Food hygiene and hospitality
Many churches pride themselves on their hospitality – indeed it is jokingly said that you can judge a church by its coffee. Joking aside we do like to gather for food whether it is refreshments after a service, bring and share lunches, or providing meals for groups such as the over 60’s. So when do food hygiene requirements apply?
The biggest question is whether you need to register with the Food Standards Authority(FSA). The requirements applies (regardless of whether you give food away or sell it) to “…undertakings, the concept of which implies a certain continuity of activities and a certain degree of organisation”. This is definition is open to interpretation and although the FSA has issued guidance it is ultimately up to your local environmental health officer (EHO) whether the requirement applies to you.
So what does it mean?
‘..organisation..’ This does not mean that there is a well-structured coffee duty rota but to the processes required to produce the food. Opening a pack of biscuits does not require organisation but the purchase, preparation, storage and serving of a full meal does.
‘..continuity..’ The FSA’s view is that this means providing food on at least on occasion in a typical month.
In the FSA’s list of example situations an organisation holding an event six times a year where a two course meal is provided using food cooked at home by volunteers but reheated in the hall kitchen (typical of many bring and share lunches) does not need to be registered as the event does not have continuity. However if it is a monthly event providing free hot food then registration is required.
Here are some common myths based on the FSA’s advice for charity and community groups.
“We need to have Food Hygiene Certificates.” This is not a legal requirement but Rural Ministries recommends that one person in the church should be responsible for food provision even if FSA registration is not required. They should also undergo training and hold a current level 2 Certificate in Food Hygiene. That person can then advise on what should (and should not) be done even if they are not present at all events.
“We need to provide labels on allergens.” There is rightly a lot of concern about allergies but if you do not need to be registered then you do not need to provide labelling. It is of course good practice to consider the risks carefully.
“Home kitchens need to be inspected if you serve home-made food.” Not true! Home-made food is perfectly acceptable so long as those making it follow good hygiene advice. Food must be transported and stored safely and be ‘safe to eat’. This means that cooked or cold foods (ready to eat) should not be left unrefrigerated for more than 4 hours.
“We can’t afford an expensive commercial kitchen.” A catering quality kitchen is not essential even if FSA registration is needed but it should be easy to keep clean without damaged worktops or other ‘dirt traps’. FSA registration may have some requirements beyond a domestic standard kitchen such as a separate hand washing sink.
Food hygiene is always important and good practice should always be followed but if you are unsure about the requirements or whether you should register then talk to your EHO. Do remember that interpretation may vary so do your research about what you are proposing and consider whether this has ‘continuity’ and ‘organisation’ and be prepared to gently argue your case.