Catering and banqueting: hygiene obligations under Reg. (EC) 852/2004

The activity: registration of the production kitchen

Catering falls within retail including the service of food and requires registration under Article 6 Article 6(2) of Regulation (EC) No 852/2004: the anchor is the production kitchen, a fixed place of production. In Italy registration is made through the health SCIA notification: see registration and SCIA in Italy. Serving at different locations does not create a fresh registration obligation for every event, but must be covered by the production kitchen's food safety plan.

Full-flow HACCP (Art. 5)

What sets catering apart is the gap between production and consumption: procedures based on the seven HACCP principles Article 5(2) of Regulation (EC) No 852/2004 must follow the food beyond the kitchen. Typical critical control points are cooking (core temperature), rapid chilling, hot or cold holding, transport and on-site regeneration or service. The plan rests on the prerequisite programmes (PRPs) and must be calibrated to the menu and logistics of each type of event. Operational framing: Article 5 (HACCP).

Hot/cold holding

The time between production and consumption is the central risk. Two strategies: hot holding keeps dishes at a safe temperature until service; cold holding chills rapidly after cooking, stores under refrigeration and regenerates on site shortly before service. In both cases food may not be held at temperatures that would result in a risk to health Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004 and the cold chain must not be broken Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004. Temperature windows and maximum times must be set as critical limits in the plan.

Transport (Annex II, Chapter IV)

The move from the production kitchen to the event is subject to the transport requirements: vehicles and containers used for food must be kept clean and maintained, food must be placed and protected so as to minimise the risk of contamination, and where necessary vehicles must keep food at appropriate temperatures and allow those temperatures to be monitored Annex II, Chapter IV, point 7 of Regulation (EC) No 852/2004. Separating hot, chilled and ambient food in transport is part of the hazard analysis.

Movable and temporary premises at the event site (Annex II, Chapter III)

When marquees, field kitchens, regeneration points or service counters are set up on site, Chapter III on movable and temporary premises applies: premises and equipment must be kept clean and in good order, with potable water available, means for personal hygiene and for cleaning, and surfaces suitable for food contact, in a manner proportionate to the activity Annex II, Chapter III, point 2 of Regulation (EC) No 852/2004. See Chapter III on movable and temporary premises.

Training

Production and service staff must be trained in food hygiene, and those responsible for the HACCP procedures suitably instructed Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004. In catering, training must also cover the off-site stages (transport, regeneration, service): in Italy the rules are regional, see HACCP training in Italy.