New Decision Tree to be adopted in CODEX General Principles of Food Hygiene

New Decision Tree to be adopted in CODEX General Principles of Food Hygiene

New Decision Tree

In our previous article we noted that it was somewhat disappointing the “CODEX” Decision Tree had been removed and no alternative offered although Codex HACCP 2020 still makes reference to using a decision tree or other approach to identify critical control points (CCPs) in Chapter Two Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application, Section 3: Application, 3.7 Determine the Critical Control Points (Step 7/ Principle 2)

The good news is that last year the 52nd SESSION OF THE CODEX COMMITTEE ON FOOD HYGIENE agreed on a new decision tree and worksheet to be passed to CAC 45 for adoption. Conclusion from the Report 52. CCFH52 agreed to forward:

  1. the “Tools to determine the critical control points (CCPs)” to CAC45 for adoption at Step 5/8 and subsequent inclusion as Annex 2 in the General Principles of Food Hygiene (CXC 1- 1969) (Appendix III, part A); and
  2. the consequential amendment to Section 3.7 of Chapter two of CXC 1-1969 to cross-reference Annex 2 (Appendix III, part B)

In the the 45th Session of the Codex Alimentarius Comission December 2022 the CODEX COMMITTEE ON FOOD HYGIENE (CCFH) (Agenda Item 4.3) was approved for final adoption.

  1. CAC45 adopted the:
  2. Guidelines for the Management of Biological Foodborne Outbreaks) at Step 8; and
  3. Revision to the General Principles of Food Hygiene (CXC 1-1969).
  1. 55. The Chairperson noted that with the adoption of the decision-tree, Codex had now completed a major revision of the General Principles of Food Hygiene (CXG 1-1969). Recalling that this was the foundational text for many of the Codex food hygiene texts and was also extensively cross-referenced in other Codex texts, it was now necessary to ensure that, where relevant, Codex texts were fully aligned with the latest version of the General Principles on Food Hygiene (CXG 1-1969).

Changes to the seven principles of the Hazard Analysis and Critical Control Point (HACCP) system in CODEX Recommended International Code of Practice General Principles of Food Hygiene 2020 Edition are highlighted in the image below.

New Decision Tree

We now expect a revised version of the CODEX General Principles of Food Hygiene to be published shortly. The Decision Tree is used to assist in PRINCIPLE 2 – Determine the Critical Control Points (CCPs). At this stage, we consider which among the available control measures listed during step 6, Principle 1 should be applied at a CCP. Critical Control points are to be determined only for hazards identified as significant as of the result of a hazard analysis.

HACCP System and Guidelines

New CCP Decision Tree – Apply to each step where a specified significant hazard is identified

Proposed Revision to the General Principles of Food Hygiene

Q1. Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)*

Yes > This step is not a CCP.

No > Go to Q2


Q2. Do specific control measures for an identified significant hazard exist at this step?

No > This step is not a CCP.

Yes > Go to Q3


Q3. Will a subsequent step prevent or eliminate the identified significant hazard or reduce it to an acceptable level?

Yes > That subsequent step should be a CCP.

No > Go to Q4


Q4. Can this step specifically prevent or eliminate the identified significant hazard or reduce it to an acceptable level? ***

No > Modify the step, process or product to implement a control measure ****

Yes > This step is a Critical Control Point (CCP)


* Consider the significance of the hazard (i.e., the likelihood of occurrence in the absence of control and the severity of impact of the hazard) and whether it could be sufficiently controlled by prerequisite programs such as GHPs. GHPs could be routine GHPs or GHPs that require greater attention to control the hazard (e.g. monitoring and recording).

** If a CCP is not identified at questions 2-4, the process or product should be modified to implement a control measure and a new hazard analysis should be conducted.

***Consider whether the control measure at this step works in combination with a control measure at another step to control the same hazard, in which case both steps should be considered as CCPs.

****Return to the beginning of the decision tree after a new hazard analysis.


Alternatively, the new CODEX Recommended International Code of Practice General Principles of Food Hygiene will include a CCP Determination Worksheet that can be used instead of the Decision Tree. The CCP Determination Worksheet will be as per the draft provided in the 52nd SESSION OF THE CODEX COMMITTEE ON FOOD HYGIENE.

Example of CCP Determination Worksheet

This is a revised version of the Diagram 2 – Example of Hazard Analysis Worksheet provided in CODEX Recommended International Code of Practice General Principles of Food Hygiene 2020

How the Decision Tree Works

Let’s look at a scenario where a process includes sorting because rocks/stones have been deemed to be significant hazard in the raw material.  However, the final product is subject to x-ray inspection after the product is packed. Rocks/Stones would be a significant hazard to the consumer if included with the final product.

Running through the decision tree questions:

Question 1: Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?

No – go to Question 2

Question 2: Do specific control measures for an identified significant hazard exist at this step?

Yes – Go to Question 3

Question 3: Will a subsequent step prevent or eliminate the identified significant hazard or reduce it to an acceptable level?

Yes – That subsequent step should be a Critical Control Point.

Is sorting a CCP?

X-ray inspection should be a Critical Control Point, it is the last step in the process where the hazard is removed.

Sorting is implemented as a prerequisite programme to assist in reducing the hazard and also prevention of damage to product, plant and equipment by the rocks/stones.

New Codex General Principles of Food Hygiene

New Codex General Principles of Food Hygiene

Codex Alimentarius

The Codex Alimentarius Commission has now published a revised Code of Practice (General Principles of Food Hygiene (CXC 1-1969)) and its Annex Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application. The new 2020 revision covers General Principles of Food Hygiene: Good Hygiene Practices (GHPs) and the Hazard Analysis and Critical Control Point (HACCP) System.

