In contrast to the earlier systems, which had a battery of 16 government agencies that controlled food safety and complicated the process to procure a licence, the Government of India has appointed one agency, the FSSAI – Food Safety Standard Authority of India. In 2006, the FSSAI introduced a law which was recently passed and has been in effect from August 5, 2011.
The new law is based on the previous law governing the PFA (Prevention of Food Adulteration) and has incorporated features from other internationally accepted laws. This is convenient as it provides a single window for clearance. On the flip side, standards are set higher and are on an international scale. Perhaps the most stringent addition in the law is the penalty structure. Under the new law, the penalty structure ranges between `50,000 to `10 lakh and imprisonment could be for six months or for lifetime based on the type of adulteration and the law that has been broken.
One thing that has majorly changed in the new food safety act is the penalty structure. Initially the penalty was `1000-2000 and one could get away by paying the money. The government has realized that unless the penalty is severe people compliance is practically not possible. This is the first time that a jail term has been introduced in big way in the new food safety act because paying a lakh of rupees as fine for an hotelier is pocket change. He could violate any rule and throw a lakh of rupees as penalty, but coming out of jail is going to be difficult.
In the new Food Safety Act, there will be a special court dedicated to handle food safety cases which will come up for trial in less than 30 days. This means that if someone is found violating any food safety norms, the FDA (Food and Drug Administration) body in Maharashtra who is currently implementing the FSSAI, files a case and it will go on trial in less than 30 days. The act also gives the consumer the right to sue a company – something unheard of in our country until now!!! Hopefully, this is the beginning of implementing hygiene and food safety a little more seriously. Furthermore, one of the unique aspects of the act is specifying the level of qualifications of the food safety officers to ensure that they are professionals with the required competency. All standards are clearly specified and sector specific, leaving no scope for multiple interpretations.
Training happens everywhere and it has to be a continuous process especially in the F&B and kitchen areas. These can be checked with regular audits, mystery audits and perhaps retraining. Beginning from the induction, it has to be drilled in again and again till it becomes a habit and start thinking and feeling it as a way of life. It is only then kitchen hygiene can become a reality. Right from the GM and head of the departments have to make it a part of their regular briefing to make it work.
Auditing & HACCP
HACCP (Hazard Analysis and Critical Control Point) has been widely propagated as a certification to ensure Hygiene and Food Safety. Unfortunately, in hotels which are certified under HACCP, the standards vary greatly from one organization to another. The new law is clearly spelt out so it will not have varied validation. HACCP is basically a preventive measure to reduce incidents that violate food safety and hygiene. Although not mandatory, it provides a guideline to ensure that there is a system in place. It is a means to an end and when used internally, it can ensure that the regulations are complied with.
HACCP training can only be carried out by certified trainers and the certification is valid for three years. Most chefs undergo this training. There is also a HACCP certification and ISO 22000 for the hotel which are for food safety but extends beyond the boundaries of the kitchen and includes the rooms and therefore Housekeeping. It ensures that there are safe practices being followed in the entire hotel.
In most cases, an internal audit is conducted by a microbiologist or food technician operating from an internal food safety laboratory or by an outside agency that specializes in carrying out these tests. This routine highlights areas prone to poor hygiene standards so that the problem can be rectified. Typically, on a daily basis, there is a hygiene manager who collects random equipment swabs and hand swabs as well as samples of raw and cooked food. These audits bring to light any shortcomings that can then be investigated and rectified. Auditing is not restricted to the kitchen area, as it covers any area where food and water are present and therefore includes the rooms and even the swimming pool.
Despite the continuous process of internal audit, it must be noted that when there is an external audit which is generally informed in advance, there is often an artificial standard of cleanliness that is projected. Such audits are not regular and are often carried out on the basis of a guest complaint.
A big challenge in hotel kitchen is dealing with a lot of cultural backgrounds… It is a bigger challenge to establish a general guideline for personal hygiene…When it comes to other aspects of personal hygiene, audits which entail a fear of punishment, is a more effective tool to maintain the baseline of kitchen hygiene.
