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.

How to Develop a Food Safety Culture

How to Develop a Food Safety Culture

A successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behavior that determine the commitment to, and the style and proficiency of the food safety management system. Senior management should plan for the development and continuing improvement of a food safety culture.

Senior management should be implementing a “It is how we do things here” food safety culture. This can be achieved by:

  • Leadership – starting from the top
  • Demonstrating visible commitment
  • Effective communication of company philosophy and policy
  • Ensuring there is accountability from the top of the organization to the bottom
  • Developing employee confidence and mutual trust
  • Developing reward schemes including ‘Employee of the Month’ award
  • Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity
  • Developing an action plan for the development and continuing improvement of food safety culture

To ensure success Senior Management should be directly responsible for food safety by ensuring adequate; organization and support, equipment and facilities, training and education of all employees, reviewing and auditing performance, and driving continuous improvement.

All employees should be empowered and individually responsible for the quality of their work, resulting in a continual improvement culture and working environment for all. Employees should be encouraged and required to notify management about actual or potential food safety issues and are empowered to act to resolve food safety issues within their scope of work.

The philosophy of Food Safety should be promoted throughout the organization and in particular the Food Safety Policy.

Communication processes for promoting food safety include:

  • Team briefings
  • Staff reviews
  • Daily Management meetings
  • Feedback mechanisms
  • Newsletters
  • Notice boards

 

Senior management should monitor and measure through reports and trend analysis the degree of development of the food safety culture by analyzing information including KPIs from:

  • Hygiene & Housekeeping Audits
  • Internal Audits
  • External Audits
  • Non-conforming products
  • Environmental monitoring
  • Review of implementation plan and numbers trained
  • Employee reviews
  • Staff surveys on values and culture
  • Customer Complaints
  • Staff Turnover
  • Staff Exit Interviews

 

All employees should undergo individual food safety culture development which can include:

  • Food Safety Policy
  • Food Safety Objectives
  • Food Safety Management System Overview
  • Job Descriptions
  • Job Training
  • Employee Briefing
  • Individual Objectives
  • CCP Controls – Training Procedures & Record Completion
  • PRP Controls – Training Procedures & Record Completion
  • Employee Review

 

A training matrix can be used for Food Safety Culture Planning:

 

Records of all training should be maintained, including those of induction, on-the-job, refresher and external training. Training schedules and records should be managed by Department Managers and where applicable include the following records:

  • Training register
  • Operator training review
  • Training matrix
  • Department training matrix
  • Individual Training records including:
    • Description of training
    • Skills description
    • Name of trainee
    • Confirmation of training
    • Date and duration of training
    • Trainer details
    • Verification that the trainer has assessed the trainee and found them to be competent
  • Identifying the competencies needed for specific roles
  • Reviewing and auditing the implementation and effectiveness of the training and the competency of the trainer with a view to taking action to improve the training.

 

Pest Management in the Food Operations

All food operations should have a proactive system for the prevention of contamination of products by pests that ensures there are effective controls and processes in place to minimise pest activity and ensure any pest infestation does not present a risk of contamination to products, raw materials or packaging.

Most organizations use Pest Control Association registered pest control contractor to implement a Pest Management programme and maintain the site free from pest contamination unless the organization employs a Pest Management Specialist.

A typical Pest Management contract agreement defines:

  • Company and contractor key contact personnel
  • Description of contracted services and how they will be completed
  • Term of the contract
  • Equipment and material storage specifications
  • A complete inventory of pesticides (must be approved by the regulatory authority for use in a food facility) detailing the safe use and application of baits and other materials such as insecticide sprays or fumigants
  • Emergency call out procedures
  • Records to be maintained
  • Requirement to notify facility of any changes in service or materials used
  • Service personnel including evidence of competency by exam from a recognized organization

 

The contracted Pest Management service should provide:

  • Site visits and inspections (including the periphery and internal and external buildings) based on a documented risk assessment including service records describing current levels of pest activity and recommendations for taking corrective actions.
  • The provision of a plan/diagram of the site showing the location of all pest control monitoring and prevention measures
  • Flying insect controls including fly killing units
  • Emergency 24-hour call-out service
  • Quarterly biologist inspection reports, visit and trend reports with recommendations
  • A current copy of the certificate of insurance that specifies the liability coverage
  • Spill control materials and procedures
  • Material safety data sheet information to ensure proper usage of pesticide chemicals.

 

A nominated manager or responsible employee should have overall responsibility for Pest Management on site so that Pest Management is manged within site control rather than relying on contractors.

