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This article features otherwise unpublished food safety management data held by BRCGS and Safefood 360° which, combined with real-time events, provides an unparalleled view of current and emerging issues and trends in the food safety industry.

The months of November and December herald the onset of celebrations including Thanksgiving, Diwali and Christmas. Common themes to most of these events include the preparation and consumption of large quantities of food and drink, the adornment of homes and, often, oneself with outlandish decorations and the general engagement in festive activities. The vast majority of this will occur in a single month, week or day and not be repeated until the following year. This fact means that many of the foods prepared and consumed, the decorations used and activities undertaken introduce new or unfamiliar hazards that can result in increased risk.

Here we explore those areas of increased risk with some thoughts on measures we can all take to manage them in our businesses and supply chains. This article will focus on two broad areas; consumption risks from things that we eat (and perhaps things we should not eat) and usage risks from handling and using general merchandise products.

 

The background

Celebrations are fun times, but surveys have shown that accidents and incidents increase during these periods. The US National Fire Prevention Association (NFPA) estimated that home fires increased three-fold on Thanksgiving. Nearly twice the daily average house fires happen on Christmas Day and Christmas Eve, with unattended cooking the leading contributing factor.

A survey published by the National Accident Helpline estimated that nearly half the 2,000 people surveyed had suffered an accident while preparing food for Christmas. Top factors included spilling hot fat on themselves (11%), cutting themselves when preparing vegetables (18%) and suffering an electric shock from badly wired Christmas lights (2.7%).

 

Celebration food safety

Let’s start with the Christmas turkey as this highlights one of the key food safety challenges to consumers, caterers, hospitality and even those in manufacturing and retail.

Everyone generally understands that a turkey brings with it the hazards of enteric bacterial pathogens such as Salmonella spp. and Campylobacter spp. and that effective cooking and cross contamination control are the keys to safety in this regard. However, many consumers and some food business operations do not store, handle or cook turkeys regularly and therefore equipment, utensils, processes and procedures are not established to accommodate the challenge brought about by the size and scale of operation needed to do this safely. Clearly, these risks apply equally to many foods but let’s use turkey as the key food for our celebration food safety considerations.

Cooking - Cooking a turkey in a food business operation is best achieved using validated cooking methods. Thermal process studies determine the temperature and time required in the oven to achieve a safe cooking process using the worst-case data i.e. largest/heaviest bird, cold spot in the oven, lowest ingoing temperature, etc. This is generally only undertaken in establishments designed for large scale cooked meat production and other food businesses such as catering and hospitality rely on calculated times at defined temperatures for the size of the bird. In these cases, temperature probes verify that safe cooking temperatures have been achieved. This, of course, is also the approach advocated for consumers and a variety of sources of guidance on cooking turkeys is available (United States Department of Health and Human Services, (USDHHS), United Kingdom Food Standards Agency (FSA), United States Department of Agriculture (USDA).

The importance of accurate cooking guidelines on pack should not be underestimated. Many consumers will be unfamiliar with cooking turkeys or similar products for festive events so on-pack guidance on safe cooking is critical. It is common practice for cooking guidelines to be validated by food businesses to ensure they deliver the minimum safe cook if followed correctly and a comprehensive guide for this is provided by Campden BRI. In the UK, a safe cook for poultry and meat is for the middle to reach 70°C for 2 minutes or equivalent and, when cooking a turkey this is usually far exceeded.

Defrosting - Undercooking a turkey often occurs when a frozen bird is not properly defrosted. Defrosting is as important to achieving a safe cook as the cooking validation or subsequent cooking guideline. In commercial operations this should be conducted under controlled conditions (i.e. under refrigeration) which can take several days and checks should be implemented to ensure the defrost is effective i.e. temperature probing. Approaches for defrosting turkeys for non-commercial operations and consumers are available in guidance provided by food safety authorities. This includes the use of water defrosting or more conventional chilled defrosting, but guidelines should also be included on product packaging.

Cross contamination – The contamination of cooked or ready to eat foods with microbial pathogens can occur from a variety of sources. Direct transfer can come from food handlers, pests and raw foods, or they come indirectly via equipment, utensils and work surfaces that come into contact with the ready to eat foods. This is all termed cross contamination and is one of the most common reasons for foodborne disease. So-called high-care or high-risk foods such as washed salads or cooked, sliced meat need extensive controls in place to prevent cross contamination. In commercial operations this is achieved through separating the raw food from the ready to eat food by a physical barrier, usually the oven or other decontamination process. Separation also extends to the flow of water (from high-care to low risk), the use of dedicated equipment, utensils, people and, where relevant, the use of positive pressure using filtered air.

Guidance on best practice for the hygienic production in such facilities is available from the Chilled Food Association. These high levels of control are designed to prevent contamination with organisms including enteric pathogens but are mainly designed to prevent exposure to Listeria monocytogenes which can grow in many chilled, extended shelf life, minimally preserved, ready to eat foods.

Control of enteric pathogen cross contamination can be achieved through the application of general good manufacturing practices in most food operations such as those detailed in the Codex General Principles of Food Hygiene and there are specific guides for food businesses (FSA). Practices in the home also present cross contamination risks with a recent survey by the USDA highlighting that 32% of participants in a home study did not thoroughly wash the plate/cutting board after use. An FSA study on practices in the kitchen identified that 26% of meals involving meat, fish and poultry were being prepared by someone who did not wash their hands. There are many good practice guides for consumers advising on measures to prevent cross contamination (FSA, USDA, Food Safety Information Council).

