The hokenjyo health inspection for business permits

Finally, after a few visits to consult with the local health department on the minutiae of their requirements, officially submitting my application and paying for the permits a few weeks earlier, the day of the hokenjyo/health department inspection arrived! (This is another of the catch-up posts I'd been planning to get around to for a few weeks now...)

Paying for biz permits at the health dept.

I had spent some time getting to know the lady who would be carrying out the inspection, and through a few enquiries learning what she would be paying attention to, only to find that with the inspection being around the end of the financial year in April she would be transferring departments and a completely new person would be attending my inspection! Ah well.

The days leading up to the inspection were busy, and a certain level of construction was completed on time, with cosmetic additions to be completed later. It was a particularly busy time for construction-related parties and the health department itself, as from April 2014 the VAT amount in Japan increased from 5% to 8%.. In practical terms this meant that places like tile companies in Japan had run out of stock (people paid upfront in March for jobs planned in the upcoming months to save money on the increased tax), and Tokyo Gas were backed up in a similar way with new businesses wanting their gas connections opened and businesses up and running before the tax hike.

Another surprise slight inconvenience was the last-minute scrabble to get a locker to put the cleaning equipment in. After trying to order a cheaper, second-hand locker I ended up paying too much to get a new one from the Askul office supplies service, just so I would have a locker for certain by the time of the inspection. It's a bit big really..

I probably needn't have worried too much however, as the inspection itself went very smoothly. I guess it might depend on who you have doing the check, and perhaps the size and nature of your business, but it was all quite quick really.

The lady who came was mainly concerned to know whether anything had changed from the plans I had consulted about with her predecessor, aside from which she noted that the fridge and freezers indeed had temperature monitors, that the floor was washable, the toilet was far enough from the kitchen and that the kitchen was divided clearly from the customer space. She also checked how many exits there were to the property and said that the low glass partition that had been held up at the workshop for tax-increase related reasons definitely needed to be in place as soon as possible. This didn't impede me being granted the business permissions however, I was given the license numbers on the day, and was to pick up the actual certificate a week or so later at the health centre.

I say "permissions" in plural, as it turned out that I needed to apply and pay for two separate licenses, as I planned to do internet sales (which required a confectioner's 菓子製造業許可 / kashi seizougyou kyoka license) and occasional bakery (which required a cafe/restaurant license / 飲食店営業許可 / inshokuten eigyou kyoka). Incidentally, I checked specifically, and the baking school part of the business didn't actually require a business permit… interesting! Applying for these business permits cost 16,000 and 14,000 yen each.

One thing that I'd consulted about in advance was regarding whether or not we needed to 'raise the floor' in the kitchen, meaning building a type of stage, under which a drain could be plumbed in to allow for a wet-space and thorough mopping. Larger businesses and those doing a lot of frying, working with oil and so on usually require such a floor drain (they are usually designed in Japan as a drain in a long strip down the middle of the floor.

My business was deigned to be light-capacity and so a floor-draining wet kitchen wasn't required, as long as the floor covering for the kitchen itself was water-tight vinyl or some similar durable and washable substance. Raising the floor would have added at least a hundred thousand yen to the construction budget, so this was lucky! I did however choose to fit a small grease trap. For my light-capacity business type it wasn't strictly necessary, but I wanted to get along with my neighbours and that means not blocking up community drains and causing a stink.

There was a little discussion about when to pick up the permit, when it would need to be renewed and re-inspected, and also something regarding an Azabu initiative against gangs involving displaying a "No! to gangs!" type sticker on the premises. Apart from that, it seems that the health inspection isn't quite as big and scary as I had imagined it might be.

I feel that if you consult with them well previously and make sure you cover the non-negotiable requirements (size and number of sinks along with their individual taps with hot and cold water, separation of customer space and kitchen space) and prepare in good faith, you'll probably be fine.

Taking the hygiene manager test - requirement for food businesses in Japan

Woo! I'm now the proud owner of this little passport-like booklet proving that I'm now a designated food hygiene manager / 食品衛生責任者 / shokuhin eisei sekininsha. Have a look at this previous post for information on how and where to apply, today's post will be about what was involved in the day itself, and the little test they give you at the end.

The seminars are held a few times a month in locations all over Tokyo, take about 7 hours including a break for lunch, and seat just under 200 people each time. There is a 10,000 JPY fee which you pay in cash on the day, plus 700 yen if you want to buy an official name plate for your premises. You're seated in the order you arrive.