Before agreeing to a contract the Pest Management Contractor should be subject to Supplier Approval to ensure that the contractor is qualified and the pest management programmes will comply with applicable legislation.

Copies of the Contract, Service Agreement, Pest Control Reports and Pest Management Contractor training records and qualifications should be held in Pest Control File on site. At the start of the contract a detailed survey of the entire facility should be completed by a qualified Field Biologist and the results documented and used to determine placement of Pest Control devices.

 

Exterior Bait Stations

Exterior rodent bait stations should be set up to deter rodents from entering the facility. Based on the detailed facility survey, exterior bait stations should be placed along the foundation walls on the exterior of the facility and along the site boundaries. Exterior bait stations containing rodenticides should be tamper resistant, anchored in place, locked, and labelled.

 

Interior Monitoring

Based on the detailed Field Biologist survey, interior monitoring devices should be placed in strategic sensitive areas specific to the rodent species, and other areas of possible pest activity. Interior rodent monitoring devices identify and capture rodents that gain access to the facility. Interior monitoring devices should be placed in areas where pest ingress is first likely to be identified and secured in position.

 

Elimination of Pest Habitat

The Field Biologist should identify any possible pest habitat around the site in the quarterly inspections. The nominated manager or responsible employee should take actions to remove or eliminate favourable conditions for pests including eliminating any rodent burrows, rodent runs and areas that provide harbourage or may attract rodents or other pests to the site or outside grounds.

 

Pest Management Reporting

Records of all Monitoring devices should be maintained, including services performed, to ensure that devices are properly placed and inspected to allow trend analysis of activity.

 

Pest Management Contractor reports include:

  • Signs of pest activity
  • Proofing requirements
  • Actions required by site
  • Type of Pest
  • Pesticide or material applied
  • Pesticide registration number
  • Rate of application or percent of concentration
  • Specific location of application
  • Method of application
  • Amount of pesticide used at the application site
  • Next action/follow up date
  • Date and time
  • Review and investigation of any missing baits
  • Signature of pest controller

 

Temporary placement of any pest monitoring devices for short-term monitoring should be documented in pest management action reports.

All personnel should be trained to identify potential issues caused by pests at induction. A pest reporting procedure should be in place such that any incident or sign of pest activity is immediately reported to the nominated manager or responsible employee and any potential product affected quarantined. The nominated manager or responsible employee maintains a log of pest sightings and the action taken by the pest controller.

The Pest Control Contractor should provide reports for all visits and advise on any trends and corrective actions.

 

Site Standards

Pests pose a major threat to the safety of food. Pest infestations can occur where there are breeding sites and a supply of food. Good hygiene practices should be employed to avoid creating an environment conducive to pests. Sanitation, inspection of incoming materials and monitoring can minimise the likelihood of infestation.

Buildings should be kept in good repair and condition to prevent pest access and to eliminate potential breeding sites. Holes, drains and other places where pests are likely to gain access should be protected or sealed. Screens for windows, doors and vents should be used to reduce the risk of pest entry.

The availability of food and water encourages pest harbourage and infestation. Potential food sources should be protected and stored above the ground and away from walls. Areas both inside and outside food premises should be kept clean. Waste should be stored in covered, pest-proof containers whenever possible.

Pest infestations should be dealt with immediately and without adversely affecting food safety or suitability. Treatment with chemical, physical or biological agents should be carried out without posing a threat to the safety of food.

Pesticides should not be used in food areas.

 

Pointers

As well as carrying bacteria, rodents can gnaw their way into materials and can cause substantial damage to buildings.

It is important to prevent access to pests, all access doors should be adequately proofed and/or screened.

Adequate measures in place to prevent birds from entering buildings or roosting.

Establishments and surrounding areas should be regularly examined by a competent person for evidence of infestation.

How to Reduce Your Complaint levels

How to Reduce Your Complaint levels

I have been involved in many projects to improve product quality and reduce food complaint levels. One of the best tools for indicating where action for improvement needs to be applied is by analyzing your complaint data appropriately.

Whilst you can identify faults in your factory your customers are your 100% inspection service so respect their feedback. Whilst all of your customers will not complain when they find a problem so you will not capture all of your product faults you will however identify trends.

The first step is to collate all of your complaint data. Your data should then be categorized by product type, complaint type and size. Analyzing complaints by numbers alone will not give you a real picture of your performance. What you need to know is the proportion of complaints you are getting for each product. By far the most practical way of doing this is by using the sales volumes to calculate the proportion of complaints you get for each product. Some people use weight or volume such as complaints per ton or 1000 Liters. My preference is to use complaints per million units.

