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Meeting Food Hygiene Regulation in Pubs/Bars
There are nearly 34,000 pubs and bars in the UK (IBISWorld). A pub will usually prepare and serve alcoholic and non-alcoholic beverages and serve food consumed on the premises. A bar tends to sell alcoholic and non-alcoholic drinks, light food and snacks. When people go to these types of establishments, they want to have a good time. What they do not want is to be made ill or injured by unsafe food and drink.
If a pub/bar fails to comply with good food hygiene and safety practices, it increases the risk of contamination and can make food and drink unsafe. Contaminated food can make customers ill, cause injuries and may even be life-threatening in some cases.
Poor hygiene and unsafe practices, such as not cooking or chilling high-risk food sufficiently and cross-contamination, can cause food poisoning. Allergen products coming into contact with non-allergen ones can result in severe allergic reactions in some people. Physical contaminants can injure the mouth and may even result in choking. Unsafe food is an even greater risk for those who are vulnerable, such as young children, the elderly, allergy sufferers and people with weakened immune systems.
There are many different types of pubs and bars. Pubs tend to serve traditional pub grub, such as fish & chips, roast dinners, steaks and pies, but some will have more extensive menus and offer starters, mains and desserts, e.g. gastropubs. Bars will often sell appetisers and snacks, such as tapas, olives, peanuts and crisps. There can be a crossover, with some pubs only serving snacks and bars offering full menus. One of the things that all types of pubs and bars have in common is the need to uphold food hygiene and safety. How each business achieves this will depend on its nature and risks.
The overall aim of any business is to be profitable. All pubs and bars will be inspected as part of the Food Hygiene Rating Scheme (FHRS). If a pub or bar has poor food safety and hygiene standards, its food hygiene rating score is likely to be lower. According to an NFU Mutual Food Hygiene Report, 69% of people check the food hygiene ratings of the establishments they use, and customers would turn away from a 3-star rated business, but not one that was 5-star rated. A poor hygiene rating can mean a loss of customers and, therefore, a reduction in takings.
This guide will provide pub and bar businesses with advice on achieving good food safety and hygiene standards. It will also highlight why food safety and hygiene is essential when running a pub or bar.
Food hygiene legislation for pubs/bars
As food operators, all pubs and bars will need to comply with food safety and hygiene legislation.
The main laws are:
- The Food Safety Act (FSA) 1990 – Provides a framework for food safety legislation in Great Britain (England, Wales and Scotland). Northern Ireland has different legislation; the Food Safety (Northern Ireland) Order 1991. The FSA 1990 covers food safety, consumer protection, food information etc.
- The Food Safety and Hygiene (England) Regulations 2013 – Created under the FSA 1990. The regulations cover the enforcement of food hygiene and the HACCP principles from Regulation (EC) 852/2004 (retained EU law). There are different regulations for each UK country, e.g.:
– The Food Hygiene (Scotland) Regulations 2006.
– The Food Hygiene (Wales) Regulations 2006.
– The Food Hygiene Regulations (Northern Ireland) 2006.
- The Food Information Regulations 2014– Places duties on food businesses to provide information to consumers on allergens. These regulations were amended by the Food Information (Amendment) (England) Regulations 2019 to include Natasha’s Law, which came into force on 1st October 2021.
Further information on the key regulations is on the Food Standards Agency webpage.
If businesses are preparing, cooking, storing, handling, distributing, supplying or selling food, they will need to register with their local authority. They will also need a licence to sell alcohol and relevant insurances, e.g. public liability and employer’s liability.
There may be other applicable laws, depending on the type of pub or bar. It is the responsibility of business owners to ensure they are aware of, and comply with, all relevant food safety laws. Ignorance of legislation is not a defence.
Environmental Health Officers (EHOs) are responsible for enforcing food safety and hygiene. They have certain powers under the FSA 1990 and various food hygiene regulations. If a business fails to comply with the law, EHOs can give a poor food hygiene rating score or issue enforcement notices. For more serious offences and non-compliance of notices, officers may decide to prosecute, which may mean fines, imprisonment and even closure of the business. If customers are made ill by unsafe food or drink, they may also claim compensation, which can be very costly.
Pub and bar prosecution cases
- A pub owner was prosecuted and fined £18,935 after 186 people fell ill with Clostridium perfringens food poisoning after eating a carvery meal. (North Somerset Council).
- A pub manager and chef were jailed for 12 and 18 months respectively after a customer died from food poisoning after eating a Christmas Day meal. Thirty-three people in total were made ill. The manager and chef fabricated food safety records for cooking the turkey. The chain that owned the pub received a fine of £1.5m (BBC News).
