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Thursday, 23 September 2010

チャーシューのネット販売は是か非か

Chashu近はお店に行かなくてもインターネットの通販で様々な物が買える時代になりました。僕はお店で現物を見て買う行為そのものが好きなので、実際にお店へ足を運んでみたり、なかったら何軒も探してみたりなんてことを楽しんでいますが、それでもなかなか手に入らないものや現物を見なくても分かっているようなものについてはネットで購入することが多いです。

 そんな中、ここ最近ラーメン屋さんのネット通販が顕著に売上げを伸ばしています。カップ麺や食品メーカーが作ったお土産ラーメンではなく、お店の厨房で作ったそのままの味を宅配するシステム。長い行列に並ばなくともお店の味が楽しめるとあって大人気です。そんな中、時々お店のチャーシューを販売しているラーメン屋さんがあります。自慢のチャーシューを1本丸々!といって、ラーメンに乗せるだけではなく、おかずの一品として、あるいはお酒のおつまみとして人気を呼んでいるようです。しかし、どうも僕が思うにほとんどのお店の場合ルール違反ではないかと思う部分があるのです。以下は僕が実際に調べたり直接聞いた範囲での話ですので、実際にはそうではないケースもあるかも知れません。あくまでも山路の私見である、その前提でご覧下さいませ。

 チャーシューというのはご存知の通り、豚肉を煮たり焼いたりして味付けして作るものです。これは食品衛生法上「食肉製品」というカテゴリに分類され、チャーシューを作ってチャーシューとして販売するには「食肉製品製造業」にあたり、当然製造販売には許可が必要になります。そして食肉製品製造業の免許取得は、厨房設備をはじめ成分規格なども厳密で、僕の感覚的には普通のラーメン屋さんで取得するのはかなりハードルが高く現実的に不可能ではないかと思うのです。というのは、僕がコンサルティングしているいくつかのお店でチャーシューのネット販売を計画した時に学んだことなのですが、厚労省や地域管轄保健所とやりとりしていく中で、販売は厳しいという結論に達したのですね。きっちり食品衛生法のルールに乗っ取ってチャーシューをネットなどで販売しようとすると、普通のラーメン屋さんの厨房ではまず無理なようなのです。

 細かい部分は割愛しますが、一つ例を挙げれば1つのお店で2業種以上の許可を取得する場合、原則として業種ごとに専用の部屋が必要だったりするのです。また汚染作業と非汚染作業について作業区域も明確にしなければなりませんし、冷凍冷蔵の設備もしっかりやらないといけない。そうやって厨房設備を作ろうとすると増築したり衛生面をクリアにしたりと偉いことになります。とあるお店の厨房は相当立派で大きなものでしたが、保険所的にはNGという答えが返って来ました。なので、普通のラーメン屋さんで普段作っているチャーシューを売るというのはどうやら厳しいと言えそうです。

 この問題について「惣菜扱いなので大丈夫」という見解が一部あるようですが、少なくとも僕が聞いた保健所ではチャーシューは「食肉=ハム、ソーセージ、ベーコンその他これらに類するもの」にあたるとの立場でしたし、仮にもしチャーシューが惣菜扱いなら対面販売しない限りは「そうざい製造業」としての資格が必要です。ちょっと話は逸れますが自家製麺のお店で生麺を販売するのも「めん類製造業」の許可が必要になるようです。同一食品でも営業形態の違い、売り方によって許可業種が異なることが多いのですね。そのあたりは酒税法における「酒類の販売業免許」にちょっと似ていますね。お店で飲む分を売るには問題ありませんが、テイクアウトを売るには免許が必要なのと一緒というか。

 ネット販売ではなく、店頭でチャーシューを売ったりする場合はどうなのか。これは色々な解釈がありますが、先ほどの「そうざい製造業」の話にも出て来たように、製造された場所での対面販売であれば「飲食店営業」の許可だけでOKということになりそうです。実は仕出し屋さんや弁当店って許可は「飲食店営業」なのだそうです。つまりその場所で作られたものをその場所で売っている分にはOK。お店で食べさせているものをテイクアウトさせている、という解釈になるのならば大丈夫なわけです。ですから、本店と支店があったとして本店で仕込んだチャーシューを支店で売るのはアウト。あるいはどこかの物販店に卸したりするのもアウト。ですから当然、インターネットの通販となればこれもアウト、ということです。

 それでもネットショップで出店しているラーメン屋さんでは普通にチャーシューを販売しています。上記のような背景を知っていて売っているとすればそれはそれで酷い話ですし、逆にそういうことを調べていなかったり、まったく知らずに売っていたとしてもそれは飲食業を営む資格がないと考えます。またそれを売らせているネットショップですが、ネットショップは飲食のみならず扱っている品目も多いですし、その部分は当然のことながら出店者任せになっているようです。確かにネットショップをテナントの大家だと考えればそこまで責任は持てないでしょうが、サイトの作り方ばかり指導するのではなく、そういうコンプライアンスの部分もアドバイスすべきだと思うのですが。

