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Food Safety Risk Management – Making the best of HACCP

With the globalisation of trade, providing guarantees that your food product is safe is now an important part of business transactions. In recent years, governments and industry have been aligning their food safety requirements. While governments in the US and Canada are mandating written Hazard Analysis and Critical Control Points (HACCP)-based preventive control plans to ensure food safety, international food safety systems standards such as ISO22000 (2005) and Global Food Safety Initiative (GFSI)-benchmarked standards such BRC, SQF and FSSC22000 are gaining popularity worldwide.

Food Safety Management Systems (FSMS) are based on the Quality Management Systems (QMS) model and aim at controlling and preventing food safety risks using a process approach based on HACCP principles. Similarly to QMS, the system is designed and led by the organisation’s senior management. Under such a model, food safety is integrated in the business operations with top management providing adequate resources for monitoring, inspecting and auditing the food safety system for efficacy.
One of the advantages of a FSMS over a stand-alone HACCP program is that, once implemented, the system’s performance indicators are monitored systematically by top management. This is not necessarily the case for stand-alone HACCP programs managed by HACCP teams. Accredited third-party certification audits or regulatory audits also provide additional assurance that senior management is actively supporting the FSMS and that the HACCP plan is achieving the right results.

Another advantage of an FSMS is that critical activities are systematically reviewed as part of internal audits. In FSSC22000, for example, this requirement or “clause” is clearly defined as “Validation, Verification and Improvement of the FSMS.” It is reported that two critical activities often overlooked during the scheduled review of HACCP programs are the validation of product design (covered in HACCP Principle #1) and the verification of pre-requisite programs. In other words, HACCP Plan reviews tend to focus on process (HACCP principle #2-7).1

Product design refers to both the formulation of the food product and its packaging (intrinsic factors impacting food safety) and how the food product is affected by the environment (extrinsic factors). Proper product design will prevent biological, chemical (includes allergenic risks) and physical risks. The review of product design takes place during the validation of the HACCP plan. The second activity that requires attention is the verification of pre-requisite programs. The Food Safety Enhancement Program (FSEP)’s pre-requite programs include Premises, Shipping/Receiving/Storage/Transportation, Equipment, Personnel, Allergen controls, Sanitation and Pest Control and Recall. These programs form the foundation of the HACCP system and should be verified prior to the implementation of the HACCP plan and a minimum of once per year after HACCP implementation. A good case study illustrating the importance of reviewing product design and pre-requisite programs is the 2008 Maple Leaf listeriosis outbreak. One of the recommendations from the independent investigation (Weatherill report) that ensued was a policy that allowed for faster approvals by Health Canada of new food additives such as sodium acetate and sodium diacetate to be used in ready-to-eat (RTE) meats and other food products. These Listeria-fighting food additives are not meant to reduce plant sanitation activities but are part of what is referred to as a multiple-control strategy or “hurdle intervention” approach to food safety. In addition, the report identified that the source of contamination originated from poor sanitation of meat slicers. Equipment and Sanitation are two critical pre-requisite programs that provide a base for the HACCP program.

Organisations that wish to implement a HACCP-based program are sometimes surprised to realise that the successful implementation of pre-requisite programs represents a much larger effort in terms of time and resources than developing and implementing the HACCP plan. Following implementation, food safety programs or systems must be adequately maintained and reviewed to ensure food safety. A valid monitoring of Critical Control Points under HACCP depends on effective monitoring of Control Points identified in pre-requisite programs.

Besides actively preventing and managing food safety risks, HACCP-based programs or systems generate a paper trail which attests to the controls put in place. Record keeping procedures (HACCP principle # 7) produce records that show proof of “due diligence” in the event of a food recall.2 The legal validity of HACCP records lies in the fact that HACCP logs are reviewed and counter-signed by a competent and trained authority within the organisation. In the case of an FSMS, business resources are specifically allocated towards inspection and auditing activities. Audits and inspections are useful in that they provide a snap shot of how well employees are trained and how “complete” the pre-requisite and HACCP records are.

For industries where food safety risks are considered low and the implementation of a HACCP-based food safety system is voluntary, the organisation’s business strategy should dictate what type of written food safety program to implement.3 The choice of implementing pre-requisite program, HACCP or FSMS will depend on whether the organisation wishes to meet customer and marketing demands, improve internal processes and business systems, access international markets and integrate quality/food safety in the planning, manufacturing and logistics functions of the organisation. In the wine industry, for instance, product quality is the one important driver of customer acceptance. Wine is also, by law, required to be manufactured following good winemaking practices and must be safe to consume. Researchers have shown that a number of food safety hazards are associated with wine.4 The implementation of an integrated food safety and quality system makes sense for a winery that is looking to sell wine internationally.3
As discussed previously, FSMS follows the QMS model which makes it easy for an organisation to integrate QMS system such as ISO 9000 with HACCP. In addition, experts have shown that integration of a QMS with a HACCP-based system is not only more effective in meeting customer expectations but also results in less paper work.3

While it may take years to reap some of the greater benefits of a QMS or FSMS, such as the development of a food safety culture within the organisation or process efficiencies, a compliant or certified business will gain immediate benefits from achieving regulatory compliance and demonstrating “due diligence.” The organisation will improve its competitiveness and legitimacy in the international market place and will develop a good grasp of processes and technology. Strong from this significant learning curve, the business will be ready to tackle quality improvements, a requirement of all quality and food safety systems.

References

1- Sperber, W. H. (1998). Auditing and verification of food safety and HACCP. Food Control, 9(2), 157-162.
2- Food Safety Risk Management through HACCP – Purchasing liability insurance is no substitute
3- Aggelogiannopoulos, D., Drosinos, E. H., & Athanasopoulos, P. (2007). Implementation of a quality management system (QMS) according to the ISO 9000 family in a Greek small-sized winery: A case study. Food Control, 18(9), 1077-1085.
4- Christaki, T., & Tzia, C. (2002). Quality and safety assurance in winemaking. Food Control, 13(8), 503-517.

Changing food safety and regulatory landscape in the food and wine industry

Weatherill Report – 2011 

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