- A pub owner was fined £3,000 and ordered to pay a victim surcharge of £170 and prosecution costs of £2,854 for serving a dessert with egg to a girl who had repeatedly told staff about her allergies. The girl suffered from anaphylaxis and had to spend the night in the hospital (BBC News).
- A cafe and cocktail bar co-owned by a famous footballer was fined £20,000 and ordered to pay costs of £2,488 and a £130 surcharge after inspectors found a live mouse and droppings in the kitchen (BBC News).
Staff training on food hygiene for pubs/bars
Legally, all pubs and bars must ensure that any staff who prepare, handle or sell food are supervised, instructed and trained in food hygiene matters. It does not mean that staff have to have a food hygiene certificate. However, having evidence of training is the best way to demonstrate to EHOs and customers that the business is committed to food safety. It also provides evidence for due diligence purposes in the event of an investigation or legal action.
Staff should receive training in line with their responsibilities, the area where they work and their tasks.
There are different levels of food hygiene training, e.g.:
- Level 1 – Introduction to food hygiene, typically for those handling low-risk food, e.g. wrapped foods. This course may be beneficial for waiting-on, bar and front of house staff with limited food contact.
- Level 2 – Basic food hygiene certificate for staff preparing, cooking and handling food, e.g. kitchen staff and chefs.
- Level 3 – Intermediate food hygiene certificate for those with more responsibilities, e.g. pub/bar owners, supervisors, managers and those involved in food safety management systems and HACCP.
If a pub or bar only serves drinks and pre-packed snacks, then a level 2 food safety and hygiene for retail is recommended, as it teaches more about storage and stock control. If a pub or bar prepares, handles and serves food to customers, then a level 2 food safety and hygiene for catering course would be more appropriate, as the risks will be higher.
Refresher training is also a requirement. The frequency will depend on the nature of the business, its risks, the food handled, and the competence of workers.
Food hazards in pubs/bars
Food hazards are contaminants that can enter food and potentially cause harm to consumers. The Food Standards Agency (FSA) defines a food hazard as “something that could make food unsafe or unfit to eat”.
There are four different types of food hazards: biological, chemical, physical and allergenic.
Biological hazards happen when microorganisms contaminate food and drink. In a pub and bar, contamination may occur due to inadequate and improper storage, chilling, defrosting, cooking and reheating of food. Poor practices provide optimal conditions for harmful pathogens to grow. It can also occur from cross-contamination, e.g. raw foods coming into contact with cooked and ready-to-eat foods, and poor personal hygiene. The risk will depend on the type of pub/bar, including the food and drink served. A bar that only serves drinks and pre-packed food will be a lower risk than a pub cooking and serving meals.
Examples of biological hazards include:
- Bacteria, e.g. Salmonella.
- Fungi, e.g. yeasts and moulds (particularly in cellars and beer line systems).
- Viruses, e.g. norovirus.
These microorganisms can cause foodborne illnesses, including food poisoning and intoxication.
Chemical hazards occur when naturally occurring or human-made substances contaminate food. In a pub/bar, chemical hazards may occur due to cross-contamination, i.e. spraying cleaning products near food or drinks. Also, beer line systems are usually cleaned with hazardous chemicals, which can cause serious harm to people if ingested. Therefore, stringent precautions are required to ensure beer and other drinks do not become contaminated with line cleaning chemicals.
Examples of chemical hazards include:
- Toxins produced by animals, plants and microorganisms, e.g. mycotoxins (produced by fungi).
- Unintentionally added chemicals, e.g. cleaning chemicals.
- Intentionally added chemicals to food and drink but could be hazardous if used in excess quantities, e.g. flavourings and colourings.
Eating food and drinks contaminated with chemicals can result in immediate harm to the consumer. It can also cause long-term health effects if exposed to the hazard over time.
Physical hazards are foreign materials, objects and extraneous matter that can enter food and drink during preparation and handling but may also be in raw ingredients. In pubs and bars, these may occur due to poor personal hygiene but can also come from packaging and poorly maintained equipment. Beer line systems can become clogged with limescale and beerstone, which can enter drinks.
Examples of physical hazards include:
- Natural hazards – Occur naturally in food, e.g. fruit pips and stones, bones in meat and fish and shells from nuts.
- Unnatural hazards – Should not be present in food, e.g. stones, human hair, fingernails (including false fingernails), plastic, glass, metal and wood.
These types of hazards can cause injuries to the mouth, teeth and gums. In some cases, physical contaminants can even result in choking, especially in the very young and elderly. Some can be generally unpleasant to find in food, i.e. a hair or plaster.
