Select Committee on Food Standards First Report


Submitted by the Textile Services Association

  The Textile Services Association represents the interests of the commercial laundry, retail drycleaning and textile rental industries in the United Kingdom. Membership of the Association includes all of the major companies involved in the supply of rented/managed workwear to the food industry, (Sunlight Service Group, Johnson Service Group, Rentokil—Initial, Sketchley Textile Services, Brooks Service Group, OCS—Smarts Group, Fishers Services) together with the majority of smaller to medium sized companies operating in the sector. The Association is formally recognised by the Department of Trade and Industry and actively promotes best practice within the sector through participation in, inter alia, appropriate working groups of CEN and ISO and on-going work with the Health and Safety Executive to review the industry's health, safety and environmental guidelines. CEN, supported by the Association, is currently working on a European standard for the hygienic quality of laundry processed textiles in sectors where it is necessary to control biocontamination (CEN/TC248/WG17). The Association is thus well placed to contribute to the proposal to form an Independent Food Standards Agency.

  The Association welcomes Government's initiative to establish the FSA as an important first step, but feels that the aim of consumer protection will not fully be met without more stringent regulation of the provision and laundering of workwear used in food processing and retailing areas.



  Government recognition of the need to manage food safety better has increased, on a worldwide basis, over the last 10 years. In Europe, one of the most powerful driving forces is the European Community Directive 93/43 EC (1993) on the Hygiene of Foodstuffs. Article 3 of the Directive states that food business operators shall identify any step in their activities critical to ensuring food safety and ensure that adequate safety procedures are identified, implemented, maintained and reviewed. Indeed, the Directive lists the first five principles of a safety management system known as HACCP (Hazard Analysis Critical Control Points). In essence the Directive is a very strong recommendation that food businesses throughout Europe should use the HACCP approach as a means of demonstrating compliance with its essential requirements.


  The HACCP system was developed by the Pillsbury Company in the USA, in collaboration with NASA, to provide safe and hygienic food for astronauts on the space programme. In some senses HACCP is a subset of ISO 9000 systems. Whereas the latter deals with the "quality" aspects of a product or service, HACCP is concerned with the safety of the product. The proper implementation of a HACCP system will require a very detailed, multi-disciplinary approach and will often employ sophisticated statistical techniques. However, at its core, it analyses the production flowline to identify points where contamination risks occur and it sets down procedures for identifying and controlling the risks.


  HACCP cannot successfully be applied if its scope is restricted to the immediate food handling, processing or manufacturing plant. It must start with the suppliers of raw materials, goods and services. The hazard of any inward goods must be identified and two questions answered. First, will the hazard be processed out at some stage? Second, is there a contamination risk to the food product, which will not be controlled? If the answers are "No" and "Yes" respectively, then the point of entry of such goods to the processing plant constitutes a Critical Control Point or CCP and a high level of control is required.

  Raw foodstuffs obviously require special consideration, but other articles, peripheral, but essential to the food processing must be controlled. One of these is the protective workwear worn by the food handling staff.


  Food handlers and other personnel with access to food processing areas could contaminate the product by introducing microbiological, chemical or physical (foreign body) hazards. Whilst plant layout and movement controls can reduce the risk, it is essential to provide the work force with appropriate protective clothing. The wearers must appreciate that the purpose of the workwear is primarily to protect the foodstuffs, although of course it will serve to keep them clean as well.

  Selection and laundering of workwear is as amenable to a HACCP systems approach as the actual food processing itself. Clearly though, the discipline to apply HACCP in order to satisfy the conditions of control at the delivery CCP can only take place in a properly managed environment.

  Most textile rental operations are ISO 9002 registered and of those providing workwear to food companies, many are already operating HACCP systems and are well used to receiving audit visits from their customers or their agents. They offer an expert, totally managed textile package, within the ISO 9002 and HACCP systems, which starts with advice on the selection of garments for staff with different duties, frequency of garment changes and includes the design of laundry processes matched to soiling types and levels.

  Above all the textile renter offers assurance through traceability. All processing equipment is properly maintained, checked for actual performance against its programming and regularly calibrated. At intervals processes are revalidated for effectiveness and monitoring records of key parameters are kept between validations to ensure processes remain within control limits. If non-compliance arises, loads are isolated for reprocessing and prescribed corrective action is taken.

  The result, for the customer, is a stain and foreign body free, hygienically clean garment which is functional, fits well and is finished to a high standard every time. It will be designed to satisfy the Food Company HACCP team, the company Marketing Director responsible for image and the staff member. This is particularly important because wearer comfort and self-esteem are vital components in a safe and successful operation.

  Food Companies are required, in the UK's 1990 Food Safety Act, to demonstrate "due diligence" in their management and operations. The decision to contract a properly managed textile renter to supply protective workwear allows a food company to demonstrate compliance in this important area.

  It is most unlikely that a laundry operated by a food company could assure all aspects of this level of service. Clearly home laundering by company staff by definition lies outside the managed environment and is completely unsatisfactory.


  R A Sprenger, Hygiene Management, Highfield publications 1983.

  S Mortimore and C Wallace HACCP a practical approach Chapman & Hall 1994.

  Laundering Workwear for the High Care sector of the Food Industry Fabric Care Research Association 1997.

  J I Rigarlsford Private Communications 1998, 1999.

  CIN IC248 WG17 Working draft: Laundry processed textiles—biocontamination control.

  ISOIC209 WG2 ISO/CD 14698 part I: Cleanroom technology—biocontamination control—general principles.


  FSA should, by regulation, improve the protection offered to consumers by:

    (1)  requiring all appropriate companies operating in food processing, handling and retailing to supply clean workwear to all appropriate staff;

    (2)  requiring such workwear to be supplied by a company operating a quality system such as ISO 9002 and HACCP systems;

    (3)  mandating that such workwear is changed on a daily basis; and

    (4)  prohibiting the home laundering of workwear with its inherent risk of cross-contamination.

Compliance Cost

  Although there will clearly be a compliance cost for businesses not currently meeting best practice, the benefits and reassurance to the end user are clear and unambiguous.

  TSA would be prepared to supply further information—or give oral evidence to the committee—if required.

March 1999

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Prepared 12 April 1999