First appeared in the
Environmental Health Journal May 2003.
Original paper reproduced by kind permission
of the Chartered Institute of Environmental
Health.
Abstract
Food hygiene training culminating in
certification for the candidates is
no demonstration of competency. Euan
MacAuslan offers some ideas for a change
to benefit food handlers and employers
if practical application of knowledge
gained on courses is going to have any
real meaning.
"Soap and education are not as
sudden as a massacre - but more deadly
in the long run" (Mark Twain, 1872).
Why is it that the Food Standards Agency
estimate that over 4.5 million people
in the UK has food poisoning every year
(1), and yet millions of food handlers
have received food hygiene certificates
by attending approved training centre
courses since the early 1980s? In addition
to which, food hygiene training has
been a statutory requirement for at
least the last 6 years. Perhaps it is
because enforcers and owners of food
businesses do not fully appreciate what
training involves and the skills required
by managers to instruct and supervise
employees who have been on courses.
Key definitions in the Food Hygiene
(General Food Hygiene) Regulations 1995,
and the Industry Guides to Good Hygiene
Practice are missing. Too much reliance
is being placed upon attaining a certificate
rather than attention is paid to achieving
competency in food hygiene practice.
Perhaps more emphasis and resources
need to be diverted towards assisting
managers to become highly motivated
food hygiene managers who develop and
maintain a food safety culture within
their business.
The Food Safety (General Food Hygiene)
Regulations 1995 for England and Wales
require "The proprietor of a food
business shall ensure that food handlers
engaged in a food business are supervised
and instructed and/or trained in food
hygiene matters commensurate with their
work activities" (2). It is simply
not sufficient for enforcement officers
to be expect proprietors to comply with
the law there is no legal definition
of key words. The Industry Guides to
Good Hygiene offer no real helpful workable
advice or definitions. The chapters
on about the training regulation are
not clear. They need updating too. Besides
which, in America, Canada, and Australia
such guides are clear, in print or readily
accessible on the internet without discouraging
businesses to pay £3.60 per copy.
The following definitions may wish to
be considered:
- Supervision: Direction or
controlling of a process, practice
or personnel.
- Instruction: The delivery
of information to enable the application
of knowledge and skills to the employees
or candidates.
- Training: Any planned activity
that involves an understanding of
knowledge that may be effectively
applied in the workplace.
It is probably fair to say that the
majority of food businesses do not have
satisfactory training policies for all
their staff (3). A small business owner
may be tempted to place the burden of
training responsibility on an external
employer, and not to shoulder any responsibility
them selves. Is this because the employer
lacks key management skills in leadership,
motivation, training and evaluation?
Or is it because everyone else goes
for a certificate course as it is the
"done thing"? Contrary to
common misconception there is no legal
requirement to hold a foundation certificate
in food hygiene. Language barriers and
the high turnover of hourly paid staff
within small hospitality businesses
does little to help resources, morale
or behavioural change.
Foundation certificates in food hygiene
courses are readily accessible from
colleges, consultants, local authorities,
or in-house trainers all of who are
registered with examination bodies such
as Chartered Institute of Environmental
Health , Royal Institute of Public Health
or Royal Society for the Promotion of
Health . None of their nationally recognised
certificates give any indication of
competence. So in this context the Foundation,
and intermediate certificates on offer
are not training in the full meaning
of the work. They are instead "education".
This involves passing on information
for the candidate to absorb, and possibly
regurgitate in a multiple-choice examination.
They may not necessarily have the ability
to apply the information practically
upon return to their workplace. Professor
Eunice Taylor is critical of training
of food handlers in the UK. In her opinion
it is because it is stand-alone, theoretical
and one-off with little attempt made
to evaluate its effectiveness (4).
One examination body goes so far as
printing a recommendation on the back
of it's Foundation Certificates in Food
Hygiene. This is for refresher training
to take place every thirty six months.