According to the Codex Alimentarius Commission* the 2020 Revision of the General Principles of Food Hygiene (CXC 1-1969) and Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application this version of the code of practice: provides a common ground for the control of food safety worldwide and forms the basis for all other Codex hygiene texts and standards. The revision includes updates which will enable better application by food business operators, competent authorities and other stakeholders.

The Codex Alimentarius, or “Food Code” is a collection of standards, guidelines and codes of practice adopted by the Codex Alimentarius Commission*. The Commission*, also known as CAC, is the central part of the Joint FAO/WHO Food Standards Programme and was established by FAO and WHO to protect consumer health and promote fair practices in food trade.

Changes and the new Structure are Highlighted in the Table Below:

The major changes in CODEX HACCP 2020 are summarized in detail below:

  • A new requirement for a Food Safety Culture
  • New & Revised Definitions
  • Enhanced Training Requirements
  • Enhanced Good Hygiene System Requirements
  • Enhanced Good Hygiene Practice Requirements in Control of Operations
  • New Allergen Awareness/Management/Controls
  • A new requirement for Product Traceability
  • Enhanced Consumer Education Requirements
  • Changes in HACCP Principles and a new requirement for Validation of the HACCP Plan

It is somewhat disappointing the “CODEX” Decision Tree has been removed and no alternative offered although Codex HACCP 2020 still makes reference to using a decision tree or other approach to identify critical control points (CCPs) in Chapter Two

Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application, Section 3: Application, 3.7 Determine the Critical Control Points (Step 7/ Principle 2)

The good news is that the Joint FAO/WHO Food Standards Programme Codex Alimentarius Commission 43rd Session 2020 Report (CAC Report 43) highlighted the following with regards to the Decision Tree:

Some Members from the LAC region, while supporting adoption and referring to written comments, highlighted:

  • the importance of the decision tree for identifying critical control points (CCP) as it was essential for implementation of HACCP.

The Chairperson of CCFH clarified that work on the decision tree was currently at Step 2 of the procedure and would be considered at the next session. The decision tree is a useful tool for the application of the general principles document; and CAC43 adopted the revised GPFH at Step 5/8 and noted that work on the decision tree to identify critical control points (CCPs) will continue in CCFH so that once completed it could be included in the GPFH as an annex;

Codex HACCP 2020 Changes in more Detail

GENERAL PRINCIPLES – Management Commitment to Food Safety – Food Safety Culture

As part of Management Commitment to Food Safety the General Principles of Food Hygiene include a Food Safety Culture Requirement:

Fundamental to the successful functioning of any food hygiene system is the establishment and maintenance of a positive food safety culture acknowledging the importance of human behaviour in providing safe and suitable food.

Food Safety Culture Diagram


The two definitions sections in the previous version have been combined and extended. There are new definitions included for Acceptable level, Allergen cross-contact, Competent Authority, Contaminant, Contamination, Food business operator (FBO), Food Hygiene System, Good Hygiene Practices (GHPs), Prerequisite Programme and Significant hazard. Other changes are that Validation has been changed to a new definition Validation of control measures and the definition of Verification has been changed from the application of methods, procedures, tests and other evaluations, in addition to monitoring, to determine compliance with the HACCP plan to whether a control measure is or has been operating as intended.


There is enhanced guidance for training to ensure that personnel have competence appropriate to the operations they are to perform.

RATIONALE: Training is fundamentally important to any food hygiene system and the competence of personnel.

There is guidance that: personnel tasked to perform any activities used in food control should be trained adequately to ensure that they are competent to perform their tasks and are aware of the impact of their tasks on the safety and suitability of the food. Systems should be in place to ensure that food handlers and personnel associated with the food business, such as maintenance staff, remain aware of all procedures necessary to maintain the safety and suitability of food. Records should be kept of training activities

Training programmes to be considered as appropriate to a person’s duties:

Training Programmes to Consider Diagram

Elements to take into account in determining the extent of training required include: the use and maintenance of instruments and equipment associated with food.

In addition, for retail and food service operations, whether personnel have direct customer interaction is a factor in training, since it may be necessary to convey certain information about products (such as allergens) to customers.

Changes in Section 7: Control of Operation

Control of operation is achieved by having an appropriate food hygiene system in place. In section 7 there is new guidance for:

7.1 Description of products and processes

7.1.1 Product description

7.1.2 Process description

7.1.3 Consideration of the effectiveness of GHPs – When such increased attention on GHPs is insufficient to ensure food safety, it will be necessary to implement a HACCP system (Chapter 2).

7.1.4 Monitoring and corrective action

7.1.5 Verification

7.2 Key aspects of GHPs – Some key aspects of GHPs such as those described in Sections 7.2.1. and 7.2.2, could be considered as control measures applied at CCPs in the HACCP system.

7.2.5 Physical contamination

7.2.6 Chemical contamination

7.2.7 Allergen Management

CODEX 2020 states Systems for Allergen Awareness Control/Management should be in place including controls to prevent cross-contact.

Lot Identification & Traceability

The requirement for a traceability/product tracing system has been added in Codex HACCP 2020.

A traceability/product tracing system should be designed and implemented according to the Principles for Traceability/Product Tracing as a Tool within a Food Inspection and Certification System (CXG 60-2006), especially to enable the recall of the products, where necessary

Consumer Education

Consumer education guidance has been enhanced, programmes should enable consumers to understand the importance of any product label information and following any instructions accompanying products, and to make informed choices. In particular, consumers should be informed of the relationship between time/temperature control, cross contamination and foodborne illness, and of the presence of allergens.

