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.