Review
HACCP: A re-emerging approach
to
food safety
Robert l.. Buchanan
7‘he tl;v,d an:dysis ~mtl criticat control point (HACCP) approach was originally developed by :I team at the PiHsbury C’ompany as a means of assuring the safety of foods prcxluced Ihr rhc (IS space program’. The presentation of ILWX’ P i’il he IV7 I US Nirtinnai C’ontkrcncr on J&d Protection? k d to encitcr> 0lt among food safety prokusional,s a:; they pereked the advantages of the approach. This was rcllcctcti in the rapid incorporat icon~rl’; ih~‘ Cl’ principles into rcgulationx for low-acid cannctl foods. lici.vvcver; after the initial tlurry of activity. adoption of IIACX.‘P into the Ltiiy operations ot’ li~rtl m;mufaclurcrr has hcct1 largely restricted 1~ Izr!i vidu~l Iargc corporations. During the intervening period. the concepts and rationale for employing HACCP have been slowly gaining acceptance throughout the food industry, and HACCP is reemerging in the 1990~1s the primary approach to assuring the safety of the food supljty. This is rellcctcd in the rcccnt r~commt:t~datinn of FIACCP hy or$aniLatirrns such :IS the National hGld6nty of Sciencrs [ISA,+, the intcrhational (‘otnn~ission ~~0 Micrcrhiologizt Spccificatic ns for I’onds (KMSF)” and ~hc Join’ US ikpwrment of Agriculture/i ic;rlth Education a~td Welfal-e National Advisory Committee on Microbiological Criteria for
Foods
(NACMCFY-7.
The
plannctf
implementation
oi
IIACCP was dcvclolrd. and has hecn largely used, by li,od microhi!)ll,~ists. However, it is not limited to controlliqg the microbiological safety of food since, being B systems approach, it citn be used to control the full range of physical, chemicai and biological factors that may affect the safety of a food product. None of the steps involved in ;I HACCP program are unique: it is the integrated nature of the method that BIIOWS usxs to rcsotirccs Ott key attributes, providing a c~tional, ct.5t-rtfeclivc means of ninintaining product I’ process itlv( Jvcs six slcps: hax~tl safety. m~cI iA(:(‘ an;ilysis. lhc itlcntific;ttioi~ 1,1’ criticid c:rurtrnl points ((X iI’s). the cst;rhiishrttcnt of <.‘CP criteria, thr, monitoring of C’c’Ps, the development of protocols for CCP deviatinns, and verification (Box I). One of the reasons why the adoption of the HACCP approach has not been emhraccd by a wider segment 01 the tbod industry may be it% initial success in monitor+ the safety of low-acid canned foods. Microbiologically. the manufacture of low-a&j canned foods k a simple ‘control situation’. Only two gcnerai CCPs have to be controlled to ensure the safety of the product: the adequacy of the thermal treatment and the integrity of the container. Both parameters rran be monitored by rapid physical measurements. Such an approach is extremely straightforward compared with that required for monitormg the manufacture of products such as refrigerated, ready-to-eat meat. poultry, and s~;tift~od”~~,to which the application of HACCP is now being considered. The processes and practices involved in the manufacture, distribution and sale of such prodin ucts ax of a substantially higher level of complexity relation to holh the moans of l’onl.‘ol of the ptuduct and the dcvclopmcat trt’ an effeciivc HACCP program. The level of complexity is likely tn increase further as the US Department of Agriculture Food Safety and lnspcction Service initiates a HACCP-based inspection system for ovcrsccing the safety of raw meat and poultry destined for consumers in the USA. However, increased complexity does not invalidate the method. ‘Ihc alternative is the traditional approach, which does not deal effectively w,.rh many of the safety concerns currently faced hy the food industry. The ICMSF” attempted 10 deal with the dificrcnces in (he extent of control that can !r: exerkcd in different types of food systems by defining two types of critical control points: CCP, s and CCP?s. CCP,s ‘assure control of a hazard’, whereas CCP-.: *minimize but cannot assure control of a hazard’. Reviewing this concept, the NACMCF5 rejected the use of a two-class CCP system. 1 believe that this ,w;Is the more desirable approach, it1 that the two-&r systen, of CCPs gives the impression thitt the cn11troi of CCP,s is an ;thsc)luic gu:u6tntec of h:Ik!ty whereas, in tc.itlity. il. simply tnirritni/.cs a ri5k with a ,higber kvct of ahsurancc than that obtained by the control of CCP+ Even the implicatio~i of an absol& guarantee should be avoided when dealing with
Trends in Food Science’& T&chnc&y
,.
Ndvember
1990
..~..
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Box 1. Stepsin the implemenlalinn tif a HACCP profdm Hazard analysis ‘Thtb hd~ard’r arstx:iat4 with the production, dislribulion, 4~ and r~nsumplion of a product are determined, and the relative risks and cone qur~es rlf each hd>artl are =t~>.. ..~d. Typic ally, this is ,Iccomplishud hy .> team, familiar with the technical aspects oirhe product. whn
Conlinl;ency plans that detajl rhe protocols that must be foilowed when a CO is found to he out of control are an integral part of 1 HACCP program. The plans detail the steps that should be taken !o bring the CCP under control and the recommended disposition oi any product manufactured while the CCP was out of control. It is essential that such plans are followed rigorously when a deviation is dctecte& Verification This is the occasional collection oi supplemental information that is used to assessthe effectiveness of a HACCP system, in relation to t&h the adherence to statetl protocols and the detection of hazards that may not have ‘been anticipated by !he K!+’ hazx! ;x1j.;t~ Verificati+a rxld include the gatheringof d&r that would not normaiiy be coiiec~edduring routine, timely analyses oi CCP status. For example, microbiological tcsling, while generally not an effective means of directly monitoring CCP5, is often effective IS a tool ior verifirafion. V&cation can k carried odt internally or by independent pxtin :uch as auditorsor regulatoryagencies.
