Food & Beverage Reporter August 2018

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By Linda Jackson
Parliament has been busy with food
issues. And about time too! Three
new regulations were promulgated
recently, all of which may have an impact
on your business.
R638 – NEW HYGIENE REQUIREMENTS
Regulations governing general hygiene
requirements for food premises, the
transport of food and related matters,
a regulation under the Foodstuffs,
Cosmetics and Disinfectants Act, (Act
No. 54 of 1972) is the long-awaited
update for the current R962.
This regulation has been a long time
coming, but hopefully you saw the draft
R364 that was promulgated in 2014 so
the final version will not be such a shock.
What’s the purpose of the regulation?
This regulation deals with the basic
hygiene requirements that every food
handling business should have in place
to ensure minimum legal compliance.
This is what we refer to as the entry level
regulation. It deals with the certificate
of acceptability that every food handling
business should have in place and the
legal physical must-haves for a hygienic
environment.
Your Certificate of Acceptability
The good news is that you don’t need
to re-apply for your Certificate of
Acceptability - on condition that the
person in charge, the site address or the
products and processes haven’t changed
since the issue of the last one!
However, the regulation now more
clearly states that you may not make any
changes to your facility without informing
the local authority first. You have one
year from 22 June to sort out any
issues you may have with your current
certificates, so I would definitely have a
good look at the old ones!
READY, STEADY,
Regulation 4(6) relating to fees has
been removed but I would check the fee
schedule for the local authorities in this
regard.
What needs to change in your
premises?
• The standards for buildings remain
the same. Regulation 3(c) iv now also
requires a controlled refuse area.
• We finally have clarification on hot
and/or cold water: You must have hot
where possible!
Standards and requirements for
facilities on your premises
• Additional requirements for the
heat treatment of milk and bulk milk
storage tankers used in retail are also
addressed specifically to improve the
safety of bulk milk sales. Look out:
there is a whole page of requirements.
• For meat and butchery, documented
cleaning procedures, including
disassembly, are required.
• For ready-to-eat non-packaged foods,
these must now also be protected
against contact by bare hands.
• The surface temperature of frozen
foods that may be re-frozen has been
lowered to 5 degrees from 7 degrees.
More detailed requirements are given
for thawing practices too.
Protective clothing
• You will now be required to provide
clothing for visitors too.
Duties of the person in charge
of food premises
You should sit up and pay attention
here! This section represents the most
significant changes, in my opinion. The
person in charge (this should be the
person who is able to supervise food
handling practices on a day-to-day basis,
and who will be liable for any criminal
acts) must now be able to demonstrate
that he/she is suitably qualified and/
or trained in principles and practices of
food safety and hygiene. This should be
accredited training or provided by the
inspector. No definition is given
for accredited.
The person in charge must then still
ensure that all food handlers are trained
in principles and practices of food safety
and hygiene – this is a different focus
from the previous regulation.
In addition to training, the person in
charge must evaluate the effectiveness of
the training through assessments (again
no definition) and arrange for follow-up
training if required.
Finally records of training must be
kept and training programmes must
be updated.
In addition to this requirement
for training, the person in charge
must demonstrate compliance with
the regulations by keeping records of
processing, production and distribution.
These should be kept for at least six
months after the shelf life of the product.
A traceability system is now required,
and a recall procedure must be in place.
A recall activation must be now be
formally reported to the local inspector
and the National Directorate: Food
Control.
No definition has been provided for
recall but the definition of the CPA should
be considered.
In general
The order of some of the regulations has
been changed to flow more logically
20 AUGUST 2018 | FOOD & BEVERAGE REPORTER www.fbreporter.co.za