New Codex General Principles of Food Hygiene

New Codex General Principles of Food Hygiene

The Codex Alimentarius Commission has now published a revised Code of Practice (General Principles of Food Hygiene (CXC 1-1969) and its Annex Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application. The new 2020 revision covers General Principles of Food Hygiene: Good Hygiene Practices (GHPs) and the Hazard Analysis and Critical Control Point (HACCP) System.

According to the Codex Alimentarius Commission* the 2020 Revision of the General Principles of Food Hygiene (CXC 1-1969) and Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application this version of the code of practice: provides a common ground for the control of food safety worldwide and forms the basis for all other Codex hygiene texts and standards. The revision includes updates which will enable better application by food business operators, competent authorities and other stakeholders.

http://www.fao.org/fao-who-codexalimentarius/news-and-events/news-details/en/c/1310284/

The Codex Alimentarius, or “Food Code” is a collection of standards, guidelines and codes of practice adopted by the Codex Alimentarius Commission*. The Commission*, also known as CAC, is the central part of the Joint FAO/WHO Food Standards Programme and was established by FAO and WHO to protect consumer health and promote fair practices in food trade.

http://www.fao.org/fao-who-codexalimentarius/en/

Changes and the new Structure are Highlighted in the Table Below:

The major changes in CODEX HACCP 2020 are summarized in detail below:

  • A new requirement for a Food Safety Culture
  • New & Revised Definitions
  • Enhanced Training Requirements
  • Enhanced Good Hygiene System Requirements
  • Enhanced Good Hygiene Practice Requirements in Control of Operations
  • New Allergen Awareness/Management/Controls
  • A new requirement for Product Traceability
  • Enhanced Consumer Education Requirements
  • Changes in HACCP Principles and a new requirement for Validation of the HACCP Plan

It is somewhat disappointing the “CODEX” Decision Tree has been removed and no alternative offered although Codex HACCP 2020 still makes reference to using a decision tree or other approach to identify critical control points (CCPs) in Chapter Two

Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application, Section 3: Application, 3.7 Determine the Critical Control Points (Step 7/ Principle 2)

The good news is that the Joint FAO/WHO Food Standards Programme Codex Alimentarius Commission 43rd Session 2020 Report (CAC Report 43) highlighted the following with regards to the Decision Tree:

Some Members from the LAC region, while supporting adoption and referring to written comments, highlighted:

  • the importance of the decision tree for identifying critical control points (CCP) as it was essential for implementation of HACCP.

The Chairperson of CCFH clarified that work on the decision tree was currently at Step 2 of the procedure and would be considered at the next session. The decision tree is a useful tool for the application of the general principles document; and CAC43 adopted the revised GPFH at Step 5/8 and noted that work on the decision tree to identify critical control points (CCPs) will continue in CCFH so that once completed it could be included in the GPFH as an annex;

Codex HACCP 2020 Changes in more Detail

GENERAL PRINCIPLES – Management Commitment to Food Safety – Food Safety Culture

As part of Management Commitment to Food Safety the General Principles of Food Hygiene include a Food Safety Culture Requirement:

Fundamental to the successful functioning of any food hygiene system is the establishment and maintenance of a positive food safety culture acknowledging the importance of human behaviour in providing safe and suitable food.

Definitions

The two definitions sections in the previous version have been combined and extended. There are new definitions included for Acceptable level, Allergen cross-contact, Competent Authority, Contaminant, Contamination, Food business operator (FBO), Food Hygiene System, Good Hygiene Practices (GHPs), Prerequisite Programme and Significant hazard. Other changes are that Validation has been changed to a new definition Validation of control measures and the definition of Verification has been changed from the application of methods, procedures, tests and other evaluations, in addition to monitoring, to determine compliance with the HACCP plan to whether a control measure is or has been operating as intended.

Training

There is enhanced guidance for training to ensure that personnel have competence appropriate to the operations they are to perform.

RATIONALE: Training is fundamentally important to any food hygiene system and the competence of personnel.

There is guidance that: personnel tasked to perform any activities used in food control should be trained adequately to ensure that they are competent to perform their tasks and are aware of the impact of their tasks on the safety and suitability of the food. Systems should be in place to ensure that food handlers and personnel associated with the food business, such as maintenance staff, remain aware of all procedures necessary to maintain the safety and suitability of food. Records should be kept of training activities

Training programmes to be considered as appropriate to a person’s duties:

Elements to take into account in determining the extent of training required include: the use and maintenance of instruments and equipment associated with food.

