CFG
09/07 final
Letter dated 11 April
2007 from Foodaware to Catherine Bowles, Food Standards Agency:
Dear Ms Bowles
FSA pre-consultation Commission proposals to amend Regulation
852/2004 on Food Hygiene
Foodaware members have been consulted by email on the European Commission’s
proposal to remove the requirement for food businesses with fewer
than 10 employees to establish a structured approach to managing food
safety by applying HACCP principles. Members understand the desire
to reduce administrative burdens in the European Community but consider
that the application of HACCP principles is necessary to protect consumer
safety and the quality of food produced by small suppliers. It should
not be considered as an ‘administrative burden’.
Identifying hazards and the actions necessary to control them are
fundamental aspects of business life in the modern world and should
form an integral part of any food business, however small. The application
of HACCP principles demonstrates that the business has considered
where its main risks lie, and has measures in place which will consistently
ensure the products are safe for sale to the public. Some documentation
and appropriate record keeping are essential to demonstrate compliance
and so that, if there is a failure, it can be traced back and preventive
measures put in place so that the failure is not repeated.
In the light of serious breaches of food law, some of which involved
small businesses, Foodaware campaigned for HACCP systems to be applied
to all food businesses, irrespective of their size, in order to protect
public health. We have accepted risk-based inspection on the basis
that food businesses have systems in place for assessing and controlling
risks. If the Commission removes the requirement for small businesses
to put in place, implement and maintain a permanent procedure based
on HACCP principles as well as record-keeping obligations, it is likely
to be extremely difficult to mount a successful prosecution for breaches
of food hygiene law by small firms. This would be a retrograde step.
This requirement is not a piece of unnecessary bureaucracy but a public
health measure.
According to FSA's 2006 consumer attitude survey, 60% of consumers
have some concerns over food safety issues and, although it is lower
on people's radar than in the past, when prompted, concern remains
high. Small food businesses such as takeaways, fast food outlets and
cafes also feature highly in people's concerns about hygiene. They
can produce large quantities of food which pose significant risks
and potentially expose large numbers of people to food poisoning.
Indeed, some of the most serious outbreaks have been caused by sole
traders. A reduction in control would give the wrong message both
to businesses and to consumers at this time when significant progress
has been made in controlling risk in the appropriate place, within
the firms themselves.
We are prepared for our views to be made public and look forward to
hearing the outcome of this consultation in due course.
Yours sincerely
Susan Knox
Chairman
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