Food & Beverage Reporter August 2018

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Food & Beverage Reporter has partnered with Food Focus to bring you enhanced coverage of food safety/compliance issues. Food Focus addresses the full range of compliance factors which South African food businesses have to face, including occupational health and safety hazards, environmental demands and corporate social responsibility. Find out more at www.foodfocus.co.za 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
REGULATE! and the wording and formatting of the document is much more user-friendly. When do the changes comeinto effect? You have to comply immediately although some requirements such as your qualification give 12 months to implement the changes from date of promulgation. R607 – THE HACCP REGULATION Regulations relating to the Hazard Analysis and Critical Control Point systems: amendment, a regulation under the Foodstuffs, Cosmetics and manufacturers who produce ready to eat, heat-treated processed meat products to implement a HACCP system • Processed meat products being meat and poultry products that have been cured, heated, smoked, matured, dried, marinated, extracted, extruded or any other treatment • Heat-treated means to a core temperature of 72 degrees • Sold as ready to eat means the consumer does not have to do anything further to the product before consuming – they can be eaten in their “raw” state without further cooking by the consumer. Unfortunately, despite numerous attempts to get clarification from the National Department of Health, it remains unclear whether alternative HACCP standards such as ISO 22000 or SANS 10330 will be acceptable. As SANAS is not accredited by FSSC, the legality of current FSSC implement the changes from date of promulgation. R588 – MAXIMUM LEVELS OF METALS Regulations relating to Maximum Levels of Metals in Foodstuffs, a regulation under the Foodstuffs, Cosmetics and Disinfectants Act (Act no. 54 of 1972) has been in the pipeline since last year. This regulation repeals the current version: GNR.500 of 30 April 2004. This new regulation has several detailed definitions for classes of food that are covered rather than trying to list each genus separately. Additional products such as rice are included, while some metals such as zinc and copper have been removed. Make sure you review the regulation closely in line with your formulations and specifications. When do the changes come into effect? We have three months to implement the changes from date of promulgation. SECTOR Meat and edible meat offal, preparations and products ENTERPRISE All processors of ready to eat heat treated meat products as defined by SANS 885 Poultry, preparation and products All processors of ready to eat heat treated poultry products as defined by SANS 885 Disinfectants Act, (Act No. 54 of 1972) has been amended in light of the recent Listeriosis outbreak. This regulation amends the current version: GNR.908 of 27 June 2003. And one might well ask why it took almost 15 years to the day to act. And the actions taken although justifiable in light of the source of the outbreak, have elicited this question from many in the industry: “Why just these sectors; why not all of us?” The regulation amends Annexure B, making the implementation of a SANASaccredited HACCP certification compulsory in key sectors (see table above) (SANS 885:2011 is the South African national standard for processed meat products. Version 3 is currently under revision). R607 will require all 22000 certificates to show compliance with this regulation is also not known. While the need for this regulation is clear, the pathway for implementation remains confusing. Watch this space. When do the changes come into effect? We have nine months to
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Food & Beverage Reporter August 2018

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