In addition, for retail and food service operations, whether personnel have direct customer interaction is a factor in training, since it may be necessary to convey certain information about products (such as allergens) to customers.

Changes in Section 7: Control of Operation

Control of operation is achieved by having an appropriate food hygiene system in place. In section 7 there is new guidance for:

7.1 Description of products and processes

7.1.1 Product description

7.1.2 Process description

7.1.3 Consideration of the effectiveness of GHPs – When such increased attention on GHPs is insufficient to ensure food safety, it will be necessary to implement a HACCP system (Chapter 2).

7.1.4 Monitoring and corrective action

7.1.5 Verification

7.2 Key aspects of GHPs – Some key aspects of GHPs such as those described in Sections 7.2.1. and 7.2.2, could be considered as control measures applied at CCPs in the HACCP system.

7.2.5 Physical contamination

7.2.6 Chemical contamination

7.2.7 Allergen Management

CODEX 2020 states Systems for Allergen Awareness Control/Management should be in place including controls to prevent cross-contact.

Lot Identification & Traceability

The requirement for a traceability/product tracing system has been added in Codex HACCP 2020.

A traceability/product tracing system should be designed and implemented according to the Principles for Traceability/Product Tracing as a Tool within a Food Inspection and Certification System (CXG 60-2006), especially to enable the recall of the products, where necessary

Consumer Education

Consumer education guidance has been enhanced, programmes should enable consumers to understand the importance of any product label information and following any instructions accompanying products, and to make informed choices. In particular, consumers should be informed of the relationship between time/temperature control, cross contamination and foodborne illness, and of the presence of allergens.

Rather than an ANNEX, Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application is now Chapter 2

Changes in HACCP Principles

There have been some changes to the 7 HACCP Principles as per the diagram below:

Validation of the HACCP Plan

There is an addition guidance 3.11.1 for Validation of the HACCP Plan:

Before the HACCP plan can be implemented, its validation is needed; this consists of making sure that the following elements together are capable of ensuring control of the significant hazards relevant to the food business: identifying the hazards, critical control points, critical limits, control measures, frequency and type of monitoring of CCPs, corrective actions, frequency and type of verification and the type of information to be recorded.

Chapter 2 includes a new ANNEX, Annex 1 – Comparison of control measures with examples.

Overall the changes are emphasizing the importance of using Good Hygiene Practices to Control Hazards in much the same way as the FSMA Final Rule for Preventive Controls for Human Food https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-preventive-controls-human-food with a requirements for Monitoring, Corrective Action and Verification.

New Allergen Awareness, Management and Controls are more than overdue given the significant proportion of recalls worldwide that are due to incorrect labelling or allergen cross-contamination.

Maintaining Food Safety Standards During a Pandemic

Maintaining Food Safety Standards During a Pandemic

So this pandemic that started in March 2020 has really disrupted the lives of everyone, but one thing that hasn’t changed is the need for food safety. Food safety is a priority for customers, specifiers, brand owners and ultimately for consumers.

The challenges that the pandemic brought about were immediate. They occurred very rapidly, they were mostly unknown and they are ever changing. The word, unprecedented, was used a lot over the last year and it was no different in food safety. It was new territory for everyone involved in the food safety chain.

So the new challenges faced by food business operations included supply chain disruptions amongst other things, but it was actually people that were most affected and the importance of staff health was upmost. One major problem for businesses was the lack of staff availability due to staff illnesses, staff self-isolating, a lack of appropriate PPE and staff needing to organise child-care and home schooling.

In fact the lack of PPE was a major issue as there simply wasn’t enough to go around, and businesses couldn’t get it ordered and delivered quick enough. These kinds of issues were impacting sites and their food safety during this pandemic. Even problems with staff getting to work with restrictions in local and national travel, and especially international travel.

So there was a lot of uncertainty over how food sites were supposed to maintain standards. How do you deal with restrictions on who is an essential worker and who is not. Especially when these restrictions and changing all the time, and are different in different regions and dependant on what part of the country you are in.

