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Page 1 of 8 CIEH Professional Examination Food 1 July 2009 Food – Case File You are a recently qualified Environmental Health Practitioner who has just been appointed to Chadwick Valley MBC’s Food Safety section as a Food Hygiene Inspector. Sebastian Simple has just opened a small chain of ethically and environmentally-conscious restaurants about a year ago. Even in this short time, and in a cash-strapped local economy, ‘Simple Tastes’ offers high-quality burgers cooked to the customer’s taste, with baked potatoes and a variety of salads. Sweets include a choice of Italian ice cream flavours, cheesecakes and gateaux. A decision not to offer alcohol with food, but instead to provide a range of soft-drink ‘cocktails’, has generated a great demand from parents of older children looking to celebrate birthdays. It is now necessary to book tables several weeks in advance. The set-up in all eight of the restaurants is much the same; chef-managers are supplied each day with a lean burger mix of a spiced minced meat, to which additional ingredients are added, to order. Burgers are formed into moulds creating uncooked weights of 100g (the ‘miniburger’), 250g (the ‘maxi-burger’) and 500g (the ‘mega-burger’), and these are grilled under a gas flame to the customer’s preference. It has become quite fashionable in the year since opening for customers to order their burgers cooked ‘rare’. The other feature of the menu worthy of note is the increasing demand for more adventurous salad ingredients, and the restaurants now have a circular ‘salad bar’ in the centre of their seating areas. In addition to the traditional mix of leaves and salad vegetables, croutons and dressings, customers may add such things as pine nuts, hummus, taramasalata, Feta cheese and chorizo sausage. An inspection of one of the restaurants ‘Simple Tastes – Take 5’ during a busy Friday evening service, results in a not entirely satisfactory outcome. Although the structure is still in good condition, and the cleaning of fixtures and fittings is of a high standard, it is apparent that the standard of management has fallen since the restaurant first opened. It is clear that staff are not being properly supervised to ensure that they practice high standards of personal hygiene, and in so doing protect food against contamination. You observe a male food handler leaving a WC compartment and failing to wash his hands before handling food, albeit raw burgers awaiting cooking. From the vantage point of the chef’s office you watch as two food handlers –one of whom is the chef you have just been seen handling raw minced meat - preparing salads for the ‘salad bar’ by taking out items from the refrigerator, cutting them up and putting them straight into bowls, ready for the waiting staff to use for replenishment. You take a moment to observe customers using the ‘salad bar’ and notice two young women periodically using their fingers to load their plates, and one is seen tasting the sauces and dressing with a ringed forefinger. You ask the chef why the ‘sneeze guards’ appear to have been detached from the ‘salad bar’, and she explains that this was a decision of her immediate predecessor who said that they were ‘more trouble than they’re worth’ as they slowed up the ‘self-service’ when young children (principally, the under 10 year olds) tried to serve themselves and found themselves dropping Page 2 of 8 CIEH Professional Examination Food 1 July 2009 food on the floor because they could not properly control the spoon or tongs. Aside from slowing up the process and causing wastage, the dropped food presented a slipping hazard to other customers. You look down at the floor and notice that there is a still a fair amount of food being dropped – cherry tomatoes, cubes of cucumber and mayonnaise – which customers are walking over. You decide to check the temperature of the burgers as they complete their cooking. You choose one of the ‘mega-burgers’ with fresh chillies and coriander which has been ordered ‘rare’. On checking with a disinfected probe a brown juice emerges and its core temperature measures 64oC. When you raise this with the chef/manager he tells you that it is his understanding that as long as the burger reaches a temperature of 63oC ‘it’s legal’. You refer to the ‘Simple Tastes’ cooking manual that was drawn up a year ago and find that the section on cooking temperatures has been covered over with a sticky label that reads ‘keep the burger under the grill until it browns up – put the cooked burger into the heater cabinet (set at 65oC) if not served immediately - SS’’. Page 3 of 8 CIEH Professional Examination Food 1 July 2009 Food – Tasks Task 1 Before you leave the premises you consider it necessary to raise the most urgent matters with the chef/manager and to suggest the taking of immediate action on his part to protect the health of the customers still in the restaurant. So as it is clear what you have said to him, make notes on three things that you advise him to do straight away (together with a brief explanation why) bearing in mind that you will shortly be raising matters of general procedure with the MD (Sebastian Simple) so that they can be implemented across the whole chain of restaurants. (30 marks) Task 2 A meeting with the MD, Sebastian Simple, called for the following morning has to be postponed because he has been called over to Ireland to deal with an urgent family matter. You are left a telephone message to set out in a letter (to be sent by e-mail) the things that you believe need to be considered across the chain as a whole, and he will attend to these in person on Monday morning. Accordingly, draft a message that takes up the issues of the personal hygiene of food handlers, the management of the salad bars