How I Use the Problem Foods Template with Customers in Pilla
Problem foods catch people out because they look harmless. Rice sits on a shelf. Eggs come in a box. Bean sprouts look like health food. But each one carries a specific hazard that your standard cooking and storage procedures won't control. I've walked into kitchens where cooked rice has been sitting at room temperature for four hours because the chef thought it was fine, the same way you'd leave bread out. It's not fine. Bacillus cereus spores are germinating the whole time, producing toxins that reheating won't destroy.
The problem isn't ignorance. Most chefs know rice needs to be cooled. What they don't know is why, or what happens when the cooling takes too long on a busy Friday night and they just leave it. This article covers what your problem foods policy needs to include, gives you a template you can edit for your own menu, and walks through the bits that trip people up in practice.
Key Takeaways
- What are problem foods in food safety? Problem foods are ingredients that carry specific hazards standard cooking doesn't address, including eggs (Salmonella), pulses (natural toxins), sprouted seeds (E. coli), and starchy foods like rice and pasta (Bacillus cereus). Each requires its own control measures
- Why do you need a problem foods policy? Regulation (EC) 852/2004 requires food businesses to identify and control hazards specific to their operation. Problem foods have caused serious outbreaks, and your EHO will expect to see documented procedures for any high-risk ingredients you handle
- How do you set it up in Pilla? Use the knowledge hub template below, edit it to match your operation, and share it with your team through the app so everyone has access and you can track who's read it
- How do you automate the follow-up? Set up Poppi to chase staff who haven't acknowledged the policy and flag when it's due for review
Article Content
Understanding What's Required of You
Problem foods are ingredients that carry hazards beyond what normal cooking controls. They contain natural toxins, harbour bacteria that survive standard cooking temperatures, or require handling procedures that differ from everything else in your kitchen. The four main categories are eggs, pulses, sprouted seeds, and starchy foods like rice and pasta.
Each one has a different hazard profile. Eggs carry Salmonella risk on the shell and occasionally inside. Pulses, red kidney beans in particular, contain natural toxins that aren't destroyed by normal cooking. Sprouted seeds have been linked to serious E. coli outbreaks because the sprouting process creates warm, moist conditions where bacteria thrive. And starchy foods harbour Bacillus cereus spores that survive cooking and germinate as the food cools slowly through the danger zone.
The legal basis is Regulation (EC) 852/2004, which requires food business operators to identify and control hazards specific to their operation. If your menu includes any of these foods, you need documented procedures for how you handle them. Generic food safety training isn't enough. Your EHO will want to see that staff understand the specific risk each problem food presents and the specific control that addresses it.
In my experience, starchy foods cause the most issues. Rice in particular. I've reviewed kitchens where the cooling procedure on paper says "cool within 90 minutes" but nobody has a timer running and nobody checks. The rice gets cooked at 11am, sits in the pan until 2pm, then goes in the fridge. By that point, the toxins have already formed. Reheating it to service temperature does nothing. Those toxins are heat-resistant.
Eggs are the second most common problem. The Lion brand requirement is well understood, but the rules around vulnerable groups and pasteurised alternatives for raw preparations are where gaps appear. I've seen kitchens making hollandaise with shell eggs because the pasteurised liquid eggs ran out and nobody wanted to take the dish off the menu.
Setting It Up as a Knowledge Hub Entry
I've built a problem foods template in Pilla covering eggs and Salmonella controls, pulse handling and natural toxins, sprouted seed requirements, starchy food cooling procedures, and corrective actions. It gives you a structured starting point, but your policy needs to reflect the problem foods you actually handle.
In the knowledge hub, create a new entry and tag it with "Food Safety Management System". Use the same tag across all of your food safety policies so they are grouped together and Poppi can track them as a set. Assign the entry to all teams so that everyone in the business can access it.
