Product description and intended use

Step 2 asks for a full description of the product, including relevant safety information. Codex lists composition; physical and chemical characteristics such as water activity, pH, preservatives and allergens; processing methods such as heat treatment, freezing, drying, brining and smoking; packaging; durability or shelf life; storage conditions; and method of distribution.

These facts tell you what can survive or grow. Water activity (aw) measures the water available to micro-organisms. pH measures acidity. A cooked, chilled, moist, neutral-pH food with no preservatives gives pathogens few barriers. A cottage pie is like this. High-sugar jam has much lower water activity and a lower pH, so its risks are very different.

Codex also says that limits already set for hazards should be accounted for. Examples are limits for food additives, regulatory microbiological criteria, maximum veterinary medicine residues, and times and temperatures for heat treatments prescribed by competent authorities.

Businesses with many products can group those with similar characteristics and processing steps. Group with care. A group is only sound if the same hazards and controls apply to all of it. A product with a different allergen, a different pack or different users may need its own treatment.

Shelf life needs evidence. Packaging is a good example of why. FSA and FSS guidance covers non-proteolytic Clostridium botulinum in vacuum and modified atmosphere packed chilled foods. Where no other controlling factor can be identified, it says the maximum shelf life should be ten days from first packing. A longer life needs controlling factors, such as a heat treatment of 90°C for 10 minutes. The guidance no longer applies to chilled fresh beef, lamb and pork with no added ingredients or further processing. It does still apply to meat that is minced, cooked or mixed with other ingredients. So a change of packaging can bring in a hazard that was not there before.

Step 3 asks you to describe the use intended by the business, and the expected uses by the next business in the chain or by the consumer. Will the food be eaten as it is, or cooked? Who will handle it? How will it be stored, and for how long?

Think about what people really do. Hazard analysis should consider known unintended use as well as intended use. Codex gives the example of a soup mix meant to be mixed with water and cooked, but commonly used without heat in a dip for chips. Information may come from the competent authority, from complaints, or from your own customers.

Then consider vulnerable groups. Codex says that in specific cases, such as hospitals, vulnerable groups of the population may have to be considered. Where food is made specifically for a vulnerable population, it may be necessary to enhance process controls, monitor control measures more frequently, verify controls by testing products, or carry out other activities that give a high level of assurance.

The FSA identifies pregnant women and their unborn babies, people with weakened immune systems, and older people as being at higher risk from Listeria. Its guidance on less than thoroughly cooked burgers, which covers England, Wales and Northern Ireland, treats children, older people, immunocompromised people and pregnant women as vulnerable.

Now apply this to our pies. They are cooked, chilled, and reheated by the customer. Many care home residents are older and some are unwell, so the same hazard may cause more serious harm. The mash contains milk, and a resident may have a milk allergy. So the team records the care homes as a distinct group of users. It tightens the cooling controls, keeps clear batch records, gives clear reheating instructions, and makes sure allergen information reaches the kitchen that serves the pies.

Instructions should suit where the food is used. If the pies go to care homes in Scotland, the instructions should fit Scottish law, which sets a reheating temperature of at least 82°C unless this would harm the quality of the food. Elsewhere in the UK the food should be piping hot throughout, and 75°C at the core is the common guide.

Intended use also decides what counts as acceptable. A significant hazard is defined by reference to the intended use of the food. If a farm-shop product starts going to a nursery, the users have changed, and the plan should be reviewed.