IHHC Food Safety Program Guide Review

The IHHC Food Safety Program Guide was developed over many years by a team of people who work in healthcare hospitality and understand the difficulties of mastering the development, implementation, monitoring, verification and ongoing upkeep of  a food safety program. Following a recent review of the Guide,  Gary Kennedy takes us through the changes.
Regulations change. New issues arise. Governments issue new directives. New products come on to the market. Menus change. An organisation’s food safety program is a living document and must reflect all of those changes. In addition, things change at sites and within the organisation.
The IHHC Guide is no different. It must be reviewed and updated regularly to make sure it also is reflective of what is happening ‘out there’ and that it is current and relevant, practical and pragmatic.
Recently, the document was fully reviewed and this article details those changes. Subtitles used within this article reflect the subtitles used within the Guide.
Background
In this section of the manual, information on the various state and territory requirements are detailed.
Many states have introduced lists of approved auditors and the guide has been updated to include where the details for each state can be found on that state’s food regulatory authority’s website.
In New South Wales, Victoria and Western Australia, hospitals and aged care can elect to swap from a government auditor to an approved private auditor.  The list of auditors is state specific, so an auditor approved in Victoria cannot do an audit in New South Wales, unless they are also approved in that state.
New South Wales and Victoria allow a manual to be approved for multiple sites by the state regulator. This has been allowed in Victoria for quite a while, but this type of multisite approval is relatively new to New South Wales.
This can be a significant advantage, as once a manual has been signed off by the state regulator, the basic manual has been ‘validated’ and individual auditors cannot ask for changes to the manual, unless regulation or onsite practices change and the manual has not kept pace.
Glossary of terms
Some definitions have been reviewed, primarily to make sure they are consistent with the terminology used by state and territory regulators.
2 hour / 4 hour cooling rule –  reflect current terminology used
2 hour / 4 hour storage rule –  NSW uses different terminology for this term
Allergens –
makes reference to food standard 1.2.4 and gives further detail on sulphites
Cook chill food with extended shelf life –
sous vide has been removed and given its own definition to reflect the current terminology used
Sous Vide –
 It unlikely that any HealthCare site will ever do sous vide.  In NSW sous vide is banned from being used for vulnerable populations. Sous vide may be cooked down to as low as 55 degrees and the restaurant / caterer serving sous vide must tell the customer that the product is raw.
Biological Hazards -  Specific controls to minimise the risk of Salmonellosis
Previously, the guideline stated “Cook Eggs until the white and yolk are solid”. However, NSW and Tasmania will allow eggs to be served in some cases where the eggs are not fully solid.
The Guide here makes reference to the NSW and Tasmanian documents, which allow eggs to be served where the white  is fully solid, with the yolk thickening.   A poached, fried or boiled egg may no longer need to be cooked all the way through to the centre of the yolk.
Food Safety  Management Tables
The pages here have been expanded with further detail. There are new hazards; control measures, monitoring controls and corrective actions. The changes have been made for two main reasons.
Firstly, many of the changes are just addition of more detail, but secondly and perhaps more importantly, as new issues arise, the audits become more thorough and as the requirements of the states and territories become stricter, new hazards and controls have been added to ensure all hazards that could exist at a healthcare site have been fully detailed.
Some states, notably NSW who have published a Vulnerable Populations manual, require that all food on site is covered by the food safety plan, not necessarily just the food in the kitchen.
Hazard and controls now covered in more detail include:
Allergens
The tables now cover allergens present in raw materials and cross contamination during all stages of food preparation and through to serving, including making sure the correct product is put on the correct tray or plate and served to the correct person.
Special and texture modified diets
The hazard that someone on a special diet may not be served the food that is appropriate for their diet has been included.  Now considered are issues such as how the special needs of patients or residents are assessed on arrival; menu design and making sure the correct product is put on the correct tray or plate and served to the correct person.
Foods bought in from outside
Covering food such as dial-in food and food bought in by relatives.  Now considered are the consideration of potential restriction of bought-in food onsite
Storage of food where patients/residents have access to the food, such as common rooms, tea rooms and pantries
Now considered are issues such as the monitoring of chilled and frozen storage outside of the main kitchen if used to store patient food and the practice of labelling of all food in common storage areas, including that bought from home or outside the kitchen.
One off functions such as barbecues and fetes
The updated guide recommends that these only be conducted by food service staff.
Cold set products [such as mousse;  cheesecake and some supplements).
If these are made up with tap water, they must still cool down to less than 5 degrees, meeting cooling regulation times and temperatures. These also do not undergo a cooking step.
Warming
Some foods such as milk for cereals and baby bottles are not “cooked” but only warmed and do not therefore reach 75 degrees. The guide makes is clear than in some cases “reheat” means cook to 75 and in other cases it means “warm” and this needs to be clearly defined in a food safety plan.
Tea trolleys, pill trolleys  and mid-meal trolleys
Need to be considered, particularly if refrigerated product is on these trolleys. What happens to that refrigerated food when it is out of refrigeration at the end of the mid-meal service?
Patient transport
Does the food put on long ambulance or other vehicle journeys meet the 2 hour / 4 hour rule if it is hot, refrigerated or frozen?
Infant formula and supplements
The 2 hour / 4 hour rule applies to these products if left unrefrigerated by a patient’s bedside, or in a resident’s room.

