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Implementation of HACCP in food businesses: the way ahead
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l;bod Control, Vol. 6, No. 6, pp. 341-345, 1995 Copyright © 1996 Elsevier Science Ltd Printed in Great Britain. All rights reserved o'456-7135/95 $10.00 + O.(X)
N
0956-7135(95)00045-3
PAPER
Implementation of HACCP in food businesses: the way ahead John E. Ehiri, *t George P. Morris* and James McEwen § Food-borne diseases constitute an important public health problem in both developed and developing countries. Although their health and economic aspects are often obscured by insufficiency of data, available evidence on incidence and associated costs of medical care indicates that they are a major cause of morbidity, and a drain on resources. A joint WHO/FAO expert committee on food safety asserts that illness due to contaminated food is probably the most widespread health problem in the contemporary world, and an important cause of reduced economic productivity. Given the inadequacies of traditional approaches to food safety control, viz. inspection and end-product testing, there is a need to apply such other strategy of proven effectiveness as the Hazard Analysis Critical Control Points (HA CCP) system which has been described as the most viable means for the prevention of food-borne diseases yet devised. While there is an extensive literature suggesting the effectiveness of HACCP in preventing food-borne diseases, food operators have yet to embrace it with the anticipated enthusiasm. This paper examines factors that are likely to hinder wider acceptance and practical implementation of HACCP in food operations and discusses measures to overcome them. It is concluded that HA CCP training and education of food operators and food regulatory officials is a conditio sine qua non for the realization of the fullest benefits of the strategy. Keywords: HACCP, food safety control
INTRODUCTION The basic principle underlying the HACCP system is that it is possible to identify potential hazards and faulty practices at an early stage in a food operation. These can then be controlled in order to prevent them from constituting risks to the consumer or economic burden on the operator as a result of spoilage or recall *Department of Public Health, University of Glasgow, 2 Lilybank Gardens, Glasgow G12 8RZ, Scotland, UK. *Consultant in Environmental Health, Scottish Centre for Infection & Environmental Health, Ruchill Hospital, Bilsland Drive, Glasgow G20 9NB, Scotland, UK. §Henry Mechan Chair & Head, Department of Public Health, University of Glasgow, 2 Lilybank Gardens, Glasgow G12 8RZ, Scotland, UK. *To whom correspondence should be addressed.
of marketed items. This is a key advantage of HACCP over other reactive approaches such as inspection and end-product testing, where a negative result can only call for remedial action by the operator or regulatory authority but does not prevent the occurrence of the hazards in the first place. Preventing problems from occurring is the paramount goal underlying the HACCP system (NACMCF, 1992). While the effectiveness of the HACCP has been highlighted in a plethora of reports (e.g. Easter et al., 1994; Ehiri and Morris, 1994; Moy et al., 1994), food operators have not embraced the strategy with the anticipated enthusiasm. It is felt that legislation requiring food businesses to implement the strategy will provide the much needed impetus to secure its wider acceptance and practical application. However, the
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Implementation of HACCP in food businesses: Ehiri et a/.
inadequacies of legislation as a means of bringing about changes in environmental health behaviour have been highlighted in literature in the general area of environment and health (e.g. OECD, 1993). The concept of HACCP was brought into food legislation in the European Union (EU), following the adoption of the EU Food Hygiene Directive in June 1993. Under the directive, food business operators are required to identify steps in their processes and activities that are critical to achieving food safety, and to ensure that adequate safety procedures are identified, implemented, maintained and reviewed based on the principles of the HACCP system. The directive is being implemented in the UK through the Food Safety (General Food Hygiene) Regulations which took effect on the 15 September 1995. The Regulations require food businesses to assess and control potential hazards 'on the basis of the principles used to develop the HACCP system' (Department of Health, 1995). Although the implementation of a complete and fully documented HACCP system is not a mandatory requirement under the Regulations, especially with regard to small businesses, the Regulations have established HACCP as a key food safety management philosophy in the UK. In the absence of a legal compulsion, however, voluntary adoption of HACCP will require a full understanding of the strategy, the procedures to implement it, and the benefits of its application. In the following sections, an account of factors likely to hinder wider acceptance and practical implementation of HACCP in food businesses and suggested steps to overcome them is presented. Limited understanding of the HACCP strategy among food operators There is evidence which suggests that most managers in the food industry have limited understanding of the principles and application of the HACCP strategy. A recent study which evaluated HACCP implementation in Scotland, reports that over half of the food operators sampled were not aware of the strategy (Ehiri and Morris, 1995). It is of vital importance that available information on principles and application of HACCP are effectively communicated to those whose duty it is to act upon them. Targeting information about HACCP on mainly experts, academics and regulatory bodies, while many managers in the food industry (especially small businesses) remain unaware of the strategy, and of the procedures to implement it, is likely to lead to a situation where the strategy is seen by many food operators as an approach, the knowledge and skills of which rest only with specialist private consultants. The unfortunate tendency is that many food operators will rely solely on such consultants to develop HACCP schemes that may be unrealistic in practical terms. An important point which has to be noted when communicating HACCP to those who should implement it, is the fact that it is neither a new approach, nor
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a new terminology. Neither the hazards addressed nor the preventive measures prescribed by the strategy are necessarily new (Bryan, 1988a). For example, there is considerable information on microbial, chemical and physical hazards which cause food contamination and food-borne diseases (e.g. Pierrson and Corlett, 1992; Cliver, 1990; Doyle, 1989; Jackson, 1990). Similarly, available data (e.g. Wall et al., 1995; Bryan, 1988b; Davey, 1985) indicate that most outbreaks/incidence of food-borne diseases occur as a result of food mishandling in homes or food establishments, including restaurants, catering businesses, canteens (in schools, hospitals, nursing homes, prisons etc.), convenience stores, or in street food vending operations. Among the most frequently cited causes are: •
•
• • •
inadequate cooking or re-heating; preparation of food far ahead of consumption, and inadequate temperature control during cold and hot storage of foods; cross contamination in food premises; use of contaminated raw materials; and infected food handlers.