Rather than an ANNEX, Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application is now Chapter 2

General Principles of Food Hygiene Sample

Changes in HACCP Principles

There have been some changes to the 7 HACCP Principles as per the diagram below:

Hazard Analysis and Critical Control Points Diagram

Validation of the HACCP Plan

There is an addition guidance 3.11.1 for Validation of the HACCP Plan:

Before the HACCP plan can be implemented, its validation is needed; this consists of making sure that the following elements together are capable of ensuring control of the significant hazards relevant to the food business: identifying the hazards, critical control points, critical limits, control measures, frequency and type of monitoring of CCPs, corrective actions, frequency and type of verification and the type of information to be recorded.

Chapter 2 includes a new ANNEX, Annex 1 – Comparison of control measures with examples.

Overall the changes are emphasizing the importance of using Good Hygiene Practices to Control Hazards in much the same way as the FSMA Final Rule for Preventive Controls for Human Food with a requirements for Monitoring, Corrective Action and Verification.

New Allergen Awareness, Management and Controls are more than overdue given the significant proportion of recalls worldwide that are due to incorrect labelling or allergen cross-contamination.

How to Develop a Food Safety Culture

How to Develop a Food Safety Culture

Food Safety Culture

A successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of the food safety management system. Senior management should plan for the development and continuing improvement of a food safety culture.

Senior management should be implementing a “It is how we do things here” food safety culture. This can be achieved by:

  • Leadership – starting from the top
  • Demonstrating visible commitment
  • Effective communication of company philosophy and policy
  • Ensuring there is accountability from the top of the organization to the bottom
  • Developing employee confidence and mutual trust
  • Developing reward schemes including ‘Employee of the Month’ award
  • Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity
  • Developing an action plan for the development and continuing improvement of food safety culture

To ensure success Senior Management should be directly responsible for food safety by ensuring adequate; organization and support, equipment and facilities, training and education of all employees, reviewing and auditing performance, and driving continuous improvement.

All employees should be empowered and individually responsible for the quality of their work, resulting in a continual improvement culture and working environment for all. Employees should be encouraged and required to notify management about actual or potential food safety issues and are empowered to act to resolve food safety issues within their scope of work.

The philosophy of Food Safety should be promoted throughout the organization and in particular the Food Safety Policy.

Communication processes for promoting food safety include:

  • Team briefings
  • Staff reviews
  • Daily Management meetings
  • Feedback mechanisms
  • Newsletters
  • Notice boards


Senior management should monitor and measure through reports and trend analysis the degree of development of the food safety culture by analyzing information including KPIs from:

  • Hygiene & Housekeeping Audits
  • Internal Audits
  • External Audits
  • Non-conforming products
  • Environmental monitoring
  • Review of implementation plan and numbers trained
  • Employee reviews
  • Staff surveys on values and culture
  • Customer Complaints
  • Staff Turnover
  • Staff Exit Interviews


All employees should undergo individual food safety culture development which can include:

  • Food Safety Policy
  • Food Safety Objectives
  • Food Safety Management System Overview
  • Job Descriptions
  • Job Training
  • Employee Briefing
  • Individual Objectives
  • CCP Controls – Training Procedures & Record Completion
  • PRP Controls – Training Procedures & Record Completion
  • Employee Review


A training matrix can be used for Food Safety Culture Planning:


Records of all training should be maintained, including those of induction, on-the-job, refresher and external training. Training schedules and records should be managed by Department Managers and where applicable include the following records:

  • Training register
  • Operator training review
  • Training matrix
  • Department training matrix
  • Individual Training records including:
    • Description of training
    • Skills description
    • Name of trainee
    • Confirmation of training
    • Date and duration of training
    • Trainer details
    • Verification that the trainer has assessed the trainee and found them to be competent
  • Identifying the competencies needed for specific roles
  • Reviewing and auditing the implementation and effectiveness of the training and the competency of the trainer with a view to taking action to improve the training.


Pest Management in the Food Operations

Pest Management in the Food Operations

All food operations should have a proactive system for the prevention of contamination of products by pests that ensures there are effective controls and processes in place to minimise pest activity and ensure any pest infestation does not present a risk of contamination to products, raw materials or packaging.

Most organizations use Pest Control Association registered pest control contractor to implement a Pest Management programme and maintain the site free from pest contamination unless the organization employs a Pest Management Specialist.

A typical Pest Management contract agreement defines:

  • Company and contractor key contact personnel
  • Description of contracted services and how they will be completed
  • Term of the contract
  • Equipment and material storage specifications
  • A complete inventory of pesticides (must be approved by the regulatory authority for use in a food facility) detailing the safe use and application of baits and other materials such as insecticide sprays or fumigants
  • Emergency call out procedures
  • Records to be maintained
  • Requirement to notify facility of any changes in service or materials used
  • Service personnel including evidence of competency by exam from a recognized organization

The contracted Pest Management service should provide:

  • Site visits and inspections (including the periphery and internal and external buildings) based on a documented risk assessment including service records describing current levels of pest activity and recommendations for taking corrective actions.
  • The provision of a plan/diagram of the site showing the location of all pest control monitoring and prevention measures
  • Flying insect controls including fly killing units
  • Emergency 24-hour call-out service
  • Quarterly biologist inspection reports, visit and trend reports with recommendations
  • A current copy of the certificate of insurance that specifies the liability coverage
  • Spill control materials and procedures
  • Material safety data sheet information to ensure proper usage of pesticide chemicals.

