HACCP – achieving the food safety benchmark

As certainly as eating is a universal activity, food safety is everybody’s business. No person or sector of the food industry can afford to be complacent. After all, the stakes are high and any negligence is potentially fatal. With consumer needs and demands becoming increasingly sophisticated and companies being held both accountable and liable, regulators worldwide are pushing for more effective food safety management.

According to information contained in the World Health Organization document WHO/SDE/PHE/FOS/99.7, foodborne diseases are estimated to affect up to 10 percent or more of the industrialised countries population annually. Worldwide, the incidence of diarrhoeal diseases alone has been estimated at 4000 million cases per year. The WHO attributes this to a serious underlying problem that is traceable to poor food safety management practices. Beyond the biological illness estimate in the WHO document, there are chemical, physical and allergen-related food safety concerns. Health-related issues are also now being raised with regards to some intrinsic components of processed foods. Examples are the trans fat, cholesterol and glycemic load concerns.

The task of managing food safety is certainly gaining complexity, and a good methodology, collaborative efforts and practical tools are needed to effectively face this task. The proven food safety management methodology recommended by the international community is the Hazard Analysis and Critical Control Point (HACCP) system. Here, we look at some important things to remember about HACCP - its marks, merits and management and – as many establishments may not have the internal recourses to implement a complete and effective food safety programme that meets all of the emerging demands – look at the external assistance available to businesses.

Food safety goes much deeper than having compliant documentation. The worldwide community of food safety guardians and practitioners agree on this fact. Good documentation is extremely important. At the same time, the true measure of a programme’s effectiveness lies in its ability to consistently deliver safe products.

In spite of good intentions, several programmes fail at the point of consistency. Change from within or outside an establishment is the greatest cause of inconsistency. Situations change; there are new discoveries, occurrences and challenges. Employee rosters change, customers demand more, governments and regulatory agencies make new rules. All of these contribute to the constantly changing world of food safety management, to which programmes must keep up while remaining strong and effective.

Some food safety programmes may appear effective if they are examined only from the perspective of compliant documentation. Hence, food safety auditors are trained to look beyond the documentation. This leads to the obvious question: what constitutes a good food safety programme?

Sources of defining information
Guidelines for the development of effective food safety programmes are provided by agencies and organizations worldwide. Among the notable sources of information are: the WHO, the Food and Agriculture Organization of the United Nations (FAO) and national regulatory agencies such as the Canadian Food Inspection Agency (CFIA), the European Food Safety Authority (EFSA), the US Department of Agriculture (USDA) and the Food and Drug Administration (FDA). Other bodies like the World Food Safety Organization (WFSO), scientific associations, educational institutions and research centres are also excellent sources of technical information.

Most national and regional food safety requirements are based on Codex Alimentarius Commission (CAC) guidelines but, while these form the general foundation, specific country or regional demands may create the need for additional requirements that are unique. It is therefore advisable for processing establishments to obtain, understand and comply with the regulatory information that apply to their countries or regions of operation. Exporting companies also need to understand and comply with the requirements that apply to their export destinations.

Why HACCP?
HACCP is a scientific, systematic, documented, disciplined and auditable approach to food safety management. It is the industry’s adopted mechanism for assessing, implementing, managing, evaluating and demonstrating ongoing food safety control. HACCP is driven more by anticipation and prevention than by after-the-fact reaction.

The HACCP concept was pioneered in a collaborative effort by the Pillsbury Company and NASA in the 1960s. NASA wanted a programme that guaranteed the safety of astronauts’ foods. Pillsbury therefore introduced and adopted the HACCP approach as a way of providing the greatest safety, while reducing dependence on finished product sampling and testing. HACCP emphasizes the establishment of controls, starting from as far upstream in the process as possible. It involves operator control and/or continuous monitoring techniques at critical control points.

A good HACCP programme is based on scientifically valid facts. Food processing is simply not an art form any longer; today, every conceivable food processing operation can be approached scientifically. It is, in fact, obligatory for food processors to adopt scientific approaches, due to the commercial, legal, social, environmental and economic pressures of today. A structured and scientific approach to developing and implementing HACCP plans is also essential for the same reasons. The advantage of this, aside from ensuring the survival and credibility of the company, is the infused ability to effectively manage the established programmes.

Several models of the scientific approach are available. The CFIA model consists of a series of 10 forms. Form 1 describes the product or products for which the HACCP plan is being developed. Form 2 lists and categorizes the ingredients, while form 3 outlines the product flow diagrammatically and form 4 provides the processing plant or facility schematic. Form 5 lists all of the possible biological hazards, and form 6 the chemical hazards and form 7 the physical hazards. Form 8 offers the CCP determination tool with a sequence of ‘decision tree’ questions. Form 9 identifies the hazards that are outside of the operator’s immediate sphere of control and, finally, form 10 provides the operating plan. Each of these forms forces the documentation of specific details based on scientifically valid facts, which may be from scientific studies, test results, industry experience or investigations.

A good HACCP programme is backed by top management and facilitated by a team with an appropriate representation. In the simplest form, this team is made up of a leader or HACCP Coordinator and individuals who are knowledgeable in the six areas identified under the prerequisite programmes. The HACCP Coordinator is expected to have completed a certified training in HACCP development, implementation and auditing before assuming the role. It is also advisable for the other team members to be given some training on the principles of HACCP as well as on auditing concepts and practice.

