John Thomas
Food Safety Matters by John Walther Thomas

According to popular myth, former US President Theodore Roosevelt was so appalled upon finding out how his dinner for one evening was really made (he was having sausages), that he instigated the Pure Food and Drug Act of 1906 as a way of enforcing minimal standards in food production. The story may be fictional but there’s no disputing that the implementation of this Act paved the way for the introduction of minimal standards in places where food was prepared and/or sold.
The push for unified and codified food acts also began in the early 20th century in Australia. For example, the Pure Food Act VIC (1905) was enacted on similar grounds as the US one. Victorian Government employee W Percy Wilkinson tested a number of foods to see what they really contained and found coal tar in a raspberry drink, alcohol in lollies and so on.
Early food acts restricted spitting or urinating in premises where food was manufactured or prepared. Their inclusion in these laws shows just how bad things used to be and how far the food industry has come.
Over the past hundred years Australian state and federal food regulations have proliferated to cover the condition and construction of premises where food is prepared and served. While some operators have decried these regulations, the consequences of consuming poorly prepared food can be devastating, and far exceed the inconvenience of red tape. The regulations are here to stay and operators must comply with them.
But in order to do this, operators must first understand the regulations. Two of the main standards specific to foodservice premises are AS 4674=2004 and FSANZ 3.2.3. All operations which prepare or provide food in Australia, whether commercial or not-for-profit, must comply with these standards.
Unfortunately, many operators have little – if any – understanding of what these regulations really mean. Even builders and architects regularly fail to comprehend their significance, and these standards are often downplayed or ignored in an effort to meet budgets. This approach is ‘penny wise, pound foolish’ as the operator risks incurring substantial fines and rectification costs in the future.
Non-compliant premises can also put an operator’s reputation on the line. In NSW for example, businesses which fail local health inspections are posted on a ‘name and shame’ list on the NSW Food Authority’s website.
Since its launch in 2008 the register has clocked up over five million hits. Most of the fines are for breaches which are largely avoidable in a correctly designed kitchen. These include:
1.    Failing to maintain at or near each hand washing facility a supply of single use hand towels ($880 fine per offence)
2.    Failing to maintain easily accessible hand washing facilities on the food premises ($880 fine per offence)
3.    Failing to take all practicable measures to eradicate and prevent the harbourage of pests ($880 fine per offence)
4.    Failing to maintain all fixtures, fittings and equipment to the required standard of cleanliness ($880 fine per offence)
All of these issues are addressed by the standards AS 4674=2004 and FSANZ 3.2.3 mentioned above. FSANZ 3.2.3 states that food premises must have ‘hand basins in work areas so staff can wash their hands in warm running water’. AS 4674-2004 adds that the hand wash basins must be ‘accessible and no further than 5m, except for toilet hand basins, from any place where food handlers are handling open food’.  Both AS 4674=2004 and FSANZ 3.2.3 state that premises must be ‘protected from pests and other contaminants such as dirt and fumes’ and ‘easy to clean and keep clean’.
The guidelines are clear and enforceable, yet these are among the most common errors found in commercial kitchens. Other common problems include:
1.    The wrong kitchen hood: either too small or too large – causing ineffective ventilation and energy wastage.
2.    Poor ventilation: kitchen exhaust hoods necessitate ‘make up air’ – new air to replace the air being drawn from the kitchen. As kitchen hoods can remove thousands of litres of air per second, make up air needs to be introduced through the hood canopy or mechanically via ceiling vents. Insufficient make air leads to ‘negative pressure’, which creates drafts through doors and windows. While the standards allow make up air to be introduced through open windows or other vents, those same standards prohibit the introduction of foreign contaminants, e.g. dust, which a standard fly screen would not prevent. Open windows also encourage drafts of up to 8-12 kilometres per hour which can interfere with pilot lights and flames, creating a fire hazard.
3.    Slippery floors. standard AS/NZS 4586 requires food premises to have a floor rated R12 for slippage. I am constantly surprised at the number of non compliant floors I encounter in restaurants where appearances have trumped safety and compliance. This is a serious OH&S issue with disastrous consequences in the event of staff or patron injury.
In my experience as both an owner and operator, I am well aware of how difficult it can be to balance customer demands and price expectations with the need to construct and maintain premises to an appropriate standard. Operators are governed by myriad regulations and at times it can feel like business takes a back seat to bureaucracy. Kitchen and premises design is often the last thing on people’s minds.
As a foodservice operations and design consultant, I design premises that are safe, clean, efficient, cost effective and compliant. Investments in new or altered premises should be spent wisely and only once. Unfortunately, we are often called in to fix rushed jobs with cut corners or poor design completed by the wrong people for the wrong reasons. While we are happy to assist, remedial work usually costs much more than the original work.
Poorly designed premises present a significant risk to any foodservice business. While it may not seem a pressing concern to the operator struggling with an avalanche of orders or a late delivery, you could be staking your future and reputation on a slippery floor or a misplaced sink.

John Walther Thomas is a foodservice operations and design consultant with Sangster Design Group.




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