 ちなみに僕が聞いた保健所の見解では、ネットで販売する場合、自家製のチャーシューは単体でなくても、ラーメンの具として同梱して販売することもダメだそうです。麺とスープがあって、そこにチャーシューを別添の袋とかでつけてもダメ、ということ。そのチャーシューが食肉製造業の免許を取った加工業者に外注している場合はもちろんOKですが、それをクリアしていない自分の店の厨房で作ったものならばアウトということになると思います。

 そうなると、おそらく大半の人が最近流行の「有名店のストレートスープによる通販ラーメン」を思い浮かべると思います。そこにも自家製チャーシューが入っていますが、その場合もNGなのでしょうか?実はこの場合は合法でまったく問題がありません。なぜこの場合OKなのか。この場合、チャーシューはスープの袋の中に入っています。チャーシューは「スープの一部」として認識されますので食肉製品とは見なされなくなるのだそうです。そんなもん同じじゃないか、と思われる人もいるかも知れませんが、それがルールというか保健所の解釈なのです。余談ですが、この手の通販ラーメンを扱う最大手の担当の方とお話をしたことがありますが、無論常時保健所の方とやりとりをされて指導を仰いでいるそうですし、出品されているラーメン店の方に対しても衛生面での留意点について呼びかけたり、時には勉強会を開くこともあるそうです。食品を扱う以上当然の姿勢といえばそうですが、さすがだなぁと思いました。

 ただこの問題には一つ別の視点があります。そもそも上記のような通販ラーメン自体が「そうざい」に当たるという解釈です。某人気ラーメン店では保健所からそのような指摘を受け、専用の厨房を作り「そうざい製造業」の許可を取ったのだそうです。これに関しても自治体や保健所の裁量、場合によっては担当の人の判断如何の部分があるので何とも言えませんが、なかなか興味深い指摘ではあります。

 僕が実際に保健所に聞いたり通販に取り組んだお店の方とやりとりした中での結論は上述の通りですが、実際の運用などは保健所や担当の方の解釈や裁量によるようですので、チャーシューを販売しているお店で保健所からお墨付きを貰っているお店ももしかしたらあるのかも知れません。しかしここで大事なのは食物を扱う仕事をしている以上、まずはしっかりと調べて怪しい部分があるならば担当の保健所とやりとりをしてお墨付きを貰う努力が必要ということ。それが飲食をビジネスにする人の常識というかモラルではないかと思うのですが、ことラーメン屋さんにおいてはコンプライアンス意識が低い人がとても多いのです。僕がこういう話をすると「え、そうなんですか!」なんて驚いている。常識的に考えてまず食品を売る場合に食品衛生法とかと照らし合わせるでしょうに。

 以前、某大手ネットサイトでチャーシューを売っているお店があって、そこのご主人を知っていたのでこの話をしたことがあります。問題あるかも知れないから、保健所に相談するなりして調べた方がいいよと。その時にはやはり問題があるので販売をやめるようなことを言っていましたが、今でも普通に売っています。以前はチャーシュー単体で売っていたのを、今はラーメンなどとセットで売るようにしたようですが、ルールを拡大解釈しているのかどうかは分かりませんが、少なくとも僕の調べた限りにおいてはルール的に問題があるのは前述の通りです。

 きっと大半のお店の方はそのことを知らないし、知っている方はバレなきゃいいだろう?と、お伺いは立てず、通らばリーチ的なやったもん勝ち的な姿勢で売ってるお店がほとんどかと思います。しかし法を守るということは法に守られるということでもあるのです。もし万が一販売したチャーシューで食中毒などのトラブルが出た場合どうなるか。もし保健所の指導下に置かれた環境で、免許を得た上で製造販売していればまだダメージは少なく済みますが、ルール違反した環境下で食中毒でも起こそうものならもう申し開きが出来ないわけで。そういう想像力に欠けるというか、リスクマネージメント意識が足りない人がビジネスを、特に飲食ビジネスをやってはいかんと思うのです。

 誤解のないように書けば、お店のチャーシューを販売することそのものがいけないとか、不衛生であるとか、そういう話ではもちろんありません。食品衛生法という決められたルールに照らし合わせてビジネスをしているのかどうか、という一点のみの話です。個人的にはそのルールの方に無理があるよなぁと思いますし、保健所とかはお役所仕事ですから非現実的なことを平気で言います。でもそれは現実的じゃない、と言って無視して好き勝手やったらどこかの国と一緒です。現状のルールがそうである以上それを遵守しなければなりません。

 あらためて、飲食業を営む人には高いコンプライアンス意識が求められます。電話の出方が酷いとか名刺の渡し方を知らないなんて笑い話とは違い、これについてはマストというか最低限のスキルではないかと思います。(2011.12に一部加筆修正しました)

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