BLUE HOUSE GOATS CEASED TRADING.
Following the routine inspection and subsequent telephone calls, I informed your inspector that I would cease trading by 31 December 2023. I was told to inform you when I had ceased, so you could amend your records. I have ceased trading. Please remove Blue house goats from your list of companies. I can assure you there is no satisfaction producing salty plasticine with a shelf life of 10 days that you require.
On the first inspection, your inspector waved his name badge, said he was from Public protection, and had the power to close me down. I do agree you have that power, what I dispute is that it has anything to do with public protection.
We were a small producer, producing goats cheese and yogurt. Small producers do not start with hedge fund backing, or unlimited supply of money. They start with their life savings and prepare to earn nothing for the first five years. They can not compete with supermarkets, farm factories, or food factories, on price or production. They can only survive with quality and taste.
Labels
It is essential that the public can read and understand food labels. Before we started we bought cheese and Yogurt from Marks and Spencer, Morrisons, Tesco, Asda and Sainsbury. We noted what was said on the labels and asked a graphics designer to produce labels similar. He said he could not produce labels that small but with a different font could make them fit. We told him to go ahead with the larger font labels.
Your inspector said the labels were illegal, They were too small even though larger than any labels in the Supermarket. We altered the size of the font and size of the labels. The cost was significant, increasing the labels cost from 15% to 23% of the product cost.
Either all British supermarkets are operating illegally, or Northumberland has its own laws.
Herbs
On a routine inspection it was noted that we produced cheese containing chives. This was a summer cheese whilst chives were growing, before flowering. Although grown in pots, cut and washed before use, the inspector considered it was a herb and thus needed to be pasteurised. It was pointed out that chives are of the Allium family (Allium species have antimicrobial activity against bacteria, fungi, viruses, and parasites. ) The inspector said, any thing added to cheese must be pasteurised. I ask how is that possible, he said, there are 3 ways to pasteurise herbs
liquid nitrogen . Having dealt with liquid Nitrogen before , and noting all the SOLAS regulations . This substance is dangerous in small spaces, and would never be used.
Strong chlorine wash, not a weak chlorine wash as in tap water. This would raise the ph of the chives, bleach the colour and destroy the taste, not to mention slipping into COSHH regulations. Clearly not feasible.
Immersing in hot water 72C for 2 minutes. I said it would make the chives like tasteless soggy grass. He was adamant this was not the case if done correctly.
I can accept that liquid Nitrogen and Chlorine were outside his skill set, so assumed immersion in hot water was something he was competent to advise on.
I said, in that case we will use dried chives. He said that was even more unacceptable as all dried herbs are dangerous unless used in cooking. He noted a serious incident at a food festival where dried curry leaves from Bangladesh caused an outbreak of Clostridium botulinum .
We stopped using chives in the cheese, although it is a popular Cheese. Immersing chives in hot water 72C turns them to soggy tasteless grass in less than 2 minutes, proved by experiment.
The last routine inspection (06/02/23) your inspector suggested it would be prudent to include another form for each cheese in the risk assessment, but I should complete a decision tree for the form. Not knowing what a decision tree was, she helpfully told me where to find the information online. This gave me a clear insight of the management of your department.
As suspected the decision tree is a flow chart. A flow chart is part of Critical path planning to ensure modules are brought together at the appropriate time to ensure no waste of materials, staff, time or money. Flow charts are used extensively in manufacture, civil engineering, and disaster planning, not form filling. I do not believe the inspector made it up, but it was gleaned from a trendy management course designed to make petty administrators think they are managers. These courses are used to reward staff and burn budgets. Government 5 year budgeting procedures (last year, this year, and three years hence.) mean it is important to use the budget allocated or the budget for the department will be cut. Budget burning courses are handy. We have all done it , but with the cost of living crisis and real term cuts to local authorities it is not appropriate and shows a lack of supervision by the chief executive and departmental heads.
Communication is critically important. Continuous use of acronyms, and house jargon does not convey competence. It is a display of arrogant contempt. If you can not convey the meaning of a formula or concept so that a four year old can understand you need to revisit the formula.
The conduct of a safety inspection.
