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forged/fabricated cooking equipment & UK food hygiene laws


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Hi folks, pardon the following essay...

 

This subject has been on my mind for a while as my girlfriend is starting a home baking business and seeing the amount of hoops she has to jump through at every stage regarding food safety to be signed off by Environmental Health as fit for business has got me wondering what forging/fabrication methods would meet official approval? The common "finish your mild steel food implements by cleaning them then baking them in vegetable oil" advice might be ok for the local bohemian craft market but Environmental Health would laugh you out of town if you wanted their approval.

 

This really is at the front of my mind now as I (may) have two frabcation/forging commissions for outdoor cooking equipment to be used by catering companies, namely a hog roast spit and a large BBQ. Obviously safety is my primary concern and with that in mind I've begun researching hygiene requirements and will also call the Environmental Health dept at my council. Early research has led me to 6 documents I will request from the European Hygenic Engineering & Design group (for spec on things like stainless welds).

 

Whilst I'm not wanting to cut any corners I would like to hear any experiences or advice that might speed up my research. Two immediate thoughts are whether every part needs to be "food safe" or only the parts in direct contact with the food, and secondly, it might be wise to buy in the parts that will be in contact with the food and simply make a housing for them.

 

One client has already rejected another fabricators quote for a stainless steel hog roaster on the basis of price and has told me he's happy for everything to be made from untreated mild steel, except the bar the pig is skewered on which he agrees should be stainless. I have told the client that 100% stainless construction would be my preferred method for sake of hygiene and the possibility of cleaning it without rusting, but if they want an untreated mild steel construction then I'll do on the grounds they sign something saying I've warned them of the rust potential, possible impact on food safety, they take responsibility etc etc etc. Obviously it can't be zinc treated or primed for safety's sake and regulations state that the materials used can't impair the taste of the food either.

 

I suppose one saving grace of this is that I'm not involved in the food preparation and could argue that I'm just supplying something for someone to use and maintain with common sense, though this is the dark realm of food hygiene where common sense alone doesn't cut the mustard - no pun intended. I suppose one of my conerns is that these items will be used to cook food which will be sold to the general public, it's not just for personal use.
 

Any pearls?

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Are there hygene regs for cooking utensils other than being clean?

 

Stainless steel and aluminium are easy to clean and maintain which I suppose is why they are popular, you could try contacting your local council and talk to the enviromental heath department to see if there are any regs?

 

I do not know how things stand re food caterers and businesses but I have been making spits, cauldrons and pans out of mild steel and iron for some time now for re-enactors and the only treatment I have ever used is vegetable oil.

 

At home I have old steel knives that have to be washed,dried and oiled before putting away to prevent rust.

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I've made and sold food items finished in vegetable oil too and been confident that they're safe, but that's just me saying they're safe, what I'm wondering now is what's needed to be officially safe. Have you ever seen paperwork saying finishing mild steel in vegetable oil is a safe utensil treatment?

 

I know I'm playing devil's advocate a bit by being so pedantic but I don't think food hygiene is an area where you can legally afford to wander off the rules. My health has been permenantly damaged by the food poisoning I got 9 years ago, massively affecting on my day to day life. I don't want to give anyone legal ammunition to say something I've made has played a part in harming them in a similar way or leave a trail of breadcrumbs that gives the caterer room to point the finger at me.

 

Are there hygene regs for cooking utensils other than being clean?

 

Here's the list of guidelines on the European Hygenic Engineering & Design group website. http://www.ehedg.org/?nr=9&lang=en

 

When you click on each one it brings up a blurb describing the guideline contents. I would imagine No.8; Hygenic equipment design criteria and No. 32; Materials of construction for equipment in contact with food might give some answers to your question.

 

There's also guidelines on the cleanability of products. Unhelpfully this website mixes and matches the words "guideline", with "criteria". A guideline has flexibility, criteria doesn't. I need to find out which these are, a call to Environmental Health first thing next week will probably clear up a lot in one swoop.