Allergens are proteins that occur naturally in some foods but can contaminate other foods by cross-contact. In a pub/bar, allergenic hazards may result from using and storing allergen products where non-allergen products are. If a pub/bar is selling just pre-packed food, the risk is lower, but it is still essential to keep allergen-free products separate from those containing allergens.
There are 14 recognised allergens, which include:
- Peanuts (groundnuts).
- Celery (all of the plant, including the root celeriac).
- Mustard (liquid, powder and seeds).
- Tree nuts (almonds, hazelnuts, walnuts etc.).
- Sesame (seeds).
- Lupin (flower and seeds).
- Cereals (gluten) (oats, rye and barley).
- Molluscs (oysters, snails and mussels).
- Sulphur dioxide and sulphites.
- Crustaceans (crab, prawns and lobster).
These types of hazards can cause allergic reactions in food allergy sufferers. In some cases, there is a risk of anaphylaxis in those with severe allergies.
There is potential for all types of food hazards to be present in a pub/bar, but it will depend on the nature of the business and what it sells. Biological and allergenic hazards are more likely a risk during the preparation, cooking and serving of food. Chemical hazards are a significant risk where there are beer lines and drinks dispensers.
Pubs and bars should follow the 4Cs of food hygiene to prevent food hazards. These are cleaning, cooking, cross-contamination and chilling. These four simple rules cover essential food hygiene and safety practices.
According to the Food Standards Agency (FSA), a lack of thorough cleaning is one of the most common reasons for prosecution. Cleaning is essential as it stops harmful pathogens and allergens from spreading, discourages pests, and is a legal requirement.
Pubs and bars should have effective cleaning procedures and schedules to ensure that food storage, preparation, serving, eating and bar areas are kept clean and safe. Adopting a ‘clean as you go’ approach will help keep areas constantly clean and tidy. It is also important to keep equipment clean, such as ice machines, beer lines and bar mixer dispensers.
Most pubs will cook food on the premises, and some bars may also offer hot food. If this is the case, it must be cooked thoroughly before serving to customers. If food is undercooked, it can cause food poisoning, particularly with high-risk foods such as meat and poultry. Cooking at the correct temperature for the appropriate time will kill any harmful bacteria.
The cooking method, time and temperature will depend on the type of food. However, businesses should always follow the cooking instructions on food packaging (where present), and food must always be piping hot before being served. When cooking, food should reach at least 70°C and stay at that temperature for 2 minutes (or at an equivalent temperature and time). Reheated food should be at least 75°C for 30 seconds. In Scotland, the regulations require food to be at least 82°C. It is advisable to test the temperature of food with a clean, calibrated probe.
Foodborne illnesses usually occur due to the transferring of harmful bacteria between people, food, surfaces and equipment. This is known as cross-contamination, and it is one of the most common causes of food poisoning (FSA). It can also occur with chemicals, e.g. spraying chemicals in the air that can land on food, surfaces and equipment. Where allergens are concerned, it is known as cross-contact. This is where products containing allergens are often unintentionally transferred to allergen-free ones.
Pubs and bars must ensure they prevent cross-contamination and cross-contact as much as possible, which can be achieved by:
- Good personal hygiene, e.g. washing hands thoroughly.
- Using separate areas, equipment and utensils.
- Cleaning and disinfecting equipment, cleaning materials and utensils before use.
- Storing food correctly, e.g. raw meat below ready-to-eat food.
- Storing allergenic foods and non-allergenic foods separately, including ingredients and prepared food.
- Adopting a high standard of cleanliness.
- Preventing and controlling pests.
Certain foods, e.g. those with use-by dates and ready-to-eat foods, must be stored chilled to be safe. Chilling does not kill harmful bacteria, but it does stop them from growing. If food is improperly chilled, it can enter the danger zone and encourage pathogens to grow, increasing the risk of food poisoning.
Where applicable, pubs and bars must ensure that food is properly chilled and stored correctly, for example:
- Refrigerator temperatures are at 5°C or below, and freezer temperatures are at least -18°C or below.
- Food is stored correctly within the refrigerator, e.g. raw meat and poultry at the bottom.
- Defrost food in the fridge overnight and in accordance with the instructions on the packaging.
- Always follow the storage instructions on food packaging and monitor use-by dates.
Personal hygiene in pubs/bars
Personal hygiene is vital when working with food and drink. It includes many different aspects of the body, clothing and habits, such as handwashing, protective clothing, hair, jewellery, smoking, illnesses etc.
If pub and bar staff do not follow good personal hygiene practices, they can contaminate food with hazards through direct contact and cross-contamination.
Businesses should instruct and train workers on the expected standards of personal hygiene when working with food and drink.