A nominated manager or responsible employee should have overall responsibility for Pest Management on site so that Pest Management is manged within site control rather than relying on contractors. Before agreeing to a contract the Pest Management Contractor should be subject to Supplier Approval to ensure that the contractor is qualified and the pest management programmes will comply with applicable legislation. Copies of the Contract, Service Agreement, Pest Control Reports and Pest Management Contractor training records and qualifications should be held in Pest Control File on site. At the start of the contract a detailed survey of the entire facility should be completed by a qualified Field Biologist and the results documented and used to determine placement of Pest Control devices.

Exterior Bait Stations

Exterior rodent bait stations should be set up to deter rodents from entering the facility. Based on the detailed facility survey, exterior bait stations should be placed along the foundation walls on the exterior of the facility and along the site boundaries. Exterior bait stations containing rodenticides should be tamper resistant, anchored in place, locked, and labelled.

Interior Monitoring

Based on the detailed Field Biologist survey, interior monitoring devices should be placed in strategic sensitive areas specific to the rodent species, and other areas of possible pest activity. Interior rodent monitoring devices identify and capture rodents that gain access to the facility. Interior monitoring devices should be placed in areas where pest ingress is first likely to be identified and secured in position.

Elimination of Pest Habitat

The Field Biologist should identify any possible pest habitat around the site in the quarterly inspections. The nominated manager or responsible employee should take actions to remove or eliminate favourable conditions for pests including eliminating any rodent burrows, rodent runs and areas that provide harbourage or may attract rodents or other pests to the site or outside grounds.

Pest Management Reporting

Records of all Monitoring devices should be maintained, including services performed, to ensure that devices are properly placed and inspected to allow trend analysis of activity. Pest Management Contractor reports include:

  • Signs of pest activity
  • Proofing requirements
  • Actions required by site
  • Type of Pest
  • Pesticide or material applied
  • Pesticide registration number
  • Rate of application or percent of concentration
  • Specific location of application
  • Method of application
  • Amount of pesticide used at the application site
  • Next action/follow up date
  • Date and time
  • Review and investigation of any missing baits
  • Signature of pest controller

Temporary placement of any pest monitoring devices for short-term monitoring should be documented in pest management action reports. All personnel should be trained to identify potential issues caused by pests at induction. A pest reporting procedure should be in place such that any incident or sign of pest activity is immediately reported to the nominated manager or responsible employee and any potential product affected quarantined. The nominated manager or responsible employee maintains a log of pest sightings and the action taken by the pest controller. The Pest Control Contractor should provide reports for all visits and advise on any trends and corrective actions.

Site Standards

Pests pose a major threat to the safety of food. Pest infestations can occur where there are breeding sites and a supply of food. Good hygiene practices should be employed to avoid creating an environment conducive to pests. Sanitation, inspection of incoming materials and monitoring can minimise the likelihood of infestation. Buildings should be kept in good repair and condition to prevent pest access and to eliminate potential breeding sites. Holes, drains and other places where pests are likely to gain access should be protected or sealed. Screens for windows, doors and vents should be used to reduce the risk of pest entry. The availability of food and water encourages pest harbourage and infestation. Potential food sources should be protected and stored above the ground and away from walls. Areas both inside and outside food premises should be kept clean. Waste should be stored in covered, pest-proof containers whenever possible. Pest infestations should be dealt with immediately and without adversely affecting food safety or suitability. Treatment with chemical, physical or biological agents should be carried out without posing a threat to the safety of food. Pesticides should not be used in food areas.


As well as carrying bacteria, rodents can gnaw their way into materials and can cause substantial damage to buildings.

It is important to prevent access to pests, all access doors should be adequately proofed and/or screened.

Adequate measures in place to prevent birds from entering buildings or roosting.

Bird prevention measures

Establishments and surrounding areas should be regularly examined by a competent person for evidence of infestation.

Pest Management Report

How to Reduce Your Complaint levels

How to Reduce Your Complaint levels

Food Complaint Levels

I have been involved in many projects to improve product quality and reduce food complaint levels. One of the best tools for indicating where action for improvement needs to be applied is by analyzing your complaint data appropriately.

Whilst you can identify faults in your factory your customers are your 100% inspection service so respect their feedback. Whilst all of your customers will not complain when they find a problem so you will not capture all of your product faults you will however identify trends.

The first step is to collate all of your complaint data. Your data should then be categorized by product type, complaint type and size. Analyzing complaints by numbers alone will not give you a real picture of your performance. What you need to know is the proportion of complaints you are getting for each product. By far the most practical way of doing this is by using the sales volumes to calculate the proportion of complaints you get for each product. Some people use weight or volume such as complaints per ton or 1000 Liters. My preference is to use complaints per million units.

So, you analyze your complaint data product type, complaint type and size per million units. From this data, you can easily spot the worst performing product lines.

You should then analyze the results for the worst performing products:

Are they all the same size?

Are they produced on the same filling machine/production line?

Is it the same type of complaint?

The answers to these questions will generate your corrective action plans. If products with the highest complaint levels are all the same size it could be a particular problem with that size of packaging. If it is all the same type of complaint then why are some product lines worse than others? If product from one particular production line is generating the highest number of complaints per million units then there must be a reason for this, it needs investigating.