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“The updated IHHC Food Safety Program Guide is  a more complete document than the previous version and has been expanded in particular to cover allergens and food prepared, handled and stored outside the kitchen.”
GARY KENNEDY

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Cleaning and  Sanitation Program - Cleaning & Sanitising Program Verification
Swabbing
A small section has been added here discussing swabbing as a way of verifying that a cleaning program is working well. Swabs are available that test for protein residues, for specific bacteria [such as Listeria species] and for allergens.
The NSW Food Authority document on swabbing “Environmental Swabbing”  is referenced here.
Dishwashers and Potwashers
Some states and territories no longer consider the monitoring of dishwashers and potwashers to be critical, provided effective chemicals are used [providing chemical sanitising].
The guide advises to check with your local authority before you remove monitoring of dishwashers and potwashers.
Food Handler Induction & Training Program
New Health and Hospitality Training packages have been introduced for states and territories. The updated packages for Health for Hospitality and for Retail have been included.
NSW only allows those registered training organisations approved by the NSW Food Authority to undertake Food Safety Supervisor training.
Pest Control Program
A recent change to food standard 3.3.2 has allowed companion dogs in outdoor dining areas, when previously only assistance animals were allowed.
Useful  Websites & Resources
Updated to ensure it is current and includes new documents, such as those relating to allergen controls.
Not updated
Many sections of the manual were not updated as they were considered current, accurate, valid and complaint with current regulation and with additional state and territory requirements for healthcare.
Effectively, if a section of the guide is not mentioned in this article, then no change has been made of any significance.
Conclusion
The updated IHHC Food Safety Program Guide is a more complete document than the previous version and has been expanded in particular to cover allergens and food prepared, handled and stored outside the kitchen.
It makes reference to new and revised government guidelines and fact sheets that provide useful alternate ways to make, store, prepare and handle food.
Using the new guide will ensure that a food safety plan for a healthcare site is even more a guarantee of safe food production.
Gary Kennedy
Gary Kennedy graduated from the School of Food Technology, University of New South Wales in 1984.
He has worked in quality assurance and product development roles in hospital catering, meat, transport and cook chill industries and as a food safety trainer, consultant and lead food safety auditor.
He is a Past President of the Australian Cook Chill Council, advising the food service, aged care and acute care industries on food safety and as a representative of this organisation advised the organising committee on food safety for the 2000 Sydney Olympic Games.
He has written over 30 papers, and has written or co-written guidelines and codes for the Cook-Chill, Smallgoods, Hospitals, Child Care and Refrigerated Transport Industries.
In Sydney, he manages a food safety consultancy business, Correct Food Systems, providing food safety advice, primarily to small and medium businesses.
He is a regular on Channel 7’s Today Tonight and ABC 702 radio in Sydney and writes articles for a number of magazines and journals.