Hygiene Code for the Butchery Industry - new working method

From October 2021, the new Hygiene Code for butchers' establishments will be compulsory. At first glance, the code looks simple, but if you read carefully you will see that many new requirements have been added. It is a catch-up move to keep up in a fast-growing sector.

Hygiene - by Anna Shvets

In addition to butchers, many small and medium-sized EC approved meat establishments also make use of this code. Regulation 852/2004 states in Chapter 3 that small and medium-sized enterprises may work in accordance with an industry hygiene code. A large part of the sector therefore works in accordance with this hygiene code. In order to remain in line with technological and scientific developments, a hygiene code must be regularly revised in accordance with the Regulation. A review period of 4 years was established at the time in the Ministry of Health's Regular Consultation on Commodities Act. As the previous version dated from 2010, a period of 11 years is really very long. And that has consequences. In the meantime, developments have continued. Companies with a certified food safety system such as BRC, IFS and FSSC22000 must test and adapt their system annually in order to remain up-to-date. With developments such as the horse meat scandal (fraud), deaths due to the presence of Listeria in meat products, Salmonella outbreaks, viruses, STEC problems, stricter recalls, allergens, healthier food with less fat, salt and sugar, safe primary packaging and so on. As a result, companies that have continued to work only in accordance with the hygiene code are now hopelessly behind.  

A lot has changed since the introduction of HACCP

A lot has changed since we started working with HACCP in 1996. Now that it is controlled from Europe in 2002, more and more scientists are looking at food safety. The more knowledge there is, the more dangers are uncovered and the more regulations are created. This is a movement that can no longer be stopped. If a company does not grow along with this and only comes into action when it is fined, it will find it increasingly difficult.

The basis of the old Hygiene Code has remained. It has mainly been expanded with new and stricter regulations and new processes. Such as dry aging, self-service sandwiches, catering, sterilising, MAP packaging, preparing sauces and so on.  

Biggest changes in the new Hygiene Code

To begin with, the critical processes (CCPs) have been expanded. The CCP heating now also includes: cooked smoking, sous vide, regeneration, sterilisation, hot filling and post-pasteurisation. Furthermore, re-cooling has become a CCP so that a minimum weekly registration is also mandatory here. A weekly registration is mandatory for all CCPs. New is the CCP for the acidity of home-made sauces and dressings. The pH must be lower than 4.2. The salting of sausages and meat products has also become a CCP for which the salt and nitrite content must be calculated. A minimum content of 40 grams of nitrite salt per 1 kg counts as preservation.

Controls including improvement measures in the Hygiene Code

Deviations from checks must be recorded on a separate registration form, including remedial action. If a deviation is registered at a CCP and no demonstrable action has been taken, this may be subject to a fine. So always fill in the deviation form when deviations are registered! Receipt of raw materials and storage temperature are not critical and therefore do not need to be registered. However, there are registration forms for these because the checks are important due to additional requirements. For example, beef shreds for tartare, filet americain and beef hamburgers may not be older than 5 days after slaughter. Well, if you do not check this, you will soon be in for a surprise. Signing a supplier's declaration is not sufficient. Moreover, the slaughter date must be known and that is difficult to check if there is only a production date on the label. Another requirement is that a bacteriological report must be made of the chips periodically. This can be requested from the supplier, but if the supplier does not provide this, you may have it examined yourself. The checks for Salmonella and STEC are particularly expensive. For ordinary minced meat and meat preparations, there are no additional requirements for freshness.   

Minimum shelf life

In addition, a minimum shelf life of 4 days applies to perishable products such as chicken. This is because at least 4 days must be taken into account for storage, processing, presentation, sale and consumption. That is why a good entrance check is important here as well.

Catering and BBQ

For catering activities such as the delivery of a BBQ or buffet, the butcher must prepare a form for the customer which includes the recorded delivery temperature (cold or hot), instructions for safe use and how to deal with leftovers. Information can be taken, for example, from the shelf life guidelines appendix.

Ensuring shelf life

Ensuring shelf life will be a new challenge. There are strict guidelines, which many butchers will find difficult to comply with because there must be more structure. It will be a challenge to organise this properly. If perishable products in a pack are opened, the shelf life is 2 days. So if packaged meat products are opened in the wall unit, they must be finished within 2 days. But if half of it is repacked, it has a shelf life of 4 days. Pre-cut meat products and meals in MAP packaging, for example, also have a shelf life of 4 days. In order to make these new requirements demonstrable (compulsory), labels must be used with a date of opening or packaging. A clear working method and instructions for employees are important here.  

Companies which work with a hygiene code will have to comply with the requirements in the code. Looking for another hygiene code does not make sense nowadays because the NVWA ensures that all codes are harmonised. However, butchers can take other control measures in consultation with the NVWA, provided that they are based on a good hazard analysis. Handy companies make grateful use of this.

Published in Vleesmagazine, December 2021.

Yvon Bemelman