Food Safety

EXECUTIVE SUMMARY

Since its development in the late 1950’s HACCP has become an internationally recognised tool to help business operators attain a higher standard of food safety. In this time, it has gone from being a recommendation of good practice to being enshrined in legislation. The purpose of HACCP is to ensure a high level of consumer protection with regard to food safety throughout the entire food chain. The HACCP system, according to Codex Alimentarius Commission 2003 (Codex), ISBN 92-5-105106-2, is science based and systematic. The use of HACCP as a tool enables the assessment of specific hazards and measures for their control to ensure the safety of food. It also puts the focus and emphasis on prevention rather than relying on end-product testing.



Hazard Analysis and Critical Control Point system - HACCP

HACCP was initially developed by The Pillsbury Company for NASA and its manned space programme back in 1959. It was based on the engineering system Failure, Mode, Effect and Analysis (FMEA) and designed as an alternative to end-product testing as a means of ensuring the safety of food. In order to establish what is a potential hazard the questions; what could go wrong and why, must be considered. The possible outcome and likelihood of occurrence are considered at each stage in the process to produce food fit for consumption by consumers.
HACCP is a systematic approach that is applied throughout the entire food chain, range of applications. The application of a HACCP approach was made mandatory in the European Union by EC regulation 852/2004 in Article 5. This article states that food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles.
Successful implementation requires the full cooperation and commitment of food business employees at all levels along with relevant training at all levels. Training requirements should be considered prior to the implementation of a HACCP system. In addition, business operators must provide the competent authority with evidence of compliance and training. This can be achieved by using a training programme accredited by a body such as Royal Society for Public Health (RSPH).



Protection of public health

A European Community White Paper on food safety published in January 2000 stated that “The production and consumption of food is central to any society, and has economic, social and, in many cases, environmental consequences.” It also emphasised that health protection must always take priority over all other issues and that every link along the food chain, from farm to fork must be as strong as the others if consumers are to be adequately protected. The paper acknowledged the need to re-establish confidence in the safety of food supply following a number of crises within the food supply chain during the 1990’s. Bovine Spongiform Encephalitis (BSE) and antibiotic use (for growth promotion) and subsequent resistance issues were just a few of the problems during the 1990’s.
There were also several outbreaks of foodborne illness, such as the Eschericia coli outbreak of 19962 and others throughout the 1990’s some of which proved fatal for a number of vulnerable people. As stated by the World Health Organisation’s Codex Alimentarius Committee, (Codex), “people have the right to expect the food they eat to be safe and suitable for consumption”.
In 2003 Codex recommended a HACCP-based approach as a means to enhance food safety. On 1st January 2006 Regulation (EC) No 852/2004 became effective. Food businesses in the UN are now required by law to implement a food safety management system based on Codex HACCP principles.



HACCP in Action

From the 1st of January 2006, when Regulation (EC) No 852/2004 came into effect, HACCP (or a food safety management system based on HACCP principles) was no longer optional for many food businesses, but became mandatory. It is the responsibility of businesses to comply with the regulation and the responsibility of local authorities to inspect and enforce it.
There are many benefits to businesses using HACCP as a tool, among them are a reduced likelihood of food poisoning outbreaks, a reduction in customer complaints, standardised training and more importantly compliance with legislation. Evidence of a live HACCP system and proof of food safety compliance is often a pre-requisite to trading with some suppliers.
A properly documented HACCP system offers inspectors evidence that essential process conditions were under control throughout processing, making inspections easier.
Before HACCP can be implemented within a process there are various steps, or pre-requisites, that need to be in place. One of these pre-requisites is training. To successfully implement HACCP training is required for HACCP team members and senior management. Training of senior management is crucial to ensure awareness and commitment to HACCP throughout. Clearly not everybody requires the same training and making sure that training is specific to employee level and operational status is an important factor for consideration as is the quality of the training given.
There are many HACCP training providers but one that is suitably accredited must be selected to ensure integrity of the HACCP system to which the training will be applied. Codex states that “Those engaged in food operations who come directly or indirectly into contact with food should be trained, and/or instructed in food hygiene to a level appropriate to the operations they are to perform”, and acknowledges that training is fundamentally important to any food hygiene system, with inadequate training of all personnel being a potential threat to the safety of food.
Training programmes should be routinely reviewed in order to ensure they take into account any changes in legislation, technology, processing procedures or emerging pathogens.






Development Timeline

YEAR PROGRESS/STEP
1950’s /60’s The engineering system of Failure Mode and Effect Analysis (FMEA) was adapted to form the beginnings of the HACCP system.
1970’s HACCP presented to public at a food protection conference which led to a number of large food manufacturers starting to use the HACCP approach. (Not required by regulators nor promoted internationally at this stage.)
1980’s Greater uptake of HACCP approach due to the recommendation by US National Academy of Science and the International Commission for Microbiological Criteria for Foods.
1994


1995 Full international acceptance of HACCP with the World Health Organisation’s Codex Alimentarius Committee on food hygiene, publishing HACCP principles.
EC Directive on the Hygiene of Foodstuffs (93/43) implemented through the Food Safety Regulations 1995.


2006/08 Commission of the European Communities publishes a white paper on food safety proposing a new approach driven by the need to guarantee a high level of food safety.
European Commission Decision 2001/471/EC requires the application of HACCP principles in licensed fresh meat & poultry meat plants and lays down certain microbiological test procedures. Member states are required to implement the decision by 7th June 2002.
European Food Safety Authority established through Regulation 178/2002. Voluntary Codes of Practice introduce a requirement for HACCP systems within the feed industry part of the food chain.
Feed Additive Regulation (1831/2003).
Food Hygiene Regulation (852/2004) All businesses shall put in place, implement and maintain permanent procedures based on HACCP principles.
Food Hygiene Scotland Regulation 2006
Feed Hygiene Regulation (183/2005) HACCP systems must be registered/approved for all except primary producers (farmers). Personnel must be trained in hygiene issues and HACCP.
Feed businesses must register with local authorities and must develop and implement HACCP systems within their operation.

This decade saw the beginnings of encompassing the entire food chain from farm to fork with regulation on the feed being fed to animals which were intended for human consumption.
2010 In accordance with Regulation (EC) 853/2004, from January 1st 2010 Food Chain Information (FCI) is required for all Cattle, Sheep and Goats submitted for slaughter for human consumption. (Required for Poultry 2006, Pigs 2008 and Calves and Horses 2009)


The above list is not an exhaustive list of legislation pertaining to food and feed businesses, passed to date.

Conclusion

Successful application of HACCP requires the full commitment and involvement of management and the workforce. The international standard ISO 22000 requires that management provide evidence of its ongoing commitment to a food safety management system. The efficacy of any HACCP system is reliant on management and employees having the appropriate HACCP knowledge and skills1, therefore ongoing training is essential for all levels of employees. It is the responsibility of each individual business to ensure they have robust HACCP processes in place which are fully documented. Constant changes in processing technology, emerging pathogens and staff turnover necessitate continuous review of HACCP procedures and training requirements.
Attention should be given to the quality of training provided which should ideally be accredited by a body such as the Royal Society for Public Health (RSPH). Such accreditation allows a company to demonstrate that staff have undertaken training which meets appropriate standards to ensure highest level of food safety.