Cooling (and leftovers) – One of the challenges presented by foods consumed during festive periods is keeping them cool to prevent the proliferation of any residual or contaminating pathogenic micro-organisms. Residual micro-organisms can include spore forming pathogens such as Clostridium perfringens and Bacillus spp. that can survive the cooking process. Pathogens like L. monocytogenes can be introduced after cooking and during exposure or handling in the food supply chain or by the consumer. The bigger the item of food cooked the more challenging it is to cool it and then to keep it cool. This is particularly the case for a large turkey cooked in the home where it may be left for long periods in a warm kitchen after serving.

In the commercial cooking of bulk meats, the use of advanced cooling methods such as blast chilling can reduce temperatures to <5°C within 4-6 hours but the key risk exists if the product remains at temperatures that are optimum for bacterial growth i.e. 52-20°C for extended periods. It is generally recommended to keep foods outside of the temperature range 8-63°C, often referred to as the ‘danger zone’. Recommendations on cooling times and temperature for commercially produced meats is available via bodies such as the NSW Food Authority. The general advice for consumers on the safe use of leftovers is to put foods in a refrigerator within 2 hours of removing from the oven (or refrigerator) (FSA, USDHHS, FDA).

Allergens – During celebration periods there are more occasions to eat out of home or consume foods not normally eaten during the year. This brings potential risks for consumers with severe allergies. The importance of allergen labelling on menus and on packaging, albeit often mandated in country laws, is critical for consumer safety. Food manufacturing businesses are often under significant production pressures as volume demands can be high leading up to or during festive periods. The high production volume, often with a large number of associated production/packaging changeovers can significantly increase the risk of mispacking or cross contamination leading to allergen mis-declarations. This risk should be recognised in the food safety management plan and production during these periods be managed accordingly.

Festive things not to eat

OK, so we have covered some of the key food safety considerations during festive periods, but there are items that emerge during these celebrations that end up in people’s mouths or stomachs that really should not be there. This includes a variety of toxic plants such as holly, mistletoe, ivy and the Christmas rose; a full list of potentially toxic plants is published by the Royal Horticultural Society (RHS). It is also worth noting that many plants are toxic to pets including cats and dogs and particular care should be exercised when introducing new plants or flowers into the home over these periods. A systematic review was published in 2023 highlighting the range of items causing adverse health effects at Christmas and included swallowing a plastic robin decoration and button batteries.

Festive non-food safety

Despite much focus being on food safety, a large number of accidents and injuries occur due to the use of non-food items over these periods. These can include injuries from putting decorations on display through to the use of unsafe general merchandise products. A recent article in Which? magazine quoted surveys reporting that 1 in 50 people had fallen out of the loft when retrieving tinsel, baubles and other decorations and that the NHS had reported that 2.6 million people had fallen from stools or step ladders when hanging their festive lights.

The wide range of consumer products and household items make it impossible to list all of the risks and controls. The products meriting particular note by the Royal Society for the Prevention of Accidents (RoSPA) in their Christmas Safety Tips include gifts especially for children. RoSPA recommends ensuring toys are suitable for the age and meet safety standards, avoiding button batteries due to the potential choking hazard and to keep cards and decorations away from potential fire risks. They also highlight the dangers from novelty items and decorations that may look like toys but are not and therefore do not need to comply with the toy regulations. Many of the products considered high risk during festive events are subject to specific legislation or testing to safety standards with UK examples including toys (UKSI 2011 No 1881), candles (BS EN 15494/BS EN 15493/BSEN 15426), decorative light chains (Electrical Equipment (Safety) Regulations 2016 and BSEN 60598 – Luminaires), fireworks (UKSI 2004 No 1836) and party costumes (UKSI 2011 No 1881, EN 71 – Safety of toys Part 2 – Flammability, BRC Code of Practice). In addition, they will all be subject to the requirement in the General Product Safety Regulations (UKSI 2005 No. 1803).

The importance of safety management systems

For businesses providing food or non-food items to the public, fundamental safety is achieved through a systematic approach to the identification of hazards, determination and implementation of control measures and an ongoing review of the efficacy and validity of the safety management system. The management system will include documentation of processes and procedures and associated process control checks and records. The use of third-party software solutions such as Safefood 360° to support hazard analysis, manage documentation and support monitoring and recording can be extremely valuable for the effective delivery of the safety management programme.

A large number of the safety management programmes in businesses globally are underpinned by third-party schemes that also provide a means to assess the robustness of a businesses’ operation of their management system through third party audit and certification. This also serves to provide confidence to the associated supply chain. Schemes such as the BRCGS Global Standard Food Safety encompasses requirements for all of the considerations raised in this article in relation to the safe production of food. Similarly, the BRCGS Global Standard Consumer Products – General Merchandise and Global Standard Consumer Products – Personal Care and Household encompass the requirements for the safe manufacture of the associated non-food products.

Summary

I hope those reading this article don’t accuse me of being ‘the Grinch’ or that my remarks are ‘Bah humbug!’ but that they have given you a reminder that whilst celebrations are a wonderful time for all to enjoy, they bring additional risks that need proper and effective management. Have a safe and fun event whatever that happens to be for you and your loved ones (and pets).

 

Author   Alec Kyriakides BRCGS International Advisory Board Chair Independent Food Safety Consultant