The terms good or best practice seem to pervade conversations about food safety at the moment. They seem to be used mainly as a qualifying term for justifying a procedure or standard, which may well be a higher standard than is really necessary! (discuss?)
Sometimes it may be necessary to provide for clarity extra detail beyond the legal minimum standard, which is mainly goal based rather than prescriptive. And many legal standards are further qualified by words such as reasonable, reasonably practicable, etc. or protected by a defence that all reasonable precautions and due diligence were taken.
Much of the FSA’s practical guidance is helpful to a point, and the industry guides offer practical systems that can be expected to demonstrate legal compliance if maintained. But the disclaimer is always hovering around, saying only the courts can decide on contravention or compliance. Even then the legal judgement is qualified either by reasonable doubt, or on balance of probabilities.
The purpose of good practice guidance should be to provide a safety margin above the legal minimum and ensure that if followed the potential for contravention is low, or that if it a contravention is alleged, a realistic defence could be constructed. And that good practice should be realistic, practical and workable in a real food business, without undue expense or resource.
As far as best practice is concerned, it is a term I try to avoid, for two reasons:
- Best practice isn’t necessary
- Best practice probably is different in every business to a greater or lesser degree
So, for example, headcoverings – what is generally regarded as good practice is for all food handlers (define them as you wish!) to wear something on the head which stops hairs falling into food. But best practice very much depends on the individual, their job, and the area they work in. Unless we want to specify that best practice is always wearing a hairnet and a full headcovering covering all the hair and ears and neck? And if we do that, some businesses will choose not to follow best practice for good reasons, but somehow feel they are failing and at risk of criticism.
As I said, at the beginning, discuss……