You should compare product performance and if there are significant differences you should ask the question why? At this point complaint trends are useful. For example, when I worked with fresh pasteurized milk sour complaints were higher in larger sized containers. The reason for this was not related to the quality of the product but the fact they took longer to consume and spent more time in and out of the fridge. Such products would be targeted for improvement projects as opposed to corrective action to remedy a problem area.

A few words of caution though, your analysis needs to take into consideration the comparative value of the products and the market. People are more likely to complain about higher value products. Also, some retail customers are much better at reporting complaints from customers to the extent that I used to get 10 times the complaint levels from one particular retailer compared to another for exactly the same product.

My last tip the more data you analyze the better. In the past I have analyzed 3 year’s worth of data. Why? It gives a year on year performance so you can see if things have been improving or deteriorating and also it shows any effects of seasonality. For example, it is not reasonable to compare summer levels of “off” complaints on a fresh product with winter levels. This is why in the Northern Hemisphere I would compare August complaint performance with the complaint levels for August in the previous year.

The complaint analyzer that I have developed based on over 30 years’ experience in the food industry is included in our Food Safety Management System Implementation Packages.

How to Develop a Food Safety Management System

How to Develop a Food Safety Management System

A Food Safety Management System should be planned, established, documented and implemented in order to ensure compliance with company, customer, regulatory and statutory requirements. Senior management need to confirm the scope of the Food Safety Management System including product categories, processes and activities conducted on by the organization.


Senior management need to be committed to the food safety management system and establishing and implementing, then fully communicating and supporting company policies, procedures and objectives. Senior management plan, establish, document and implement the food safety management system by:


  • Establishing and implementing a Food Safety Policy.
  • Communicating and Maintaining the Food Safety Policy.
  • Establishing and implementing Food Safety Objectives.
  • Communicating and Maintaining the Food Safety Objectives
  • Leading and supporting a food safety culture within the site
  • Conducting regular pro-active management reviews and communicating outputs.
  • Communicating commitment to satisfying customer requirements including food safety, quality and service
  • Supporting and planning the development and operation of the Food Safety Management systems.
  • Ensuring the food safety management system is maintained when changes are planned and implemented.
  • Establishing documentation required for the effective development, implementation and updating of the food safety management system and communicating pertinent information throughout the organization.
  • Providing the human and financial resources, and training, to manage the Policies and Objectives effectively.
  • Providing the infrastructure and work environment to manage the Policies and Objectives effectively.
  • Promoting an ethic of continuous improvement throughout the company.
  • Ensuring the strict observation of all food safety system procedures, the use of correct materials and equipment, recording and reporting of both standard and non-standard events and compliance with the company rules.
  • Providing the resources to audit the Food Safety Management system effectively.
  • Providing the resources necessary for the food safety team to effectively implement a Food Safety HACCP plan.
  • Carrying out regular Management Reviews.
  • Implementing and maintaining Corrective Action, Preventative Action and Continuous Improvement Plans.
  • Communicating effectively throughout the food chain from primary suppliers to end consumers including any relevant food safety information.
  • Providing the resource to ensure the company is kept up to date with all industry codes of practice, legislative, scientific and technical information appropriate to the products in the countries of raw material supply, production and product sales.


Due diligence


An effective Food Safety Management System demonstrates due diligence of the company in the effective development and implementation of safe food operations. The Food Safety Management System documents are supported by the completion of specified records for the monitoring of planned activities, maintenance and verification of control measures and by taking effective actions when non-conformity is encountered.

What is a Food Safety Consultant and Why Does Your Restaurant Need One?

What is a Food Safety Consultant and Why Does Your Restaurant Need One?

Food Safety Consultant

As a restaurant owner, you need to abide by many food safety standards. This is where a food safety consultant comes in. Here’s why you need one.

Do you run a restaurant or a business with a kitchen? Does it feel overwhelming when you think about all the balls you juggle every day?

Most of the time, a kitchen manager handles everything from kitchen food safety to personnel changes and sometimes the dining room, too. If you feel stretched thin, read this article to find the help you need.

Below, we’ll tell you all about what a food safety consultant is and why you need one. When you’re ready to make the leap, use our quick tips for choosing a consultant that’s right for your kitchen.

What Is a Food Safety Consultant?

Food safety consultants give you confidence that your kitchen complies with all regulations. They are an outside pair of eyes to keep you and your kitchen staff on track.

Protecting your customers from getting sick is of the utmost importance. With guidelines that change all the time, having someone else around to work alongside you on this project is a must.

Why Does Your Restaurant Need One?

You may think that everyone knows how to follow basic safety rules like wearing gloves or avoiding cross contamination. But sanitizing daily and checking storage temperatures isn’t everyone’s first priority.

In fact, some employees choose not to read the instructions or cut corners to speed things up. This can lead to failed inspections, or worse, sick clientele.

While you want to have speedy service, you also need to avoid these problems. When you hire a consultant, it’s a lot easier to meet both goals.

Here are three big reasons your restaurant needs a food safety consultant.


There are regulations to follow in any kitchen. No matter which food safety management system you follow, you want to maintain your certifications. Here are some standard food safety certifications:

  • BRC certification (most popular) – British Retail Consortium
  • SQF from Global Food Safety Initiative (GFSI)
  • FSSC 22000 also from GFSI

You have to follow many guidelines for legal compliance and certification. Staying on top of everything requires a lot of meticulous list-keeping.

If that’s not you, a food safety consultant can help you stay in compliance. Let someone else make the lists and double check them. Having another person on your team to keep track of the nit-picky items is an asset you can’t afford to work without.

Extra Support

When you hire a food safety consultant, did you know you hire extra support? They are they to help organize and manage the system, but they also give advice.

