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Hygiene, HACCP and the information required under Section 43 of the IfSG

Was das Gesundheitsamt bei der Kontrolle sehen will, wie ein brauchbares HACCP-Konzept aussieht und welche Temperaturen gelten.

11 Reading time: minutes

Food inspections may take place unannounced. Keep hygiene records, temperature logs and test certificates to hand. This will enable you to explain the procedures in the food truck and answer any questions about your food.

Legal basis

DE Germany

EU Regulation 852/2004 und LMHV. Erstbelehrung nach § 43 IfSG vor Tätigkeitsbeginn. Der Arbeitgeber belehrt nach Aufnahme der Tätigkeit und danach alle zwei Jahre.

AT Austria

The same EU regulation, dazu das LMSVG. Statt der Belehrung eine Hygieneschulung.

CH Switzerland

LGV and Hygiene Regulations. Inhaltlich nah, aber eigenständig. Selbstkontrollkonzept ist ausdrücklich vorgeschrieben.
Das Hygienekonzept muss zu deinen Lebensmitteln und Arbeitsabläufen passen. Kläre zusätzliche Vorgaben vor dem Einsatz mit der zuständigen Lebensmittelbehörde.

The basis

The key factor is the Regulation (EC) No 852/2004 on the hygiene of foodstuffs. Annex II, Chapter III applies to mobile food outlets. In Germany, these are supplemented by the Food Hygiene Regulation (LMHV) and the Infection Protection Act.

The regulation does not specify a particular type of vehicle. It requires results: that food is protected from contamination, that cleaning can be carried out and that temperatures are maintained.

What must be present in the vehicle

  • Hand basin with hot and cold water, liquid soap and disposable towels – separate from the sink
  • Drinking water in sufficient quantities, tank made from food-grade material
  • Wastewater tank, to be emptied concisely and systematically
  • Smooth, washable surfaces without spaces
  • Refrigeration facilities with thermometer
  • Separate sections for raw and prepared food
  • Rubbish bins with lid, cannot be opened by hand
  • Option to, Workwear store separately

Temperatures

The following table provides guidelines for planning. The permitted temperature depends on the foodstuff, its labelling and the stage of processing. Set out the requirements and measurement intervals in the business’s hygiene policy.

WhatTemperature
Perishable foodstuffs7 °C maximum
Minced meat2 °C at most
Poultry4 °C maximum
Fishon slush, 0 to 2 °C
Frozen goodsmaximum −18 °C
Keep warmat least 65 °C
Cook thoroughlyat least 2 minutes at a core temperature of 72 °C

Measure and record the refrigeration temperatures at least once a day. The records must correspond to your inspection points. More frequent checks may be necessary for perishable goods or in the event of temperature deviations.

HACCP – without all the accounting jargon

HACCP stands for Hazard Analysis and Critical Control Points. Every food business must have such a plan in place. For a food truck, this doesn’t mean fifty pages of paperwork. It means you’ve thought about where things could go wrong and you check these areas regularly.

The seven steps: a practical guide

  1. Identify risks. Where are the risks of germs, foreign bodies and allergens?
  2. Identify key points. Typically: goods receipt, refrigeration, thorough heating, keeping food warm, cleaning.
  3. Set limits. Determine product-specific refrigeration temperatures and suitable combinations of core temperature and heating time.
  4. Monitor. Measure and write down.
  5. Please proofread. What do you do if the reading is incorrect? Dispose of the goods, check the equipment.
  6. Check. Is the system still working?
  7. Documentation. Verifiable, with date and signature.

Realistic scope: For a one-person food truck, five to ten pages are usually sufficient, plus forms for temperature, cleaning and stock receipt. The BGN and many Chambers of Industry and Commerce (IHKs) provide templates free of charge. Choose one of these and adapt it to your business – an unread, generic template sitting in a folder won’t help during an inspection.

Cleaning

A cleaning schedule must be displayed clearly inside the truck. It answers four questions: what, with what, how often, who. Example:

SectionFrequency
Workspacesafter each step
Chopping boards, knivesafter a product change
Deep-fat fryer, barbecuedaily
Inside the fridgeweekly
Extractor hood, filterweekly to monthly
Disinfect the water tankquarterly

Staff

  • Everyone needs the Information pursuant to Section 43 of the IfSG, before she starts.
  • As an employer, you must Refresher training to be undertaken after starting work and every two years thereafter and document this.
  • Anyone suffering from diarrhoea, vomiting or infected wounds must not handle food – this is a prohibition on working, not a recommendation.
  • Clean work clothes, headwear; no watches or rings on the hands.

What happens during the review

The inspector may arrive unannounced and enter the premises. They usually check the following:

  1. Cleanliness of surfaces, equipment and vehicles
  2. Refrigeration temperatures, measured using our own equipment
  3. Best-before dates and storage of goods
  4. Hand washbasin with soap and towels
  5. Documentation: HACCP, temperature logs, cleaning schedule, instructions
  6. Allergen labelling

At the end, there is a report. Any complaints are given deadlines. Read the report before signing it and clarify any points you do not understand. Make a note of the deadlines and document how you are rectifying the issues raised.

Inspection results are published in several federal states. Complaints can become public via transparency portals and consumer information requests. For a business that relies on its reputation, this is a good reason to take hygiene seriously – quite apart from the fines.

Quellen zu den überarbeiteten Angaben

The right toolsWhat licences do you need?Get a country-specific checklist tailored to your location, land use, alcohol licence and gas system.→

This does not constitute legal advice. This article reflects the current situation to the best of our knowledge and is not a substitute for advice from a public authority, solicitor or tax adviser. Many matters are regulated at local authority level and vary from town to town – if in doubt, check with the relevant authority before making any firm decisions.

Regarding country-specific information. The comparisons for Germany, Austria and Switzerland provide a general framework, not details of individual cases. Amounts and thresholds are subject to change; in Switzerland, moreover, each canton regulates many matters independently. Use the information as a starting point for asking the right question in the right place.

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