The CIEH response to the department of health, also proposes a number of refinements to the draft regulations:
Probationary licensing system
The government may wish to consider the provision of a probationary licence system. This would be a licence issued to new food businesses for a period of three months. It would allow food authorities to verify whether full HACCP procedures are in fact being carried out in practice.
The CIEH cautions against the presumption that where a HACCP system exists, all outlets have fully complied. It states, 'it is a question of fact as to whether a HACCP system at an individual shop is operating correctly or not. Regardless of how impressive a HACCP document is, it is dependent upon management of the system at individual sites and staff being aware of their duties and implementing them accordingly'. This means that the local enforcing officer, while giving due regard to the Home Authority approved HACCP system, should still consider appropriate action at the local level.
Fast-track processing of appeals
A fast-track appeal procedure will be necessary to avoid giving a competitive advantage to those businesses which fail to comply with requirements and appeal against the revocation of a licence. Otherwise, a non-compliant food business will enjoy an unfair advantage in trading with competitors who may have implemented full HACCP requirements.
David Statham, chairman of the CIEH food committee, said, 'We hope the government will look favourably on these suggestions. It is in the interest of everyone for the licensing regulations to be as effective as possible'.
- HACCP -Hazard Analysis Critical Control Point, a food safety management system identifying the critical control points in the food preparation process. Full implementation of HACCP was recommended by the Pennington Inquiry in to the 1996 Lanarkshire E. coli outbreak.