Environmental health visit

[FreeFall]

Weights... over weight is as bad as underweight

Really? Why is that? (Not saying you're wrong - just interested).

Can you get away with overweight jars if you state 'minimum content' on the label?

 

[Poly Hive]

Quoting Weights and Measures here...

Underweight is cheating the customer who buys the jar.

Over weight is cheating the competitor who fills precisely to the weight.

Hmm.. so much for free choice.

PH

 

[FreeFall]

Over weight is cheating the competitor who fills precisely to the weight. PH

Thanks for that. So if you want to legitimately 'cheat' your competitor, then fill to the exact weight but just charge less!

Or is there some stupid bureaucratic nonsense that prevents that as well?

 

[Teebeeaitch]

A lot of misinformation in the previous posts. If you are preparing food at home for sale to the public, you are required to register your premises with your Environmental Health Dept at your local authority. You will be considerered as a low risk operation, similar really to those who make wedding cakes at home to sell to the public. Your initial visit is probably the only visit you will receive unless there is a problem or complaint relating to your operation. You will be required to stick to some very basic common sense principles regarding hygiene. The EHO will probably hand you the guidance for home caterers. Follow that and everyone will be happy. Finally with regard to labelling, this is enforced by the EHO if you live in a unitary authority, otherwise its Trading Standard at your County Council.

 

[Moggs]

BBKA Advisory Leaflet B10

"Food hygiene.
'Registration of premises does not apply to the direct supply by the producer of small quantities of primary products to the final consumer or to local retail
establishments directly supplying the final consumer.’

However the BBKA do recommend that beekeepers who offer honey for sale
familiarise themselves with the basic hazards and practices in food handling.
The Royal Society for the promotion of Health produce a booklet on this
subject and a course run by some local authorities leads to the RSPH
Certificate in food hygiene awareness"

 

[Compostcritter]

I do not understand why you would not want to register, as it reassures your customers.

 

[Moggs]

CC - agreed.

An early post asked if registration was compulsory. It's not, according to advice for the hobbyist beekeeper from the BBKA.

 

[jackbee]

I do not understand why you would not want to register, as it reassures your customers.

Why invite trouble

 

[drstitson]

agree that the CURRENT situation needs clarification.

The health inspectors prog on BBC that precipitated the OP getting in touch with EH did indeed show the EHO at a car boot insisting that anyone selling foodstuffs (even non-prepared!!!) to the public now had to be registered. The man confronted on the prog had a crate of freshly picked apples for sale on his stall.

 

[RoofTops]

DrS, shouldn't it be: "Timeo hominem, unum Google legentem" these days?

 

[Teebeeaitch]

Some confusion probably arises from the domestic premises situation. There is an exemption for honey production and if you intend to sell only from your domestic premises, you could ask for an exemption. However, if you intend to sell elsewhere such as boot fairs, markets, etc you may not qualify for the exemption. Again, you inspecting EHO will be best placed to advise you. Remember the exemption concerns food premises registration and not exemption from food labelling regs.

 

[MandF]

Weights... over weight is as bad as underweight so you need scales and possibly stamped weights too to do sample checking.

PH

Not what I was told, nor what I have read anywhere else. A search for "trading standards jar contents weight" led me to this statement, which was exactly as I understood the regulations. Perhaps you can link to the regulations which state you cannot have overweight jars?

Excerpt below, my highlights;

---------------------------------
Honey can be filled either to Minimum Quantity or to Average Weight. In either case the scale used must be one that has been tested and approved for trade use. A stamped/verified shop scale is ideal, (see our factsheet, Weighing Equipment in Use For Trade, for more information)

For Minimum Quantity each jar should contain (net) at least the declared weight. Each jar or container must be individually weighed.

For Average Weight, there are certain rules - The Packers Rules- which must be followed. These allow for some weights to be a limited amount below the weight shown on the jar, provided that average weight is equal to or above that weight

For small producers one of the easiest ways to comply with these rules is to fill each jar by eye or on a scale then check (and make a record of ) the weights making sure that the weights are all at or above the weight declared.

 

[Poly Hive]

No I cannot point to the regs as it was a verbal conversation on the premises at the time with the Trading Standards person concerned.

It's possible of course that sine 1992 or so the rules have changed but I could see where they were coming from.


PH

 

[johnandyrob]

I was under the same belief as ph I and have again read it recently. I will see if I can find where I read it.

 

[MandF]

Ok, well then I think it is safe to say that overweight jars are legally ok, and in fact being a few grams over per jar is the safest way for us hobbyist beekeepers to remain legal.

I bottle by eye, weigh the jars.. if they are a few g's over the lid goes on. If they are more over the lid stays off, then I transfer using a small spoon to any which are slightly under, and continue to do so until it is within a few g (over) of the target weight.