This has lead to much confusion and some delays and disruption but of course the demand from the public was increasingly for safe food, especially in the retail sector. The pandemic also affected the ability of some prerequisite services to operate like pest control, waste disposal and cleaning agencies. They were in huge demand but with staff on furlough and other challenges the supply chains were challenged.

So the pandemic has created a very clear prerequisite for all of us and that is adapt how you operate your business or risk losing your business altogether. With all of that going on how were you expected to ensure effective oversight of your food safety management system when resources were compromised or, another way of looking at it, with less staff on site how do you ensure that your food safety systems are not at risk.

We know thousands of sites demonstrate their commitment to food safety by getting certificated to a GFSI scheme such as the BRC global food standard and maintaining that certification during the pandemic was not without its challenges.

We have observed over the last 12 months how businesses have adapted to ensure they have maintained food safety and maintained their certification during the pandemic. There are many lessons to be learned from this pandemic and there is still more to be encountered as the pandemic continues its course so of course, these lessons cannot all be covered in this article.

Just focussing on five main areas of discussion, the first is talking about how BRCGS adapted their approach to auditing to ensure all sites had options to maintain their certification where possible. Also going to talk about the use of ICT and digital platforms to help make the audit process feasible for both sites and auditors. We will also take one of the prerequisites, Pest Control Management and discuss some feedback that we had from two pest control companies on their lessons learned and then we can mention briefly some of the known conformances raised during the pandemic just to understand if we’re seeing differences across sites as a result of the new audit approach that were taken at BRCGS. Finally we can discuss the importance of having contingencies for training when face-to-face training is not possible.

In the face of all this, BRCGS adapted their approach to auditing to give sites a set of options to maintain their certification. There was also some good feedback received from the auditors and certification bodies which I will talk about too. BRCGS launched a suite of audit options that took in to account a number of issues like the GFSI’s position and requirements, the account brand, the retailer feedback, the ever changing and evolving local restrictions, and auditor availability. The maturity and the history of the site’s certification was also taken into account.

The following image shows the audit options available to businesses during the pandemic.

Announced  audits still continue to be used where it is possible for an auditor to conduct an on site audit. One thing that was learned very early on in the pandemic though was that unannounced audits were in fact an unnecessary burden on sites and they actually increased the challenges of both the certification bodies and auditors in arranging the audits. So BRCGS took the decision to temporarily suspend the unannounced audit program until at least the end of 2021. Where this happens the certification body will contact the site to arrange either an announced audit or blended audit. BRCGS will keep this temporary suspension under review and hope to restart unannounced audits as soon as possible. Sites will be given at least 3 months notice before they can be offered this option but if a site really needs an unannounced audit this can be carried out by exception. For example, if a customer requirement insists upon it or if perhaps it is part of a combined audit with another standard.

The blended audit can be carried out where an on-site visit is possible, but only for existing sites. This blended audit approach consists of 2 parts. The online remote assessment of some or all of the documents plus the shorter on site assessment. This requires a reduced amount of time for the auditor to be on site. This works well when an auditor can visit a country or region for a short amount of time before having to quarantine. This blended audit option will remain in the future for announced audits.

Where access to the site is not possible and the audit is due, the certificate extension could apply. There must be an existing valid certificate in place and this can be extended by 6 months based upon a risk assessment and review by the certification body. It is based on the controls that are already shown to be in place on the site.

Next option on the list is the full remote audit, which is not GFSI benchmarked. This is available for sites where the certificate extension has expired but it is still not possible for a visit to take place by an auditor due to Covid restrictions. It could also be used if a site does not need a GFSI recognized certificate. It involves a complete review of internal audit documents and usually a video audit of production and storage facilities.

Finally the BRCGS also offer a Covid-19 additional module and have published a separate assessment standard and may be used to provide assurances around the management of Covid-19 risks. It’s carried out like a remote audit and focuses on the areas of the food safety system which are potentially at a greater risk as a result of the changes forced to address over covert 19.

BRCGS offers plenty of options to allow sites and certification bodies to work together to ensure food safety assurances are still in place during the pandemic. However in order for these options, especially the remote and blended options, to be successful sites had to adapt their approach to the audit.

In the next article in this series we will be talking about some of the obstacles and issues that had to be addressed to carry out the various audit options available, and feedback on these from both the sites and auditors.