The support an independent consultant gives is invaluable. Your consultant should be able to help with anything from kitchen emergencies to encouragement and recommendations.

While it’s hard to quantify this type of help, the results you see from its implementation won’t be nebulous.

Current Information

The regulations for these and other organizations or laws change often. It’s hard to keep up with all the requirements.

A food safety consultant keeps up with all the guidelines and assesses your specific needs. They’ll help you change processes or procedures when the rule changes, so that you don’t miss a beat.

You can achieve compliance with the help of a consultant, even with ceaseless updates to the regulations.

How to Choose a Food Safety Consultant

That’s great, you’re convinced that a consultant is important for your restaurant. But if you want to hire one, where do you start?

How do you know that the one you’ve picked out is the right fit for your business? Here are a few questions to ask to make sure you’ve made the best decision.

Do They Have Outside Resources?

Food safety consultants should have access to outside resources because of the field they’re in. Even if they don’t know the answer to a question you have, they should be able to find it within their network of experts and colleagues.

Are They Too Cheap?

Don’t rule out an expensive consultant. Most often, you get what you pay for, and having to pay a little more for quality service is worth it.

Ask all the questions before you go with someone who charges less than their competitors. There’s doubtless a reason they can’t charge the same prices as other consultants you looked at.

Trust your instincts, and triple check before you hire the cheapest option.

Do They Understand the Regulations?

Choosing someone who has memorized the rules won’t help you if they don’t understand them. You need a consultant who has experience applying the rules to the real world.

Being able to recite the rulebook doesn’t mean they can interpret it. Food safety consultants are like the judges in the courtrooms of the kitchen. Instead of quoting it, they have to be able to interpret the law.

Ask your prospective consultant if they have experience in the kitchen. If not, give them some real-life scenarios you have encountered in your own kitchen to respond to. This way you can make sure they know how to handle a difficult situation.

Abiding By Safety Standards

Keeping up with regulations doesn’t have to be a headache you’re used to. A food safety consultant can help you be compliant, keep up with changes, and find the extra support you need.

To choose a consultant, ask some basic questions about their experience, resources, and pricing. Soon your restaurant will be a slick machine, and you will be able to focus on other aspects of the kitchen.

With over 20 years of expertise, TCI can help you achieve these goals. For more about food safety management systems developed around your needs, select a consultant package on our website.

Top 10 Food Safety Tips for Restaurants and Commercial Kitchens

Top 10 Food Safety Tips for Restaurants and Commercial Kitchens

Food Safety Tips

Food safety is one of the most important aspects of running a restaurant. Read on to learn about the top ten food safety tips.

You’re surely aware of salmonella, E. coli, listeria, and norovirus — but did you know that there are over 250 food borne illnesses? Each year, says the Centers for Disease Control and Prevention, 48 million people get sick from a food borne illness. Of those, some 128,000 must be hospitalized, and 3,000 die as a result of getting sick from poor food handling practices. If you supervise a restaurant or commercial kitchen, it is absolutely imperative to understand food safety. We’ve compiled a list of food safety tips to get you started.

Hand It to Safety

One of the most important tips to help keep your commercial kitchen safe is good, old fashioned hand washing. “Employees Must Wash Hands” is more than just a mandatory poster on the kitchen, bathroom, or break room wall. Make hand washing an iron-clad rule. Train your employees in proper hand washing procedures.. And administer strict and swift consequences for those who don’t follow this rule.

Make Gloves Mandatory

In addition, your workers should be trained in the proper use of gloves. Whenever someone is preparing food in a commercial kitchen, they should be wearing gloves. Not only that, but they should change gloves frequently. New gloves should be worn each time the cooks switch from raw to cooked food, for example, and vice versa. Far too many food service workers see gloves as magical shields that somehow render germs powerless, no matter what that person does with their hands. If you see staff members wearing gloves while scratching or touching their skin, and then handling food without changing the gloves, stop them. Retrain your staff as necessary.

Clean and Sanitize Equipment Daily

Of course, the equipment in the kitchen must also be cleaned and sanitized not just on the regular, but properly. Your may have specific requirements surrounding food sanitation, so make sure to ask. In general, you won’t go wrong with hot, soapy water and/or commercial bleach. Wash down all dishes, prep containers, pots and pans, utensils, cooking surfaces, cutting boards, and countertops. Sweep and mop not just the kitchen proper, but also the coolers, freezers, and storage areas.

Set a Regular Deep Cleaning Schedule

It’s also a smart idea to set a firm schedule of how often the entire kitchen should be scrubbed down and cleaned out. Asking your employees to take care of heavy-duty cleaning “as needed” or “when they have down time” is asking for a dirty kitchen that will fail a health inspection. During a deep clean, tackle the ovens, grills, fryers, and appliances. Don’t forget grease traps, range hoods, fans and vents, lighting fixtures, and the like.

Avoid Cross Contamination When Storing Food…

Raw meat and poultry should be kept entirely separate from their cooked counterparts. In addition, keep them away from vegetables, prepared sauces, rolls or bread, and any other foodstuff. This practice ought to be a no-brainer. Anyone who’s ever watched even one episode of “Kitchen Nightmares” knows that raw chicken can’t be kept in a bucket with cooked steak. But you’d be surprised how many shortcuts busy kitchen staff will resort to! The same policy of strict separation goes for knives, cutting boards, utensils, mixing and prep bowls, trays, storage containers, and thermometers. You must have separate prep and cooking tools and supplies for raw poultry, raw meat, raw seafood, cooked proteins, vegetables, and other foods.

