Jackie Dickson, Environmental Health Officer and Training Provider

Never have there been more challenging times for hospitality businesses and food providers to navigate their way through the ever changing and sometimes complex legislation that applies to them. Since March 2020 a whole raft of new COVID specific Regulations have been introduced to sit alongside existing Health and Safety Legislation, placing obligations to update, review and introduce new risk assessments and implement new working practices. It’s a difficult time especially when also trying to keep heads above water!

As an EHO working with businesses for over 20 years I have always understood that my role is to educate as well as to enforce. That’s why, in these incredibly challenging times I feel it’s important to remind food businesses of the fundamentals of food safety. Whilst a lot of time, energy and focus is going into ensuring COVID compliance, let’s not forget the basics…

With business models being changed to meet the requirements of new Regulations along with customer needs, it is important to update existing food safety management systems. All compliant food businesses, from a large commercial kitchen or a small food outlet must have an up to date food safety management system based on the principles of Hazard Analysis and Critical Control Point. This could be the Food Standards Agency ‘Safer Food, Better Business’ booklet or a larger more complex site-specific system, but the fundamentals are the same. Whilst these documents are usually completed at business start-up, they are often left on the shelf until the EHO arrives to carry out an inspection or to follow up on a customer complaint or a food poisoning outbreak. It’s at this point that businesses can become unstuck, as they realise that their business model and practices have changed, but their dusty document has remained the same!

There are common changes to business models following the COVID crisis that should be reviewed within a food safety management system; here I have highlighted some key areas to consider…


Here are 5 key areas to think about:

1. Allergens

How is allergen information communicated with the customer? As a food business you have a legal obligation to provide up to date allergen information. You must have a statement on your website (if you have one) where the customer can obtain allergen information. This should then be provided either verbally when taking the order, or in writing (i.e. the menu on the website).

In order to do this effectively you must ensure that your allergen matrix is accurate for staff to refer to and all staff should be trained in dealing with allergens. 

Upon delivery, it is important that the allergen containing food is clearly labelled, either by sticker or by writing on each individual food container.

Drivers must ensure there is no cross contamination of allergens during the delivery process – one way of achieving this is by keeping them in completely separate bags etc in case of spillages.

2. Temperature control during delivery

Food safety management systems must be updated to include temperature control requirements during the delivery process. Depending how long delivery rounds are will determine the exact requirements and it may be necessary to keep a record of any monitoring undertaken.

3. Delivery vehicles

If vehicles are used for transporting anything other than food, then they must be adequately cleaned to ensure there is no risk of cross contamination. Local Authorities can advise further regarding the suitability of a particular vehicle for food delivery.

4. Have new menu items/substitute ingredients been introduced?

Don’t forget to add them to the allergen matrix. Ensure that adequate cooking time/temperatures have been assessed and that any associated documentation has been completed.

5. Food Service/ Preparation

Is food being served outdoors or in areas not usually used for food service or food preparation? If so, it is important that you run through your food safety management system and check that you haven’t introduced any new hazards you aren’t controlling. Things to consider are:

Hygiene facilities outside
There must be handwashing facilities available in areas where food is prepared or cooked to prevent cross contamination and personal hygiene. Portable facilities
are available. 

Pest Control
Is food being stored in a new area outdoors? Remember that food must be protected from contamination by rodents or other pests. You may need to contact your pest control company for advice.

Temperature control
You must ensure adequate temperature control for food stored outside – this should be added to your FSMS.

Staff Training
Have staff numbers been reduced leading to colleagues being asked to take on new roles. You must ensure that all staff are adequately trained for the role they are carrying out and records of this training must be available.

You must inform your Local Authority of any changes made to your registered business activities but they are also there to help and advise you. There is also lots of helpful information available on the food.gov.uk website.

Remember, whatever your role, think about any updates that may be required to your own food safety management system and make sure they are fully implemented to ensure food safety!