This does not help employer or employee
with practicing proper food hygiene
skills. The word refresher is vague
and could be taken to mean further study
of a subject by an individual to bring
their knowledge up to date. Perhaps
a phrase such as "update training
as required" would be a better
option. The requirement would specify
update training to take place following
a food poisoning incident, customer
complaint, review of a hazard analysis,
new ingredients or process etc.
Training must be appropriate to each
individual business. Motivated employers
and employees must properly apply it.
"To learn, you must want to be
taught" (Proverbs 2:1). Certificates
are often proudly displayed in workplaces.
These look impressive. However, these
qualifications are pointless unless
the named certificate holders are constantly
putting in to practice their knowledge,
which in turn they are keeping up to
date.(5)
Closer reading of the regulation will
help to demonstrate that there is no
legal requirement to hold a certificate.
What is a certificate? It could be defined
as a piece of paper confirming attendance
of an event or achievement. If this
is the case how will a manager or enforcer
know whether the holder is competent
to do their job? Too much reliance has
been placed upon certificates and not
enough on competence. This defined as
the ability of an individual to demonstrate
the activities within their workplace,
or to function to the standards expected
in a food business.
Richard Sprenger (Managing Director
of Highfield Publications) supports
the case for competency. His views include:
increased emphasis placed on the importance
of in-house competency based training
and supervision, and during inspections,
authorised officers should assess the
competence of food handlers by observations
and questions, not by the presence of
certificates on walls (6).
To some extent National Vocational
Qualifications (NVQs) require candidates
to demonstrate competency through assessments
and verification. Unfortunately, the
Qualification Curriculum Authority (QCA)
is at odds with improving standards.
This Authority is behind the uniformity
of accredited examination bodies calling
their courses similar titles and placing
them within the national framework of
recognised qualifications. For instance
a foundation course is level 1 and an
advanced course is at level 3. Contact
with learning and Skills Council, who
distribute funding to training and further
education providers are also complacent
of increasing certification.
The Restaurant Association is piloting
a training programme called Food Safety
Together. This is based restaurants
appointing a mentor (trained in food
hygiene practice) to work with a new
employee in order to find positive approaches
to improving standards within a particular
business. This "what can we do
together" approach is a significant
step away from the old "you are
required to know this or that for the
certificate course".
The UK's track record of food hygiene
courses in languages for individuals
whose mother tongues are not English
is shameful. MacAuslan highlighted this
issue in some depth in 2001 (7). While
examination bodies make proud claims
that examination papers in other languages
apart from English are available, their
usefulness has much to desired. What
is the point in offering papers in a
range of languages if the trainers are
simply in short supply or not at all?
The examination and governmental organisations
must work together to encourage potential
trainers from ethnic and minority groups
to come forward and undertake the necessary
training to become community based food
hygiene trainers capable of wining over
the confidences of their peers. The
Asian and Oriental School in London's
Hackney Community College is going down
this road. The School takes training
a stage further. It offers pre course
assessment, theoretical training, followed
by onsite practical application and
evaluation.
Computer based training (CBT), e-learning,
etc is going to have an extensive role
to play in contributing to the training
of food handlers and managers. Designed
by the right people, and put in the
hands of motivated trainees CBT is a
value training aid. It also teaches
another key skill, namely IT skills.
CBT may suit individuals who have difficulty
in training rooms for a range of reasons.
These may include learning difficulties,
special needs, language barriers, staff
shortages, courses not at a time to
suit individuals or businesses, etc.
Richard Taylor of Creative Learning
Media is of the opinion that use of
CBT ensures that learning can be automatically
managed and evaluated across an entire
organisation. This includes analysis
of who is learning what, when, where
and how; comparison of pre- and post-learning
assessments; and, evaluation of the
system to enable continuous improvement.
(8)
The QCA prefers statistics rather than
helping employees put into practice
what they have been taught. It is a
missed opportunity for the UK that these
two bodies have not understood what
is at stake with regards to a nation's
food safety whilst at the same time
helping individuals to gain a meaningful
qualification. The Food Standards Agency
(FSA), QCA, LSC and industry bodies
such as the Hospitality training Foundation
or Restaurant Association to speak to
each other.