So, you analyze your complaint data product type, complaint type and size per million units. From this data, you can easily spot the worst performing product lines.

You should then analyze the results for the worst performing products:

Are they all the same size?

Are they produced on the same filling machine/production line?

Is it the same type of complaint?

The answers to these questions will generate your corrective action plans. If products with the highest complaint levels are all the same size it could be a particular problem with that size of packaging. If it is all the same type of complaint then why are some product lines worse than others? If product from one particular production line is generating the highest number of complaints per million units then there must be a reason for this, it needs investigating.

You should compare product performance and if there are significant differences you should ask the question why? At this point complaint trends are useful. For example, when I worked with fresh pasteurized milk sour complaints were higher in larger sized containers. The reason for this was not related to the quality of the product but the fact they took longer to consume and spent more time in and out of the fridge. Such products would be targeted for improvement projects as opposed to corrective action to remedy a problem area.

A few words of caution though, your analysis needs to take into consideration the comparative value of the products and the market. People are more likely to complain about higher value products. Also, some retail customers are much better at reporting complaints from customers to the extent that I used to get 10 times the complaint levels from one particular retailer compared to another for exactly the same product.

My last tip the more data you analyze the better. In the past I have analyzed 3 year’s worth of data. Why? It gives a year on year performance so you can see if things have been improving or deteriorating and also it shows any effects of seasonality. For example, it is not reasonable to compare summer levels of “off” complaints on a fresh product with winter levels. This is why in the Northern Hemisphere I would compare August complaint performance with the complaint levels for August in the previous year.

The complaint analyzer that I have developed based on over 30 years’ experience in the food industry is included in our Food Safety Management System Implementation Packages.

How to implement a HACCP System

How to implement a HACCP System

Introduction

A HACCP System ensures that all food safety hazards, that may reasonably be expected to occur, are identified by this process and are then fully evaluated and significant hazards that have been identified are controlled so that products do not represent a direct or indirect risk to the consumer.

Resultant control measures are implemented through the HACCP (food safety) plan and where applicable Prerequisites/GMPs. Below is the process of establishing an effective HACCP System.

Prerequisite Programs/GMPs

Environmental and operational programs necessary to create an environment suitable to produce safe and legal food products should be established. Good Manufacturing Practices that should be implemented prior to Hazard Analysis include:

  1. Environment controls
  2. Construction and layout of buildings and utilities
  3. Layout of premises, including workspace and employee facilities
  4. Supplies of air, water, energy and other utilities
  5. Supporting services, including waste and sewage disposal
  6. Suitability of equipment
  7. Management of purchased materials
  8. Measures for the prevention of contamination/cross-contamination
  9. Cleaning and sanitizing
  10. Pest control
  11. Personnel hygiene
  12. Control of rework
  13. Product recall procedures
  14. Warehousing
  15. Product information and consumer awareness
  16. Food defense, bio vigilance and bioterrorism
  17. Training and Supervision

HACCP Preliminary Steps

1. Assemble the HACCP team, with at least one team member who is HACCP trained

A core multidisciplinary team should be utilized within the company to develop the Food Safety Management System. This core team should be supplemented by other staff when specific areas or products are being analyzed.

2. Make a description of the product, how it is processed or manufactured and the storage and distribution process

The HACCP team should document the end product characteristics, including legal food safety requirements, for the purpose of conducting the Hazard Analysis.

3. Identify the intended use of the products

The HACCP team should identify all possible users and consumers for each product and process category.
Vulnerable groups of the population may have to be considered. The HACCP team should consider the consumers of the product:

  • Is the product intended for babies or infants, children or adults?
  • Is the product intended for a wide spectrum of the population?
  • Is the product likely to be consumed by high risk groups?

4. Identify consumers of the products

The intended use should be based on the expected uses of the product by the end user or consumer.
Consider the intended use of the product:

  • Is the product intended as an ingredient for further cooking?
  • Is the product ready to eat?

5. Confirm the HACCP Scope

HACCP team should define the scope of the HACCP study. For each different type of product or process the HACCP team should define the scope of each HACCP plan, including the products and processes covered.

6. Consider the process and draw a flow diagram

The HACCP Team should construct flow charts for the products and process categories covered by the scope of the food safety management system. For each step in the flow chart the Food Safety team should describe the step and the control measures.

7.Confirm the flow diagram is correct by following the process

Flow charts should be physically confirmed by the HACCP (Food Safety) Team

HACCP principles

All processes used in the manufacture of food products and product groups should be subject to hazard analysis incorporating the Codex Alimentarius HACCP principles

Principle 1

Prepare a flow diagram of the steps in the process. Conduct a hazard analysis by identifying potential hazards. Assess likelihood of occurrence of these hazards and identify control options.