A good HACCP programme uses efficient management resources and tools. It is possible to manually execute everything that has to do with HACCP. However, due to the ever-present threat of human error and lack of time, the use of good management tools is highly recommended. Several HACCP management systems are available on the market – the CPoint HACCP management software offered by Chartwell Consultancy Ltd is one example.

An effective programme is also subject to regular internal verification – not to be confused with the necessary external verification – which is driven more by the determination to continuously improve the programmes. This sustains the confidence of customers and regulatory bodies as an incidental yet crucial benefit. External verification, on the other hand, which is preferably executed by a reputable body, focuses more on the validity and reliability of the programmes. In this case, continuous improvement is the incidental yet crucial benefit.

A good HACCP programme is complete and continuously effective. This is achieved through the prompt and systematic elimination of deficiencies detected from both the internal and external auditing programmes. A consistent track record of product integrity and safety is maintained with a good HACCP programme. Where food safety programmes are poorly managed, the lucky streak of having no consumer complaints often runs out. History, in fact, shows that the absence of good food safety programmes can be fatal to both people and organizations. At the end of the day, the true measure of any food safety programme is the confidence and consistency with which it delivers safe products to consumers.

Benefits of enlisting external assistance
Some regulatory agencies offer food safety programme implementation assistance to companies. Assistance is also offered by organizations like the WFSO and other consulting companies.

In enlisting external assistance, many businesses focus only on the available internal resources and cost. Where there are internal resources to develop, implement and manage the programmes, these are often the only resources used. If not, the next choice is the least expensive. This may be a government regulatory agency that subsidizes the costs of programme implementation. Sometimes the decision to go with the regulatory agency is based simply on the fact that they are also the enforcers – the ‘killing two birds with one stone’ strategy. However, there are more things to consider.

Services offered by regulatory agencies are good, but they often stop at ensuring that the mandatory requirements are met. They seldom offer cost optimization and competitive advantages. In fact, most regulatory agencies deliberately avoid giving one company a competitive advantage over another within their jurisdiction. Since most regulatory agencies operate only within their jurisdictions, it is reasonable to expect that the fair advantage approach is the predominant modus operandi.

Well known organizations like the WFSO, on the other hand, are highly specialized, and provide instant credibility, availability of concentrated expertise and the marketing advantage of the working association. Even where there is internal expertise, it is both legally and logistically advantageous to enlist the assistance of a reputable external body.

In addition, as the WFSO constantly interacts within the sphere of emerging industry developments, it is a good source of current information on developments and trends. Beyond the provision of information, guidance and solutions, the WFSO also actively engages in the assessment of programmes and offers relevant coaching and other support services. Enlisting the help of organizations like the WFSO also maximizes the efficiency and benefits of the programmes, which brings with it the associated cost optimization benefits. It is certainly the fastest route to meeting and maintaining the marks of programme excellence outlined earlier.

Pursuant to maintaining such excellence, the WFSO offers a training programme on HACCP principles. It also offers the WFSO membership programme, the food establishments Food Care Award certification programme, food lead auditors certification programme, consultant registration and Food Processing Best Practise scheme. The WFSO is committed to interpreting and communicating food laws, regulations, standards and food safety management techniques in a language and through channels accessible to all levels of industry participants worldwide.

Simplicity and effectiveness are the key factors in achieving an efficient HACCP management system. The WFSO offers a cost-effective and easily implemented programme designed for food businesses to achieve a food safety (HACCP) benchmark in line with International criteria, incorporating a dedicated software ‘Cpoint’ and the international Food Care Award .

In addition to being the Canada/US Regional Representative for the World Food Safety Organization, Felix Amiri is the Director of Technical Service for Amiri Food Industry Support Services (AFISS).

For more information please email canAm@worldfoodsafety.org.
Links to the agencies and organizations mentioned in this article can be found on the AFISS website at http://www.afisservices.com/Links.html.

A good HACCP programme
Akin to the question of what constitutes a good food safety programme is the question: what is a good HACCP programme?

The answer is one supported by strong foundational programmes. An example are the prerequisite programmes recommended by the CFIA. Under the CFIA Food Safety Enhancement Programme (FESP), specific areas within a food processing or handling operation are listed as needing detailed attention. These include:

• Premises
• Transportation and storage
• Equipment
• Personnel
• Sanitation and pest control
• Product recall

The CFIA has outlined the detailed requirements for each of these areas to guide programme developers as well as make the programmes auditable.

A good HACCP programme is also based on the seven principles of HACCP. These are the systematic steps that must be followed in the establishment of HACCP plans. A facility is expected to:

Conduct a hazard analysis
Determine the critical control points
Establish critical limits
Establish a system to monitor control of the CCP
Establish the corrective action
Establish procedure for verification
Establish documentation and record-keeping

Merits of a good programme
Advantages of good food safety management programme include, but are not limited to:

• Consumer protection, confidence and loyalty
• Prevention of unnecessary legal liabilities
• Proof of due diligence
• Lower insurance premiums
• Cost effectiveness
• Increase in profitability
• Good company reputation
• Positive employee motivation
• Reduction in staff turnover rate

Poor food safety management, on the other hand, leads to:

• Food wastage
• Product-related illness
• Loss of customers
• Legal consequences
• Loss of reputation
• Possible closure of business