In your welcome pack is a notebook for the day's proceedings and a phone book-sized tome that includes a hundred or so pages of explanation that you'll be taken through during the day and another 100 or so pages of food hygiene-related articles from Japanese law.

Also in there were a handful of leaflets with details of various government-affiliated health, liability and employers' insurance especially for food businesses, some of which are cheaper than commercial options, and many of which had cute drawings and lots of big colourful fonts.

Speaking of cute drawings, check these out! The salient points of the fairly dry lectures were frequently illuminated with characters of germs looking afraid and hygiene managers looking stern and powerful. These ones show the legal requirements for the set-up of the staff hand-washing facilities, and the 3 ways to avoid causing food poisoning from unwanted microbial activity (don't introduce them, don't let them grow, kill them off!).

The first talk was about food hygiene law, and involved lots of kanji being written on a whiteboard, and lots of instruction of when to "赤ライン！ / underline in red!" in our books. Handy kanji to know for this section include:

• 法規 / houki - law
• 法律 / houritsu - law
• 憲法 / kenpou - the constitution
• 業種 / gyoushu - type of industry
• 許可 / kyoka - permission
• 厚生労働大臣 / kousei roudou daijin - Minister for Health and Welfare
• 表示基準 / hyouji kijun - labelling criteria
• 総合衛生管理製造過程 / sougou eisei kanri seizou katei - HACCP
• 添加物 / tenkabutsu - additives
• 禁止 / kinshi - prohibited
• 条例 / jyourei - regulation
• 保護 / hogo - protect
• 公衆 / koushu - public
• 方針 / houshin - policy
• 責務 / sekimu - obligation

There are 34 types of food business permitted under Japanese law - including those serving food and drink, those creating and selling confectionary, sales of fish products, sales of dairy-based products etc. - all of which require a designated food hygiene manager  / 食品衛生責任者 / shokuhin eisei sekininsha as well as a business permit / 営業許可 / eigyou kyoka. 7 of these types of business - such as businesses processing meat, fish or dairy products etc. - require a fully qualified hygiene supervisor / 食品衛生管理者 / shokuhin eisei kanrisha, which is a specific career choice, entailing a multi-year course of study rather than an informal 1-day seminar.

The second talk was about public health, and included some really interesting information on  Japanese demographics, illness and society. Have a look at the following tables, the far left column is the years running from 5th year of Showa (1930) until the 23rd year of Heisei (2011), see here for conversions.
The first table paints the familiar picture of a severely aging Japanese society.

Japanese population by age-band

Overall population (column 2, above) has slowed to stay around 127.8 million during the last 13 years. Recently 2 out of 10 people are over 65, set to increase as only 1 out of 10 people is currently under 14. In 1930 almost 4 out of every 10 people were under 14.

This second graph shows the main reason why the population is aging, and why it is projected to shrink to 95.2 million by 2050 - the birth rate in Japan (2nd column) has fallen from 32.4 per 1,000 people to 8.3 in 2011. This chart also shows in the 4th and 5th columns the marriage and divorce rates, which are decreasing and trending upwards respectively.

Birth, death, marriage and divorce rates in Japan

These charts show the main causes of death in Japan (left) and the main causes of food poisoning (right). After high incidences of tuberculosis in the early 1950s, up until the 1980s deaths from cerebrovascular causes such as stroke were the highest, since which point cancer (red line) and heart disease takes over. The food poisoning graph shows that reported cases (this graph is not about deaths) of Norovirus are by far the most common in Japan but that incidences of campylobacter and salmonella do also occur.

Including a short video, the afternoon was about hygiene and food-borne illnesses, and was hard to focus on attentively in the hot room, after lunch (maybe 20% of the attendees were sleeping at this point). There was some important stuff in here though, such as why and how to properly wash your hands - on a slightly related note I wish Tokyo would start providing soap in the public and train station loos!

The shokunineisei sekininsha test

Finally the test. As you can see in the image above, this was a 5-question multiple choice quiz that we were given 5 minutes to answer by writing the appropriate number on slips of paper. These were collected and quickly scored, but my impression is that you get the certificate from just having attended the seminar. No-one got zero points on the day I attended, in fact 70% got 5/5 questions correct. Including me, big swot I am ;).