Make Proper Food Storage a Priority

Do you understand how different types of food — dry vs. wet, hot vs. cold, vegetables vs. meats — must be stored? Do your employees? You can be certain that the health inspector does, so you should too. Several factors must be taken into consideration when storing food. Ventilation is important, as is temperature. Container sizes, how those containers are sealed, and how food is rotated in and out of containers and storage areas are all crucial to safety in commercial kitchens. Never store food directly on the floor, even if it’s in a box or bin. Never store meat on upper refrigerator or walk-in shelves, where it could potentially drip onto other ingredients underneath. Make sure your employees understand and follow all protocols related to storage.

Follow the Rule of First In, First Out

Want to make certain that your ingredients are as safe as possible, while minimizing the amount of food you need to discard? Be strict about following a “FIFO” policy. FIFO stands for “First In, First Out.” It means that the oldest supplies should be used up first. There are two super simple ways to accomplish this. One is to label every box, bag, package or container with the date it arrived in your kitchen. Then, place it behind any existing stock of that same product or supply in the walk-in or on the shelves. That makes it easier for busy chefs to grab the oldest product first. While FIFO might not be quite as exciting as YOLO or even BOGO, it will help your restaurant or commercial kitchen run more safely and efficiently.

Make Sure Storage Temperatures Are Right

According to the Food and Drug Administration, food should be keep at 41°F or below, while hot food needs to reach 135°F or above. This is to ensure that harmful bacteria never gets a chance to grow. Keep a thermometer in the refrigerator as well as in the freezer. The refrigerator should operate at 40°F or below, while the freezer temperature must be 0°F or below.

Cook All Food to Temp, Too

Similarly, cooking food to the proper temperature will also prevent food borne illness (as well as dishes returned to the kitchen for being undercooked!). Chicken must be cooked to 165°F. Ground beef, veal, lamb, and pork should reach 160°F. Train your cooks to use thermometers often, rather than relying on the look or feel of a dish to know if it’s thoroughly cooked.

Food Safety Tips Are Not Enough

We’ll be honest: these food safety tips are fairly elementary. Most home cooks understand them, and most of your workers probably know the basics of keeping things clean and sanitary, too. In order to truly feel confident that your commercial kitchen or restaurant is in compliance with all necessary regulations and guidelines, contact us. We’ll be able to better assess your needs, and help you achieve compliance, by knowing more about your kitchen!

Information About SQF Code Certification

Information About SQF Code Certification

Safe Quality Food

SQF code or the Safe Quality Food code is the set of rules that govern the standardization of products that are distributed to consumers by food suppliers for the sake of safety and quality management. The certification program in place is tailored towards maximized consumer protection and regulation of all related trading activities. Meeting product requirements like safety, trace and quality within cost estimates is thus ensured to enable both parties to have a fair trading platform.


This was developed in 1994 from a harmonized agreement to produce a program that when implemented would be applicable in food industry as this is one of the most important components of an economy and far more sensitive. Experts in food safety, quality management, food processing, food regulation, food retailing, agricultural production systems, Hazard Analysis Critical Control Point and food distribution came together and had a joint consensus to formulate these codes. Every participant in this industry is therefore strictly required to follow the rules and regulations.


In August 2003, the Food Marketing Institute acquired the rights to this program after which there was an establishment of the Institute Division to manage this program. The set standards meet the Global Food Safety Initiative due to the satisfaction of meeting the benchmark requirements. This has been incorporated by countries globally to govern the production and supply to industries.


The Technical Advisory Council is responsible for overseeing the necessary changes and makes reviews and recommendations. This must be in line with the contemporary requirements and expectations in the sector. Another important source of information to be used in decision making is the stakeholders who make comments on things that should be included; this makes their input very vital.


After the reviews have been made and the necessary amendments considered, there is a necessity for a date on which these changes are implemented and adjustments made. The official date for the making of amendments is the third anniversary date of a previous edition of the same document. This is usually done by the responsible panel that come together and make the amendments.


Situations may arise where an important amendment needs to be done before the three year amendment period passes. Is such a case, the amendment segment has to be included in the current edition as it may take too long to wait for a complete review cycle. This helps prevent loopholes in regulations which may lead to misuse of marketing rights.


Suppliers are required to make a prompt implementation of amendments within a period of six months of a posting of a new edition either on an official website or other media. A provision is given to all users to make a contribution by way of their views and changes that they want implemented. Address for delivery of such reviews is given to enable fast communication.


Knowledge of the SQF code is very important as it gives clear guidelines on the trade ethics that must be keenly followed by every participant in the industry. Failure to abide by these rules and regulations may call for strict legal action. The document has been scrutinized for any case of ambiguity to facilitate perfection, as it must be very comprehensive to cover every detail of this industry in an effort to cultivate healthy trading activities.

What Is SQF Code?

What Is SQF Code?

SQF Code

The SQF Code is a Global Food Safety Initiative (GFSI) benchmarked Food Safety Management System standard which is recognized worldwide. SQF certification program is managed by the Safe Quality Food Institute (SQFI), a part of the Food Marketing Institute (FMI) which represents food retailers and wholesalers and has annual collective sales of over $600 billion.


The SQF Code is a Hazard Analysis Critical Control Points (HACCP)-based food safety and quality management system standard based on CODEX Alimentarius Commission HACCP and National Advisory Committee on Microbiological Criteria for Food (NACMCF) Principles and Guidelines. In 2012 SQF Code Edition 7 replaced SQF 2000 Code edition 6 for Food Manufacturing & Distribution and the SQF 1000 Code edition 5 which was for Primary Producers.


