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Food & The Law

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THE FOOD SAFETY ACT 1990

The Food Safety Act 1990 made substantial changes to strengthen and update the previous food safety law.

It replaced the existing primary food legislation in England and Wales and in Scotland with a single statute covering the whole UK. The main feature of the Act is the number of enabling powers that it contains. This allows Ministers to make further regulations to implement food safety measures and produce codes of practice to bring about more consistent standards of enforcement.

Food has a very wide definition under the Act by including virtually anything that is eaten, drunk or sold as a food product. The definition of food also includes tap water (not covered under previous food legislation) and products of no nutritional value which are used for human consumption, such as:

(a) releasing agents used in bakeries
(b) food additives or colourings
(c) bulking agents used as an ingredient in some processed foods
(d) chewing gum


The sale of food includes offering food as a prize or reward or giving it away, as well as exchanging food for payment. If food is provided at a public function, sports event, concert, etc then this also constitutes selling.

Where food, either a finished product or an ingredient, is on any premises it is presumed to be for human consumption unless it can be proved otherwise.

Food law is usually enforced by local authorities, although Ministers do have some powers relating, in the main, to national emergency situations:-

1. Matters relating to public health (i.e. fitness of food, food hygiene) are dealt with by district councils through Environmental Health Officers (EHOs).
2. Matters relating to consumer protection (i.e. compositional standards of foodstuffs, labelling) are dealt with by county councils through trading standards officers (TSOs).

The Food Premises (Registration) Regulations 1991
The Food Premises (Registration) Regulations 1991 (as amended) have been made using the powers contained in section 19(1)(a) of the Food Safety Act 1990.
  • The regulations require that food premises (including vehicles and other moveable structures) may only be used for the purposes of a food business if they have been registered by their local food authority – the district or borough council.
  • The purpose behind the registration is to allow the authorities to keep up-to-date lists of premises within their districts – so that they can visit them when they need to. How often a particular premises is visited will depend on the type of business carried on there.


THE FOOD SAFETY (GENERAL FOOD HYGIENE) REGULATIONS 1995

The main features of the Regulations are as follows:

1. Increased attention to the need to identify and prevent food safety risks at all stages in the preparation and selling of food using "hazard analysis", the principles of Hazard Analysis Critical Control Points (HACCP) (regulation 4(3)).
2. A requirement to comply with the "rules of hygiene" listed in Schedule 1 of the Regulations (regulation 4(2)).
3. A general requirement to carry out all food activities in a hygienic way (regulation 4.1)
4. The introduction of the concept of voluntary industry guides to good food hygiene practices (regulation 8(2)(c)).
5. A requirement for food handlers to report actual or suspected infections which could result in the contamination of food (regulation 5).
6. A requirement for the supervision, instruction and/or training of food handlers in food hygiene (Schedule 1, Chapter X).

Breaches of the Regulations may result in the issue of improvement notices, emergency prohibition notices, prohibition orders or emergency prohibition orders (Food Safety Act 1990, s.10, 11 and 12) and/or prosecution.

THE FOOD SAFETY (TEMPERATURE CONTROL) REGULATIONS 1995
These Regulations contain certain national provisions relating to temperature control of food. Part II of the Regulations lays down food temperature control requirements for England and Wales.
The purpose of the Regulations is to control the temperature at which foods likely to support the growth of pathogenic micro-organisms or the formation of toxins are kept.
For many foods, adequate temperature control is the only hurdle to the growth of micro-organisms and so these requirements seek to maintain this barrier, thus protecting food safety, by laying down chill and hot holding conditions for such foods.

Defence of Due Diligence
(Section 21)
A statutory defence is provided where the defendant can prove that he or she took all reasonable precautions and exercised all due diligence to avoid committing an offence.


  • THE TRADE DESCRIPTIONS ACT 1968
    This act makes it an offence for a person acting in the course of a trade or business to make false or misleading statements about goods or knowingly or recklessly to make false or misleading statements about services. accommodation or facilities.

    THE HEALTH & SAFETY AT WORK ACT 1974
    Health and safety in catering and other food premises is governed primarily by the Health and Safety at Work, etc Act 1974 (HSW Act) and its subordinate Regulations.

    • The Act lays down general principles for providing satisfactory standards of health and safety at work and places specific duties on employers, employees, premises occupiers and manufacturers/suppliers.
    • The purpose of the Act is to prevent employees or anyone else suffering harm associated with any work activity.
    • The scope of the Act includes the physical and mental well-being of employees and the provision of certain welfare facilities.



    RISK ASSESSMENTS
    Risk assessment is the systematic identification of hazards, evaluation of risks and determination of necessary control measures for all the work activities carried out in the undertaking.

    The Management of Health and Safety at Work Regulations 1992 (as amended) require this assessment of risk and then the taking of measures to remove those risks or reduce them to an acceptable level.

    The purpose of risk assessments is to identify what can cause injury to employees or other persons, decide how serious it could be and then take action to improve the situation.



    FIRE PRECAUTIONS
    • The nature of the work and equipment in use in many food activities makes the risk of fire very significant. The Fire Precautions Regulations themselves do not require a fire risk assessment but modify the Management of Health and Safety at Work Regulations 1992.
    • This in turn means that the general assessment of risks to be carried out by every employer must take account of those from fire. Carrying out a straightforward check on what activities take place at the establishment, and questioning the hazards and risk may identify possible fire risks which are easily removed or at least reduced.