PART 1 THE FOOD SAFETY (GENERAL FOOD HYGIENE) REGULATIONS 1995 (a) THE IDENTIFICATION AND CONTROL OF FOOD HAZARDS FOLLOWING THE PRINCIPLES OF REGULATION 4(3) Regulation 4(3) states: "A proprietor of a food business shall identify' any step in the activities of the food business which is critical to ensuring food safety and ensure that adequate safety procedures are identified, implemented, maintained and reviewed." "Food business" includes the steps involved in the processing, packaging, storage, distribution and sale of the honey. This is the first time that there has been a requirement to identify food hazards. The reason for introducing this is to try and ensure that you think about things that are likely to go wrong and take precautions to prevent them doing so. To comply with this requirement, it is necessary to break the production of honey down into a series of steps, e.g., the removal of honey as one step. Having done that, we consider the hazards and control measures and decide whether or not it is critical for food safety to control the hazards. The controls identified as necessary are then implemented. While the legislation does not require any form of documentation, you may well decide that some would be useful to show that the controls have been properly identified and preventative steps taken. Even an understanding of this Code and a copy at hand may show that you are adhering to the legislative requirements. Environmental Health Departments recommend some documentation. An explanation of the regulatory requirements of the five principles (a) (e) in Regulation 4(3) is as follows: Text of Regulation
There are three categories of food hazard (potential to cause harm). These are microbiological, chemical and physical. 4(3)(a) analysis of the potential food hazards in a food business operation Microbiological mainly bacteria that cause illness but also yeasts and moulds. The nature of honey inhibits bacterial growth but bacterial spores such as Clostridium botulinum can survive (there have been no reported cases of Botulism associated with honey in the UK). Some honey producers and packers label honey as being unsuitable for infants under 12 months because of the occurrence of Infant botulism and its association with honey. Chemical this could occur in the hive as a result of treatments or applications or from cleaning chemicals used in the honey house. Physical from the hive, from the beekeeper during removal of the honey and from such things as glass and other packaging. The beekeeper must properly identify which hazards are likely to occur within their own business. In honey production, physical contamination is the most likely hazard although chemical residues are becoming increasingly important. 4(3)(b) identification of the points in those operations where food hazards may occur; The beekeeper should prepare a flow diagram, breaking the operation down into a series of identifiable steps and at each step consider each of the potential hazards in turn, microbiological, chemical and physical. Details of hazards that might be realised should preferably be recorded. In relation to honey, the most likely problem is one of contamination, mainly physical, but could be with any of the other two food hazards, microbiological and chemical. Although bacteria are unable to grow, they may survive. Other micro organisms such as yeasts may, given the right conditions, grow and multiply although they are more likely to affect product quality rather than product safety. 4(3)(c) deciding which of the points identified are critical to ensuring food safety ("critical points") Critical control points (ccp) are those at which hazards must be controlled to ensure that hive products are safe for human consumption. All steps where the products can be contaminated must be properly controlled and should be designated as critical control points.
This part of the regulation requires two courses of action 4(3)(d) identification and implementatio n of effective control and monitoring procedures at those critical points; (a) controls have to be determined; (b) there has to be a system of monitoring these to ensure product safety. The control must be adequate to prevent the hazard being realised or be effective in reducing it to a safe level. In the main, the control will be the prevention of contamination or, where this is not possible, a processing step such as straining to reduce or remove any possible contaminants. Control will also be required over such things as staff hygiene and the cleaning of premises as these will help prevent contamination. Where a critical control point is likely to go out of control, there should be a procedure for corrective action to be taken to prevent the honey or other hive products going out of specification as the object is to try and achieve "nil defects". 4(3)(e) review of the analysis of food hazards, the critical control points and the control and monitoring procedures periodically, and whenever the food business's operations change. This requires that the situation must be reviewed when changes occur and on a regular basis. When you buy new or second hand equipment, when you change premises or methods, you should consider the effects these changes may have on food safety. Note: Whilst hazard analysis can be used to control both safety and quality, priority should be given to the safety of the honey when considering potential hazards. (b) FLOW DIAGRAM AND GENERIC ASSESSMENT In accordance with Government recommendation, the Scottish Beekeepers' Association has produced a flow diagram and generic description of honey hazards and their control. The purpose has not been to analyse all honey hazards or identify all critical control points on behalf of SBA members but to give helpful information on typical hazards and critical control points. A blank form is included at the rear of the documentation (Appendix A). This may be photocopied and used
to personalise and add to the generic assessment. You may wish to include other steps in the flow diagram to suit your own operation. PROCESS FLOW DIAGRAM HIVE & HONEY REMOVAL TRANSPORTATION OF HONEY IN SUPERS UNCAPPING, EXTRACTION & SETTLING STRAINING STORAGE PREPARATION TO BOTTLE & BOTTLING
DISTRIBUTION & DISPLAY GENERIC HAZARD ANALYSIS HONEY PRODUCTION CRITICAL CONTROL POINTS STEP HAZARD ACTION THE HIVE AND HONEY REMOVAL Contamination from chemical repellents, preservatives, paints, vermin and bee disease treatments. Contamination from soil and grass. Use only non tainting preservatives and paints. Control vermin. Use only approved disease treatments. Use good hygiene practices. Protect honey in supers. TRANSPORTATION OF HONEY IN SUPERS Contamination from trailer, car, environment, animals or insects. Load surfaces to be clean check prior to use. Supers to be protected from contamination. UNCAPPING, EXTRACTION AND SETTLING Contamination from the equipment, premises and the beekeeper. Ensure hygiene awareness and high standard of personal hygiene. Premises are of satisfactory construction and clean. Equipment to be of food grade and clean prior to use. STRAINING Failure of straining to remove all extraneous material. Strainers to be food grade and of an appropriate size to remove physical contaminants.
