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Meeting Food Hygiene Regulation for Street Food Businesses
The street food market has grown significantly in the UK over recent years and is estimated to be worth around £1.2 billion (Stir it Up Street Food Trend Report). Therefore, the growing popularity of street food and the relatively low investment required is attractive for those wanting to start this type of business. However, operators must ensure the food they serve to customers is safe to eat.
All street food businesses must comply with good food hygiene and safety practices. If they do not, it increases the risk of contamination and can make food unsafe. Contaminated food can make customers ill, cause injuries and may even be life-threatening in some cases. It is an even greater risk for those who are vulnerable, such as young children, the elderly, pregnant women, allergy sufferers and people with weakened immune systems.
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 allergen-free ones can result in severe allergic reactions in some people. Physical contaminants can injure the mouth and may even result in choking.
Street food businesses are usually seen in the high street or at events, such as festivals, markets, fairs and shows. Operators may choose to sell their food from a van, trailer, bicycle or cart. Alternatively, they may decide to have a stand or stall. Each type of set-up will require different food hygiene and safety precautions that will need to be considered in HACCP systems.
The type of food offered by street food businesses is very varied. Some cater for specific diets, such as vegan, vegetarian, halal and kosher. Others may specialise in a particular cuisine, such as Indian, Mexican, Jamaican and Chinese. One of the things that all types of street food businesses have in common is the need to uphold food hygiene and safety. How each operator achieves this will depend on its nature and risks.
The overall aim of any business is to be profitable. All street food businesses will be inspected as part of the Food Hygiene Rating Scheme (FHRS). If an operator has poor food safety and hygiene standards, their 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 street food operators with general advice on achieving good food safety and hygiene standards. It will also highlight why food safety and hygiene is essential when running a street food business.
Food hygiene legislation for street food businesses
As food operators, all street food businesses 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.
Street food businesses will need to register with their local authority, and most will require a street trader licence (if selling on the public highway). 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 street food business. It is the operator’s responsibility to ensure they know 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 street food businesses do not comply with legislation, 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, they may also claim compensation, which can be very costly.
Street food prosecution cases
- Over 400 people reported symptoms of food poisoning after the Street Spice festival in 2013, and there were 29 confirmed cases of salmonella. After investigation, investigators found that raw curry leaves in a chutney were contaminated with several bacteria, including salmonella, E. coli and shigella. Victims received a joint payout of over £400,000 (BBC News).
Staff training on food hygiene for street food businesses
Legally, all street food operators must ensure that any staff (or themselves if they work alone) 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 this type 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 useful for staff with limited food contact.
- Level 2 – Basic food hygiene certificate for staff preparing, cooking and handling food, e.g. preparers, cooks and chefs.
- Level 3 – Intermediate food hygiene certificate for those with more responsibilities, e.g. street food business owners, supervisors, managers and those involved in food safety management systems and HACCP.
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 street food businesses
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 poor practices provide optimal conditions for harmful pathogens to grow. In a street food business, contamination may occur due to inadequate and improper storage, chilling, defrosting, cooking and reheating of food. It can also result 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 street food business, including the type of food served. One that only serves drinks and pre-packed food will be a lower risk than another cooking, hot/cold holding and serving food (especially high-risk foods, such as rice, dairy, eggs, meat, fish, shellfish and poultry).
Examples of biological hazards include:
- Bacteria, e.g. salmonella, E. coli, listeria and campylobacter.
- Fungi, e.g. yeasts and moulds.
- 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 street food business, chemical hazards may occur due to cross-contamination, i.e. storing or spraying cleaning products near food and preparing food on surfaces where chemicals have been.
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 but could be hazardous if used in excess quantities, e.g. flavourings and colourings. There is also a risk of deliberate contamination at public events.
Eating food 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 during preparation, cooking and serving but may also be in raw ingredients. In street food businesses, these may occur due to poor personal hygiene but can also come from packaging, poorly maintained equipment and pests.
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), jewellery, plastic, glass, animal droppings, 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 the 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. 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.
In a street food business, allergenic hazards may result from using and storing allergen products where non-allergen products are. It can be difficult keeping them separate during the preparation, cooking, display and serving of foods in a relatively small working space.
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).
The type of allergenic hazards present will depend on the food sold.
