Graham Walker

1. Graham Walker Director of Training The Royal Environmental Health Institute of Scotland

2. Food Standards Agency Guidance E.coli O157 - Control of Cross Contamination Guidance for food business operators and enforcement authorities

3. Cross contamination Following the Scottish and Welsh E.coli O157 outbreaks FSA consulted on its approach to cross contamination control between 14 July and 5 October 2009 There was a particularly high level of response to the consultation

4. Controlling Cross Contamination Risk approach based on: Every consumer needs to be protected from the risk of an isolated instance of low level contamination of food by E. coli O157 This statement also applies to other pathogenic micro-organisms

5. Preventing Cross Contamination Required level of protection: The best possible protection requires complete physical separation between raw and ready-to-eat food operations. This would include preparation areas, equipment, utensils, cleaning facilities, storage facilities for foodstuffs and other materials, food display areas, and staff.

6. Preventing Cross Contamination Required level of protection: Separation of raw and ready to eat (RTE) foods and their preparation to the highest degree physically possible, which includes dedicated (single purpose) use of complex, hard to clean, equipment such as vacuum packers, mincers and slicers.

7. What type of business does the guidance apply to? The guidance applies to food businesses of all sizes and categories where both raw food and ready‐to‐eat foods are handled.

8. Raw food Raw food in this context would include raw meat and any raw ingredients that are potential sources of E.coli O157, such as raw root vegetables, fruit or other vegetables that are likely to have been contaminated by soil.

9. Ready-to-eat Ready-to-eat foods are foods that will not be cooked or reheated before being eaten and include foods such as cooked meats, sandwiches, cheese, salads and desserts.

10. Pennington Report 2009 “For a vac packer, I do not think that such a demonstration is possible to allow its use for ready to eat foods and raw meat.”

11. Separation: Designation and maintenance of a microbiologically clean area Strong parallels with infection control Everything in the clean area must be a safe contact surface for hands, clothing and equipment as well as food

12. Separation is the only reliable control Greatest extent physically possible: Size of establishment must be adequate ‘Dual use’ of complex equipment should never be considered safe. Small utensils must be for separate designated use unless heat disinfected between use

13. Separation is the only reliable control Minimum level of limited exceptions Equipment washing sinks if disinfected before used to disinfect ‘clean area’ equipment Non food contact wall and worktop surfaces. Staff, provided there is a full hand-washing regime

14. E. coli O157 Cross Contamination Decontamination considerations: A misplaced reliance on cleaning with chemicals to sanitise surfaces in contact with raw and cooked meats was a very important issue in the Central Scotland outbreak. Pennington report 2009

15. Enquiry into the Aberdeen Typhoid outbreak1964 “Only detergents and sterilisers whose bactericidal properties have been proved should be used in food premises”

16. Selection of cleaning agents & disinfectants Appropriate European standards, e.g. BS EN 1276 or BS EN 13697 – FBOs should use this as part of their purchasing criteria. Food Business Operators must strictly observe manufacturers’ instructions for use. Manufacturers can market to a recognised standard but will need to provide clear usage instructions.

17. Disinfectants • BS EN 1276 • Suspension test • 5 minute contact time at 20°C* • 5 log reduction in viable counts • Test organisms include E. coli • BS EN 13697 • Surface test • 5 minute contact time at 18 – 25°C* • 4 log reduction in viable counts • Test organisms include E. coli *Can be conducted at alternative temperatures and for different times to suit intended conditions of use

18. Approach to cleaning and disinfection • Use of a single stage sanitiser is not sufficient Two stage approach only • Clean to a visibly clean standard • Disinfect using suitable disinfectant in accordance with the manufacturer’s instructions

19. Additional considerations Hygienic design Machinery supplied for use at work from 1995 should be CE marked to indicate that it was designed to comply with the European Machinery Directive, Directive 2006/42/EC, and all previous Versions BS EN 1762-2:2005 +A1:2009

21. Additional considerations Hygienic design Manufacturer must: • Specify the intended use • Design for hygiene considering intended use and foreseeable misuse • Provide cleaning instructions as part of the design

22. Additional considerations

23. Additional considerations

24. Effective Hand Washing Hand washing is a critical control: • at all safety-critical points • It must be consistent and an appropriate technique. Clean hands should not make contact with taps. Alcohol hand gels cannot be substituted for hand washing.

25. Hand Washing Reference: Hand Hygiene. A guide for healthcare staff Health Protection Scotland

26. Cross Contamination Culture A loss of control due to any lapse in procedures would: • Necessitate active intervention to protect consumers from an imminent risk • Call into question the ability of the Food Business Operator to continue to rely on current procedures.

27. Cross Contamination Culture Lead to a presumption that operations would not be allowed to continue until the food business operator implements effective and credible procedures.

28. Training and supervision Training of applicable staff in the specific procedures required to control cross-contamination involving E. coli O157 will be crucial to effective cross-contamination control.

29. Training and supervision Effective hand washing technique is critical to cross-contamination prevention. Staff must know when hand washing is essential and how to do it properly. It is critical that all relevant staff are trained and verified as competent in hand washing technique before being deployed to work unsupervised in any safety-critical areas.

30. Training and supervision Disinfection techniques set out in the guidance will require training of all staff that carry out safety-critical cleaning and disinfection. It is essential that staff are trained and verified as competent before being deployed to dilute and apply disinfectants, or to undertake hot water or steam disinfection.

31. Training and supervision Where the food business operator cannot rely fully on training then supervision of staff is required, as necessary, to ensure food is being safely prepared, This might be the case where staff are new to a particular duty.

32. Training and supervision Staff responsible for the development or maintenance of the HACCP-based food safety management procedures should have adequate training in the application of HACCP principles.

33. Link to the Cross Contamination Guidance E.coli O157 Control of Cross-Contamination Guidance for food business operators and enforcement authorities http://www.food.gov.uk/foodindustry/guidancenotes/hygguid/ecoliguide

34. REHIS Response • Update course syllabuses and resource packs • Develop a Control of Cross Contamination Course (Intermediate level) • Develop a Cleaning and Disinfection Course (Elementary level)

35. Any questions Contact me 0131 229 2968 gw@rehis.com