Food Safety and HACCP Training in Dublin: FSAI Requirements

Food safety and HACCP training in Ireland is not a single legal course. The framework is set by Regulation (EC) No 852/2004 on the hygiene of foodstuffs, and the Food Safety Authority of Ireland (FSAI) explains how it expects food businesses to meet it. If you run a restaurant, cafe, caterer, retailer or food producer in Dublin, the key duty is to make sure food handlers are supervised, instructed and trained to the level their work requires, and that whoever looks after your HACCP-based procedures has had adequate training. Our HACCP and food safety training guide gives a wider introduction; this article sticks to what the FSAI pages say.

The rules are national and European rather than specific to Dublin. We drew on four FSAI pages we could open: its page on the hygiene of foodstuffs, Guidance Note 12 on the inspection of food safety training and competence (2007), a Level 3 training guide for management (2016) and a Level 1 training guide page dated 12 February 2016. We did not open the Regulation on an EUR-Lex page, so the wording of the Regulation below is as quoted by the FSAI.

What Regulation 852/2004 requires on training

According to the FSAI's page on the hygiene of foodstuffs, operators must ensure that "food handlers are supervised and instructed and/or trained in food hygiene matters". Guidance Note 12 identifies the source as Chapter XII of Annex II to the Regulation and quotes the requirement as being "commensurate with their work activity". It adds that the proprietor or registered owner has a legal obligation to ensure that all food handlers are supervised.

Two features of that wording are worth noticing. First, it is a mix of supervision, instruction and training, so a business may meet the duty through a combination rather than a single course. Second, the standard is tied to the work activity: for example, in our view a person plating cold desserts and a person handling raw meat do not necessarily need the same content.

HACCP: who needs training and what the procedures are

The FSAI page says operators outside primary production must have "a permanent procedure or procedures based on the HACCP principles". It lists seven elements: hazard identification, critical control points, critical limits, monitoring, corrective actions, verification and records. Procedures must be reviewed when products or processes change.

The FSAI also notes that low-risk businesses may rely on prerequisite hygiene requirements, and that guides to good practice are permitted. Its Level 3 guide describes three routes, chosen with the agreement of an enforcement officer: prerequisite hygiene controls, a recognised guide to good practice, or the seven HACCP principles. It also says a prerequisite programme covering general hygiene rules must be in place before HACCP-based procedures are implemented.

On training, the FSAI's pages say that staff who develop or maintain HACCP-based procedures, or who implement a recognised guide to good practice, must have adequate training in applying the HACCP principles. The Level 3 guide puts it as those responsible "must have received adequate training in the application of the HACCP principles".

The FSAI competence levels

Guidance Note 12 (Revision 1, published in 2007) sets out a staged view of competence, and the Level 1 guide page confirms the approach: the knowledge and skills needed depend on a worker's level of responsibility, whether they work in a high-risk or low-risk area, and how long they have been in the business.

• Level 1, Induction Skills: skills expected on starting work (Stage I) and within the first month (Stage II).
• Level 2, Additional Skills: expected within three to six months in a high-risk area, or six to twelve months in a low-risk area.
• Level 3, Food Safety Skills for Management: for managers and supervisors, who must also have the authority to make food safety decisions.

The Level 1 guide page says the standard applies to all workers in food service, retail and manufacturing businesses, including food handlers and non-food handlers, whether full-time, part-time, seasonal, occasional or voluntary. The Level 3 guide describes 43 skills for people who supervise staff or influence their food safety behaviour, such as proprietors, managers, supervisors and charge hands.

Are certificates required?

This is the question most employers ask, and Guidance Note 12 sets out the FSAI's position. It does not make any particular certificate or course mandatory. It says training records and certificates show a planned approach to training but do not prove that staff apply what they learned, and that in-house training "may adequately meet food safety training requirements even when programmes are not certified". It also says authorised officers should not state or imply that attending any particular course is mandatory.

That does not make records pointless. The same note says the proprietor or registered owner must assess staff competence on an ongoing basis, based on the risks in the operation, and that authorised officers verify this during inspections. Being able to show what you did is the practical way to demonstrate it. Guidance Note 12 dates from 2007, so check the FSAI site for any later guidance before relying on it.

Where responsibility lies

The Level 3 guide states that, legally, the primary responsibility for food safety lies with the food business operator. Guidance Note 12 says the proprietor must be responsible for continuously encouraging and improving the competence of staff with regard to food safety. In our reading, that means delegating training to a manager or buying a course does not move the legal responsibility.

A practical approach for Dublin food businesses

These are our suggestions, not legal requirements:

• Map each role against the FSAI Level 1, 2 and 3 skills and note the gaps.
• Name who maintains the HACCP-based procedures and record what training they have had in applying the principles.
• Build food hygiene instruction into the first day and the first month, matching the FSAI's induction stages.
• Keep a simple training and competence record for each person, including in-house sessions and supervision checks.
• Review the procedures and retrain when a menu, supplier or process changes.

Record-keeping also fits with wider employment paperwork; our employer guide to mandatory training and the written statement may be useful alongside it.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is a food safety certificate legally required in Ireland?

According to FSAI Guidance Note 12, in-house training "may adequately meet food safety training requirements even when programmes are not certified", and authorised officers should not state or imply that attendance at any particular course is mandatory. The legal requirement is that food handlers are supervised, instructed and/or trained commensurate with their work.

Who needs HACCP training?

The FSAI's pages say those who develop or maintain procedures based on HACCP principles, or who implement a recognised good practice guide, must have adequate training in applying the HACCP principles.

Do small or low-risk businesses need full HACCP?

The FSAI page says low-risk businesses may rely on prerequisite hygiene requirements and that guides to good practice are permitted. The Level 3 guide says the route chosen is agreed with an enforcement officer.

Does the requirement cover part-time and temporary staff?

The Level 1 guide page says the standard covers full-time, part-time, seasonal, occasional and voluntary workers in food service, retail and manufacturing businesses.

How often should food safety training be repeated?

The FSAI pages we read do not set a refresher interval. Guidance Note 12 refers to ongoing assessment of competence based on the risks in your operation.

Because enforcement officers assess competence in practice, keep your records, procedures and supervision aligned and check the FSAI site for current guidance.