Research into the use and perceptions of guidance on food safety and standards

This chapter addresses how food businesses and food law professionals use guidance to support compliance with food law among food businesses. It sets out how guidance is used on a day-to-day basis by food businesses to help them comply with food law requirements, as well as how food law professionals use guidance. It then considers how food businesses and food law professionals currently use FSS guidance and their perceptions of how it positively impacts their work.

At the start of the interviews, food businesses were asked about the challenges or risks their business faces when complying with food law requirements. Food businesses highlighted multiple factors they continuously address to maintain standards and described how they use guidance in overcoming any challenges they face when doing so.

For most food businesses, guidance means the range of practical tools they use to ensure day-to-day compliance with food safety and hygiene within their business. Guidance is used to help staff create and follow daily or regular routines, covering daily temperature checks, cleaning schedules and allergen matrices. Food businesses know it is essential to demonstrate compliance with these requirements if they want to continue to pass their inspections. 

Food businesses typically use a range of resources, but often refer to specific templates for daily or weekly logs. These were often templates from CookSafe, but several food businesses did not refer to it as CookSafe without prompting, or were unaware that it is FSS guidance. 

Food businesses described in detail the types of processes they follow. Temperature control is a core area where they seek out and rely on guidance. Businesses described using information on safe cooking temperatures, cooling and reheating rules, and hot holding requirements for equipment such as bain-maries as part of their daily compliance routines. Fridge and freezer monitoring was widely mentioned.

Hygiene standards and cross-contamination controls were also noted as areas where guidance is regularly used. This included information on handwashing procedures, sink placement, hot water requirements, and colour-coded chopping boards and fridge segregation to prevent contamination. Kitchen layout guidance was noted as another area of interest, particularly for reducing contamination risks and meeting inspection requirements. Several businesses relied on HACCP frameworks and CookSafe for step-by-step guidance on how to ensure compliance. 

When asked what topics, issues or information about food safety and standards that businesses most need guidance on, food law professionals cited labelling requirements, allergen management, and developing HACCP procedures and their ‘house rules’ in CookSafe. They also raised general food law compliance, safe food handling, hygiene, temperature control, storage, as well as advice on record keeping and maintenance.

Many of the issues which trigger food businesses to refer to guidance were also raised by food law professionals. They detailed various issues commonly faced during inspections, such as food businesses not having food safety management systems in place, cleanliness concerns, complex labelling requirements, a lack of cross-contamination records, and shellfish compliance challenges. 

More broadly, guidance relating to environmental health topics were sought or needed by food businesses. Topics included seasonal pest management, waste disposal standards and equipment safety and infrastructure standards.  

For several long-standing businesses, there is a sense that there have been limited changes in compliance requirements over time. This means they are not actively looking for updates to legislation or other regulations which may affect their business. While they often hear about changes organically, there is no consistent way in which food businesses find out about changes. Conversely, others reflected on how food safety needs have changed over time, noting a shift from basic hygiene and temperature standards to more detailed requirements around allergens, labelling, and supplier traceability. 

As with guidance overall, food law professionals play a central role in keeping businesses updated, though a small group of businesses had used the FSS website or local authority website. Businesses described being told about changes during inspections or after an issue arises, although a small number described being proactively notified to changes by food law professionals or by FSS. 

Allergen management and labelling were described as increasingly complex and constantly evolving, but essential to compliance. Dedicated support and guidance in this area is seen as increasingly necessary; businesses noted they require robust systems and clear guidance to avoid any harm to customers and/or legal action.

Businesses reflected on the changing nature and rising customer demands related to allergens, with some noting that the increasing scale of allergen management causes them concerns. These concerns were evident across many business types, notably smaller food businesses where owners or managers felt responsible for ensuring they were applying guidance correctly or could risk reputational damage. 

Earlier practices relied on customers asking about allergens, whereas current legislation requires full disclosure. The need to provide detailed ingredient information, including for compound ingredients such as sauces, to comply with labelling regulations, was stressed. Natasha’s Law was frequently mentioned as a driver of change in this area, requiring clear allergen disclosure on prepacked foods.

Food businesses also recognised shifts in consumer habits, with food businesses needing to remain vigilant to the increased scope of legislation and regulations. One business reflected on an experience related to a customer suffering an allergic reaction in their premises: 

While there was a variable awareness of FSS and limited use of FSS guidance beyond CookSafe, the businesses familiar with FSS guidance typically described the range of resources they had used as comprehensive and easy to understand. 

Food businesses highlighted the crucial role CookSafe has in maintaining food safety and standards in their establishments. CookSafe was highlighted as the key piece of food safety guidance they use, with multiple businesses describing CookSafe as their ‘bible’ that underpins their approach to food safety and noting how often they use it and refer to it to structure daily checks, record keeping, and ensure compliance. CookSafe was mentioned by many businesses regardless of their awareness of FSS, though some attributed CookSafe to local authorities or the FSA. 

Businesses highlighted the universality and flexibility of CookSafe as valuable. One noted that because food businesses across Scotland use the standard manual, this keeps food hygiene information the same for everyone and is easy for their staff, new hires and food law professionals to reference. Others appreciated being able to customise their CookSafe manual for their business. One business noted that it can add updated information to its manual to ensure it remains accurate. 

When asked what they liked about CookSafe, food law professionals also reiterated its importance and commented that they liked its clarity, structured food safety management system, simple format, ease of use, and understandability. They also appreciated its practical tools such as templates, wide use and recognition, availability in multiple languages, and that it is free. 

Beyond CookSafe, allergen guidance was also often noted as being used by businesses, with a few reporting using FSS training on allergen information. In these discussions, the important role of food law professionals in directing their attention to the changes and new guidance was often highlighted by food businesses. 

A few businesses used FSS posters in their kitchens to remind staff of allergen information, and these posters were praised by one interviewee for their clear graphics and good visuals. The allergen information available on the FSS website was also described as helpful. 

The online allergen training module on the FSS website was mentioned by a few businesses and praised for being clear, practical and flexible. Businesses found that their staff were able to complete the modules around their availability. Managers and owners appreciated that the training was free. Food law professionals also commented positively on the online allergen training. They emphasised the value of it being free, accessible through being online, and described it as helpful, comprehensive, and easy for food businesses to use and understand. 

After CookSafe and allergen guidance, the most used was guidance on labelling. Businesses highlighted their awareness of the importance of accurate labelling to ensure the safety of their customers. A small number of businesses used the Eat Well Guide. One catering business used the Eat Well Guide for the community, creating a cookbook and using posters from FSS as a conversation starter about good health in community settings. Two interviewees noted they frequently referred to FSS’ cleaning products guidance.

Specialist guidance was used by a small number of food businesses. These businesses noted their awareness of specialist or technical guidance, but felt it was outside their job scope to deal with it regularly. For example, one fish restaurant manager was aware that the head chef used FSS shellfish guidance but had not used it personally. Another fish business was aware of the guidance around caught fish, but felt it was irrelevant to them as they bought and sold their fish daily rather than storing any of it. However, a few did refer to using guidance to prepare shellfish safely.

Survey comments and subsequent conversations with food law professionals also highlighted many positives of FSS guidance. In addition to the above positives, they also felt it was helpful that FSS guidance reflects the Scottish context. One noted that they felt FSS is trying to make their guidance more user-friendly. It was also noted that FSS guidance is expanded or changes over time to reflect changes in legislation and regulations, for example, labelling guidance on prepacked for direct sale food.

A few stakeholders also expressed positive views on FSS’s existing guidance and the ease of finding the guidance on the FSS website.