Food Safety Law: What does ‘due diligence’ mean in practice?
All reasonable precautions
Reasonable precautions in food safety law simply amount to the process of identifying all the food safety critical stages of food production, storage and distribution, then identifying suitable control measures to adequately prevent the risk of food safety failures and putting in place appropriate management control procedures to ensure they effectively happen.
Reasonable precautions can be demonstrated by producing satisfactory HACCP documentation and QMS documentation. There is an established format for all this documentation, broadly accepted within the food industry and endorsed by the Food Standards Agency and it is obviously advisable for food businesses to follow accepted formats, especially for presenting evidence in Court.
SME foodservice businesses should essentially be complying with ‘all reasonable precautions’ if they have set up Safer Food Better Business to the satisfaction of their local EHO.
For larger multi-site foodservice businesses with their own policies and procedures in place the complexities multiply. Whether the experience promised by the brand is delivered consistently across all outlets depends on the consistent application of group policies and procedures – hundreds or even thousands of staff, undertaking dozens of daily tasks that add up to optimised service and safety.
Food safety law – demonstrate compliance
All due diligence
‘All due diligence’ means operating those ‘all reasonable precautions’ explained above – in other words, actually carrying out the control measures and management procedures that have been set out in the HACCP and QMS documentation… i.e. ‘doing it’!
‘All due diligence’ can only be practically demonstrated by producing bona fide records of implementation in some format acceptable under scrutiny to a food safety law enforcement officer (i.e. an EHO) and, ultimately, a Court of Law.
If, for example, the HACCP analysis identifies that the safety of a particular food requires appropriate temperature control at one or more stages of production, storage and distribution, then presenting corresponding temperature records consistent with the HACCP risk assessment will be the only practically acceptable means of demonstrating due diligence to the satisfaction of the local EHO and a Criminal Court.
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