Food banks / distribution centres - Q and A
1. Why do charities such as food banks/food redistribution centres have to register as a food business?
Under the food hygiene legislation, food businesses are required to register the business with the local environmental health office as this serves to notify the inspectors of the food activities being carried out in each premises.
2. What does this registration process involve?
To register a food business, contact the local environmental health officer (EHO) (full list is available here) who will send out a registration form. Once completed, return the form to the office. An EHO will schedule an inspection based on the types of activities carried out. Enforcement of food legislation is carried out by EHOs for the Food Safety Authority of Ireland (FSAI).
3. If we simply redistribute food without handling it at all, are we required to register as a food business?
Yes, food distribution businesses are required to register with their local environmental health office. The storage and distribution steps will be subject to inspection.
4. Does a food bank/food redistribution centre have to comply with food/hygiene legislation?
Yes, it is essential that any food business (including charities) comply with the food hygiene legislation to ensure that the food it supplies/serves is safe. The food hygiene legislation is Regulation (EC) No 852/2004
5. What is traceability?
It is a system in which all food business must record what ingredients/food products it receives and from whom. It must also record what product it dispatches to which customers with the only exception being direct supply to final consumers, i.e. the people that you serve. This is called the ‘one-step forward, one-step back’ system. All food businesses must have a traceability system in place.
6. What traceability is required if a food bank/food redistribution centre receives food from a food business to re-distribute it again?
Traceability within a food bank charity re-distributing food requires a ‘one-step forward and one-step back’ system where the charity must record who supplied them with each batch of food and in addition, they must be able to trace to whom they supplied donated food, i.e another charity. This is to trace and track the food should there be a safety issue with the donated food.
‘One-step back’ - The food bank/food redistribution centre should receive and record the following traceability information from the food business who is donating the food:
- Name and address of the supplier
- Accurate description of the product
- Date of delivery
In addition to the general rules for traceability above, more specific information is required for food of animal origin, e.g. meat, fish, eggs. Food of animal origin include unprocessed, e.g. raw meat and processed food products, e.g. salami, but it excludes food containing both products of plant origin and processed foods of animal origin, e.g. pepperoni pizza or ham and spinach quiche.
The additional information required for these products is:
- Volume or quantity of food
- A reference identifying the lot or batch
To make it easier to record the ‘one-step back’ traceability information, it is recommended to talk to the donating business to see if it could generate a receipt or if there was some way of using its ‘one-step forward’ traceability information. While the donating business is not obliged to provide traceability information, it may assist if asked.
‘One-step forward’ - If a food bank/food redistribution centre is distributing food to another food business, ‘one-step forward’ traceability is required to record to whom the food was donated.
7. What types of food can be received by a food bank/food redistribution centre?
Any unsold or surplus food may be donated once it is in an acceptable condition and is within the ‘use-by’ date where appropriate. Examples include:
- Dried, canned foods in acceptable condition
- Whole fresh fruit and vegetables
- Food which remains in packaging (but that was bought by a food business in excess)
- Refrigerated food which has been maintained at 0-5°C ( and within ‘use-by’ date)
- Frozen food which has been maintained at <-18°C
8. Are staff or volunteers working in a food bank/food redistribution centre required to have completed food hygiene training?
Staff and volunteers handling and serving food within a charity are required to be trained and/or supervised appropriate to the level of activity they are involved in. There are a number of training options available which include developing an in-house training programme for staff based on the FSAI’s Safe Food to Go and/or the FSAI’s Guides to Food Safety Training.
The training guides detail the food safety skills food handlers and non-food handlers should demonstrate in the workplace.
Other training options are as follows:
- Attend the FSAI’s ‘Food Safety and You’ course which provides staff with the skills to carry out training of their own staff
- Avail of an independent trainer provider
- Avail of e-learning programmes
9. Are food bank/food redistribution centres required to maintain a HACCP system?
Yes, all food businesses, including food banks/food redistribution centres, are required to put in place and maintain a food safety management system based on the principles of HACCP (Hazard Analysis and Critical Control Point). There is a requirement to ensure that all steps are put in place to prevent a hazard causing a risk to the safety of the food. Hazards include:
- Microbiological, e.g. bacteria, viruses
- Chemical, e.g. cleaning solutions, pest control agents
- Physical, e.g. glass, jewellery, screws
- Allergens, e.g. any one of the allergens listed in Appendix 1
The complexity of the food safety management system will depend on the nature and size of the business. Additional guidance is available from the FSAI and in the National Standards Authority of Ireland’s I.S 341 document Hygiene in Food Retailing and Wholesaling.
10. Can food received by a food bank/food redistrubtion centre be frozen on the ‘use-by’ date?
Yes, however only provided that:
- The food is suitable for freezing, e.g. as indicated by manufacturer’s instructions
- The food is in an acceptable condition
- The food is frozen before midnight on the ‘use-by’ date
- This new step is included in the food safety management system and
- The instructions for use are provided which make it clear that the product should be thawed under refrigeration and cooked immediately
While the food may not be fully frozen before midnight, it must be at least colder than -2ºC. The labelling requirements, e.g. regarding shelf-life, instructions for use, etc. will change now that the product has been frozen (See Q11).