and the cooking of burgers, drawing attention to any legal requirements and guidance that relates to these issues, whilst stressing their importance in terms of food safety. (70 marks) For the purpose of this examination you should justify any assumptions you have made within the answers given Page 4 of 8 CIEH Professional Examination Food 1 July 2009 Food – Marking Advice Task 1 Before you leave the premises you consider it necessary to raise the most urgent matters with the chef/manager and to suggest the taking of immediate action on his part to protect the health of the customers still in the restaurant. So as it is clear what you have said to him, make notes on three things that you advise him to do straight away (together with a brief explanation why) bearing in mind that you will shortly be raising matters of general procedure with the MD (Sebastian Simple) so that they can be implemented across the whole chain of restaurants. (30 marks) The Task refers specifically to matters that demand the immediate attention of the chef/manager in order to protect the health of the customers still in the restaurant. These should be framed in terms that reflect the risk that exists on the Friday evening and focused on protecting the customers on the premises from the food that may be contaminated with pathogenic bacteria or viruses arising from poor hygiene practices observed. One might reasonably assume co-operation on the part of the chef/manager, but the action should be decisive. 1. The chef who you have seen visiting the WC and then handling open food was instructed to discontinue handling food until he had thoroughly washed his hands as he may have had potentially harmful bacteria on them from his bowel or the raw meat, and these may have caused the contamination or cross-contamination of salad items that are going to be consumed without heating or any treatment that is likely to reduce the contamination. Salad items that this individual handled should be removed from display and disposed of forthwith. One would want to see the food physically discarded. 2. The food items that you have seen being touched by the hands of the customer should be removed from display and disposed of, as it is possible that the hand-tomouth contamination may communicate Staphylococcus aureus onto the foodstuffs. There is also the possibility of some sort of physical contamination. If the ‘sneeze guard’ can be re-assembled then this should be completed overnight, but this will do nothing to protect the food already contaminated. 3. Until such time as you can explore the cooking process in detail with Mr Simple, you should instruct the chef/manager to ensure that all burgers subsequently cooked during the service should be heated to ensure that their core temperature reaches 70 oC for a minimum of two minutes (better still, 75oC for 30 seconds), and any undercooked Page 5 of 8 CIEH Professional Examination Food 1 July 2009 burgers should be discarded, or, if feasible, to have their cooking resumed to ensure that this is the case for the remainder of the service. If there is any doubt that this can be achieved then you might instruct the person in control to remove the ‘mega-burger’ from the menu and to instruct waiting staff to inform customers that burgers can no longer be served ‘rare’. Task 2 A meeting with the MD called for the following morning has to be postponed because he has been called over to Ireland to deal with an urgent family matter. You are left a telephone message to set out in a letter (to be sent by e-mail) the things that you believe need to be considered across the chain as a whole, and he will attend to these in person on Monday morning. Accordingly, draft a message that takes up the issues of the personal hygiene of food handlers, the management of the salad bars and the cooking of burgers, drawing attention to any legal requirements and guidance that relates to these issues, whilst stressing their importance in terms of food safety. (70 marks) It is possible that the officer would send a formal letter to Mr Simple as an attachment, though this is not in the spirit of the task which specifically refers to the drafting of a ‘message’. Previous contact with Mr Simple would suggest that he is a co-operative sort, and it would inappropriate to couch the letter in legalistic terms if this interfered with the desire to direct the MD through the force of the argument as much as the threat of formal action. It should be saying to Mr Simple that these are really important issues but that you trust him to attend personally to them at the earliest opportunity. The most important thing is that the candidate communicates with Mr Simple on the three issues stated in the Task, but not on matters of general import, or indeed on anything that might have emerged during an inspection but is not mentioned in the case file. Clearly, though, the candidate might feel drawn to make reference to the need to see personal hygiene, management of the salad bars and the cooking of burgers incorporated into a ‘food safety management system based on the principles of HACCP’ but does not require here a discourse on the principles of HACCP. Page 6 of 8 CIEH Professional Examination Food 1 July 2009 Dear Mr Simple, As instructed I am setting out below several things that came to light in my inspection of ‘Simple Tastes – Take Five’ on Friday evening which I believe should be considered as being relevant to the Simple Tastes chain as a whole. I would urge you to give these your immediate consideration when you return on Monday, as they would attract unfavourable attention from an enforcement officer observing what I saw on Friday, but, more importantly, could result in a case or cases of food-borne disease I have detailed, where appropriate, where these hygiene