Note to rogue Environmental Health Officers - Commercial Dishwashers ARE fit for purpose
What I can never understand is when the individuals who are employed to police legislation and guidelines from government organisations, ignore basic principles and ‘go rogue’.
Let’s face it, we have all met one or more in our working lives. You know... the omnipresent H&S officer who ignores the simple risk calculation and for reasons best known to themselves, assesses every situation as high risk, causing panic and unnecessary costs all over the shop.
And so we get to Environmental Health Officers (EHO’s). In recent months I have encountered a number of catering establishments including Food production units, cafe’s and coffee shops that have had direct instruction from EHO’s demanding that their commercial dishwashing machine, amongst other irrelevant requirements, rinses at 90 degrees Celsius in order to eliminate bacteria.
Their demands are
- Not based in science
- Do not match guidelines from the FSA – the government body that decides such things.
- Frankly, made up.
And so our Top Tips for rogue EHO’s
- Go back to school 1 – basic O level / GCSE’s science tells us that protein, which makes up bacteria, denatures above 41 degrees Celsius. Therefore this is the temperature that all bacteria that would be found in a catering environment would die.
- Go back to school 2 – Bacteria cannot exist in other hostile environments. For example, in the presence of certain chemicals such as detergents and bleach.
- Understand what a standard commercial dishwasher does during the wash cycle – Washes from 55-65 degrees Celsius, with detergent and/or sanitizer.
- Understand what a standard commercial dishwasher does during the rinse cycle – Rinses from 82-85 degrees Celsius.
- Think about hand washing - the FSA’s guidelines for hand washing talks about using hot soapy water, which is understood, to eliminate campylobacter. Commercial dishwashers wash and rinse at temperatures far hotter than hands could stand, with detergent. QED.
- READ the FSA’s guidelines – Issued July 2013 “the Agency is not requiring a specific temperature for dishwashers and the advice we provide to businesses and local authorities is stated in Q44 of the Q&A document: ‘food businesses should ensure that any (commercial) dishwasher is maintained in good working order, fit for purpose and at the appropriate setting’.” OR if you want another reference :- “Disinfectants and sanitisers must meet officially recognised standards and should be used as instructed by the manufacturer”. - http://www.food.gov.uk/business-industry/guidancenotes/hygguid/ecoliguide#sthash.KT1xXgVO.dpuf
- FOLLOW the FSA guidelines.
- Understand what the catering business can and can’t reasonably do with their commercial dishwasher – Measuring wash temperature and rinse temperature in the tanks can be unsafe and will provide misleading results.
- Ensure a CE marked commercial dishwasher is being used and is properly maintained. Thereafter trust the CE process and the manufacturers who have put millions into ensuring the technology works.
- Treat businesses fairly – Being a Local Authority funded EHO may be a sinecure – however private enterprise is a very different story. SME’s in the catering industry need proper guidance from the outset to ensure that they comply with the FSA guidelines. What they don’t need is made up ‘regulation’ which puts further strain on their business finances making commercial life even more precarious than it needs to be.
If any caterers out there who have ‘challenging’ EHO’s then just contact us on firstname.lastname@example.org and we will provide them with a copy of the original letter from the FSA on the use of Dishwashers in your kitchen.
written by David Teasdale