Whether it is FSSAI or HACCP, the statements need to be translated into actual provisions when designing a kitchen. However, there is no documentation to address this issue. There are no infrastructure norms laid for the purpose of hygiene and food safety, so if one notices that there are identical infrastructures, it is due to the fact that they belong to a large international group having their own brand SOPs. Clearly, there are no codes or list of codes or checklists starting from the design perspective. In the US, you cannot start construction until the facility adheres to a set of codes listed in a rule book. Even the new law does not provide for a concrete set of codes like the ventilation code or the per employee square footage code. Creating one’s own set of standards is fine just as long as it surpasses the statutory requirements laid down by the Government.
Speaking about equipment in general, if it is in a pre-opening stage, the technical services team specifies what equipment are required. Most hotels have their own technical specifications and some recommend the brands based on which the kitchen is designed. The chefs come in at a much later stage, when the equipment is expected to come in. The question here is whether this makes sense, considering that engineering and maintenance are not the people who are actually going to cook the food. To overcome this, ideally a technical services team would include people who have had hands-on experience working in the kitchen and they are the ones who specify what the layout should be. Although this works in a chain of outlets with a standard set-up and a core centralised technical service team, it becomes quite complex.
The technical team faces a problem because it needs to be versatile. If not, the chefs face a problem because when they come in later and realise that they cannot work in the set-up, they start shifting things around. The technical team would object to this movement of equipment despite the fact that the layout is not workable. This is where the drawback lies. What seems to work better is to decide the generic term of the equipment. For example, one may decide that one needs a combi-oven or one may need a continental range with an oven. One may specify brands or adhere to brand standards that are set. All these are interlinked with the type of cuisine being served.
Three levels of training is given at Hyatt – Food safety & hygiene and allegiance for chefs, personal hygiene for everyone and kitchen stewarding for maintaining basic kitchen hygiene. The training begins with the orientation process and follows with periodic training. To translate the same regular tests are conducted. If the equipment swabs fail or the hand swabs fail, we bring the staff back into training. If the same person fails the tests again, then he or she is barred from entering the kitchen till he or she has learnt to follow the rules.
If the operator is an International Chain, then the norms are clearly documented in booklets which pin-point every detail. This often proves to be a problem when crisscrossing these details with what has already been done. Rectification can only be done at a certain stage. At the macro level of planning the brief is created and the space planning is discussed with the architect. It is only after this is done that the micro level planning is conducted wherein the kitchen drawings are made ready and the services at the premises i.e. plumbing, electricity, exhaust… Once the plan has been transferred from paper to reality, minor changes may be possible but any major change is likely to have repercussions on all other areas as well. Looking at the drawing board stage, there are two ways of planning a kitchen. One is to build a structure and then plan a kitchen around it. The other is to plan a kitchen and build the structure around it. The worst scenario is when the entire construction was originally planned for another purpose and then converted into a kitchen or even when there is a takeover of a property, leaving no scope for structural change. Once built, changes in infrastructure may not only be expensive but they may simply be impossible.
We are involved a lot of time in the project stage and there is a war of thoughts between the revenue generating areas and so called non-revenue generating areas. It has been a misconception in the minds of people that all the back-of-the-house facilities are more of a support service and do not create revenue directly. The architects focus first on the front area, position it well and then squeeze in the back facilities. But we make them realize that the responsibility of architect is to invite guests and the responsibility of the back of the house facility planner is to retain the guest. Once that is understood, people have agreed across the board. Earlier, the architect was always first on the board, but today we are there on the board shoulder to shoulder with the architect.
In some instances, the operator may be decided after the restaurant or hotel is built… After building the property, the owners invite someone to manage it or acquire a franchise. It may be that the restaurant chain was designed to be Chinese and is now having to serve Indian cuisine. No amount of adaptation can rectify such a situation. Kitchen layout is not only about locating equipment to keep a correct flow of work, but also about making sure that the facilities of the services are proper. For example, just to fulfil a workflow requirement, ‘hot zones’ cannot be located in an area where building constraints do not allow for exhaust. Macro level planning requires a greater focus. It has a cascading effect that is detrimental… let us say that the slab level or the clearance between slabs is incorrect, then there is a problem with the ducting, the inadequate height in the kitchen makes the exhaust ineffective and this leads to the discomfort of the staff
because of excessive perspiration which is also a hygiene problem.
