Kathryn Gilbertson

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Getting hospitality businesses ready for reopening: identifying risks

Regulatory / 30 March 2021

In this final instalment of our ‘Getting hospitality businesses ready for reopening” series, we share our tips on bringing your compliance documents to life and ensuring robust due diligence defence.

Having inadequate compliance documents or due diligence defences can often be what falls apart when it comes to investigations. Many hospitality businesses have been shut in response to the national lockdown and old tier lockdown rules, meaning few, if any, people will have been in the kitchens or office for some time.

Now is the perfect time to cull your old papers as part of a deep-clean and to make space. Starting afresh in readiness for reopening will mean your new documents focus on what is important to your business, including any new business strategies and rules about Covid-19 safety. You should:

—  Review your existing or new menu: do the ingredients carry any risks? For example, if you are making crème brûlée from scratch using fresh eggs, are you using inoculated eggs to mitigate the risk of salmonella? See our previous update discussing salmonella risk in more detail here.

—   Identify steps to be taken to prevent food poisoning and cross-contamination, particularly with poultry? See our previous update discussing campylobacter here.

—  Ensure you and your staff know the ingredients of all dishes to handle allergen queries? See our previous update in this series.

—  Review your Hazard Analysis and Critical Control Point (HACCP) manual to ensure you are managing food safety hazards; ensure action is taken; that procedures are followed and are working; and keep records to show what you have done.

—  Carrying out a Covid-19 Risk Assessment as soon as practical, including consulting with employees to understand the practical realities and difficulties of working, both in the outdoor and indoor spaces. All businesses with more than 50 employees must publish their risk assessments. Irrespective of size, all businesses should download and display a notice stating it has complied with the Government’s guidance on managing the risk of Covid-19, including that it has carried out a risk assessment specific to Covid-19. Even if you carried out a risk assessment after the easing of the restrictions last summer, you should carry out a new risk assessment and display a new notice.

— Finally, there were discussions last week about the use of a vaccine passport scheme as a condition of removing restrictions to enter pubs and restaurants. UKHospitality’s Chief Executive, Kate Nicholls, has said ‘It is crucial that visiting the pubs and other parts of hospitality should not be subject to mandatory vaccination certification. It is simply unworkable, would cause conflict between staff and customers and almost certainly result in breaches of equality rules.’ If you would like to understand more about your position with regard to vaccine passports and consequential implications for your business, please get in touch.

If you would like help with your risk assessments, vaccine passports or food safety generally, please do get in touch. We wish all our hospitality clients and contacts a successful reopening and look forward to visiting you soon. 

 

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This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. For advice, get in touch with your usual Greenwoods GRM contact or scroll down to complete our enquiry form.

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