A shift is required away from a qualification
based on theory to one that provides
an employee with confidence in putting
into practice what has been taught,
and employers with an increased knowledge.
The FSA's five year strategy to improve
food safety standards and reduce incidences
of food poisoning is based upon promotion
of a culture of learning and training
within the UK (9). A look at letters
in Caterer and Hotelkeeper magazine
or discussions with the hospitality
industry indicate that the Agency has
done little to be won over by the shock
tactics of sending businesses sick bags,
or publishing "statistics"
which pass the burden of blame for food
poisoning purely on to the shoulders
of food premises. Practical, collaborative
efforts are required. A little more
nurturing by central Government and
enforcement agencies would not go amiss.
Perhaps it could be argued in another
paper that Foundation Certificates (or
any other level in Food Hygiene) have
had their day. The emphasis now needs
to be put on helping managers understand
what is expected of them, and giving
them support in managing effective food
hygiene. The FSA has started down this
road with recently inviting tenders
from specific training providers for
provision of helping managers of small
and medium sized (SMEs)food premises
produce a workable HACCP system relevant
to the individual needs of each business.
This will involve training managers
and guiding them through the practicalities,
rather than theory of HACCP. Good documentation
will serve as a valuable training aid
for both employers and employees (10)
The FSA would do well to link up with
Learndirect or a computer based training
company to provide on-line basic management
skills relevant to SMEs.
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Conclusion
In the 1600s Spinoza said, "I
have striven not to laugh at human actions
but to understand them".
There will always be a place for certification,
but if food hygiene is to improve practical
application of the theory taught on
courses must be properly managed. If
certificates are to remain they must
specify whether competency has been
assessed, and when update training may
have to be considered. For the future
clear definitions of training, instruction
and supervision are required. Practical
training, evaluation and guidance in
management and food hygiene skills are
required for SME managers. In addition
to which community groups will need
empowerment to adopt workable food hygiene
solutions that benefit employees and
consumers - such as delivery of training
in their own specific languages. Enforcement
officers will need clearer guidance
about how to determine effective training
and/or instruction, and supervision.
In the future they will need more advice
about the range of training media available
and how the best media to suit business
and employee needs can be accessed.
Future effective food hygiene training
strategies in the UK must encompass
behavioural change or behaviour modification.
That is to say a change in knowledge,
skills, or attitude of individuals that
occur as a result of a planned set and
schedule of reinforcements (11).
Euan MacAuslan, FRIPH, FRSH, FITOL,
MCIPD, Environmental Health Training
Co-ordinator, Council Offices, 37 Pembroke
Road, London W8 6PW, England Tel: +44
(0) 20 7341 5606 Email: euan.macauslan@rbkc.gov.uk.
The views expressed in this article
are those of the author and not necessarily,
the Royal Borough of Kensington and
Chelsea.
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References
- Food Standards Agency (2001). Annual
Consumer Report. London: Food Standards
Agency
- Food Safety (General Food Hygiene)
Regulations 1995. Statutory Instrument
Number 1763. London: The Stationery
Office.
- Aston, G (2001) Food hygiene legislation
- a review . J Roy Soc Health; 121
(4) p210
- Taylor, E. (1996) Is food hygiene
training really effective? Environmental
Health, September, 275-276.
- White, E (2001)Food hygiene training:
there is much more to it. J Roy Soc
Health; 121 (4) p209-210
- Sprenger, R (2001) Is there a need
to improve food hygiene training?
www.highfield.co.uk
- MacAuslan, E(2001). Food hygiene
training in the UK: time for a radical
rethink? J Roy Soc Health 121 (4)
pp213-219
- Taylor, R (2001). Developing and
e-learning strategy. www.highfield.co.uk
- Warburton, N (2003). Safety first.
CIEH Environmental Health Journal.
February 2003. pp42 -45
- Worsfold, D (2001). A guide to HACCP
and function catering. J Roy Soc Health;
121 (4) p224-229
- Institute of Training and Occupational
Learning (2000). A glossary of UK
training and occupational learning
terms. ITOL, p 5.
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