Having done safety inspections for a number of years for a government agency, I am aware of inspection protocols. The power to close someone down is delegated power, from an act of Parliament, to the Secretary of state, delegated to the chief executive of the council, and downward to the head of department to the inspector. The inspector is acting on behalf of the Secretary of state, thus normal delegation protocols must be adhered. i.e. the authority delegated must match responsibility for action and staff commitment. Managers must ensure delegated authority is used correctly. This has not been done.
The inspection will be signed off by both parties as a true account of the inspection and action to be taken. It goes to say there must be clarity in what is compulsory, advisory, and for information.
Any follow up action must also be signed off as an accurate account of the inspection. Phone calls and emails after the inspection with no sign off protocol is harassment and malpractice. A competent manager can see what has been agreed and subsequent action. If they differ, malpractice has occurred, for which as head of the department, they are culpable, as is the Chief Executive that must ensure all departments operate with the law. Councils like Birmingham have been bankrupt by litigation, and lack of oversight.
85%+ of the population use supermarkets for food. So it would be prudent to check how well the council is protecting the public.
Labels . No change in the size of illegal labelling, in many cases the labels are smaller. In Aldi I noticed precooked rice. Rice is a major cause of food poisoning, so I tried to read the label. The writing on cooking instructions was far too small to be read. I asked a helpful assistant if she had a magnifying glass. She pulled out her mobile phone, expanded the label, and offered to send it in an email, most helpful. Sadly the majority of people with defective vision are over 60. Of the 23% of the population that do not have a smartphone or computer the majority are over 60. Northumberland has an aged population.
All labels have multiple font sizes, delicious and tasty are far larger than the ingredients or allergen information which are seriously undersized.
Allergen information. I recently went into the Green shop in Berwick following an inspection. It is festooned with Allergen posters, something you would never see in a supermarket, where Celery, is either tasty or succulent, not an allergen.
Herbs. These highly toxic products are tasty and delicious used raw or in cooking. There are no warnings that all herbs must be cooked or are a serious health risk. The dried herbs have no warning to only use in cooking. If your inspector was correct, there must be a government warning on the product.
Cheeses coated in herbs or herbs in the cheese are plentiful. Even Cottage cheese with chives are available.
Cheese Your inspector wants all cheese to be heated to 90C for 10 minutes, and 50% more salt, increase the acidity and have a shelf life of 10 days. Supermarkets are selling reduced salt cheese.
The shelf life of 10 does not exist. The shortest shelf life I could find was 13 days and it had a large yellow label reduced to clear. Most hard cheeses had a 3 to 4 months shelf life.
Pasteurised milk had a shelf life of 14 days.
Clostridium botulinum
I have never had a case of Clostridium botulinum in all the years of cheese making in Orkney and Northumberland which is not surprising considering :
The International Commission on Microbiological Specifications for Foods does not recommend routine testing of milk products for Clostridium botulinum spores, but testing for other microbes, such as sulfite-reducing clostridia (limit 100 cfu/g) may be useful as indicators of process control and sanitation
Destruction of Botulinum Toxin by Milk Bacteria (journalofdairyscience.org) Milk is the raw material for cheese!
If I haven't got Clostridium botulinum, where could it come from?
Clostridium botulinum is prevalent in land flooded with salt water or flooded in polluted water. I can see where poisoning occurred in herbs originating from Bangladesh. You can still buy Authentic Bangladeshi herbs and spices online, even Noori and Neem. You can not buy Chives, they come from the Netherlands and Belgium
Bearing in mind my smallholding is 100M above sea level and 5 miles from the coast. The nearest river is 7 miles away and 90M below. We are the highest farm on this part of the moor; all water runs off the property not onto it. We do not feed Silage. In the winter we feed Hay, Straw, oats and barley, Not fishmeal. We use only milk produced on the farm, and do not buy in stock. When we run out of milk we stop making cheese. The quality of the milk is more important than the quantity. If I am at risk of Clostridium botulinum, so is every farm in Britain.
Every cheese in the supermarkets would be boiled to 90c and have added salt. The Government is trying to reduce salt in the diet, contrary to the policy of Northumberland.
The inspector has not closed me down. I have a 5 hygiene rating. The inspector is ensuring my product can no longer compete in the trading environment, Why?
There are three possible reasons:
1 The department is short staffed. The department can no longer reach the target of one routine inspection every 18 months. This will affect bonus payments. Targets and bonuses are not the best way to improve efficiency. It creates a hostile environment, short cuts and risk taking. Banks used bonuses, and Ofsted used Targeting.
