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

Graham Walker

Director of TrainingThe Royal Environmental Health

Institute of Scotland

Food Standards Agency Guidance

E.coli O157 - Control of Cross ContaminationGuidance for food business operators and enforcement authorities

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

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

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.

Preventing Cross ContaminationRequired level of protection:Separation of raw and ready to eat (RTE)foods and their preparation to the highestdegree physically possible, which includesdedicated (single purpose) use of complex,hard to clean, equipment such as vacuumpackers, mincers and slicers.

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.

Raw foodRaw 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.

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.

Pennington Report 2009

“For a vac packer, I do not think that sucha demonstration is possible to allow itsuse for ready to eat foods and raw meat.”

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

Separation is the only reliable control

Greatest extent physically possible:Size of establishment must be adequate

‘Dual use’ of complex equipment shouldnever be considered safe.Small utensils must be for separatedesignated use unless heat disinfectedbetween use

Separation is the only reliable controlMinimum level of limited exceptions

Equipment washing sinks if disinfected beforeused to disinfect ‘clean area’ equipment

Non food contact wall and worktop surfaces.

Staff, provided there is a full hand-washingregime

E. coli O157 Cross Contamination

Decontamination considerations:A misplaced reliance on cleaning withchemicals to sanitise surfaces in contactwith raw and cooked meats was a veryimportant issue in the Central Scotlandoutbreak. Pennington report 2009

Enquiry into the Aberdeen Typhoid outbreak

1964

“Only detergents and sterilisers whosebactericidal properties have been provedshould be used in food premises”

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.

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

Approach to cleaning and disinfection

Two stage approach only

1. Clean to a visibly clean standard2. Disinfect using suitable disinfectant in

accordance with the manufacturer’s instructions

Use of a single stage sanitiser is not sufficient

Additional considerationsHygienic designMachinery supplied for use at work from 1995 should be CE marked toindicate that it was designed to complywith the European Machinery Directive,Directive 2006/42/EC, and all previousVersions BS EN 1762-2:2005 +A1:2009

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

Additional considerations

Additional considerations

Additional considerations

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.

Hand Washing

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

Cross Contamination CultureA 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 oncurrent procedures.

Cross Contamination Culture

Lead to a presumption that operations wouldnot be allowed to continue until the foodbusiness operator implements effective andcredible procedures.

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.

Training and supervisionEffective 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.

Training and supervisionDisinfection 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.

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.

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.

Link to the Cross Contamination Guidance

E.coli O157 Control of Cross-ContaminationGuidance for food business operators and enforcement authorities

http://www.food.gov.uk/foodindustry/guidancenotes/hygguid/ecoliguide

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)

Any questionsContact me

0131 229 2968

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