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Why P1053 is such a disappointment

In November, the government will be voting on the P1053 amendment to the food safety standards. We were hoping it would bring the standards up to the 21st century. Instead it looks like they barely made it out of the fifties.

P1053, a moment of brief celebration

At a recent conference I was absolutely stoked to hear about P1053 and the changes to the food standard. We were finally moving from the dark ages to the 21st century.

The problem with the existing standards is that they simply say that you need to do something. The problems with this approach include:

There is no requirement to measure if the standards have been met
There is no specification on how success or failure can be measured
There is no requirement to later prove that the standards have been met.

It sounded like P1053 finally tackled these issues. P1053 was finally going to make the industry accountable.

Then I read the fine detail of P1053 and it looks like we jumped all the way to the mid-20th century.

Technology has moved on. Let’s get with the times.

“Records must be kept“.

What a vague concept, especially when it comes to temperature.

Does it mean that I can walk around and just write down the current temperature once a day? Twice a day? Once a week?

If it is too hot, can I just come back 10 minutes later? Or fake it?

Does it matter how accurate the thermometer is?

Can I use the reading from the fridge itself or does it have to be an independent sensor?

While P1053 started to address the requirement to measure and prove, it totally dipped out on specifying how success or failure was to be measured.

20 years ago they knew how to store vaccines...

20 years ago the standards for vaccine storage had already clicked onto the ground breaking technology of a min/max thermometer. That’s how you guarantee that a fridge is always within the correct temperature range throughout the day.

This allowed them to do a twice daily check (before opening and at the end of the day) that would allow them to prove the vaccines were at the correct temperature for the entire day.

It was also a totally independent check of the fridge.

And now there is an even better solution

A min/max thermometer, however, will only tell you that there was a problem, and tell you how bad it got. It won’t tell you for how long, or when it started, or finished. That is critical information when you are trying to decide if you need to dispose of stock. It is also critical information in trying to work out the cause of a problem.

That’s where temperature loggers start to make a difference. By giving you a reading every 5 minutes, it is possible to pinpoint when a problem started, when it finished and how bad it got.

Or it gives you totally independent, reliable proof that a fridge or freezer has always been keeping PHF outside the danger zone.

But wait, there's more....

For restaurants and cafes, the perfect solution is something that will notify them the moment their fridge or freezer starts to get too warm. This gives them a chance to fix the problem, move stock, or know that they have a problem.

Systems like Clever Logger do just that. It can send an email and phone notification as soon as a problem starts, and will continue to remind them until it is fixed.

When it comes to any aspect of food safety and HACCP, the fundamental goal is to be able to detect a problem as soon as possible and rectify it. Cloud based temperature logging solutions now make it possible to know the instant a problem starts.

Is it the best solution for all restaurants and cafes?

Unfortunately too many restaurants and cafes are barely holding on. They don’t have any money to spare, and they are more concerned about today and tomorrow, then what their reputation will be in 6 months time. Temperature loggers aren’t a priority.

Pubs, clubs and many franchises are at the other extreme where they are pure businesses, and their reputation is everything. They also know the cost of manually checking the temperature and record keeping. Temperature loggers are of strong interest to them.

To me, the interesting group are the ones in between. These are the small restaurants and cafes that are wanting to offer an exceptional product to their customers and do so with “best practice” and profitability

What P1053 could have said instead

The horse has bolted for the next 5 (LOL, 10!!!) years. Next time around my recommendation would be to specify:

For recording temperature in fridges and freezers:
- An independent min/max thermometer that is checked at the start and end of shift, or
- A temperature logger with a visual indicator that is visually checked twice a day, and downloaded once a week, or
- An external monitoring solution with immediate notification to the user if there is a problem
The intent of this is:
- To minimise the time between a problem and staff being aware of it
- Provide independent proof that there has not been a temperature breach
The thermometer or logger needs an accuracy of 0.5° or better