The template is designed to be edited, not just filed. If you don't serve pulses, remove that section. If you do a lot of rice-based dishes, expand the starchy foods section with your specific cooling procedure and timings. The EHO wants to see that your policy matches your menu, not that you've filed a generic document covering foods you don't use.
Some types of foods will require extra care to ensure food safety, in particular eggs and egg products, pulses and rice.
Steps must be taken within the processes and procedures to ensure that these particular foods do not present a risk to consumers.
Staff must follow the safety points below to ensure that a consistent level of safety is achieved.
Safety points - Raw egg products
Raw eggs and lightly cooked eggs are commonly used in catering; however, they are considered too high of a risk to be served to vulnerable or risk groups such as pregnant and nursing mothers, very young children and infants, the elderly and immunocompromised individuals.
Foods such as bearnaise and hollandaise sauces, homemade mayonnaise, some salad dressings, ice cream, icing, tiramisu and other desserts containing eggs, the company policy is to use pasteurised liquid eggs only.
- Pasteurised egg products must be kept refrigerated, strictly abide by the date of use once opened
Use by dates and handling
- Raw shell eggs should always be treated as a raw product as the shells can hold pathogenic bacteria. Store separately to avoid cross contamination
- Eggs must not be used past the best before date printed on them
- Company policy is only to purchase and use hen eggs holding the "lion brand"
- Store eggs away from high risk and RTE foods
- Always wash hands after handling shell eggs
Storage
- Store eggs in the fridge
- Eggs must not be moved between chilled and ambient temperatures unless about to use. Fluctuations in temperature can alter the internal consistency and permeability of the eggs making them higher risk
- Broken or cracked eggs should be discarded
Lightly cooked
- Due to consumer pressure there may be times when eggs with lightly cooked yolks are requested. Although this is still a risk, you must always purchase eggs from a reputable supplier supplying lion branded eggs
- Lion branded eggs have been through stricter controls including hens being vaccinated against salmonella enteritidis as one day old chicks. This is not a total guarantee as other pathogens can potentially be present
Thorough cooking
- If shell eggs are cooked thoroughly then there should be no risk to consumers
Safety points - Pulses
Fresh pulses
- Some pulses, red kidney beans in particular, contain natural toxins that must be destroyed before they can be served to consumers
- Fresh pulses and beans, such as chickpeas and dried beans must go through a process of soaking for a time period, rinsed thoroughly, then cooked for a specified time. Follow manufacturer's instructions strictly as to this procedure to avoid hazards from these toxins
Tinned pulses
- Tinned pulses are pre-cooked to very high temperatures of 121°c for a specified time under pressure in a manufacturing plant (botulinum cook) to make the product commercially sterile i.e. All organisms are destroyed including resilient spores and toxins
- Tinned pulses are safe to eat straight from the can, as long as the tin is intact
- Damaged, rusty and leaking tins must be discarded
Safety points - Sprouted seeds
- Sprouted seeds such as alfalfa, mung beans (commonly called bean sprouts) and fenugreek must never be eaten raw. These products must be cooked every time before consumption
- Various types of bean sprouts have been linked to serious outbreaks of E. coli; current guidance is that these are not served raw
Safety points - Starchy foods (e.g. rice, pasta, cous cous and similar products)
Poor cooling
- It is critical that cooked starchy foods be cooled down quickly then chilled, if they are not intended for immediate consumption
- Once cooked, the spores of a pathogenic bacteria called bacillus cereus can germinate quite quickly at relatively high temperatures
- The quickest method of cooling these starchy foods is to run them under cold potable water using a colander
- Alternatively, the food can be spread thinly over a clean surface or tray to speed up the process
- Protect the cooling food from contamination, however, do not use cling film or foil as they will act as insulators and subsequently slow the cooling process down which is not advised
Storage following cooking
- Once cooked, if not intended for immediate consumption these foods must be stored in a sealed container in a fridge. This is especially important if the food is to be served cold
Reheating
- It is safe to reheat these foods but only if food has initially been cooked correctly and chilled down quickly
- Reheating will not remove any heat resistant toxins that may have formed during poor storage conditions, therefore correct chilled storage is critical to safety
- Staff must understand that foods can only be cooled down once and reheated once
Cook and serve
- Whenever possible always try to cook once only and serve immediately
- Alternatively, rice can be cooked first and held in rice cookers at temperatures above 63°c
Corrective actions
- Review and change suppliers if food safety or quality of foods is an issue
- Discard any foods that have been handled incorrectly or unsafely
- Discard any foods that have become contaminated
- Discard foods that have not been cooled within 90 minutes
- Discard foods that have been left at ambient temperature
- Change methods if foods are not cooling quickly enough
- Use tinned pulses instead of fresh to remove potential hazards
- If staff do not follow the above safety points, then retrain them and increase supervision until competency can be shown
Record keeping
- Record any contraventions of the above safety points and the corrective actions taken
- Record any training or retraining undertaken
This is a preview of the template. In Pilla, you can edit this to match your business.