It can include (this list is not exhaustive):
- Washing hands thoroughly before handling and preparing food/drinks.
- Tying hair back and/or covering it with a hat (especially when working in the kitchen).
- Short fingernails, no false fingernails and no nail varnish.
- No jewellery or watches, except a plain wedding band.
- No strong perfumes or other toiletries, which could taint food.
- Wearing suitable clean protective clothing, such as hairnets, gloves and aprons, in food preparation areas.
- No coughing or sneezing over food and preparation/serving areas.
- Discouraging behaviours, e.g. touching the face/hair, spitting, chewing gum and picking teeth/nose.
Under Regulation 852/2004, food handlers must maintain high standards of personal hygiene and cleanliness.
If workers are ill, it can compromise food safety. Employers have a legal responsibility to ensure that staff do not handle food if they have an infection. It also applies if they show any symptoms of food poisoning, e.g. vomiting and diarrhoea, and have any infected wounds, skin infections or sores. Any cuts and sores should be covered with brightly coloured waterproof plasters or dressings, even if they are not infected.
Businesses should have reporting procedures for when food handlers have gastrointestinal symptoms, Hepatitis A, and wounds, sores and skin conditions. If a worker has diarrhoea or vomiting, they should report it to the manager immediately. If they are at home, they should stay there or go home straight away if they are at work. They must not return to work until 48 hours after their symptoms have stopped.
Food allergens in pubs/bars
Legally, pubs and bars must inform customers in writing if any of the 14 allergens are in the ingredients of the food (and drink) prepared and served. It will apply to pre-packed, pre-packed for direct sale (PPDS) and non-pre-packed (loose) food.
These are foods that are already in packaging before being sold. They are in packaging that has to be opened to be altered and are ready for sale. Most pubs and bars will likely buy and sell pre-packed food, such as bottled and canned drinks, biscuits, chocolate, crisps, meat snacks, olives and peanuts.
There has to be an ingredient list, with all of the allergens emphasised, on the packaging. Businesses should check the labels to ensure the allergens are clear before serving pre-packed foods to customers.
Pre-packed for direct sale (PPDS)
PPDS foods are prepared and packed on the same premises where they are sold and before they are ordered or selected by customers. For example, if a pub or bar makes salads, sandwiches, fast food or pies and puts them in packaging ready for sale, this will apply.
The regulations have recently changed regarding PPDS food. Natasha’s Law came into force on 1st October 2021. Businesses must now label PPDS foods with a full ingredients list, with all of the allergens emphasised, on the packaging.
The Food Standards Agency (FSA) has further information on the allergen labelling changes for PPDS foods.
Non-pre-packed foods will include meals prepared, cooked/ready-to-eat and served to customers, e.g. fish & chips, carveries, burgers, steaks and desserts.
Pubs and bars must provide allergen information for all loose foods containing any of the 14 allergens. They can do this by adding complete allergen information to menus or putting it on a chalkboard. They can also provide written information packs or a notice informing customers on how to obtain allergen information.
When preparing food, pubs and bars must ensure that food allergens are handled and managed effectively to prevent cross-contact, which can be achieved by:
- Including allergenic hazards in HACCP systems and putting controls in place.
- Providing allergen training for staff, including what to do in an emergency if a customer has an allergic reaction.
- Looking for hidden allergenic ingredients, e.g. Worcestershire sauce contains anchovies (fish).
- Preparing and storing allergen-containing products separately from non-allergen products, e.g. using separate colour-coded boards.
- Cleaning and disinfecting surfaces and equipment thoroughly where separation is not possible.
- Carefully checking pre-packed food labels for allergenic ingredients.
- Labelling any ingredient containers clearly with the allergens they contain.
- Recording allergen information accurately, including product specification sheets, ingredients labels and recipes of the dishes.
Unlike bacteria, allergens are not affected by cooking. Pubs and bars will also need to consider various dietary requirements and food intolerances. Avoid cross-contact as much as possible when preparing and handling food and drinks.
Safely storing food in pubs/bars
Pubs and bars will store a variety of foods on the premises, such as:
- Ambient, e.g. dried goods, such as bread, crisps, peanuts, sugar, flour, coffee and tea.
- Chilled, e.g. refrigerated foods, such as sandwiches, salads, butter, desserts and milk.
- Frozen, e.g. foods kept in the freezer, such as ice cream, fish, chips, ice and vegetables.
All food must be stored correctly to prevent contamination from food hazards and to keep it fresh, so good quality, safe food and drink is served to customers.
Here are some top tips:
- Check all food and drink deliveries before putting them into storage and reject anything that could compromise food safety and quality.
- Keep dry goods in sealed, labelled containers.