Most of the mistakes made were with Q3

There is a lot of interesting and important stuff related to you during the day, but there is also a lot of very dry and lengthy reading aloud of laws and responsibilities. You'll be most comfortable if you can read a fair amount of kanji and follow most of what goes on, but much of the day reinforced my feeling that this training seminar is more to do with the Health Centers doing their part (we gave them a copy of their legal requirements so..) and making sure you know that you are responsible if something should go wrong, rather than ensuring that people who attend are fully aware of how to avoid something going wrong.

This probably shouldn't be the sole resource to inform the hygiene policy at your business. A good additional resource would be an online food hygiene course from your home country. Any certifications wouldn't be valid in Japan of course and some of the information will differ (for example regarding egg safety, the emphasis in the Japanese seminar was that only fresh eggs should be eaten raw, whereas in the UK the Department of Health recommends that raw egg recipes be avoided completely), but you'll learn more from extended self-study to protect your customers and livelihood than from a 1-day seminar.

Once you have the hygiene manager certificate it's yours for life without attending this particular seminar again. Once you've registered your business you will receive information from the Health Centre periodically about additional seminars on varied topics that your hygiene manager must attend during the life of your business. If you are an employee then your certificate goes with you to the various companies you work with during your food industry career anywhere in Japan.

So gosh, yes, I am now officially moving closer and closer to be able to legally run my own food biz in Tokyo. Quite scary/exciting!

Getting a food business permit - visiting the public health center

This week I got around to paying a visit to the Minato-ku public health center / みなと保健所 生活衛生センター / Minato Hokensho seikatsu eisei senta. A short walk from Azabu Juban and sandwiched between large Mita hospitals, the health center is in charge of inspections for food businesses, and deals with various other public health issues for the Minato ward area including disease control, pest control, hygiene, and food regulation.

On the 5th floor there is a long counter with stations for consultations in Japanese regarding food businesses - if your premises is in Minato ku this is where you will need to come to apply for an inspection in order to get your business permit. If you are at that stage already, there's more information on that process in my previous post.

I'm not at the space-hunting stage yet, but wanted to check a couple of things to help with planning my business model as the requirements might impact the kind of space I will need to look for.

I would like to have a multi-purpose space - which could be a cafe while also being a workshop for the bakery and orders, as well as allowing me to hold practical lessons - but I learned that a local bread school were not allowed to use their teaching kitchen as a commercial space, and so I wanted to know exactly why. It turns out that the problem is with who can enter the kitchen / 厨房 / chuubou - if I keep my kitchen quite separate from the café area through the use of a counter and a swing door for example, and do not allow customers or students into the kitchen, then I can use the café area outside business hours to teach. Of course this will mean I'll have to get creative with using tables as workstations and make sure only me and my staff ferry trays and things to the kitchen, but it looks like there may be a way to make this work, legally, in a small space.

This also means that if you are running a bakery from home in Japan, apart from your facilities meeting the confectionery business permit requirements, they will also have to be in what amounts to a second kitchen to be used solely for your business activities. The health center staff confirmed that a business permit will not be granted to a food business using their regular domestic kitchen because family members using the space and your own domestic food preparation presents a health hazard for a commercial food business.

Basic requirements for a food business permit

On the back of the application is a list of the basic requirements you'll need to meet, along with diagrams. I've done a rough translation here, but do check with your ward office as requirements are different for each area (these from Hiroshima are very nicely illustrated) and may change.

1. Building – made out of suitably durable material
2. Plan – walls and boards etc. made of suitable material and arranged appropriately for intended purpose
3. Floor – comprised of easy to clean and water resistant material
4. Interior walls – at least the bottom meter should be water resistant and washable
5. Ceiling and walls – made of easy to clean material
6. Ventilation – there should be separate ventilation for customer area and kitchen
7. Kitchen sinks – need to have at least 2 (of at least the dimensions in the 1st image below)
8. Hot water – to aid hygiene there needs to be hot running water
9. Staff hand-washing sink – need to be in the kitchen and in the visitor area (of at least the dimensions in the 2nd image below)
10. Hand sanitation – should be provided at the staff hand-washing sink (9)
11. Refrigeration – units need to be big enough to hold the required amount of chilled food appropriately
12. Temperature regulation – thermometers should be placed in the refrigeration/freezing units and in the kitchen area
13. Storage – there is shelving of adequate size to store the number and sizes of vessels required for the business 
14. Waste disposal – bins are of sufficient size and have lids
15. Cleaning equipment – have their own storage area
16. Changing room or locker – is outside the kitchen area
17. Customer area – should be positioned so as not to interfere with food preparation areas, and a toilet should be provided

Much of what they wanted to emphasise to me when I visited was about the sinks - that in addition to a staff hand-washing sink, there should be two kitchen sinks for a restaurant/cafe type permit, or one kitchen sink if it was only a confectionery business without eat-in areas, and that these all had to meet the specified sizes.