At ITC, when we construct a hotel, a team of senior chefs based at the headquarters in Kolkata are involved right from the planning stage. With the corporate chefs and the senior chefs being involved at the design stage, issues like drainage, garbage room… everything is taken care off.
One can safely conclude that the challenge of creating the right environment for Kitchen Hygiene lies in proper kitchen design. Unfortunately, there is no ideal design as the variables for each kitchen differ greatly like the cuisine, the menu, the type of service and essentially the work flow. Of all the design aspects, the water supply and drainage, waste disposal and exhaust must feature on the top of the list. In most established chains, there is a team of senior chefs involved at the project stage so that they are involved in approving design and the subsequent onus of executing operations rests with the kitchen team. With the rapidly increasing focus on food safety, one can look forward to fewer challenges in the recently built kitchens of star category hotels. The crux of the matter is that management is partial to allocating space to what they perceive as revenue generating areas. Seating areas in the restaurants seem to be a more lucrative proposition.
While chefs do understand the value of real estate, there has been in recent times a certain level of awareness and a jump in the expectations of the customer with regard to the entire dining experience. Since food is an integral part of this, chefs are always trying to maintain the balance between the understanding that kitchens are getting smaller globally and the fact that customer expectations are rapidly rising. To overcome this, stand alone restaurants have the option of keeping the core activity of the kitchen in the same premises and use cheaper rentals nearby for staff facilities and main stores. There are also cases where the production unit may be somewhere else and the semi-prepared products come to the restaurant for finishing and are then served to the guest. This reduces the space needed if one were to carry out production from scratch. This is often the case in restaurant chains that operate with a central kitchen and satellite kitchens. To take this one step further, the semi-prepared products might even be outsourced! In resort hotels there is no dearth of space but in cities where the FSI is much lower, there are a lot of constraints and compliances that require to be adhered to.
It’s not that chefs do not understand the value of real estate and how every business owner wants more seats and smaller kitchens. But at the same time there’s also a certain level of awareness and jump in the expectation of customers with respect to variety, quality and dining experience, of which food is an integral part. As chefs we try to always run the balance between trying & understanding owners and meeting diners’ expectation. Most of the times it doesn’t work!
In fact, it is difficult to draw a line for the responsibility for kitchen hygiene. The supply chain also affects the food safety. Vendors need to maintain the frozen food at the requisite temperatures. Most vendors do not invest in the refrigerated vans an here begins the challenge of food safety. This is particularly with reference to dairy products and meats. It is very difficult to get vendors to agree to the standards of delivery. Taking all of this into consideration, the misconception of considering a kitchen to be a back area can have dire consequences.
Recently, the GM of a 5-star hotel property which is coming up in Mumbai, approached us to know about the pest management aspects that need to be considered at the time of construction. He was more interested in the kitchen part of it and so the chef joined the board and together we worked on the kitchen design. It all started with the receiving area, which is a major pest issue. When you are talking of kitchen hygiene, actually the chain goes back to the vendor point… there are places where the receiving area is not covered. There should be at least a kind of netting to prevent birds roosting. The droppings can happen on the food that is received leading to food contamination. Thereafter, we moved inside the kitchen. We consulted on the number of entry and exit points. More the entry and exit points, more the challenges of pest management.
Improper planning and layout can interfere with the workflow and create a chaotic state at peak hours of operation. Poor kitchen design can also radically affect cleaning processes and pest control. The crevices and corners that are so difficult to access for cleaning are the same ones that harbour bacteria and pests. In fact pest management perspectives place a strong focus on the receiving area. These are often uncovered and have birds nesting above, not to mention rodents and other animals making their way into this space. Bird droppings as well as animal excreta might well contaminate the raw foodstuffs before they even enter the kitchen area.