11. If the food can be frozen, what labelling information must be declared?
As the food has changed from a fresh to a frozen product , the original labelling will need to be amended and the product label must now also contain the following information:
- Best before date (as opposed to original ‘use-by’ date)
- Date of freezing for meat and fish
- New storage instructions*
- Cooking or defrosting instructions as appropriate
- Name and address of the food business operator responsible for freezing the food, i.e. donor
Where the prepacked food is to be supplied for use in another food business, i.e. the charity, e.g. used as an ingredient, then all the information can be provided either on the outer packaging or in commercial documents with minimum information required on the outer packaging. The minimum information is as follows:
- Name of the product
- ‘Best-before’ date (as opposed to original ‘use-by’date)
- New storage instructions *
- Name and address of the food business operator responsible for freezing the food, i.e. donor
Where the prepacked food could be passed on to the final consumer (via the charity), the above additional information must be on each package along with the remaining mandatory labelling information as per Appendix 2.
Information which is no longer consistent with the new information must be over- stickered/over-labelled or removed e.g. ‘use-by’ date.
* New storage instructions:
As a rule of thumb, it is recommended that the food be used within one month of freezing. The quality of frozen food will deteriorate over time. If the donating business has evidence to support a longer shelf-life, this can be applied. Instructions for use must be provided where appropriate, e.g. defrost before cooking.
12. What is the difference between a ‘use-by’ date and a ‘best before’ date?
Foods, which from a microbiological point of view, are highly perishable and are therefore, likely after a short period, to constitute a danger to human health, will be labelled with a ‘use-by’ date. The ‘use-by’ is the date up until which a food may be used safely, i.e. consumed, cooked or processed, once it has been stored correctly.
A ‘best-before’ date is the date until which a foodstuff retains its specific properties, e.g. taste, aroma, appearance, any specific qualities which relate to the product, vitamin content etc. when the product has been stored appropriately and the package unopened.
13. Can food which is beyond its ‘best-before’ date be offered for donation?
Food may be donated when it is past its ‘best-before’ date once it is safe and in an acceptable condition. Issues with food carrying a ‘best-before’ date are usually related to quality and not safety.
14. What does a food bank/food redistribution centre have to do in the event of a withdrawal or recall?
From time to time, issues involving the safety and suitability of food may arise along the food chain, e.g. this may be due to a packaging defect on the food, an issue with ingredients not being declared on a food label or a manufacturing or storage problem.
Withdrawal: The removal of unsafe food from the market before it reached the consumer.
Recall: The removal of an unsafe food from the market when it may have reached the consumer and the notification of the consumer.
All food businesses donating food must maintain the ‘one-step forward’ traceability information as described in Q.6.
The FSAI publishes all recall and withdrawal information in the food alert section of the website. You can also subscribe to receive these alerts.
15. What labelling information should be on the foods coming into a food bank/food redistribution centre?
Any food that is donated in a prepacked form, e.g. box of cereal, pot of yogurt or jar of jam, will be required to have all of the mandatory labelling information (Appendix 2) declared on the label and this information will not be altered by the donating food business.
Where the food being donated was originally intended to be sold loose by the donating food business, it may bulk pack the food for delivery/transport to the charity and this business then only needs to display the following four pieces of information on the bulk pack:
- Name of the food
- Date of minimum durability, i.e. ‘use-by’ or ‘best-before’ date
- Storage instructions
- Business name and address of the donating food business *
All of the mandatory information must also be provided by the donating business in a document accompanying the food, e.g. delivery docket or invoice.
* If the manufacturer of the food being donated is different to that declared by the donating food business, this will be available through the commercial documents (delivery docket or other) that must accompany the food. The documentation that accompanies the food being donated will list any allergens in the food (Appendix 1). The charity can use this information to display on loose food that it handles or serves.
16. What labelling is required on foods leaving a food bank/food redistribution centre?
Foods that were prepacked by the manufacturer or other food businesses before entering the food redistribution centre, will have all of the mandatory food labelling information already declared on the labels. These prepacked foods may be redistributed in the same state.
17. What about repacking?
If a food bank/food redistribution centre opens and repacks certain food products, it will be required to transfer all of the mandatory labelling information onto the redistributed foods. A full list of the mandatory labelling information is available in Appendix 2. Restrictions are in place for the repacking of foods of animal origin such as meat, fish and cheese. Charities wishing to repack these foods should first contact the FSAI on email@example.com.
18. What additional help is available to our charity?
The FSAI Safe Food to Go booklet is also a very helpful resource to highlight the basis food hygiene principles.
The National Standards Authority of Ireland (NSAI) has also published ‘Hygiene in Food Retailing and Wholesaling’ which is an Irish standard to be used as a guide to the food hygiene legislation (Regulation 852/2004).
If you have any further questions on the safety of donating or storing food, you can email the Food Safety Authority of Ireland at firstname.lastname@example.org.
Last reviewed: 17/7/2018