 

A few lines copied from the blurb describing guideline No.13; Hygenic design of equipment for open processing

"This means that in open plants, environmental conditions, in addition to appropriate equipment design, have an important influence on hygienic operation. The type of product and the stage of the manufacturing process must also be taken into consideration. This paper deals with the principal hygienic requirements for equipment for open processing and applies to many different types, including machines for the preparation of dairy products, alcoholic and non-alcoholic drinks, sweet oils, coffee products, cereals, vegetables, fruit, bakery products, meat and fish. It describes methods of construction and fabrication, giving examples as to how the principal criteria can be met."

 

I think BBQ's would definitely fall into that category. I read "environmental conditions" as "rust" and "equipment design" to include material spec.

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Right, following a call to the Foods Standards Agency and a chat to someone in the "materials in contact with food" department, the info is laid out in European Regulation 1935/2004. This is the link via the FSA website you want if you're interested. http://www.legislation.gov.uk/uksi/2012/2619/contents/made

 

I chatted to the guy for about 10 minutes and came away happy that the regulations follow common sense. (He obviously knows them inside out). In short, it's the parts that are in contact with the food that are the most important and materials like stainless steel are best because you can clean them easily and you know how they're going to react. With regards to finishing your mild steel items in vegetable oil - to keep within the rules you've got to state how the item can be used and an aftercare procedure to be done by the customer. That's bascially because you have to make the customer aware of the limitations of the product and the oil finish isn't going to last as long as the steel itself.

 

 

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The people preparing the food will be liable, not you. 

Anything further to that I personally would ignore, as it comes down to hygiene, not materials.

Bacteria don't have any harder time living on forged s/s than forged m/s. Meat is either cooked or it's not, and that's about the end of it.

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The people preparing the food will be liable, not you. 

Anything further to that I personally would ignore, as it comes down to hygiene, not materials.

Bacteria don't have any harder time living on forged s/s than forged m/s. Meat is either cooked or it's not, and that's about the end of it.

 

 

I'm not 100% sure that's the case, at least in the US. There are specific regs here when it comes to doing sanitary welding of food processing equipment. I'm not up on all of them but one is that the welds have to be blended smooth so there aren't any nooks and crannies that collect bacteria or food particles. That means all those nice pretty "stack of dime" tig welds need to be sanded smooth and blended. As far as I know it's the welders responsibility that all those welds meet code.  On stainless that usually means all the welds have to be back purged to prevent "sugaring" ( the crusty black bumps that form when stainless is exposed to O2 above a certain temp)

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Untreated steel, and cast iron has been used for centuries to cook on.

Basic food safety covers things like crevices where bacteria can grow. Also having it smooth will aid in cleaning. Do it in steel, and then show them how to care for it properly.

The temps in a pig roaster should be above the 165°F limit for meats, so even if a few of the little beasties are still on it the temps will kill them.

Build it to the customer's specs, and have them sign off on the design. Always cover your behind first.

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  • 1 month later...

Just seen this thread - moved and only got the net this week thanks to 'high speed' BT!

 

Pretty much all I do is make iron cooking gear in an 18th Century style and being a lawyer I wanted to make sure I knew what I was doing when I started to sell to others.

 

The above is all right, but... although the duty of care lies with the manufacturer / supplier of any piece of work, the courts do follow the old maxims of the common law in addition to extra-national rules (usually giving priority to common law).

 

I can only write in respect of England and Wales, but here any court will take it for granted that if an item was sold for culinary use any buyer will know that it must be kept clean and not allowed to rust.

 

Consumer protection is all well and good, but the steps toward North American levels of 'Safety Warnings', risk averseness and over-litigation that came at the start of the century were seen by the legal establishment, well the Judiciary anyway, as leading to a slippery slope. Ditto that for the EU nanny-state proliferation of 'rules'.

 

Currently there is a low-level conflict between the health and safety brigade (FSA included) and the more pragmatic members of the bench; the Law Commission is trying to consolidate and codify all of our law and will have a fine time trying to reconcile these two viewpoints.

 

Final advice = just hand out a flyer stating the bleeding obvious and mentioning that until pretty recently we had used iron, steel and brass for thousands of years without trouble.

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