Food safety management plan: what a restaurant must do, write down and keep

Since 1 January 2006, Regulation (EC) No 852/2004 on the hygiene of foodstuffs has required every food business operator to put in place good hygiene practices and procedures based on HACCP principles. Regulation (EC) No 178/2002 adds traceability and the handling of non-compliant products. In France, the whole package has a name: the plan de maîtrise sanitaire, or food safety management plan.

Its aim is simple: no unsafe food should reach the customer. Responsibility lies first with the operator: it is the operator who identifies the hazards in their kitchen and chooses how to control them.

The plan is scaled to the size of the business. A technical instruction from the French Ministry of Agriculture (DGAL/SDSSA/2018-924, amended in 2024) allows a simplified PMS where five people or fewer work in contact with food, counted by head rather than in full-time equivalents: some procedures can then remain oral, provided everyone can explain them.

The PMS brings together three elements: prerequisite programmes, including good hygiene practices; a system for traceability and handling non-conformities; and procedures based on HACCP principles. The first two form the foundation on which the third rests.

Good hygiene practices do not target a specific hazard. The Ministry’s ‘commercial catering’ sheet sets them out: well-maintained premises and equipment, at least one probe thermometer, a cleaning and disinfection plan known to the team, pest control, checks on receipt of goods, drinking water, storage temperatures, separated waste, staff clothing and health.

The HACCP plan deals with the hazards these practices do not control. It starts from a step-by-step analysis of biological hazards (pathogens, parasites, toxins), chemical hazards (cleaning product residues) and physical hazards (glass, metal), allergens included: hence the value of an up-to-date recipe card for every dish. For each hazard identified: a control point and its limit, monitoring, corrections if there is a deviation, verification and documentation.

Even in a restaurant, the analysis is necessary: it confirms that no hazard escapes good hygiene practices, failing which a HACCP plan is added. Some steps require particular monitoring, such as sous-vide cooking or cooling: without a validated time-temperature schedule, a cooked dish must not stay for more than two hours between +63 °C and +10 °C at the core.

The traceability required of a restaurant is first about knowing who supplied what, and when: suppliers’ names and addresses, the nature of the food, dates of receipt. Delivery notes and invoices are the proof; also keep the label of a product taken out of its packaging for as long as it is in use. No template is imposed, and internal traceability, from batch to dish, is optional, but it allows a more targeted withdrawal in the event of an alert.

A non-conformity is a deviation: a cold room that is too warm, a product delivered damaged, a use-by date that has passed. You record the correction, which deals with the deviation (destroying or isolating the food), then the corrective action, which removes the cause (repairing, changing supplier, revising an instruction), on the same document, in any form you like: a notebook or a diary will do.

When a product may present a hazard, the PMS sets out what happens next: withdraw it, recall it if it has already left, and notify the departmental directorate for the protection of the population (direction départementale de la protection des populations, DDPP or DDETSPP). Every restaurant must have written down its procedure for handling health alerts, non-compliant products and suspected collective food-borne illness outbreaks (TIAC).

The sector sheet distinguishes between what you check, what you keep and what you record. With a simplified PMS, you mainly record deviations and the measures taken, plus the monitoring of high-risk steps and, continuously, the temperature of frozen-food storage units.

Maximum storage temperatures come from the ministerial order (arrêté) of 21 December 2009: +3 °C for dishes prepared in advance, +2 °C for minced meat and fresh fishery products, +4 °C for other highly perishable foods; −18 °C for ice cream, −12 °C for other frozen foods. A dish delivered or handed to the customer hot stays at +63 °C or above. Defrost in the fridge or by cooking directly, never at room temperature, and never refreeze a defrosted product.

Above 25% polar compounds, a frying oil is deemed unfit for consumption (Decree no. 2008-184 of 26 February 2008). Stock rotation by date is covered in the stock management guide.

A guide to good hygiene practice and the application of HACCP principles (GBPH) is a voluntary document, written by a trade sector and approved by the authorities. For a restaurant, the reference guides are the ‘Restaurateur’ guide (November 2015) and the ‘Restauration rapide’ (quick service) guide (2024), available free on the French Ministry of Agriculture’s website.

Its hazard analysis, control points and limits can stand in for your own, provided that you know it, have it on site, complete it where it says to, apply it, and that it matches your activities exactly. A process it does not cover must be analysed separately.

Two training obligations exist side by side. Everyone who handles food is supervised and receives hygiene instructions or training suited to their role, and at least one person in the business can show they have been trained in HACCP principles. In commercial catering, quick service included, at least one person at the site must also have completed the 14-hour specific food hygiene training, with an organisation approved by the regional prefect (préfet de région).

People who can show three years’ experience as a manager or operator in a food business, or a qualification on the list in the order of 18 November 2024, are exempt. This training has no expiry date and does not need renewing; but an inspection that finds poor knowledge of good practices leads to a training obligation.

Inspections take place without notice, during opening hours, by the DDPP’s food hygiene and safety department, which knows about the business through its declaration of activity, made before opening. The inspector observes the kitchen, questions the team and asks for documents: temperature records, including the time-temperature pairs for cooking and cooling, receipt, cleaning and oil-check sheets, training, analyses, supplier contact details, non-conformities and corrective actions.

Penalties range from a warning to closure, by way of a formal offence report (procès-verbal). The result is published on Alim’confiance for one year, on four levels: ‘very satisfactory’, ‘satisfactory’, ‘needs improvement’ and ‘urgent correction required’. Displaying it in the window is not compulsory.

The Ministry’s instruction imposes neither a template nor a medium for these records: paper, spreadsheet or software are all fine, as long as the information is accurate, dated and retrievable. Paper costs nothing, but alerts no one when a check is missing; the sector sheet itself mentions automatic alarms for monitoring storage units. HACCP record-keeping software sends reminders for checks and keeps the history; in a restaurant group, it shows head office which site is behind.

Adopting a standard PMS without adapting it. A guide or template is only worth something if it matches your activities, your premises and your recipes, and if it is applied. The inspector judges what happens in the kitchen, not how thick the binder is.

Taking readings without noting what followed. An out-of-range temperature with no action recorded proves a deviation, not that it was controlled. Write down what was done and what happened to the food.

Relying on a thermometer that is never checked. A reading is only accurate if the instrument is: check it periodically and keep a record of it.

Throwing delivery notes away too soon. They are your traceability evidence: keep them for at least six months, the recommended period for perishable foods.

Oral instructions nobody can explain. In a simplified PMS, a procedure can remain oral; an employee unable to explain it to the inspector is a non-conformity.

Is a PMS compulsory for a small restaurant? Yes: every food business operator must apply one, whatever its size. What changes with size is the amount of paperwork. Where five people or fewer work in contact with food, the Ministry’s instruction allows a simplified plan, with oral procedures and records focused on deviations.

How long should documents be kept? For traceability, the regulations set no period; the European guidance document recommends five years, and six months for perishable foods with a use-by date of less than three months or with no date. Analysis results are kept for three years, collection notes for animal by-products for two years. For everything else, follow your good practice guide.

Do you have to record fridge temperatures every day? Storage units are monitored at least once a day, and those holding frozen food are recorded continuously. For a site with a simplified PMS, the sector sheet only requires deviations and the measures taken to be written down; the inspector may still ask for your temperature sheets.

Who can you ask about a specific case? The DDPP or DDETSPP in your département, which inspects restaurants, and the good practice guide for your sector. This guide summarises the texts; it is not a substitute for advice on your situation, for example sous-vide cooking, selling to other businesses or a catering activity.