If your staff prepare, serve or handle food, they need food hygiene training. The question is what kind, and what the rules actually say. This guide covers the EU framework that applies in Spain, the Spanish rules on food handlers, allergen information, and what is known about Gibraltar.
The EU baseline: Regulation (EC) 852/2004
Regulation (EC) No 852/2004 on the hygiene of foodstuffs places the responsibility for training on the food business operator. Annex II, Chapter XII requires operators to ensure that:
- food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity; and
- those responsible for developing and maintaining the business's food safety procedure have received adequate training in the application of HACCP principles.
Article 5 requires operators to put in place, implement and maintain a permanent procedure based on HACCP principles. In plain terms: someone must understand hazard analysis well enough to build and run the system, and everyone else must be trained to the level their job needs.
The regulation does not name a specific course or level. "Commensurate with their work activity" means a kitchen porter, a chef and a kitchen manager need different depths of training.
Spain: food handlers (manipuladores de alimentos)
Real Decreto 109/2010 repealed Real Decreto 202/2000, which had regulated training for food handlers through prior administrative authorisation of training bodies and programmes.
The preamble of RD 109/2010 points to Regulation 852/2004, Annex II, Chapter XII, which makes food businesses responsible for supervising and instructing or training food handlers. Responsibility therefore sits with the business, which must be able to show during official inspections that its staff have been properly trained.
For an employer, that means keeping records: who was trained, when, in what and to what level. A certificate on file is the simplest way to show it.
Allergens: Regulation (EU) 1169/2011
Regulation (EU) No 1169/2011 on food information to consumers makes it mandatory to indicate any ingredient or processing aid listed in Annex II, or derived from one, that causes allergies or intolerances and is still present in the finished product (Article 9(1)(c)).
Article 44(1)(a) makes this information mandatory for non-prepacked food too. That covers restaurants, bars, cafés, delis and catering, not just packaged products.
The 14 allergens in Annex II are:
- Cereals containing gluten
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk
- Nuts
- Celery
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites
- Lupin
- Molluscs
Getting allergen information wrong is a serious risk to customers. Staff taking orders need to know where to find the information, and kitchen staff need to prevent cross-contact.
Gibraltar
Gibraltar's Food Hygiene Regulations (1977) set hygiene duties for people who handle food, including personal cleanliness and not handling food when aware of an infection that could contaminate it. The Environmental Agency is closely involved with food hygiene and safety in Gibraltar, deals with the licensing or registration of food premises and lists food safety among its training areas.
For current requirements on training in Gibraltar, check directly with the Environmental Agency before relying on any general guide, including this one.
Who needs which course?
- Level 2 Food Safety and Hygiene: for anyone who handles, prepares or serves food, such as kitchen staff, bar and front-of-house staff, catering assistants and galley crew. It covers the hygiene knowledge expected of a food handler.
- HACCP Level 2: for staff who work within a HACCP-based system and need to understand monitoring, critical control points and record-keeping.
- HACCP Level 3: for supervisors, managers and those responsible for developing and maintaining the business's HACCP procedure.
- Food Allergy Awareness: for anyone who prepares food or talks to customers about what is in it, front and back of house.
Many businesses combine these: Level 2 Food Safety for all handlers, Allergy Awareness for everyone who serves, and HACCP for those who run the system.
Training is not a one-off exercise. Staff, menus and suppliers change. Reviewing training whenever a role or a risk changes, and keeping the records current, is the practical way to show that every handler is still trained to a level that matches the work they do.
Course details
James Daniel Holman, ProTrainings instructor, delivers these courses in person in Gibraltar, Cádiz and on clients' premises:
- Level 2 Food Safety and Hygiene: 1 day, €150 per person
- HACCP Level 2 or Level 3: 1 day, €150 per person
- Food Allergy Awareness: 1 day, €150 per person
Courses run for a minimum of six people. Successful candidates receive a ProTrainings certificate, which gives you a training record to show at inspection.
Practical steps for employers
- List every role that touches food, including temporary and seasonal staff.
- Decide the training level for each role based on what they actually do.
- Keep training records and certificates where an inspector can see them.
- Review allergen information whenever recipes or suppliers change.
This is general guidance, not legal advice.
See course details on the food safety courses page.