Principle 2

Identify the Critical Control Points in the process using the decision tree.

Principle 3

PEstablish critical limits, which must be met to ensure each Critical Control Point is under control .

Principle 4

Establish a monitoring system to ensure control of the Critical Control Point by scheduled testing or observations.

Principle 5

Establish the corrective action to be taken when monitoring indicates that a particular Critical Control Point is moving out of control.

Principle 6*

Establish documentation concerning all procedures and records appropriate to these principles and their application.

Principle 7*

Verify that HACCP is working effectively.

* Note that in CODEX Annex Guidelines Principle 6 and Principle 7 are verify then document, from a practical point of view I find it easier to document then establish verification procedures which should also be documented.

The following steps should be implemented in establishing the HACCP System:

 

Hazard Analysis

The HACCP team should conduct a hazard analysis for food safety hazards that are reasonably likely to occur for each product and process category. Taking the confirmed process flow diagram your HACCP team will now need to conduct a Hazard Analysis for each step to identify the threats to human health, which might be introduced into products as they are produced.

 

Hazards are predominantly grouped into three categories:

  • Biological (including microbiological)
  • Chemical
  • Physical

 

Allergens and radiological hazards may also need to be considered.

The next step in performing a hazard analysis is for the HACCP team to consider the list all of the hazards that may be reasonably expected to occur at each step.

This first step in identifying hazards which might be associated with your production process might be considered a “brainstorming” session.

 

For each Food Safety Hazard Identified, the acceptable level of the hazard in the end product is determined taking into account:

  • Regulatory requirements
  • Customer food safety requirements
  • Historic information
  • Scientific literature
  • Professional experience
  • Intended use by the customer

 

This hazard list is referred to as a Preliminary Hazard List and covers all hazards that could potentially occur in the product.

 

In conducting the hazard analysis, wherever possible the following should be considered:

  • The probability of hazards occurring
  • The severity of hazards by their adverse health effects
  • The qualitative/quantitative evaluation of the presence of hazards
  • Survival or multiplication of microorganisms of concern
  • Production or persistence of toxins, chemicals or physical agents
  • Conditions leading to the above
  • Customer complaints and previous internal non-conformances
  • Prerequisite programs that create hygienic and safe conditions

 

The HACCP team must then consider what control measures, if any, exist which can be applied for each hazard.

 

Each potential food safety hazard should now be risk assessed by the Food Safety Team to determine whether its elimination or reduction to acceptable levels is required to produce a safe product and also any controls required to achieve the acceptable levels.

 

Hazard Assessment

Each potential food safety hazard is risk assessed to determine whether its elimination or reduction to acceptable levels is required to produce a safe product and also any controls required to achieve the acceptable levels.

For each step grades of impact (severity of adverse health effects) and probability (likelihood of a food safety hazard occurring) need to be allotted and the combined matrix used to judge the significance and priority for elimination or minimization of the hazard.

 

First the Food Safety Team assess the probability of the hazard occurring and enter:

1 for Highly Unlikely

2 for Possible

3 for Likely

 

Then the Food Safety Team assesses the severity of the hazard and enters:

1 for Not Severe

2 for Could possibly cause illness

3 for Severe (Could be fatal)

 

Probability and Severity are Multiplied to give a Significance Score for the Hazard.

 

All of the food safety hazards that score a 9 are regarded as significant and form the Significant Food Safety Hazard List

 

Critical Control Points

HACCP Principle 2 is to identify the critical control points in the process. A CCP is a step in a food process at which control can be applied to prevent, eliminate, or reduce to acceptable levels a food safety hazard. Critical Control Points are established using the decision tree as the latest step in the flow path where controls can be effectively administered for a particular Significant Food Safety Hazards.

Note: You should still ensure that your control measure or prerequisite programs adequately control significant hazards even if not identified as controlled at CCPs. Each hazard on the Significant Food Safety Hazard list must be controlled by a control measure (or combination of control measures) that prevent, eliminate or reduce the hazard to the defined acceptable levels.

Critical Limits for each CCP

For each CCP, the appropriate critical limits are defined. A critical limit is the maximum or minimum value to which a physical, biological, or chemical hazard must be controlled at a critical control point to prevent, eliminate, or reduce to an acceptable level the occurrence of the identified food safety hazard.

Critical limits are exact and specify the limits required for food safety using the preventive measures put in place at CCPs.

A critical limit can be an upper limit where a set amount or level cannot be exceeded.

