Although not strictly a licensing matter, being registered as a Food Business often appears to be so. Northumberland County Council, as our local authority, is obliged to register the food preparation premises of all businesses which prepare food for consumption by the public. However, the government, in response to lobbying by community buildings and other voluntary and community groups (including your Consortium) has agreed that in certain circumstances organisations like village halls do not have to register. Whether your hall does or not hinges on two criteria:
- How often food is prepared – if it is once a month or more then it is considered “regular” and will therefore have to be registered.
- The level of complexity of the supply and/or whether it’s supplied to vulnerable people.
An overriding obligation is that all food supplied outside of the domestic and family setting is required by law to be safe to eat. This is regardless of whether the operation supplying or selling the food is doing so to make a profit.
It is also important to recognise that the organisation responsible for preparing the food is the potential Food Business. For some halls this might be the lunch club hiring the hall on a regular basis. In these circumstances it is good practice for the hall to ensure that the hirer is aware of its obligations. On the other hand, it may be the hall’s Management Committee which organise the preparation food more frequently than once/month. So, in theory, several organisations working out of one hall might need to be registered as Food Businesses. Food preparation in respect of registering as a Food Business does not include the frequent supply of tea, coffee and biscuits, the supply of canned or bottled drinks, crisps etc. More information can be found in the 2015 Guidance produced by the Food Standards Agency. This Guidance, which replaces the one of 2013, provides more useful examples (albeit non-exhaustive) of the circumstances when halls need to register as a Food Business.
Photograph: Wingates Institute