STORAGE Contamination by other substances and from container. Fermentation in storage due to high moisture content. Moisture content to comply with the statutory requirements. Store away from substances likely to taint, strong sunlight and extremes of temperature. Avoid mechanical damage. PREPARATION TO BOTTLE AND BOTTLING High process temperatures resulting in spoilage. Contamination from the environment, equipment, glass bottles and metal. Do not overheat. Premises and equipment to be of a good standard and clean. DISTRIBUTION AND DISPLAY Damage due to poor handling and tampering at point of sale. Prevent damage by appropriate packaging. Use of tamper evident seals. (c) THE FOOD SAFETY (GENERAL FOOD HYGIENE) REGULATIONS 1995 SCHEDULE I RULES OF HYGIENE The hygiene requirements that you have to comply with are contained in chapters 1 10 within Schedule I of The Food Safety (General Food Hygiene) Regulations 1995. Each chapter deals with a different requirement; those which are most likely to be applicable to the smaller scale beekeeper are as follows: THE FOOD SAFETY (GENERAL FOOD HYGIENE) REGULATIONS 1995 SCHEDULE I RULES OF HYGIENE Number Application of Chapter
Chapter III Chapter IV Chapter V Chapter VI Chapter VII Chapter VIII Chapter IX Chapter X Requirements for dwelling houses, etc. Transport Equipment Food waste Water supply Personal hygiene Provisions applicable to foodstuffs Training The following tables are in two columns; in italics in the first column is the legal requirement this is an exact copy of the relevant part of the Food Safety (General Food Hygiene) Regulations 1995; the second column is an interpretation by the Scottish Beekeepers' Association of what is necessary for the beekeeper to do to comply with that requirement. Other action may well be appropriate. If in any doubt, prior to incurring expenditure, you are advised to seek further guidance. Guidance is available from the Environmental Health Department of your Local Authority. CHAPTER III REQUIREMENTS FOR DWELLING HOUSES ETC. Legal Requirement 1. Premises shall be so sited, designed, constructed and kept clean and maintained in good repair and condition, as to avoid the risk of contaminating foodstuffs and harbouring pests, so far as is reasonably practicable. Kitchens within domestic premises which are of good construction, well maintained and clean, are satisfactory for the smaller scale extraction of honey, further processing and bottling. Prior to use, the kitchen must be cleaned, ancillary areas must be clean, domestic activities such as food preparation and laundry should be discontinued and the area free from pests and domestic animals. Children should be excluded. 2. In particular, and where necessary
(a) appropriate facilities must be available to maintain adequate personal hygiene (including facilities for the hygienic washing and drying of hands, hygienic sanitary arrangements and changing facilities); Within the bathroom or sanitary accommodation, there should be a flush water closet, wash hand basin with hot and cold water over suitably drained to the sewage system. At the wash hand basin there should be non tainting soap and suitable, clean hand drying facilities. (b) surfaces in contact with food must he in a sound condition and he easy to clean and, where necessary, disinfect. This will require the use of smooth, washable, non toxic materials, unless the proprietor of the food business can satisfy the food authority that other materials used are appropriate; All surfaces must be clean and capable of being maintained in a clean condition. They should be non absorbent, smooth and nontainting. Equipment in direct contact with honey should be non reactive and preferably of stainless steel or food grade plastic. Prior to use, the spray application of a nontainting antibacterial cleaner is recommended and the application should be in accordance with the manufacturers' instructions. (c) adequate provision must he made for the cleaning and, where necessary, disinfecting of work utensils and equipment; Within the kitchen the sink with hot and cold water over and suitably drained to the sewage system will be satisfactory for this purpose. A supply of non tainting detergent should be available. The use of a spray nontainting antibacterial cleaner is also recommended after washing and before use. (d) adequate provision must he made for the cleaning of foodstuffs; In honey production, adequate straining should be available after extraction.