Since I was there, I took the opportunity to ask a few additional things. The staff who helped me were amused at how strict the international examples I came up with seemed to be - apparently there is no legal requirement in Japan for egg products to be brought above 71 °C, and there are no regulations about the weight of bread. Grease traps, which are a legal requirement for commercial kitchens in many countries are not legally required in Japan (at least, according to the staff I spoke to), but your building owner may want you to have one fitted, and it makes sense to adhere to best practice regarding waste fats, oil and grease disposal even if it isn't a legal requirement.

Finally, I checked but there are currently no resources available in English to help with the process, and all consultation is in Japanese. The staff at the Minato public health center said that other ward areas may provide this information, so if you are in another area it's worth asking!

Required Facilities for Opening a Food Business in Japan

Recently I've picked up my investigations into what kind of paper trail will be required in the opening of a small cafe/cake shop business in Tokyo. Each ward office has their own system, but by all accounts they are quite similar. I'm currently thinking it's likely I'll open up shop in Minato-ku, and so this post will look at the requirements laid out by the Minato-ku ward office in Daimon.

There are lots of fantastic areas in Minato-ku which would suit this kind of business - like Nishi Azabu, Azabu Juban, Minami Aoyama - and it would have the added advantage of coming under the jurisdiction of the same ward office as my residence. This might seem like a strange consideration, but since much of the paperwork involved in applying for and updating various certificates and permits, for private as well as business reasons, needs you to be physically present at the ward office... well, it'd be nice if I don't need to schlep from Daimon to Shibuya for example on a regular basis to process papers. And there is a kafkaesque amount (did I just write that?) of paperwork in Japan. To illustrate this, I came across this company who, in the interests of persuading you to contract their services, did a nifty little comparision of the required time and form-filling for setting up a business in Seattle vs. Tokyo. (21 forms versus 2 forms, people!) 

Ok plunging right in, here is the Minato ward office's "opening a new business" /  新規開店のとき page in Japanese, showing the procedure for applying to start a food business.

Roughly translated, once you've found your premises and before you do any building work, you're supposed to make an appointment with your local health centre / 保健所 / hokensho (for me it's the Minato hokensho seikatsu eisei centre / みなと保健所生活衛生センター) to look at a detailed plan / 平面図 you have prepared of your space and receive advice on anything that looks like it might need amending to pass the inspection. You'll be given a pack of documents containing your application form-filling mission.

You're to return the completed forms at least 7-10 days before your desired inspection date. When they carry out your inspection, the inspector will check that the property fits the details on your application, and that the health and safety requirements are met. You'll need your company stamp for your permit if you pass the inspection. I'm not clear whether you get the permit right away then, or whether there is further processing past that point.

The documents listed in the table on the Minato ward office page are as follows:

• 営業許可申請書(1通) / Application for business permit (x1)
• 営業設備の大要(2通) / Summary of required facilities (x2)
• 許可申請手数料 Application handling fee (14,000 JPY for a confectionery business + 16,000 JPY if you are also a cafe/restaurant type space),
• 登記事項証明書(1通) / Official copy of "certificate of registered matters" for your company (x1, less than 6-months old. Not clear at the moment if this is your incorporation certificate or a different one.)
• 水質検査成績書 / Certificate of water hygiene inspection test (less than 1-year old, copy ok)
• 食品衛生責任者の資格を証明するもの/ Certificate of designated food hygiene manager (copy ok)

Examples of the Japanese application forms can be found here. I presume these are the documents you get in your welcome pack at your first health centre meeting. 

The most complicated of the application forms is the "summary of required facilities" 営業設備の大要 (pdf) which looks like a check list that shows you are prepared from a health and safety view point. I had a go at translating it to English, here you go. (pdf)

Click to go to the pdf

When I do make an information-gathering trip to the health centre (done! read my post here), I'm going to see if they have official versions in English (nope), and whether they have a list of requirements, such as "toilet areas need to be ...metres away from food preparation areas" rather than leaving it for me to find out after making the plan that I needed another door, or another few metres.

