HACCP Implementation in the UK PETER HEWSON & JOANNA FULLICK Food Standards Agency 1 HACCP Implementation Topics:! E. coli Inquiry! HACCP in 2002! Hygiene Package! HACCP flexibility! Food safety diary! UK Meat Industry Guide! Conclusions 2 HACCP The intention behind HACCP is to improve the management of food safety. Some operators, perhaps especially those not under the watchful eyes of their customers (supermarkets or final consumers), take this responsibility less seriously. Unfortunately, sometimes this lack of responsibility has serious consequences 3 116
In September 2005 an outbreak of E. coli O157 affected more than 150 people, mostly children, in Wales. 31 people went to hospital and a 5 year old boy died. E.coli Inquiry E.coli butcher jailed for a year Friday, 7 September 2007, 15:41 GMT 16:41 UK A butcher has been jailed for food safety offences which led to a fatal E.coli outbreak in 2005. Cardiff Crown Court heard that a vacuumpacking machine, "wrongly used" for both raw and cooked meats, was the source of contaminated meat to schools. Public Inquiry website: http://new.wales.gov.uk/ecoliinquiry/?lang=en. 4 HACCP in 2002 Since 2002 under EC law 1 meat plant operators have been required to have food safety management procedures based on HACCP principles. 1. Commission Decision 2001/471/EC 5 HACCP in 2002 Challenges in small premises included: Poor prerequisites Time & resource needed Paper work burden People: literacy, language, turnover Limited HACCP/hazard expertise Nature of the business Few of these issues have gone away! 6 117
HACCP in 2002 FSA help to industry: Guidelines booklet Meat Plant HACCP Manual & CD Newsletters & implementation timeline Paid time for advice by OVs for small plants Training course & accredited qualification Workshops http://www.food.gov.uk/foodindustry/meat/haccpmeatplants/ 7 Hygiene Package " Reg 852/2004 (H1) Article 5 FBOs shall put in place, implement and maintain a permanent procedure based on the HACCP principles " Reg 852/2004 (H1) Chapter XII Training requirements for HACCP implementation " Reg 853/2004 (H2) Annex II Section II Objectives of HACCP-based procedures - acceptance of animals (ID, FCI, clean, disease area, health, welfare) " Reg 854/2004 (H3) Article 4 point 3 Official controls include audits of HACCP-based procedures 8 HACCP Flexibility 2005 Commission Guidance Annex I: Guideline on implementation of HACCP principles (Codex) Annex II: Guidance on HACCP flexibility GHP may be sufficient Use of guides Full HACCP 9 118
HACCP Flexibility: Guides GHP in place M a n u f a c t u ri n g Start CCP CCP End Generic guides may be appropriate in sectors: where there is a lot of commonality between businesses; where the manufacturing process is linear; and where the hazard prevalence is likely to be high, (e.g. for slaughterhouses as long as they are adapted to reflect company conditions). 10 HACCP Flexibility FLEXIBILITY INCLUDES: CCPs - generic guidance may include pre-determined CCPs. Critical Limits - not always a numerical value, especially where monitoring procedures are based on visual observation. Monitoring - may be a simple procedure, e.g. a visual observation. 11 UK Meat Industry Guide (MIG) http://www.food.gov.uk/foodindustry/meat/guidehygienemeat 12 119
HACCP Template (MIG) IMPORTANT: COMPLETE A COPY OF THIS PAGE FOR EACH PROCESS STEP - AMEND LOWER COLUMN HEADINGS AS APPROPRIATE PROCESS STEP: 1 NOTES A Critical Control Point (CCP) is a process step at which control is FOOD SAFETY HAZARDS CONTROL MEASURES essential to prevent, eliminate or reduce a hazard to an AND CAUSES acceptable level. The decision tree annexed to PART THREE Chapter 1 of the Meat Industry Guide may be used to help determine CCPs. If this process step is a CCP establish at least one critical limit, monitoring procedures and corrective actions for this step. If this process step is one of these:! Acceptance of animals (visual contamination)! Acceptance of raw meat (visual contamination / temperature)! Dressing Procedures (visual contamination)! SRM Remo val! Chilling/storage/dispatch (temperature) it is a control point required by the regulations. If not identified as a CCP, establish a legal limit, monitoring procedures and corrective actions for this step. LCP / CCP CRITICAL / LEGAL MONITORING PLAN CORRECTIVE ACTION PLAN Frequency Responsibility Procedures Responsibility LIMIT(S) Procedure Records Records 13 HACCP Template (MIG) IMPORTANT: COMPLETE A COPY OF THIS PAGE FOR EACH PROCESS STEP - AMEND LOWER COLUMN HEADINGS AS APPROPRIATE PROCESS STEP: 1 FOOD SAFETY HAZARDS AND CAUSES CONTROL MEASURES NOTES A Critical Control Point (CCP) is a process step at which control is essential to prevent, eliminate or reduce a hazard to an acceptable level. The decision tree annexed to PART THREE Chapter 1 of the Meat Industry Guide may be used to help determine CCPs. If this process step is a CCP establish at least one critical limit, monitoring procedures and corrective actions for this step. If this process step is one of these:! Acceptance of animals (visual contamination)! Acceptance of raw meat (visual contamination / temperature)! Dressing Procedures (visual contamination)! SRM Removal! Chilling/storage/dispatch (temperature) it is a control point required by the regulations. If not identified as a CCP, establish a legal limit, monitoring procedures and corrective actions for this step. 14 HACCP Flexibility FLEXIBILITY INCLUDES: Recording - in the case of visual monitoring procedures it can be acceptable to record results only when there is a problem and the corrective action that has been taken i.e. exception reporting. A diary can be a suitable method of record keeping. 15 120
Food Safety Diary One page lists what needs to be checked every day before, during and after operations www.food.gov.uk/mul timedia/pdfs/foodma ndiary2006.pdf 16 Daily diary Sign every day that procedures carried out correctly Record what went wrong and what was done about it Confirm opening, operational & closing checks 17 4 weekly review Follows industry guide chapters Record what went wrong and what was done about it Note continuing problems and reminders to staff 18 121
Conclusions A requirement to apply HACCP principles does not make poor operators take responsibility. The application of some HACCP principles (monitoring, corrective action, record-keeping) in operations without CCPs needs to be clarified. Each link in the food chain needs to control hazards as if it is the last link and not rely on later treatment e.g. cooking. Checklists and diaries can be effective tools for small operators who want practical help with food safety management. 19 MERCI 20 122