What I'd want to see when reviewing this:
The egg section needs to be specific about which preparations use pasteurised liquid eggs and which use shell eggs. A blanket statement saying "we use pasteurised eggs where appropriate" isn't good enough. I'd want a list: hollandaise, bearnaise, mayonnaise, tiramisu, icing, ice cream, and any other preparation where eggs aren't fully cooked. Those get pasteurised liquid eggs. Everything else can use shell eggs, provided they're Lion branded and within date.
The starchy foods section is the one I spend most time on with customers. The cooling method needs to be explicit: run under cold potable water using a colander, or spread thinly over a clean tray. The 90-minute window needs to be stated. And the cool once, reheat once rule needs to be clear to every member of staff who handles rice or pasta. I'd also want to see the alternative documented: rice held above 63 degrees in a rice cooker during service, which avoids the cooling risk entirely.
Common mistakes I see:
The sprouted seeds section is often missing entirely. Kitchens that use bean sprouts in stir-fries usually know they need cooking, but the policy doesn't state it. If an EHO asks "what's your procedure for sprouted seeds?" and the answer is "we cook them," that's not documented. The template covers this, but I still see businesses skip past it because they think it's obvious.
The corrective actions for starchy foods are usually too vague. "Discard food that has been left out too long" doesn't tell anyone what "too long" means. The template specifies discarding foods not cooled within 90 minutes and discarding foods left at ambient temperature. Those are the specific triggers your staff need.
The egg storage rule about not moving eggs between chilled and ambient temperatures catches people out. Temperature fluctuations alter the shell's permeability, drawing bacteria through it. I've seen egg deliveries left on the counter for an hour while the kitchen sorts the rest of the order. That hour matters. Eggs go straight in the fridge on arrival.
Automate the Follow-Up with Poppi
Writing the policy is one thing. Making sure your team has actually read it is another. Poppi can handle the chasing so you don't have to.
If you mark the knowledge hub entry as mandatory, Poppi will track who's read it and who hasn't. You can set up automations to chase staff who are behind, notify managers when someone completes the policy, and get a regular report showing where the gaps are.
Here are three automations I'd set up for any knowledge hub policy:
Tom, you have 2 overdue policies to read and acknowledge
Overdue training reminders
Automatically chase team members who have mandatory policies they haven't read yet. Poppi sends the reminder so you don't have to.
Tom, you have 2 overdue policies to read and acknowledge
Emma has completed a mandatory policy
Video completion alerts
Get notified when a team member finishes reading or watching a policy, so you can track progress without chasing.
Emma has completed a mandatory policy
Training Report: 87% team completion. Tom and Sarah behind on 2 mandatory policies, due 3 days ago.
Training gap analysis
Get a regular AI report showing which team members are behind on mandatory policies and where the gaps are across your team.
Training Report: 87% team completion. Tom and Sarah behind on 2 mandatory policies, due 3 days ago.