safety, Failure
particularly vmcn introducing a new ‘ystem. of 3 CCP, 10 ‘assure control of a hazard could
un.jusGfiahly discrcdit the HACCP approach if the means of control was psrccivcd as ahsolutu. Err example. the cooking limes/tcniperatures Ih;rt were relied on for the destruction ol vegetative cells of pathogenic bacteria were found to be substantially less effective when dealing with Lists-ia morroc~~c~,yenes, a microorganism that has recently emerged as an important foodbome pathogen. As Archer”’ apliy stated: ‘The greatest threat to food safety assurance comes from a of the Ilariability and a
HACCP programs, particularly on an industry-wide basis. The Iwo major areas of concern appeared to @z the incorporation of safety versus qu:llity attributes, arid mandatory IIACCP programs. ‘The issue of whether to limit HACCP systems to safety-related concerns or to include quality parameters or non-safety regulations (e.g. indicators of economic fraud) is one that seems to have evenly divided food safety professionals and regulators alike. For example, the ICMSF’ considered both safety and qualiiy in their discussions, whereas the NACMCF-’ spe~ificully mrorntncnded that ~~NXKI~ HACCP programs be restricted to safety concems. The latter recommendation has been tentatively adopted by the US Food Safety and Inspection Service in their planned implementation of a HACCP approach to meat and poultry inspection. In contrast, the HACCP program being consider-d by the US National Marine Fisheries Service’ incoprates a definition of hazards that includes economic fraud issues, such as species identification rend net weight. While there is no inherent scientific reaspq ;vhy EI s;ritems approach similar to HACCP could nut be ased to deal with quality-related issues, I am concerned that the incorporation of quality attributes into a processing plant’s HACCP program would dilute efforts to control attributes associated with public health. Considering the newness of HACCP to major portions of the food
1%
Trends in Fofd Science X Technology November 1990
‘.’
I
,.
Itwrc we a
r,umlr:r
ol
issucc, ;t\sclciated
with
the
01’ JTl~WkltO~y Ii.‘,ccP pR,cstnhli&c;Grlr debated by the toed gr&lJS. that are being aclively industry. The implementation of mandatory HACCP programs for produces with a relatively high degree uf risk has been recommended by a number of advisory bodies, including the National Academy of Sciences
potenriat
ITSA and IIK NACMC’I”. E!owever. there hw tan
rcb
lively little consideration of how to atlminisrcr s~rc’l prtrgrams and what ,I, do ‘pith cstahl~shmcnts that ate ntj~ using
R tI,%(WJ sysrenr. This is particularly importam when considering how ttr implement programs for pro& ucts Ihal contain :I signilicant pfnporrinn of component\ imported from other r:ounlries. Wcrenl NA.(‘MC:I: rectMn lentlali(JnS” pcrlnlrting IO cooked, D3ltl~~tO-~~ll crabmeat and shrimp deal cxlensivoly with the qucslion of how lo cnsurc that a ~hiilld~I0~~ ~IACX’F’ program does not favor either domeslic or impnrted products, and include a proposed approach for administering :i national HACCP-based systcrn f,r the manufacture of such products in the USA. Altelhpliilg to administer TIandalory HACCP programs has several challenges ihat may significantly Giirct~ihe way regulatory agm ies Interact with the food industry. One of the key atrribrxs of a HACCP system is that it focuses on’ partictihrs, dealing with the specifics of each production 13ne for each product in a processing plant. This requires !h:lr the primary empha-
sis for dcvelopin.g and validating a HACCP play must he tit the Factory level; rcpulat~~y agencies cannot mand,.llc it ‘generic’ HACCP sys~m and expect II trr be cffrctivc. The ~!ear irnplica~ic~n is thar re::ul:tmry agcncich will h
When considered in a wider arena. such concerns appear to be largely unfounded. The civil liabilities associated with food manufacture in the USA imply that, at least irl lhat country. manufacturers responsibilities include factors over which tfq have lilttc control, and eticrrtnp;rRs
a miclr
wider arc:) Ihan is aclivcty 1101 illcrcasc thr. rcsl’ort~ilrilitioi, of’ rrl:illllf;Iritirc:l.:s: il il: a tool IhL I”:tcili~8 13X% Ilirx rillitrnal mimcg?cmcnI (11 cxisling liabilities, fix tfx imeqration f,IACYI’ xhoultl pmvi(lc ;I t’mnwwk ol’ the various levclx of food safely regulation (tedcral, bi311:and local) into a consolidated whole. Clearly, a tiumbcr of issues have to he rcsolvcd as IIACC’P is applied to larger sc~;,mcn!s of the food in&l%-. tty. Howcvcr, !hc discussions ol. ihc cxpctt commit:zc\ arc cncournging. al~d indicate lhat IIIC system ih evol~.. ing to enhance ins applicability. making u good mnl cvcn %:cr. After I5 years, in which HACCP coocepts have graduaily gained the acceptance of rhe food industry, HACCP has emerged as an approach that can be used to manage the safety of the world’s food supply throughout the 1990s and into the next cemury. Wgtlli~lctl
by
Reierences
:Illy :prlcy.
I1ACXY’thw