The system is designed to ensure that foods are prepared and served hygienically. The EC has now issued a draft regulation suggesting a change is made to existing regulations, saying that all food businesses must have a procedure based on the principles of HACCP.  

The FPB's Food Adviser, Bob Salmon, said the system can be quite onerous. "A proper HACCP scheme has a team of people monitoring critical points in the production process and keeping copious records to ensure the checks have been done. Such a scheme is impractical for very small businesses." 

During the drafting of the original EC food regulations, the FPB insisted on the inclusion of words like "where necessary" and "commensurate with the nature and size of the business". This allowed some flexibility on interpretation for low-risk undertakings. The Food Standards Agency (FSA), meanwhile, has drawn up guidance called Safer Food, Better Business (SFBB). This is designed to allow flexibility in line with the original EC guidance. However, the EC proposal would allow exemption from record keeping even of the minimal sort called for in SFBB.  

The FPB welcomes the idea of eliminating bureaucracy, but thinks the EC draft is loosely worded and would lead to confusion and the possibility of some businesses being prosecuted unnecessarily.  

Mr Salmon explained: "The draft speaks of a limit of 10 employees or less than €2 million turnover. The FPB would like to see a reference to risk. For example, there might be more need for a small company making meat pies to have HACCP than, say, a retailer selling pre-packaged sweets. I cannot see any magic in the figure of 10 employees." 

The EC aim is to save 25% of the €220 million existing costs to business from bureaucracy in their regulation. The FPB supports this and believes, if approved, the exemption could be applied to two-thirds of the 600,000 food businesses in Britain. However, the draft regulation also seems to contradict itself in places. The FPB has submitted detailed comments to the FSA and is working with other organisations to ensure a workable compromise is reached, which is clearly understood by all and does not jeopardise food safety. Without some records of the risk analyses, it could be impossible to demonstrate to the authorities that all the necessary steps have been taken.