The Global Food Safety Initiative provides a framework for assessing the compliance of food safety management certification schemes based on ‘benchmarking’ the scheme against a model of essential requirements produced by group of food safety experts. GFSI officially announced that the SQF Code 7th Edition Level 2 had been successfully re‐benchmarked against GFSI Guidance Document Edition 6 on 15th October 2012. There are a number of benchmarked standards recognized by GFSI but SQF is the only program recognized by the GFSI that is headquartered outside of Europe.


The current edition of the SQF Code (edition 7.1 July 2013) covers all sectors of the food industry from primary production to transport and distribution.

SQF Code is current recognized by GFSI for certification to the following scopes:


  • Al: Farming of Animal Products
  • Bl: Farming of Plant Products
  • C: Pre-Processing of Animal Products
  • D: Pre-Processing of Plant Products
  • El: Processing or Animal Perishable Products
  • Ell: Processing of Plant Perishable Products
  • Elll: Processing of Animal and Plant Perishable Products
  • ElV: Processing of Ambient Stable Products
  • L: Production of Biochemicals
  • M: Production of Food Packaging


All Farming of Fish and Bll Farming of Grains and Pulses are to be submitted as scope extensions when 10 accredited certificates are in place.


Unlike most GFSI benchmarked standards the requirements for all organizations in the food chain are covered by a single standard, the SQF Code. Organisations do not need to comply with all of the SQF Code as it has relevant sections based on SQF food sector categories. For example, organizations in Food Sector Category 2 Growing and Harvesting of Animal Feeds need to comply with Module 2: System elements and Module 3: GMP for animal feed production and organizations in Food Sector Category 10 Dairy Food Processing need to comply with Module 2: System elements and Module 11: GMP for processing of food products.


The SQF Code covers a broad range of categories, overall there are 35 Food sector categories defined ranging from primary production to brokers and agents.


There are a range of food sector categories related to primary production and preparation including production, capture and harvesting of livestock and game animals, growing and production of fresh produce, fresh produce packhouse operations, harvest and intensive farming of fish and slaughterhouse, boning and butchery.


There are a range categories for the processing of food products and for foods manufacture based on the type of food, then there are other sector categories including transport and distribution of food products, food wholesaling and manufacture of other food related items such as dietary supplements, pet food, agricultural chemicals, animal feed and food sector packaging.


In order to achieve certification all organizations need to Module 2: SQF System Elements of the SQF code then depending on the food sector category comply with Food Safety Fundamentals defined in other relevant modules such as Good Agricultural Practices for Farming, Good Manufacturing Practices, Good Aquaculture Practices for Farming of Fish or Good Distribution Practices. Normally an organisation will need to comply with the SQF System Elements and one of the Food Safety Fundamentals modules although there are occasions when more than one will be applicable for instance when an organisation has primary production and food processing.


There are mandatory Elements in SQF Code Module 2 that must be complied with in order to achieve certification; these are summarized in the table below:


SQF Mandatory Elements /Clause
Management Policy 2.1.1 Product Release 2.4.8
Management Responsibility 2.1.2 Validation and Effectiveness 2.5.2
Food Safety & Quality Management System 2.1.3 Verification and Monitoring 2.5.4
Management Review 2.1.4 Corrective and Preventative Action 2.5.5
Document Control 2.2.1 Internal Audit 2.5.7
Records 2.2.2 Product Identification 2.6.1
Food Legislation 2.4.1* Product Trace 2.6.2
Food Safety Fundamentals 2.4.2 Product Withdrawal and Recall 2.6.3
Food Safety Plan 2.4.3 Food Safety Plan 2.4.3
Food Quality Plan (at level 3) 2.4.4 Training Program 2.9.2
* Compliance with legislation regarding Allergens (2.8.2 Allergen Management not mandatory – may be not applicable)


In the table you will see that Food Quality Plans are included, this is because certification to the SQF code is at three levels:


  • Level 1 Food Safety Fundamentals: An entry level for new and developing businesses covering only Food Safety Fundamentals and basic food safety.
  • Level 2 Certified HACCP Based Food Safety Plans: Requires a food safety risk analysis, documented Food Safety Plans and compliance with Module 2 Food Safety Elements and the relevant Food Safety Fundamentals Modules.
  • Level 3 Comprehensive Food Safety and Quality Management System: As per Level 2 but also requires a food quality risk analysis and documented Food Quality Plans.

Level 2 certification is benchmarked by GFSI and therefore a recognized food safety certification scheme whereas level 1 certification is not recognized by GFSI.


Level 2 certification is benchmarked by GFSI and therefore a recognized food safety certification scheme whereas level 1 certification is not recognized by GFSI.


Unlike some GFSI benchmarked standards, the SQF code and practical guidance documents are free, this means you can review the SQF Code and decide if it suits your organisation without any financial outlay. In addition to this the SQFI have Licensed Training Centers which offer SQF related training courses including:


  • Implementing SQF Systems
  • SQF Levels 1 & 2 – Food Safety Fundamentals and Certified HACCP Food Safety Plans
  • SQF Level 3 – Comprehensive Food Safety and Quality Management Systems
  • SQF Practitioner Training
  • Auditing SQF Systems


Being recognized by GFSI, the SQF Code and SQF Certification are widely accepted by retailers, foodservice providers and regulatory authorities around the world. SQFI also provides online access to a list of suppliers which buyers can access and identify relevant SQF certified suppliers.