There is potential for all types of food hazards in a street food business, depending on the situation, location and food produced.
Street food businesses 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.
Street food businesses should have effective cleaning procedures and schedules to ensure that food storage, preparation, cooking and serving 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.
Most street food businesses will provide cooked food, which may be prepared either on-site or off-site. Food must be cooked thoroughly before serving. If food is undercooked, it can cause food poisoning, particularly with high-risk foods such as meat, poultry, fish and rice. Cooking at the correct temperature for the appropriate time will help kill any harmful bacteria. It is also important to hot hold food properly (see the safely storing food section).
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, i.e. 80°C for 6 seconds). It is advisable to test the food temperature with a clean, calibrated probe to ensure it is properly cooked.
If reheating any food, it should be at least 75°C for 30 seconds. In Scotland, the regulations require reheated food to be at least 82°C. Only reheat food once.
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.
Street food businesses must ensure they prevent cross-contamination and cross-contact as much as possible, which can be achieved by:
- Good personal hygiene, e.g. washing and sanitising hands thoroughly.
- Thoroughly washing salad, fruits and vegetables.
- Not washing raw poultry, as bacteria can splash onto surfaces, equipment and other foods.
- Using separate areas, equipment and utensils for different types of foods, e.g. raw and cooked.
- Cleaning and disinfecting equipment, cleaning materials and utensils before use, between uses and after.
- Storing food correctly inside and outside, e.g. keeping raw foods away from cooked and ready-to-eat foods.
- Storing allergenic foods and non-allergenic foods separately, including ingredients and prepared food.
- Covering open food.
- Adopting a high standard of cleanliness at all times.
- 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 help to 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.
Street food businesses must ensure that food is properly chilled and stored correctly, for example:
- Ensuring chilled and frozen food is stored at the correct temperature on receipt/delivery.
- Ensuring chilled food is kept out of the refrigerator for the shortest time possible during preparation.
- Refrigerator temperatures are at 5°C or below, and freezer temperatures are at least -18°C or below. If using cool boxes, the same temperature must be maintained and checked. It may be worth having vehicles with suitable refrigeration units if transporting chilled food to events further away.
- Ensuring food is stored correctly within refrigerators/chillers, e.g. raw food at the bottom or in separate fridges to ready-to-eat and cooked foods.
- Defrosting frozen foods in accordance with the instructions on the packaging or safely in the refrigerator overnight.
- Following the storage instructions on food packaging and monitoring use-by dates.
Personal hygiene in street food businesses
Personal hygiene is vital when working with food. It includes many different aspects of the body, clothing and habits, such as handwashing, protective clothing, hair, jewellery, smoking, illnesses etc. If operators do not follow good personal hygiene practices, they can contaminate food with hazards through direct contact and cross-contamination.
If street food operators have employees, they should instruct and train them on the expected standards of personal hygiene when working with food.
It can include (this list is not exhaustive):
- Keeping hair, body and hands clean.
- Washing hands regularly and thoroughly, e.g. after visiting the toilet, after handling raw meat and before handling ready-to-eat/cooked food. There should be a handwash basin (with hot and cold water and soap) sited within a reasonable distance of food preparation, cooking and serving areas.
- Tying hair back and/or covering it with a hat.
- 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, and changing it regularly.
- No coughing or sneezing over food and preparation, cooking and serving areas.
- No smoking around food, including outside and in vehicles.
- 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. Street food operators have a legal responsibility to ensure that staff (including themselves) 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.
If street food operators have employees, they 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 operator 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 street food businesses
Legally, street food businesses 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 street food businesses will likely buy and sell pre-packed food, such as bottled and canned drinks and snacks.
There has to be an ingredient list, with all of the allergens emphasised, on the packaging. Street food operators 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 sold and before they are ordered or selected by customers. This will apply if street food operators make food on-site and put it in packaging ready for sale.
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 ingredient list, with all of the allergens emphasised, on the packaging.
Non-pre-packed foods will include unpackaged foods served to customers, e.g. cooked food, hot drinks made to order and any loose unpackaged foods selected from displays.
Street food businesses 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, street food businesses 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 equipment, such as 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.
- Labelling allergen-free foods and keeping them separate during transit.
- Recording allergen information accurately, including product specification sheets, ingredients labels and recipes of the dishes.