- Keep storage areas clean and tidy.
- Have an effective stock rotation system, e.g. First In First Out (FIFO).
- Regularly check the temperatures of fridges and freezers.
- For pre-packed foods, always follow the storage instructions on the packaging.
- Where possible, store raw and ready-to-eat foods separately. If it is not possible, keep higher risk foods, e.g. raw meat and poultry, below ready-to-eat and cooked foods.
- Allergen-containing foods must be kept separate from other foods.
- Store chemicals and cleaning equipment away from food storage areas.
- Keep an eye on use-by dates and best before dates, and dispose of any food that has expired. Using food beyond its use-by date is unlawful.
- Label any non-pre-packed foods with the name and any allergens.
- Label any chilled and frozen food with dates put into storage.
Some pubs and bars may hot hold food, e.g. in heated display units, which provides a perfect opportunity for harmful bacteria to grow if it is not at the correct temperature. When hot holding food, it must be at a temperature of 63°C or above. Businesses can keep food below this temperature for up to two hours. However, if not used after this time, it should be disposed of properly. It is always best to throw out any leftovers to minimise the risk of food poisoning.
Some pubs and bars may have chilled display units for food and cold drinks. These must be cold before use, i.e. set at 5°C or below, and the temperature should be checked at least once a day (using a clean probe between chilled food packs). Display all chilled food for the shortest possible time.
Safely serving food in pubs/bars
Food contamination can also occur during food and drink preparation and service. All areas and equipment should be kept in good repair and clean. All staff handling and serving food must maintain a high standard of personal hygiene at all times.
When serving food:
- Take extra care when handling and serving ready-to-eat foods, as bacteria and allergens will not be killed by cooking or reheating.
- Use utensils to serve wherever possible to avoid direct touching of food.
- Follow hot holding guidance where food has to be kept hot before serving, and the same for chilled.
The Food Standards Agency (FSA) has further guidance for businesses that deliver food and drinks to customers.
Waste management in pubs/bars
Pubs and bars are likely to produce mostly food and packaging waste. If waste management is inadequate, it can encourage pests and may even result in infestations. It can also increase the risk of pathogens in the food premises. Rotten food can start to smell as it deteriorates, which customers will find unpleasant.
All pubs and bars should have appropriate provisions for the segregation, storage and removal of waste, for example:
- Not allowing waste to accumulate by removing it regularly from food areas.
- Having appropriate bins inside and outside the food premises, e.g.:
– Sufficient in number.
– Different types of bins for different wastes.
– Bins with foot pedals, so no hand touching.
– Bins with tight-fitting lids to prevent pests.
- Cleaning and disinfecting bins regularly.
- Lining bins with appropriate liners.
- Regularly emptying bins inside and outside.
- Ensuring bins are placed and kept in areas designated for waste disposal.
- Keeping outside bins locked when not in use.
Pest control in pubs/bars
A pest is any insect or animal which can contaminate food with harmful pathogens and become an infestation if uncontrolled. They can also introduce physical hazards, e.g. contaminating food with droppings or the pest itself.
Pests in food businesses are relatively common, and EHOs close down food businesses due to pest infestations more than any other problem.
Many different types of pests can contaminate food. The ones that may be in and around pubs and bars may include:
- Rodents – Mice and rats.
- Insects – Flies, ants and cockroaches.
- Stored product insects – Beetles, particularly weevils, can be found in flours, grains and cereals.
- Birds – Pigeons (outside).
Some examples of pest prevention and control methods include:
- Checking the premises regularly for gaps or holes that could allow pests into buildings.
- Ensuring external areas around the premises are kept clear of vegetation and anything that could encourage or harbour pests.
- Looking for evidence of pests or pest damage when checking deliveries, e.g. insects or gnawed packaging. Do not accept deliveries if there are any signs.
- Keeping the premises clean and tidy, particularly where food is prepared, served and eaten.
- Removing internal and external waste regularly.
- Using fly screens on any open windows.
- Not having open bins and keeping lids closed when not in use.
- Storing food correctly, e.g. not on the floor, and keeping it covered or well-sealed.
- Having an approved contractor to manage and monitor pest control within and around the premises where possible.
The Food Standards Agency (FSA) has a food safety management pack called Safer Food, Better Business. It can help pubs and bars meet the requirements of food safety and hygiene legislation. For pubs and bars that only sell pre-packed food (particularly non-chilled), it is best to contact the local authority environmental health team for further advice, as the SFBB pack may be too complex for the risks.
We also offer various food hygiene and HACCP courses, which can help pubs and bars understand their legal obligations and assist them in achieving a five-star food hygiene rating.