first year after launch.
What happens when the threat to the business arrives out of the blue, however? The consequences of a food safety incident can be devastating, ranging from a fine to closure right up to criminal charges.
But food service managers must have a contingency plan for food safety incidents nonetheless.
Staff need to be appropriately trained to help maintain compliance at all time
To that end, one of the key safeguards for the business in case of investigation is the defence of due diligence.
This article will explain what due diligence means, how it can be enforced, and how the HACCP App is a vital tool in achieving compliance.
What is Due Diligence?
Several pieces of UK, EU and US legislation set out the requirements and parameters for safe food service. In the US, the Food and Drug Administration is the governing authority.
The General Food Law Regulation (EC) 178/2002 is the EC legislation on general food safety. In the UK, it is the Food Safety Act 1990 which lays out the framework for all food legislation.
Under the Food Safety Act, it is an offence to:
- render food injurious to health
- sell, to the purchaser’s prejudice, food which is not of the nature or substance or quality demanded
- falsely or misleadingly describe or present food
If any of these offences are committed, the business owner could be liable for fines or a possible custodial sentence in the event of wilful negligence.
Those with experience in the food sector will know all too well that too many food service establishments pay alarmingly little attention to food safety in the pursuit of higher margins.
Watch a single episode of Ramsay’s Kitchen Nightmare’s for evidence of walk-ins stuffed with oozing, rotten vegetables, contaminated raw meat and expired cooked meat.
The worst offenders are only too willing to serve out of date, poorly prepared food, perform only perfunctory hygiene checks, and even substitute cheap rogue ingredients in place of what is listed on the menu. For these businesses, there is no safe haven in due diligence.
If, on the other hand, your business suffers a food safety incident that is not consistent with overall hygiene standards within the kitchen, you may be covered (at least from criminal charges).
Under UK and EU law, due diligence dictates that: “No person or company should be guilty of a criminal offence for an act or omission which could not be reasonably avoided.”
In other words, if your food service operation has the processes and structures habitually in place to eliminate defective food, and have taken all reasonable care to avoid contamination, you have shown ‘due diligence’.
If you want to read about Due Diligence, read our blog All you Need to Know about Food Safety Due Diligence here.
The focus of this article is in the small print of the law’s application, because the burden of proof in cases of food safety lies with the person or establishment accused. Let’s repeat that. The food safety manager has to prove that Due Diligence was taken.
Typically, that means providing documentary evidence of a system in place with checks, tests, inspections and supervision to avoid contamination outbreaks.
Why Due Diligence isn’t as simple as you might think
It looks easy, no? Here’s the problem, though…
” The majority of food service businesses are still using pen and paper for recording their data.”
From small businesses to franchise chains, you will still find establishments recording deliveries on a clipboard, checking off storage temperatures and restroom cleaning schedules with a marker pen, and referring back to a stack of invoices on a spike when it comes to traceability.
This approach is costing your business money through wasted manpower in the short-term, and exposing you to serious risk in the event of a crisis.
The future is digital
With a digital resource such as the HACCP App, the entire food safety architecture can be transferred to cloud-based storage with automated functions running in real time and accessible to designated staff both on-premise and in remote locations. The advantages are clear…
An example of HACCP App in action
To illustrate the benefits of digital due diligence, let’s take a look at the example of a batch of fresh chicken on its journey through the restaurant.
HACCP requires a record of the origin of the chicken to ensure traceability, the date of slaughter and packaging, the cold storage on premises, the date of expiry/ use by date, then the safe preparation of the raw chicken as it is cooked, served and refrigerated or disposed of.
That’s already a trail of paperwork to complete for a single bird. With a digital app, it can be processed and accessed beneath a single thumb.
With the HACCP App, any authorized member of staff can enter delivery and storage details, monitor temperature control with digital sensors connected to a Bluetooth gauge, take pictures as proof of correct preparation and storage, print labels to attach date codes and allergens, and scan QR codes to retrieve data from all points throughout the supply and processing chain. All from a single database.
The HACCP App records the use by date and prescribed storage conditions for each item on premises and can send alerts to any location in case of failure. Should there be an incident of food poisoning, the food service manager not only has the ability to pinpoint exactly the origin and cause of the outbreak, but also prove to any investigative authority the precautions taken to avoid such an incident.
More than a food safety resource
Particularly with larger establishments such as franchise outlets, the HACCP App also offers significant benefits when it comes to setting up and monitoring a cleaning schedule, and ensuring the safe operation of machines and chemicals within the business.
Rather than sticking to a prescribed schedule based on time passed, the App can exploit data analytics relating to footfall and occupancy to adjust cleaning schedules.
For example, digital sensors can measure the number of times a soap dispenser is pressed in the restroom and interpret the data to gauge how busy the restaurant is as a result, sending an alert that a cleaner is required.
Likewise, the App can store all the Material Safety Data Sheets relevant to the business in a single device, allowing staff to scan miscellaneous containers with a QR code and establish instantly whether they are correctly stored, safe to use or appropriate for the task.
The fundamental principle of food safety and due diligence is that written records must be kept by the business manager. By using digital technology, managers can make light work of a task that would otherwise be a serious headache.