A critical limit can also be a lower limit where a minimum amount is required to produce the safe effect.

 

Validation of Control Measures

The HACCP team should confirm that the control measures (or combination of control measures) are capable of achieving the defined acceptable levels for each food safety hazard by validation activities.

 

Supporting validation documentation can consist of information from:

  • Regulatory limits or Industry Code of Practice Guidelines
  • Scientific journals
  • Documented challenge studies
  • In-house data

 

The HACCP documentation must identify:

  • The hazard or pathogen, including the level of hazard prevention or pathogen reduction to be achieved
  • The processing steps that will achieve the specified reduction or prevention

 

Establishing a Monitoring System for each CCP

A monitoring procedure should be established for each CCP to ensure compliance with critical limits.

The most commonly recognised monitoring procedures are from instruments but can be employee checks such as inspecting the documentation accompanying incoming materials.

Continuous monitoring is always preferred when it is available. This is normal when the process is continuous rather than by batch.

Monitoring should ideally provide information in time to make adjustments to ensure control of the process to prevent it exceeding the critical limits.

Ideally adjustments should be taken before a critical limit is breached.

 

Establishing a Corrective Action Plan

The corrective action to be taken when monitored results indicate a failure to meet a control limit is defined including responsibilities.

The corrective action plan needs ensure:

  • the cause of the deviation has been identified and eliminated
  • the CCP reverts to a controlled state after the corrective action has been taken
  • measures to prevent recurrence of the deviation have been established
  • product is quarantined until it is established that it is safe

 

Establishing HACCP Documents and Records

The HACCP team should establish procedures and records to ensure adequate food safety controls are in place. This includes documenting the HACCP plan which summarises all the critical control points, the monitoring procedures, critical limits, corrective actions, records and responsibility and authority.

 

Verification Planning

The HACCP team should define the methods, frequencies and responsibilities for verification activities (the simplest way to do this is by review of product analysis results and/or audit of HACCP documentation).

 

Review of the HACCP Plan

The HACCP team should review the HACCP plan and prerequisite programs at least annually and prior to any changes which may affect food safety.

 

References

“Hazard Analysis and Critical Control Point (HACCP) system and Guidelines for its Application” (Codex Alimentarius Commission, Geneva).

How to Develop a Food Safety Management System

How to Develop a Food Safety Management System

A Food Safety Management System should be planned, established, documented and implemented in order to ensure compliance with company, customer, regulatory and statutory requirements. Senior management need to confirm the scope of the Food Safety Management System including product categories, processes and activities conducted on by the organization.

 

Senior management need to be committed to the food safety management system and establishing and implementing, then fully communicating and supporting company policies, procedures and objectives. Senior management plan, establish, document and implement the food safety management system by:

 

  • Establishing and implementing a Food Safety Policy.
  • Communicating and Maintaining the Food Safety Policy.
  • Establishing and implementing Food Safety Objectives.
  • Communicating and Maintaining the Food Safety Objectives
  • Leading and supporting a food safety culture within the site
  • Conducting regular pro-active management reviews and communicating outputs.
  • Communicating commitment to satisfying customer requirements including food safety, quality and service
  • Supporting and planning the development and operation of the Food Safety Management systems.
  • Ensuring the food safety management system is maintained when changes are planned and implemented.
  • Establishing documentation required for the effective development, implementation and updating of the food safety management system and communicating pertinent information throughout the organization.
  • Providing the human and financial resources, and training, to manage the Policies and Objectives effectively.
  • Providing the infrastructure and work environment to manage the Policies and Objectives effectively.
  • Promoting an ethic of continuous improvement throughout the company.
  • Ensuring the strict observation of all food safety system procedures, the use of correct materials and equipment, recording and reporting of both standard and non-standard events and compliance with the company rules.
  • Providing the resources to audit the Food Safety Management system effectively.
  • Providing the resources necessary for the food safety team to effectively implement a Food Safety HACCP plan.
  • Carrying out regular Management Reviews.
  • Implementing and maintaining Corrective Action, Preventative Action and Continuous Improvement Plans.
  • Communicating effectively throughout the food chain from primary suppliers to end consumers including any relevant food safety information.
  • Providing the resource to ensure the company is kept up to date with all industry codes of practice, legislative, scientific and technical information appropriate to the products in the countries of raw material supply, production and product sales.

 

Due diligence

 

An effective Food Safety Management System demonstrates due diligence of the company in the effective development and implementation of safe food operations. The Food Safety Management System documents are supported by the completion of specified records for the monitoring of planned activities, maintenance and verification of control measures and by taking effective actions when non-conformity is encountered.