Hi Smart 17.
I don't know the answer to all of your questions but you can certainly sell nuts loose. They do so in Lidl and in the zero waste stores. But I wouldn't allow consumers to help themselves if you can avoid it to prevent cross contamination risks and hygiene hazards especially as I'm assuming they're not in shell. And having worked in a shop when I was 18 who had pick and mix, you will get nibbers!
I once saw a nut shop with roasting machine in situ in Bulgaria. It was close to where I was staying so I passed it several times. Each time I passed it had a different nut running through. I wondered, perhaps as you are, how effective the cleaning from nut to nut was.
Legally you can of course validate the cleaning of something like that but they tend to have mesh belts which I would think could, on occasions, have small pieces of debris in them and that not being adequately cleaned out is probably more of a risk than the film that could be left from inadequate cleaning of the surface oils and proteins which will come out as the nuts are roasted.
There was some interesting research a while back about airplanes and nuts. To summarise, the main issue was through surface contact not through air. But that said, any vents from your roaster will probably contaminate nearby surfaces. So I'd put that out of the way if you can.
As for food licencing, you'd need to register with your local authority and make it clear they're producing on site. EHOs are generally pretty helpful.
Remember too that even items sold loose or made on the premises now need to be with allergen information since Natasha's law.
Of course what is legal isn't necessarily best practice. And there would be a few concerns I'd have:
Food safety:
- What you may not realise is people with nut allergies may not be told by consultants to avoid all nuts anymore as the more modern approach is that allergies can be acquired by not being regularly exposed. If you only sell direct to the public, you'd probably find consumers with any nut allergy wouldn't walk in so you will self select but you also don't know who people are buying for and if you are distance selling.
- Therefore you MUST control the cross contact with one nut and another. I would be tempted if they're only using the roaster to entice people in, why not only use it for one nut type? Vastly reduces risk.
But...
Health and safety
- ALSO the proprietor must consider the EHS risk to the consumers. The roaster will get hot so needs to be protected and away from inquisitive hands.
- Additionally that bad boy is going to be a significant fire risk. They will need to tell their insurer and it will probably bump up premiums. If there is a flat or similar above the shop I would definitely avoid. That's got "oops we left it on and then they couldn't escape" written all over it.
But I'm not a retail expert. I'm sure someone who has more experience in that area may know more.