The New Staff Member and the Records That Weren't There
You are the owner of a small takeaway that has just been visited by a food safety officer. The officer finds: (1) no documented food safety programme - the owner says 'we know what we're doing, we've been here 10 years'; (2) no temperature records for the last two months; (3) a new staff member who started three weeks ago and has had no food safety training or induction; (4) a cleaning schedule that exists but has not been signed since last month; (5) a cooked chicken dish in the display cabinet with no date label; (6) the owner says the officer is 'being picky' because the shop has never had a complaint. The officer issues a notice requiring corrective action within 10 working days. The owner asks you (as the person responsible for food safety) what actually needs to be done and whether the 'no complaints' argument helps.
1. Explain the legal and practical position: what is the business required to have, why 'we've never had a complaint' is not a defence, and what the absence of records means for the business.
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What the business is required to have
- A documented food safety programme appropriate to the business: identified hazards, controls, monitoring, corrective actions and verification. The size and complexity can be proportionate, but it must exist and be followed.
- Temperature monitoring records for high-risk food (receiving, storage, cooking, cooling, hot/cold holding, reheating). Records are the evidence that controls are working.
- Training and induction records for every food handler, including new starters, covering hygiene, temperature control, cross-contamination and allergen awareness.
- Cleaning and sanitising records - a schedule that is actually completed and signed.
- Date labelling of cooked/opened high-risk food so stock rotation and shelf life can be managed.
Why 'no complaints' is not a defence
- Foodborne illness is under-reported: most people do not complain, and a single incident can involve multiple customers who never contact the business. Absence of complaints is not evidence of safety.
- The legal duty is to prevent harm, not to wait for it. Compliance is judged on whether controls and records exist, not on whether anything has gone wrong yet.
- The officer is not 'being picky' - the findings are objective: no programme, no records, untrained staff, unsigned cleaning schedule, unlabelled high-risk food. These are the things an officer is entitled to require.
What the absence of records means
- Without records, the business cannot demonstrate that food has been kept safe. In practice, an absence of records is treated as an absence of control.
- It also means the business cannot investigate a complaint or a recall, and cannot show due diligence.
- The unlabelled chicken dish is a direct risk: unknown cook date, unknown shelf life, unknown whether it has been cooled correctly.
Bottom line: the notice is reasonable, the 'no complaints' argument does not help, and the 10-day deadline is achievable if the work is prioritised.
2. Produce a prioritised action plan to meet the 10-working-day deadline, including what you would do about the unlabelled chicken, the untrained staff member and the missing records.
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Priority 1 - today (immediate food safety)
- Unlabelled chicken dish: remove from display and discard unless you can establish the cook date and safe shelf life with certainty. If you cannot, discard. Record the disposal. From now on, every cooked/opened high-risk item gets a date label (cook/open date and use-by).
- New staff member: do not let them handle high-risk or RTE food unsupervised until induction is complete. Complete a documented induction today covering handwashing, temperature control, cross-contamination, allergens and reporting illness. Record it, with signature and date.
Priority 2 - within 2–3 days 3. Temperature records: start a daily log immediately (fridge/freezer, cooking, hot holding, cooling, reheating). Use a calibrated probe. Record actual readings, not ticks. Back-fill is not acceptable - start from today and note the gap honestly. 4. Cleaning schedule: complete and sign it from today; assign named responsibilities per shift; verify weekly. 5. Date labelling: introduce a labelling rule and stock rotation (FIFO) for all high-risk food.
Priority 3 - within 10 working days 6. Written food safety programme: document the hazards and controls for this business (receiving, storage, cooking, cooling, hot/cold holding, reheating, cleaning, pests, allergens, training). Keep it proportionate - a short, practical document that staff actually use is better than a generic template. 7. Training records: train all staff (not just the new starter) and keep records. 8. Verification: a weekly check by the person responsible (you) that records are complete and corrective actions are closed. 9. Respond to the officer in writing before the deadline: list each finding, the action taken, the date and the evidence. Keep a copy.
Records to keep
- Corrective action plan and completion evidence.
- Temperature logs, cleaning records, training records, date-label checks.
- Disposal record for the chicken.
What to say to the owner 'The notice is fair and the deadline is doable. The chicken goes today, the new starter gets inducted today, and we start records today. The programme can be written in the 10 days. Complaints aren't the test - records and controls are.'