2 Covering your back. With ultimate authority, no responsibility, staff become unconsciously incompetent. Alarmed at anything new or unfamiliar, and just want it to go away. It is difficult for an inspector dealing with someone who knows their subject.
3 Corruption
Some suggestions.
1 You can not have each council setting different rules. Food safety and hygiene must be a central government responsibility. The function of safety inspections should be removed from Councils
2 Authority can not be exercised without responsibility. Any targets for closing down and litigation should be cancelled. Staff should concentrate on improvement, greater safety, informative, and advice, not threats.
3 malpractice, if managers are overwhelmed and unable to supervise staff efficiently, each inspected property should be sent a generic questionnaire a month after inspection. Questions should include, have you made any changes, were the changes highlighted by the inspector in the inspection report. Did you sign the inspection report to agree to the changes? The form should be anonymous. The other alternative is 2 body cameras, one for the inspector and one for the client. The client body camera to be sent to a monitoring facility not the inspector. Anomalies reported to the head of department, (10% check would be sufficient to deter malpractice.)
4 unconsciously incompetent staff. This is normally dealt with by new challenges, sideways physical move, or training. (Knowledge, skills and attitude are inadequate). An educationalist should be consulted, and appropriate training given. A trendy management course run by chums is not appropriate. A peer review by an organisation with a proven track record of legal inspections would prove helpful. Ofsted should not be considered, where an inspection left a well liked head teacher fearing loss of livelihood committed suicide . If the above are not cost effective, Hire and fire.
5 Risk assessments. HACCP is an example of the Peter Principal. An administrator promoted to a managerial role they are not suitable for. To justify their position they change things radically, constantly call for reports, focus groups and meetings. The food safety agency is burdened with the concept of Critical points (procedures and protocols) not risk, hazards, occurrence and remedy. The specialist cheesemaker's risk assessment is the blueprint for a risk assessment by HACCP. I watched in amazement how the inspector, trying to emphasize a point, struggled to find what they wanted, Not just once. This document has a contents list, glossary, index, and appendices. Yet still difficult to use as a working document. You will not get assistance or ease of reading from a small producer.
Risk assessments like emergency planning must have a working document, easy to use, that clearly defines tasks, responsibilities and actions taken. In the mid 80's I was promoted to a new job. One of the first tasks was to review the 270 page emergency plan. The Chief Constable for Devon and Cornwall John Alderson, asked for all emergency plans to be one side of an A4 sheet, 2 at the most.
Emergency plans in those days were Shakespearean waffle. Information could not be found easily, and more concerned with blurring responsibly and obfuscation. The Emergency control room was a library of plans. What was needed was a sheet of A4 for each organisation, easy to amend, simple to read, with a clear decision pathway. Risk assessments were the same, easy to read generic form ( a working document). Since then we have drifted back to waffle and obfuscation, more pages equals a better risk assessment. Inspectors unable to read or understand the procedure will call for a simpler form to be included, and like topsy it will grow out of control. Most information in the risk assessment is duplication. This obsession with procedure and protocols did not stop an outbreak of e.coli in a Lancashire cheese plant. The HACCP risk assessment needs to be scrapped and totally rethought, However as a petty administrator's brain child it is never going to happen. The only safe way forward is to separate the HACCP from the routine inspection risk assessment. The HACCP is created and updated as changes occur. It would have to be signed off by the client and the council. A generic risk assessment identifying risk, hazards, occurrences, remedial action, further action required and by whom to be created. This will probably be about 3 pages, easy to use, time saving and gives more time for the inspector to interview, and inspect. It will free up time pre and post inspection, the department may even be able to reach the 18 month inspection target.
6 make up your mind as a council. You can not be supporting local business, at the same time as making trading impossible.
There are two ways of securing food security. One is a few mechanised mega farms and mega food factories. The other way is small production, loads of them.
If a problem occurs with a mega farm or factory the outcome is massive food shortage, panic buying and riots.
If a small producer has a problem, others will be able to take up the slack.
All brutal revolutions started with food riots
Northumberland was renowned for artisan small food producers, It is becoming a county known for dream catchers and bangles.
I have told you, so you are official warned, as your inspectors like to say
D Goggin
Blue House Goats