(e) an adequate supply of hot and/or cold potable water must be available; All water used should be fit for human consumption and wholesome. Water from a private supply may require testing or treatment to ensure adequacy. Mains water, until the point it enters the house, can be assumed to be satisfactory. To prevent contamination water used should be direct from the rising main. (f) adequate arrangements and/or facilities for the hygienic storage and disposal of hazardous and/or inedible substances and waste (whether liquid or solid) must he available; Water must not come in direct contact with honey. Waste honey should be stored in clearly marked covered receptacles whilst waiting final disposal to prevent attraction to bees, other insects and vermin. (g) adequate facilities and/or arrangements for maintaining and monitoring suitable food temperature conditions must he available; Where honey is to be subjected to heat treatment, e.g., in softening, sufficient thermometers and, additionally, a thermostat should be provided to prevent over heating. Honey is best stored under cool conditions. Honey should only be placed in clean containers that, where appropriate, are capable of being adequately covered. Storage areas should be free from tainting substances. (h) foodstuffs must be so placed as to avoid, so far as is reasonably practicable, the risk of contamination Food handlers must maintain a high standard of personal hygiene, wear protective clothing and take steps to prevent contamination of the honey. Specifically, domestic pets and children should be excluded and activities likely to expose the honey to contamination discontinued during processing. Persons suffering from communicable diseases or conditions should not act as food handlers.
CHAPTER IV TRANSPORT Legal Requirement 1. Conveyances and/or containers used for transporting foodstuffs must be kept clean and maintained in good repair and condition in order to protect foodstuffs from contamination, and must, where necessary, he designed and constructed to permit adequate cleaning and/or disinfection. It is usual to transport honey supers, sections, etc. in cars, vans or trailers. The means of transport must be clean, capable of being kept clean, and free from any substance likely to cause contamination of the honey. Supers may be covered with screens and tarpaulin or placed in clean plastic bags to exclude physical sources of contamination and protect from rain. 2(1) Receptacles in vehicles and/or containers must not he used for transporting anything other than foodstuffs where this may result in contamination of foodstuffs. Covered pails are likely to be used for the transportation of broken honey comb. These should be food grade and clean, capable of being maintained in a clean condition and not have been used for any other substance that may taint or otherwise contaminate the honey. Covering of these receptacles is recommended. 2(2) Not appropriate for smaller scale beekeepers. 3. Where conveyances and/or containers are used for transporting anything in addition to foodstuffs or for transporting different foodstuffs at the same time, there must he effective separation of products, where necessary, to protect against the risk of contamination. If any other materials, e.g., repellents or engine oil, being transported, they must be kept separate from honey to ensure that there is no contamination.
4. Where conveyances and/or containers have been used for transporting anything other than foodstuffs or for transporting different foodstuffs, there must be effective cleaning between loads to avoid the risk of contamination. Prior to the collection of honey, vehicles, trailers, or other means of transport, must be properly cleaned and free from any source of contamination. Plastic sheets may be used on which supers may be placed or supers may be placed within clean, plastic bags for transportation. 5. Foodstuffs in conveyances and/or containers must be so placed and protected as to minimise the risk of contamination. Honey should not be placed so as to expose it to risk of contamination during transport. See (4) above. 6. Not appropriate for the transportation of honey. CHAPTER V EQUIPMENT REQUIREMENTS Legal Requirement 1. All articles, fittings and equipment with which food comes into contact shall be kept clean and the season whilst in use the equipment must be kept clean and sanitised prior to each use. Prior to use at the start of the season, all equipment must be checked and effectively cleaned. During the season whilst in use the equipment must be kept clean and sanitised prior to each use. (a) be so constructed, be of such materials, and be kept in such good order, repair and condition, as to minimise any risk of contamination of the food; Ideally, equipment should be constructed of stainless steel but other materials, such as food grade plastic, and the use of plastic linings may be appropriate.
(b) with the exception of non returnable containers and packaging, be so constructed, be of such materials, and be kept in such good order, repair and condition, as to enable them to be kept thoroughly cleaned and, where necessary, disinfected, sufficient for the purposes intended; All equipment should be smooth, impervious and free from areas that are inaccessible for cleaning. (c) be installed in such a manner as to allow adequate cleaning of the surrounding area. Equipment should be installed to enable all round cleaning. This may mean that the equipment should be moveable if located against a wall surface. CHAPTER VI FOOD WASTE Legal Requirement 1. Food waste and other refuse must not be allowed to accumulate in the food rooms, except so far as is unavoidable for the proper functioning of the business. Suitable and sufficient covered receptacles should be provided for the storage of refuse. They must be removed from the production area as necessary during the working day and at the end of each working day. They should not be allowed to overflow. 2. Food waste and other refuse must be deposited in closable containers unless the proprietor of the food business can satisfy the food authority that other types of containers used are appropriate. These containers must be of an appropriate construction, kept in sound condition, and where necessary be easy to clean and disinfect. Honey unfit for human consumption should be kept in covered containers suitably identified to prevent accidental usage until final disposal usually as animal feed or returned to the bees. Refuse other than unfit honey should be stored in clean, covered receptacles. Broken glass should be wrapped to prevent injury.