I watched a film at last year's TIFF, called "A Better Life" (Une Vie Meilleure) where the characters cut corners and failed the inspection, leading to tragedy after tragedy as they spiralled into debt. Not worried at all.. no.. :)

It must be quite a nice job though, to be an inspector of new businesses just before they open. I'm sure you'd meet so many hopeful new business owners, eager to get started. I wonder though, if the rule among inspectors, like the inspectors who came to check the condition of my flat before I moved, is to be intimidating? Have you had an inspector experience for opening a business in Japan, or anywhere else? How were they, and did you pass? Or are you a premises inspector with tales of ridiculous lack of preparedness and ensuing tears?

Becoming a food hygiene manager in Japan

One of the requirements of opening a food related business in Japan is that you need to have a person who is the designated 'food hygiene manager' / shokuhin eisei sekininsha / 食品衛生責任者. My understanding is that if you are already a qualified chef, nutritionist (etc.) you can be given this designation fairly simply. Since I'm not already qualified, and since I'm planning to start this business alone I've been looking into the possibility of becoming a food hygiene manager as a foreigner in Japan.

The training takes the form of a 1-day seminar with sessions on relevant topics, ending with a short test to see that you've taken in the information given during the day. Yes, it's all in Japanese, but there is no guidance against foreigners applying, and on the Japan Food Hygiene Association's official website's FAQ they discuss non-Japanese people taking the test saying something like there shouldn't be a problem "as long as they have enough linguistic ability to pass the test, and have an alien card" (or the upcoming equivalent replacement of the alien card, I guess).

The seminars for Tokyo are held multiple times a month. You apply by post (application form) or directly at the health centre, specifying your top 3 choices of times and places to attend - it seems they get booked up. If all goes well on the day and you pass the test, you'll come away with the certificate there and then. You must then display it in an easy to see place on your premises. I'm going to see if I can spot and take pictures of some of them I see round and about town.

According to blogs from people who have attended the seminars, the test is supposed to be fairly simple. It's a multiple choice, so if your kanji reading skills are good and if you study up in advance I don't see why there wouldn't be a very good chance of passing. Since this is just a one-day thing it does seem to me that the real rationale behind this requirement is to designate the person to blame (fire?) in the event something goes wrong (^ - ^); 

There is a nice page here, with a sample test, along with explanations of the answers:

http://foodpia.geocities.jp/seika_2006/18seika/houki/houki.htm

And here is one of the questions, with a rough translation:

衛生法規問題

問１ 食品衛生法に基づく営業許可に関する記述で、正しいものはどれか。

1. 菓子製造業を営業しようとする者は、都道府県知事が定めた施設基準に適合しなければ営業許可が与えられない。
2. 菓子製造業の常業許可には、有効期限がないので、一回取得すれば施設がある限り営業することができる。
3. 菓子製造業を営業しようとする者は、住所地の市町村長の営業許可を受けなければならない。
4. 菓子製造業の営業許可を受けた者は、施設に必ず食品衛生管理者を置かなければならない。

Hygiene Law Questions

Q1 Based on food hygiene law, which of the following is correct regarding business permits?

1. Persons wanting to run a confectionery business will not be given a business permit if their facilities do not meet the requirements of the relevant authority.
2. A confectioner's business permit has no expiry date, so you can continue to operate as long as you have the facilities.
3. Persons wanting to start a confectionery business need to get permission from their local mayor.
4. A person who has a permit to run a confectionery business has to have a food hygiene supervisor at the facility.

The correct answer is 1. 

Hmm, it was a bit trickier than I thought it might be, because as I was thinking that 4 could also be correct. Reading more carefully though, it seems that the distinction is between a food hygiene sekininsha, and a food hygiene kanrisha. The kanji translates roughly as 'person responsible' in the case of sekininsha and 'manager' for kanrisha, but confusingly the most common usage of 食品衛生責任者 in English uses 'manager' for sekininsha already. Easier to think about it in Japanese I guess! The reason 4 is wrong then, is that although you need a food hygiene sekininnsha ('person responsible for') you don't need a food hygiene kanrisha ('supervisor' or official manager) when you're only running a cake shop or restaurant. Kanrisha are needed when you're manufacturing things like dairy products and meats, in factories I should imagine.

Aside from studying up for and taking the test, I also need to find out what the health and safety requirements are for opening food businesses in my area of Tokyo. That's one of my next tasks, and maybe it'll require a trip to the local Health Office. I'll keep you posted.