Hence, solutions like cockroach trap drains with water seal which does not allow the pest to enter in the reverse direction and air curtains at all entry and exit points to keep flies away can be put in place. In order to maintain hygiene levels, the exhaust systems installed should enable collection of grease to avoid it from falling all over the place.
But, hygiene levels cannot be achieved with just the right kitchen plan; availability of right cleaning products and systems plays an equally crucial role. The kitchen should be equipped with facilities which in turn will affect the personal hygiene of the staff, food hygiene and kitchen hygiene levels in the premises.
A single sink will not suffice for both washing vegetables and washing hands. Even if there are separate wash areas, the taps should have provisions like elbow operation option or foot control. This is essential to ensure there is no cross contamination by touching the tap. Sanitizer liquid should be easily available at various points. Handwash/dispensers should be suitably located.
There is no point in preaching hygiene when the facilities are not suitably provided to meet standards.
As far as the 3-star and 4-star hotels are concerned I would say the facilities which are there at times are far better than the 5-stars for the staff facilities certainly. The requirement in smaller hotels is much lower comparatively. In restaurants, back facilities requirements are changing considerably. There are centralized areas for staff for changing, resting rooms, etc. So it is changing for the better.
Personal hygiene is an important aspect in relation to kitchen hygiene as well as food safety. As far as food safety is concerned, in more than 80% of the cases, food poisoning incidents have occurred post cooking. The contact points with food handlers after the food has been cooked and served include storage, the place where it is kept, how it is served, the plates, people serving the food… All this adds to contamination.
In fact, there is no system to ensure that every food handler has washed hands after leaving the restroom. Moreover, in most hotels there are no separate toilets for the kitchen staff! Every single staff needs to be trained in personal hygiene and essentially monitored to enforce hygiene practices. A lot of five star hotels do not practise what they preach. If they wanted to actually implement hygiene they would equip their kitchen staff with four uniforms and aprons instead of two. Similarly, they would ensure kitchen linen is washed separately and not put together with the guest linen.
Having said so, there are instances of hotel that treat kitchen linen separately, but do not have inhouse laundry. Well, how the linen gets washed at the private launderers is anybody’s guess. Even in the case of footwear, many hotels do not provide change over footwear for kitchen staff and expect them to buy their own. Resultantly, a junior chef using the restroom during his break walks back into the kitchen with the same footwear. This could turn disastrous.
One of the practical problems that hotels encounter is the quality of kitchen staff. Most of them come from families with low hygiene standards. Hence, they are unable to comprehend hygiene unlike those who have grown up in families that are hygiene conscious and have the educational background. Hygiene thus comes naturally and it is common sense. Staff coming from villages do not even know the difference between washing under a running water and stored water as they do have running water facility back home. In such cases, enforcement of practices is ensured through punishment. But, this does not always hold true.
HACCP requires a qualified trainer because t here are many things that come out of the Hazard analysis and the identification of critical control points. There is a huge debate between the critical control points in the industry. Where we lose out is in terms of the standard, the way it needs to be done, the decision tree which needs to be taken care… before arriving at a critical control point. That’s probably the reason HACCP has not been made mandatory.
In one of the audits at a premise, the customer was recording e.coli continuously for three consecutive months. I first sat observing the various activities in the kitchen. It was picture perfect; all the staff had their headgears and gloves on, clean apron, footwear… One of the staff while cutting dropped a piece of vegetable on the floor, which he promptly lifted with his gloved hands, opened the dustbin and threw inside.. Immediately he returned back to his cutting board with the same gloves on. After a while, he visited the washroom with his gloves on and returned back to work in the kitchen with the same gloves on. When questioned, he defended himself saying, ‘What is wrong? I am wearing gloves and doing my work. My boss said that if he spots me without gloves, he would sack me!!!’ Ultimately, when the kitchen staff were taught to wash hands after every activity, the e.coli dropped.
Doing something without knowing what it is all about is the main cause of the above incident. Thus, effective training is most critical.