 

[MandF]

I was under the same belief as ph I and have again read it recently. I will see if I can find where I read it.

As long as you read it in a trading standards doc then fine. Word of mouth, from whoever, is no good.

If you take a look at any bottled/jarred goods in the supermarket (milk, wine, beer, honey, pickled onions etc), you will see they all have differing amounts in each jar/bottle. If this "overweight is illegal" is true, then most of the produce on sale in supermarkets from commercial suppliers is illegal.

in fact, one could say the same about being served a pint of beer at the local. There is a minimum, not a maximum, weights and measures mark on the glass.

 

[MandF]

I just searched my local trading standards website (Richmond), which echoes the previous information i gave. And it is also important to note that these guidelines will be applicable to ALL honey packagers, and as we all know, the regulations are more lax in places for those selling at the door and so on.

http://www.richmond.gov.uk/food?article=122623

Excerpt;

-------------------------
Weight control

Honey can be filled to either minimum quantity (each jar should be at or above the declared weight), or to average weight.

------------------------------------------

 

[Rosti]

In strict terms both sides of this argument are correct, but correct depending on which pack weight compliance model you are working to (minimum weight or average weight).

Minimum Weight
In the event that you are working to (and can demonstrate) that all packs sold comply with minimum weight then you can give away as much as you like. To comply you would have to either:
a) tare off every jar individually and then fill to target or >target weight <or>
b) produce a statistically valid jar tare weight that allowed for negative variance (normally 3 times the standard deviation), and repeat this for each new batch of jars
Under such circumstances an over weight is not to the commercial detriment of the consumer and hence not illegal. In practical terms your ability to give away honey is limited by the volume of a standard jar (although volumetric filling is not a permissible option either because of aeration during extraction and varying specific gravity of honey's)

Average Weight
This is where you could fall foul of legislation (in this instance the Weights & Measures (Packaged Goods) Regulations 2006, which covers average weight control; rather than the over arching Weights & Measures Chapter 72 1985 act)
There are 3 'packers rules' for average weight
1. The overall average must be equal to or higher than the declared (nominal) weight.
2. No more than 2.5% of packs can fall below the nominal minus 1x negative tolerance (T1)
3. No packs may fall below a weight of nominal - 2x negative tolerance (T2)

There are tables that tell you tollerable negative error (TNE) and hence T1 & T2 for a given nominal. Before giving the explanation remember that average weight legislation was brought in to allow a level of flexibility in fill accuracy for the producer without such variation being to the 'average' detriment of the consumer. A help to all in that a quicker packing process is a cheaper process and so gives better consumer value.
How you could fall foul of this legislation ?

In the event that an overall packing run average was below the declared (nominal) weight then a packer may think they could throw some heavy weight packs in to bring the overall run average up. This may well work but if the low average was also caused by light weight packs that were below the T1 and the percentage of these was above 2.5% and remained so even after the heavy packs were added then the whole packing run (including the heavy packs) would still be illegal. Remember also that no packs below T2 are permissible under any circumstances. So you could have over weight jars which are part of an illegal packing run, aka illegal themselves. As the producer you must be duly dilgent and demonstrate that you have exercised all reasonable controls - bunging in a slack handful of over weight packs does not meet these defence criteria (neither would a pack weight distribution that varies significantly from the noirmal to the adverse interest of the majority of consumers).

The stats to support average weight and running nominal averages can be onerous with regard recording individual packs and calculation to give a due diligence position, especially with small batch runs where percentages build up quickly. Frankly, whilst I support clients to take full advantage of average weight legislation; for me, packing a bit of honey now and again, taring each jar and filling to nominal weight is simply easier and requires much less due diligence documentation.

And while we are at it how do you make sure your scales are accurate? Purchase an accurate 500ml tall thin plastic measuring cyclinder from a home brew shop or laboratory supplier. Tare to zero on your scales. Fill accurately to 500ml with 20'C tap water. Make sure your scales read 500g, if not make a note of the calibration adjustment you must apply. Don't waste your money on reference weights - which once their first year calibration certificate runs out mean nothing without a new calib cert - and cost a whole lot more! If you are producing jars greater than 454g then get a bigger cylinder ensuring it exceeds the nominal weight you wish to validate

I hope that helps. R

 

[Baggyone]

I'm doing my food hygiene course on Monday with Boston enviromental health (albeit a course specifically aimed at Butchers so the whole place is doing it) and if anyone has any questions I will ask them for you.

Please PM any you want asking.

Baggy

 

[Compostcritter]

Easy question is do bee keepers need to register with their local EHO to sell their honey in shops, car boots etc and what is entailed. I have my meeting now with the EHO in a couple of weeks he sounds really nice and wants to help (had to postpone on the phone for a week, due to work commitments).