HACCP based procedures in small meat approved plants - Flexible?

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1 HACCP based procedures in small meat approved plants - Flexible? Javier Dominguez Deputy Veterinary Director & Head of Strategy Food Standards Agency United Kingdom Montenegro, Podgorica, 7& 8 March 2013

2 Food Safety Management Diary for Meat Producers The Diary 2

3 Pre-requisites and the Diary The Diary does not replace pre-requisite documentation, however, model documents are provided (e.g. maintenance plan, staff training records, etc) some of these could be kept in the Diary 3

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5 Pre-requisites and the Diary The Diary s 4-weekly review covers Structure Water supply Maintenance Cleaning Pest control Training Personal hygiene Etc. What are these if not pre-requisites? 5

6 6 Fco. Javier Dominguez Orive - Zagreb 26 & 27 Nov 07

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10 Flexibility - Records It is important to recognise the importance of establishing appropriate documentation and records which are proportionate to the level of risk Francisco Javier Dominguez Orive UK FSA 10

11 Flexibility - Records It is acceptable to do EXCEPTION REPORTING, i.e. record monitoring results only when there is a problem and the corrective action taken. The FBO may choose to record by exception using the Food Safety Management Diary for Meat Producers (the Diary ) 11

12 Flexibility Records Due Diligence Defence The FBO must realise that, if something goes wrong, records and other actions may help to proof that all reasonable precautions were taken and that all due diligence had been exercised This may also help OVs to encourage the application of HACCP based procedures by FBOs Remember that due defence defence is not a legal requirement. 12

13 The Diary Exception Reporting A traditional HACCP system relies heavily on recording that all procedures are followed correctly Quality control, Quality Assurance or HACCP team Can you expect the same level of documentation in a small/medium size business? They may choose to record when things go wrong and what has been done about it EXCEPTION REPORTING 13

14 Exception reporting - Examples Examples of what the FBO may decide to record Trimming of contamination - action taken Gastrointestinal spillages during evisceration Refrigeration equipment fails Supplementary training for staff (good hygiene practices) Knife sterilisers not working and actions taken Pest infestation problems - action taken Product exceed the temperature critical/legal limit - action taken 14

15 The Diary advice to the FBO How to use the Diary correctly? The diary could replace all monitoring records, e.g. a small slaughterhouse slaughtering few animals one day a week, but most require additional records Advise the FBO on how and when to use the Diary and how to incorporate it into their HACCP plan, including the principle of recording by exception. 15

16 Records The key is that food safety management records are written down SOMEWHERE!! It does not matter where it is on pieces of paper, in the diary, or stored electronically, but it is pointless to write things down twice! The FBO must produce the records in a way that allows the audit by the OV. 16

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18 HACCP plan Review Checklist 18

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20 20 Fco. Javier Dominguez Orive - Zagreb 26 & 27 Nov 07

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22 22 Fco. Javier Dominguez Orive - Zagreb 26 & 27 Nov 07

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24 Countryside

25 Egton Village

26 Egton Abattoir Since well before World War II, 83 years old!! Operates 3 days a week: Monday: 7:00 16:00 Tuesday: 10:00 16:00 Wednesday: 7:00 12:00 Throughput: Pigs: 25 (Mondays) Sheep: 25 (Tuesday and/or Wednesday) Cattle: 2-3 (Tuesday and/or Wednesday) Animals arrive from farms (10 miles radius) Customers: local butchers and farmers 26

27 Egton Abattoir

28 Hazard Analysis live pigs 28

29 Records Corrective action 29

30 Evisceration 30

31 CCPs 31

32 Review 32

33 @javiorive