The HACCP (Hazard Analysis and Critical Control Point) system of food safety management is detailed by the FSA (Food Standards Agency) as the most effective way for food businesses to ensure consumer protection.
The FSA believes that application of effective HACCP-based controls across the food chain will help reduce food borne disease, and is taking action to increase the awareness and application of HACCP in UK food businesses.
The HACCP system is internationally accepted as the system of choice for food safety management. It is a preventative approach to food safety based on the following 7 principles:
* Analyze hazards. Potential hazards associated with a food and measures to control those hazards are identified. The hazard could be biological, such as a microbe; chemical, such as a toxin; or physical, such as ground glass or metal fragments.
* Identify critical control points. These are points in a food's production--from its raw state through processing and shipping to consumption by the consumer--at which the potential hazard can be controlled or eliminated. Examples are cooking, cooling, packaging, and metal detection.
* Establish preventive measures with critical limits for each control point. For a cooked food, for example, this might include setting the minimum cooking temperature and time required to ensure the elimination of any harmful microbes.
* Establish procedures to monitor the critical control points. Such procedures might include determining how and by whom cooking time and temperature should be monitored.
* Establish corrective actions to be taken when monitoring shows that a critical limit has not been met--for example, reprocessing or disposing of food if the minimum cooking temperature is not met.
* Establish procedures to verify that the system is working properly--for example, testing time-and-temperature recording devices to verify that a cooking unit is working properly.
* Establish effective recordkeeping to document the HACCP system. This would include records of hazards and their control methods, the monitoring of safety requirements and action taken to correct potential problems. Each of these principles must be backed by sound scientific knowledge: for example, published microbiological studies on time and temperature factors for controlling food borne pathogens.
The History of HACCP
In the 1960s, the Pillsbury Corporation developed the HACCP control system with NASA to ensure food safety for the first manned space missions.
The HACCP system and guidelines for its application were defined by the Codex Alimentarius Commission in the Codex Alimentarius Code of Practice. This Commission implements the Joint Food and Agriculture Organisation (FAO) of the United Nations and World Health Organisation (WHO) Food Standards Programme.
Following an outbreak of E. coli 0157 in Scotland in 1996, The Pennington Report recommended that HACCP be adopted by all food businesses to ensure food safety. HACCP principles were incorporated into specific UK regulations, including those for the meat and seafood industries.
The British Retail Consortium Technical Standard for Companies Supplying Retailer Branded Food Products requires the adoption of HACCP. Retailer branded products now represent over 50% of all food sold in the UK.
The European Product Liability Directive (1985) introduced a burden of proof on manufacturers in respect of defences of defective product. It was noted that if best practices are not followed, then manufacturers would be unlikely to make successful defences in the event of liability claims.
The Food Safety Act 1990 states that it is an offence to:
- sell food which does not comply with food safety requirements
- render food injurious to health
- sell food which is not of the nature, substance or quality demanded
The Act describes a legal defence of ‘due diligence', which enables someone to be acquitted of an offence if they can prove that they ‘took all reasonable precautions and exercised all due diligence to avoid committing that offence’. Offences under the Act are liable to penalties of prison sentences of up to 2 years and/or unlimited fines.
Producers and suppliers in the food chain are being confronted with an increasing number of food safety standards, such as HACCP, British Retail Consortium (BRC) food and packaging, International Food Standard (IFS), EUREPGAP and Good Manufacturing Practice (GMP). There are also broader initiatives such as the Global Food Safety Initiative of the European Retailers. Many organisations need to be certified to several of these standards. However, this can lead to unnecessary costs and duplication of effort.
All these measures have not yet led to the harmonisation that everyone is waiting for. A large number of supermarkets still require certification against a specific standard, such as BRC or IFS, and will not accept any of the alternative approved standards.
The current EU Legislation (1995) states that Food Business must carry out a hazard analysis. However it makes no reference to physical traceability i.e. writing the results down. Therefore in replacing the current EC Directive 93/43 the new EU Directive EC No 852/2004 comes into effect on the 1st January 2006 requiring all Food Business operators to have in place, implement and maintain a permanent procedure/s based on the HACCP principles to include corrective action procedures where critical point events fall out of their limits.
The new legislation is needed to modernise, consolidate and simplify EU food hygiene legislation. It is intended to apply effective and proportionate controls throughout the food chain, from farm to fork.
Along side this legislation the British Standards Institute are developing a new standard, ISO 22000, to offer a good solution the problems highlighted. However, the acceptance of the stakeholders in the food chain and the will to use it as a basis to control food safety throughout the whole chain is a condition for success.
The important advantage of ISO 22000 is that it will be possible to use it throughout the chain. It will be internationally accepted and cover almost all of the requirements of retailer standards. The most important difference with standards like BRC and IFS is that ISO 22000 will not have a detailed list of requirements for good practices. But, being realistic, it is impossible to make a list that covers all such requirements for all organisations and all situations. However, ISO 22000 will require the implementation of good practices and expects organisations to define the practices that are appropriate to them. And, as a result, the standard makes references to several internationally recognised codes of practice relating to the Codex Alimentarius.
If the chain stakeholders, such as supermarkets, accept ISO 22000 as a basis for the implementation of management system requirements and need only a limited number of additional requirements, the large overlap between standards and certification assessments will disappear. And this will surely be of benefit to the food industry.
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