3. Adequate provision must be made for the removal and storage of food waste and other refuse. Refuse stores must be designed and managed in such a way as to enable them to he kept clean, and to protect against access by pests, and against contamination of food, drinking water, equipment or premises. Refuse should be stored in suitable covered containers in an external area whilst awaiting final disposal. CHAPTER VII WATER SUPPLY Legal Requirement 1. There must be an adequate supply of potable water. This potable water must he used whenever necessary to ensure foodstuffs are not contaminated, A public supply is likely to be potable on entry to the premises; thereafter it is the beekeeper's responsibility to ensure satisfactory protection of the water to prevent contamination. Private supplies may require to be examined to ensure suitability. Water is not used in contact with honey but may come in contact indirectly where used for cleaning of equipment, services and personal hygiene. 2. Not appropriate to smaller scale beekeepers. 3. Not appropriate to smaller scale beekeepers. 4. Not appropriate to smaller scale beekeepers. CHAPTER VIII PERSONAL HYGIENE Legal Requirement
Every person working in a food handling area shall maintain a high degree of personal cleanliness and shall wear suitable, clean and, where appropriate, protective clothing. The appropriate clothing will vary according to he type of work being carried out. Veils, overalls, etc., will be required for the removal of the honey and these may well be worn until the honey is placed in store. Thereafter, protective clothing and head gear of a type worn by food handlers would be appropriate. All clothing must be kept clean to prevent the risk of contamination. Beekeepers will maintain a high standard of personal hygiene, wash hands frequently and refrain from any activity likely to cause contamination. They should obey the Hygiene Code contained at the end of this document. 2. No person known or suspected to be suffering from, or to he a carrier of, a disease likely to be transmitted through food or while afflicted, e.g. with infected wounds, skin infections, sores or diarrhoea, shall be permitted to work in any food handling area in any capacity in which there is any likelihood of directly or indirectly contaminating food with pathogenic microorganisms. Beekeepers should not process honey if they have any communicable disease, skin infection or condition likely to contaminate the honey. CHAPTER IX PROVISIONS APPLICABLE TO FOODSTUFFS Legal Requirement
1. No raw materials or ingredients shall be accepted by a food business if they are known to be or might reasonably be expected to be so contaminated with parasites, pathogenic micro organisms, or toxic, decomposed or foreign substances, that after normal sorting and/or preparatory or processing procedures hygienically applied by food businesses, they would still be unfit for human consumption. Any honey purchased from another beekeeper should be checked to ensure that it is satisfactory. Written assurances may be obtained. All products of the hive should be checked prior to processing to ensure fitness. This will generally mean inspection using senses and the use of a refractometer. 2. Raw materials and ingredients stored in the shall be kept in appropriate conditions designed to prevent harmful deterioration and to protect them from contamination. Honey should be stored in cool, dry, rodent proof establishment accommodation prior to processing. 3. All food which is handled, stored, packaged, displayed and transported, shall be protected against any contamination likely to render the food unfit for human consumption, injurious to health or contaminated in such a way that it would be unreasonable to expect it to be consumed in that state. In particular, food must be so placed and/or protected as to minimise any risk of contamination. Adequate procedures must be in place to ensure pests are controlled. Honey in supers should be covered and/or screened. All containers used for the storage and packaging of honey should be food grade, sound, clean and free from any residues or physical contaminants. Pest control measures must be in place. Glass jars used should be physically checked prior to use to ensure that there are no glass fragments on internal surfaces. Procedures should be in place to discard honey if a glass breakage occurs. 4. Hazardous and/or inedible substances, including animal feedstuffs, shall he adequately labelled and stored in separate and secure containers Food that is not intended for human consumption should be clearly labelled and kept separate from other food. Feedstuffs for bees should be similarly separated. CHAPTER X TRAINING Legal Requirement
1. The proprietor of a food business shall ensure that food handlers engaged in the food business are supervised and instructed and/or trained in food hygiene matters commensurate with their work activities. Honey is a low risk food with the main hazard being physical contamination. As a minimum, it is recommended that beekeepers be provided with and have regard to information on personal hygiene and practices such as is contained in this Guide. Beekeepers are strongly advised to present themselves for the SBA examinations. In this way they will obtain further information. Contact the Education Convener for further details or examination syllabuses.