Unlike bacteria, allergens are not affected by cooking. Street food operators will also need to consider various dietary requirements and food intolerances. Cross-contact should be avoided as much as possible when preparing and handling food.
Safely storing food in street food businesses
Street food businesses will store a variety of foods on the premises, such as:
- Ambient, e.g. dried goods, such as sauces, herbs, spices, bread, tea and coffee. They may also store vegetables.
- Chilled, e.g. refrigerated foods, such as meat, fish, salads, butter, desserts and milk.
- Frozen, e.g. foods kept in the freezer such as ice cream, ice, fish, chips, meat and vegetables.
Store foods correctly to prevent contamination from food hazards and to keep them fresh, so good quality, safe food is served.
Here are some top tips:
- Check all food 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.
- Do not store any food, equipment or utensils on the ground.
- 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.
Most street food businesses will 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. Operators can keep food below this temperature for up to two hours.
However, if not used after this time, it should be:
- Reheated until it is steaming hot and put back into hot holding (only reheat once).
- Cooled as quickly as possible to a temperature of 8°C or below.
- Disposed of if it has been out for more than two hours.
It is always best to throw out any leftovers to minimise the risk of food poisoning.
Some street food businesses may display chilled food for sale. Before putting any food into chilled units, they must be at the correct temperature before use, i.e. set at 5°C or below. 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.
When taking chilled food to events, it is always best to use a refrigerated vehicle or have a refrigerator inside. If this is not possible, use a cool box with a thermometer inside to monitor the temperature. Hold cold foods below 8°C, but ideally between 0-5°C. It can be held above 8°C for up to four hours, but only once. After this time, the food should be disposed of properly.
Safely serving food in street food businesses
Food contamination can also occur during food 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:
- Have separate serving areas and counters for different types of foods, e.g. raw and cooked.
- Take extra care when handling and serving ready-to-eat foods, as bacteria and allergens will not be killed by cooking or reheating.
- Provide and use utensils to serve wherever possible to avoid direct touching of food.
- Use gloves when serving and change them regularly.
- Follow hot holding guidance where food has to be kept hot before serving, and the same for chilled.
- Always follow the 4Cs.
The Food Standards Agency (FSA) has further guidance for businesses that deliver food to customers. Street food operators should follow this advice if preparing food off-site and then taking it to events.
Waste management in street food businesses
Street food businesses are likely to produce mostly food, packaging, disposable plates/cutlery/cups and water waste. If waste management is inadequate, it can encourage pests and may even result in infestations. It can also increase the risk of food becoming contaminated with harmful pathogens. Food can start to smell as it deteriorates, which customers will find unpleasant.
All street food operators 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, 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.
- Ensuring bins are placed and kept in areas designated for waste disposal.
- Keeping outside bins closed when not in use.
- Piping wastewater into sealed containers or tanks and not discharging it on-site.
- Removing waste from events and disposing of it legally and properly.
Pest control in street food businesses
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 street food businesses 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.
Some examples of pest prevention and control methods include:
- Checking regularly for gaps or holes that could allow pests into the premises, vehicle or trailer. All should be pest-proof.
- Keeping premises and vehicle windows and doors closed and locked when not in use.
- Ensuring external areas are kept clear of vegetation, rubbish and anything that could encourage or harbour pests.
- Looking for evidence of pests or pest damage when checking deliveries, e.g. larvae, insects or gnawed packaging. Do not accept deliveries if there are any signs.
- Keeping the premises, vehicle, equipment, trailer, stall clean and tidy, especially where food is transported, prepared, cooked and served.
- Removing internal and external waste regularly.
- Using fly screens on any open windows.
- Covering food that is out in the open.
- 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 pest control methods for outdoor events, e.g. flying insect devices with catch trays.
- Having an approved contractor to manage and monitor pest control and contacting them if there are signs of an infestation.
The Food Standards Agency (FSA) has a food safety management pack called Safer Food, Better Business. It can help street food businesses meet the requirements of food safety and hygiene legislation.
Street food operators should contact the local authority environmental health team for advice on food safety and hygiene specific to their business. There is also guidance from the CIEH on mobile catering that operators may find helpful.
We also offer various food hygiene and HACCP courses, which can help street food operators understand their legal obligations and assist them in achieving a five-star food hygiene rating.