HACCP for Farm Shops: A Complete EU Compliance Guide

Introduction

Many farm shops struggle with compliance, especially when it comes to raw milk sales. A common failure is selling raw milk above 5°C, which not only violates regulations but also puts customers at risk of E. coli O157 contamination.

What you'll learn

• Specific temperature controls and legal requirements for raw milk and other perishables.
• How to maintain effective separation between farm environments and food retail areas.
• Key supplier checks and staff training requirements for compliance.

What Auditors Check First

• Temperature records for raw milk and other chilled items.
• Separation practices between animal areas and food retail, including boot wash stations.
• Compliance with allergen labeling, especially for homemade products.

Hazards Specific to Farm Shops

Biological Hazards: Key pathogens include E. coli O157, Listeria monocytogenes, Campylobacter, Cryptosporidium, and Salmonella.

On a busy Saturday when customers are allowed to pet lambs before entering the shop, there's a risk of E. coli O157 or Cryptosporidium contamination. This can happen if visitors do not wash their hands properly after animal contact.

Control Measure: Display extra handwash signage and ensure handwashing stations are stocked with soap and disposable towels. Remind staff to monitor and enforce hand hygiene compliance.

Chemical Hazards: Chemical risks mainly arise from improper handling of allergens and homemade products without proper validation.

For instance, if a staff member prepares homemade chutney without checking the pH level, there's a risk of botulism due to low-acid conditions. The chutney could be sold without proper labelling or allergen information.

Control Measure: Validate the pH of homemade preserves to ensure it is below 4.6. Maintain written records of pH/Aw levels for each batch made.

Physical Hazards: These include contamination from foreign objects and cross-contamination from farm environments.

On a busy Saturday when customers are handling both raw and ready-to-eat products, there's a risk of cross-contamination. If a staff member uses the same utensils for raw poultry and pre-packaged salads, pathogens can transfer.

Control Measure: Implement strict utensil separation protocols for raw and ready-to-eat foods. Regularly train staff on using color-coded equipment and ensure regular monitoring.

Seasonal Considerations

During spring lambing, the risk of E. coli O157 and Cryptosporidium peaks. Extra handwash signage should be displayed for visitors who pet animals before entering the shop.

In summer, the influx of local produce leads to rapid stock turnover. Enforce strict use-by dates on all farm-made items to prevent spoilage.

During the Christmas season, with pre-assembled hampers containing mixed ambient and chilled items, ensure clear storage instructions are provided to prevent temperature abuse.

Critical Control Points

• Raw Milk Sales
  • Measure:
    • Keep raw milk below 5°C at all times.
  • Monitor:
    • Use a calibrated fridge thermometer, check every 2 hours.
  • Corrective Action:
    • If temperature exceeds 5°C, discard milk that has been above this limit for more than 1 hour and document the incident.
• Farm-to-Counter Traceability
  • Measure:
    • Every product must trace back to farm/field/animal.
  • Monitor:
    • Conduct weekly reviews of traceability records and ensure all products are logged correctly.
  • Corrective Action:
    • If a product lacks traceability, remove it from sale immediately and investigate the source.
• Separation of Farm Environment from Retail
  • Measure:
    • Ensure a proper boot wash/change station is in place and used.
  • Monitor:
    • Check daily that the station is stocked with disinfectant and functioning properly.
  • Corrective Action:
    • If not in use, enforce immediate staff training on proper hygiene practices and restrict access to the retail area until compliance is achieved.
• Temperature Control for Mixed Retail
  • Measure:
    • Chilled items must be kept at ≤ 5°C, ambient items at ≤ 20°C, and frozen items at ≤ -18°C.
  • Monitor:
    • Use separate thermometers for each zone, check temperatures every 4 hours.
  • Corrective Action:
    • If any item exceeds the temperature limit, segregate it immediately and assess for spoilage before deciding on disposal.
• Homemade Preserves
  • Measure:
    • Validate pH and Aw (water activity) levels for safety.
  • Monitor:
    • Test every batch; maintain records of pH (≤ 4.6) and Aw (≤ 0.85).
  • Corrective Action:
    • If levels are unsafe, discard the batch and review production methods to ensure future compliance.

Common Mistakes

• Mistake:
  • Raw milk sold above 5°C → Fix: Implement strict temperature monitoring and staff training on compliance.
• Mistake:
  • No separation between farm yard and food retail area → Fix: Install and enforce use of boot wash/change stations.
• Mistake:
  • Homemade preserves without validated pH/Aw records → Fix: Conduct regular testing and maintain records for all batches produced.

Supplier management is critical for maintaining food safety and quality in farm shops. You are responsible for every product you sell, whether made on-site or sourced from local producers. Implementing strict receiving checks can prevent contamination and ensure that your customers receive safe, high-quality products.

Delivery Acceptance Checklist

• Verify each supplier's food business registration and allergen specifications.
• Check raw milk for current quarterly TB test results and somatic cell count records.
• Confirm brucellosis-free status before accepting raw dairy products.
• Ensure game from local shoots is tagged with the kill date and that the dealer license is verified.
• Inspect homemade preserves for validated pH/Aw records to mitigate botulism risk.

When to Reject a Delivery

• Raw milk above 5°C or without required warning signage.
• Game that lacks proper tagging or documentation.
• Homemade preserves without validated pH/Aw records.
• Products from suppliers without valid food business registration.

Daily Monitoring Checklist

• Check raw milk temperature:
  • <5°C.
• Verify raw milk warning signage is visible.
• Inspect that boot wash/change station is operational.
• Monitor all chilled storage areas for temperatures:
  • <5°C.
• Ensure separation between farm animal areas and food retail is maintained.
• Confirm that homemade preserves have validated pH/Aw records.
• Check eggs are stored at <5°C if labelled 'keep refrigerated'.
• Review stock for use-by dates, especially on farm-made items.

What Records Auditors Expect

• Batch records for all on-farm products, including date, ingredients, and temperature logs.
• Quarterly TB test results for raw milk, along with cow somatic cell count records.
• Allergen specifications from local producers for any items sold.
• Game tagging records, including kill date and dealer license verification.
• Documentation of staff training sessions, including dates and topics covered.

Staff Training Requirements

• All staff must understand the 14 allergens and provide written allergen information for homemade products.
• Staff transitioning from animal areas to food handling must change outer clothing and wash hands thoroughly.
• Raw milk staff must be trained on legal requirements, including signage, temperature control, and TB records.
• Seasonal workers must complete a food hygiene induction before handling any food for sale.

Conclusion

Farm shops must adhere to specific regulatory requirements to ensure food safety. Comply with EC 852/2004 Annex II (general hygiene), EC 853/2004 Annex III (products of animal origin), and the Raw Drinking Milk (England) Regulations 2006 (sale restrictions, labelling, TB testing). Additionally, understand allergen management as outlined in Regulation 1169/2011 Annex II, which applies to all food sold.

Quick-Start Action Plan

1. Review and update your food safety management system to align with EC 852/2004 Annex II requirements.
2. Check all raw milk products for correct signage and ensure they are stored at <5°C.
3. Conduct a thorough inspection of your retail area to ensure separation from animal contact zones.
4. Verify that all homemade preserves have validated pH/Aw records to mitigate botulism risk.
5. Train staff on allergen awareness and the proper procedures for handling raw milk products.

Generate your free Farm Shops HACCP plan at ilovehaccp.com/builder - it takes under 10 minutes and covers all the points in this guide.

For practical implementation, review digital-vs-paper-records and haccp-for-pizza-takeaways-eu before finalizing your HACCP records.