matters appear in the legislation, together with the documents that make reference to them. As a general rule, the hygiene requirements of food business premises such as yours feature as Chapters in Annex II of EC Regulation 852./2004 and these are subject to enforcement through the Food Hygiene (England) Regulations 2006. In the case of cold- and hot-holding of food the legal requirement is itself contained in the 2006 Regulations (Regulation 30, Schedule 4). I would draw your attention to the Industry Guides to Good Hygiene Practice – Catering Guide (1999) which still provides valuable guidance on compliance with the legislation, but, more importantly, sets out good catering practice. (5 marks) 1. The personal hygiene of food handlers Aside from the role played by careless food handling in the cross-contamination of ‘high-’risk’ foods by bacteria found in raw meat (see below), there is the immediate hazard that a food handler might be harbouring a pathogen in their gut and this may contaminate any number of foodstuffs in the restaurant. This is especially possible as I witnessed a food handler at ‘Take 5’ leave the WC without washing his hands. Although there is no evidence to suggest that this individual, or any of your other staff, are excreting a pathogen such as Salmonella or Hepatitis A virus (a pathogen that is exclusively passed on by the faecal-oral route), it is quite possible that someone is doing so, without exhibiting symptoms. Certainly, you should have regard to the recently revised guidance on the personal hygiene expected of a food handler who is suspected of harbouring a pathogen in their gut or on their skin (‘Food Handlers: Fitness to Work – a practical guide for food business operators’), and to adopt the hygiene regime expected of someone who might be excreting a pathogen. To this end, all food handlers, but especially those handling open, high-risk foods, should be scrupulous with their hand washing, using soap and hot water to cleanse them, and hot air dryers and/or disposable paper towels to dry them. (20 marks) Page 7 of 8 2. CIEH Professional Examination Food 1 July 2009 The management of ‘salad bars’ Whilst I would applaud you for providing such an adventurous assortment of foodstuffs on your salad bar, these are potentially points of where ‘high-risk’ foods are contaminated by customers who forget or ignore the fact that others will be eating from the same bowl or dish. Some of these are also foodstuffs that may support the growth of pathogens and so there are limitations on the length of time that they are displayed for sale outside of the temperature limit of 8oC specified in Appendix 4 of the Food Hygiene (England) regulations 2006. Although it might be that the ‘sneeze guards’ on the ‘bar’ are only missing at ‘Take 5’, you should ensure that they are reinstated at each of your units as they present a physical barrier between customer and the food. Clearly, as a barrier they will present some degree better to impose an age limit on visiting the ‘bar’ of impediment to children and so I would encourage you to consider whether it would be some sort of management such as requiring children to be assisted by an adult when attending the salad bar. You might like to consider adopting the following ‘rules’ on the display of food at the salad bars in the group: - ensure that there is always a ‘sneeze guard’ in place - provide separate utensils for each type of salad - do not put salad on display too far in advance - store food at 8oc or below - remove all salad items and their containers before replenishing - provide customers with clean plates if they return for second helpings - remove from display any unused salad items within 2 hours (20 marks) 3. The cooking of burgers Arguably, the most serious issue concerns the need to subject the minced beef burgers to a sufficiently high temperature for long enough to destroy pathogenic bacteria, especially those that might be present in raw beef such as Escherichia coli, one type (O157) which caused outbreaks at Wishaw in Scotland in 1996 and in South Wales in Page 8 of 8 CIEH Professional Examination Food 1 July 2009 2005. It is generally accepted (though not required by law) that meat should be heated so that at the core of the burger the meat is held for 2 minutes at 70oC or for 30 seconds at 75oC. The problem with using visual appearance such as ‘juices running clear’ as an indicator of adequate heating is that burgers are simply too small, and the browning of the surface has been demonstrated to occur at temperatures substantially lower than 70oC. Once cooked, the burgers must be kept at a minimum of 63 oC, though not for more than 2 hours (Regulation 30 and Schedule 4 of the Food Hygiene (England) Regulations 2006). I am most concerned that you should be responding to the demand for ‘rare’ burgers as these are not steaks comprising a sold piece of meat where any bacterial contamination is likely to be on the external surface and therefore capable of being eliminated by ‘flash’ cooking. Minced meat distributes any contamination on the muscle to the inside of the burger and therefore resists the impact of being ‘flash’ cooked. (20 marks) It remains for me to ask you to give careful re-consideration to your ‘food safety management system’ in light of these observations, and whilst some of the points noted during the inspection at ‘take 5’ constitute pre-requisites of good hygiene practice, the risks identified are best controlled and monitored by a HACCP-based system. However, let us discuss this further after you have confirmed on Monday (by e-mail or telephone – 01234 56789) that the matters set out below have been attended to, and, in particular, that any possibility of serving under-cooked burgers has been eliminated. Yours truly, A. Candidate. (5 marks)