Other factors which increase the risk of food contamination and food-borne diseases in developing countries include (Mortajemi et al., 1991): • • • • • •
use of untreated nightsoil for crop cultivation; poor standards of hygiene and lack of basic sanitation facilities; contaminated water supply; inadequate, or lack of, food safety infrastructure; climatic conditions favouring the multiplication of micro-organisms; and lack of food technology and quality assurance techniques.
The HACCP strategy is built upon the fact that it is better to concentrate safety control efforts on potential hazards and faulty practices as against the approach hitherto whereby time and resources are wasted mostly on issues which may not be critical to achieving safety, viz. cracked tiles, dirty walls and ceilings, blown bulbs etc. Given this premise therefore, it is clear that the concept of HACCP is mainly a shift of emphasis from structure and layout of food premises to raw material and process control. It clearly delineates ways in which already known procedures can be applied in a logical order to: (i) facilitate effective assessment of hazards and the severity of their risks; and (ii) establish priorities for control and monitoring at critical safety stages. To realize the fullest potential of HACCP, these basic principles underlying it must be effectively communicated to food operators at all levels, and to the general public. As Woodrow Wilson, one time president of the
Implementation of HACCP in food businesses: Ehiri et al.
USA (1913-21) rightly observed, 'the man who has the time, the discrimination, and the sagacity to collect and comprehend the principal facts, and the man who must act upon them, must draw near to one another and feel that they are engaged in a common enterprise'. One way by which information on HACCP can be made widely accessible to food operators at all levels of the food chain is to build hygiene certification training programmes around the concept of HACCP. An important advantage of this is that it ensures that data on high-risk hazards and preventive measures at critical control points are translated to training and education messages (Griffith and Worsfold, 1994; WHO, 1990). The use of HACCP data to inform food safety education is particularly relevant in situations where adequate food-borne disease surveillance programmes may be lacking as is often the case in many developing countries. The idea of HACCP is no longer new to many large food manufacturing/processing businesses, especially those that are major suppliers to leading food retailers who now encourage the application of HACCP by their suppliers. There is need for collaboration among food businesses, and with regulatory authorities, so that HACCP data and expertise available in these larger businesses can be used in the effective promotion of better understanding and implementation of the strategy in smaller ones. Concern about the applicability of HACCP to some operations
There is concern that the HACCP system does not readily lend itself to application in certain types of operations, especially small businesses and food service operations. For example, it is perceived that HACCP is not readily adaptable to the catering industry where a large variety of foods may be prepared in one operation, and with usually no uniform standard procedures for processes. It is argued (Sheard, 1986) that there is often a wide scope for variation and improvization in the food service sector, and that processes depend not only on the desire to meet customer demands, but also on prevailing circumstances and the skills of employees on duty at a particular time. However, these concerns are not only unfounded (both on scientific and practical grounds), but may equally be linked to limited understanding of the principles and applications of HACCP. Procedures for the application of the strategy to food service operations, street food vending operations, domestic kitchens and cottage industries have been identified by the WHO (Silliker et al., 1982), and clearly described by Bryan (1992). These procedures have been field-tested in a number of countries (e.g. Teufel et al., 1992; Bryan et al., 1992; Michanie et al., 1988). HACCP is, in fact, a commonsense approach to food safety control. It requires every one involved in food processing, manufacturing, preparation or service at whatever level of the food chain to reflect on the following questions:
(i) What is my process? (ii) What hazards are associated with the process? (iii) At what stages of the process are these hazards likely to occur? (iv) What is the likelihood that these hazards will constitute a risk to my customers, and what is the severity of such risk? (v) What must I do to prevent or control these hazards in order to ensure the safety of my customers? Once the hazards are known, where they occur identified, and the means to prevent or control them devised, the next important step is to implement the controls at those stages of the process where their application is critical to achieving safety, and to keep records of all important actions. An objective consideration of the above facts will surely concede to the applicability of HACCP in any operation, size notwithstanding. Most catering operations observe more or less similar steps, from purchasing/receiving of foodstuffs and ingredients through storage, preparation, cooking and chilling/freezing, hot/cold holding, re-heating to serving (hot or cold). It is simple to apply effective controls at critical control points in catering operations. For example, receiving of ingredients and foodstuffs is an important critical control point which can be simply monitored and controlled in catering operations. First, it has to be realized that checking temperature of supplied products (the usual practice in many catering operations) has little practical value if the products have already been contaminated from the supply point. For example, cooking may destroy bacteria or other organisms in supplied foodstuffs, but may not destroy toxins. The starting point, therefore, is to ensure that foodstuffs and ingredients are purchased from safe and reputable sources. Auditing of suppliers' (or potential suppliers') operations is thus, a vital element of monitoring at the receiving stage, since this is an important step on which decision for selection of new suppliers or suspension of those that do not meet specified safety criteria can be based. It is equally essential that criteria for accepting foodstuffs and ingredients are identified, documented and strictly followed on a daily basis. Permissible levels of temperatures can be set as appropriate; for example, frozen foods at -18°C (critical limit = -14°C); chilled foods at +5°C (critical limit = +8°C), etc. When such criteria are specified, it becomes easy to work towards them, and goods failing to comply with the critical limits can easily be identified and rejected accordingly and records of actions kept. Temperature and time of cooking, re-heating, cold and hot storage of foods are also important critical control points that can be easily controlled and monitored in a catering operation. Temperature control criteria for processes can be set and strictly worked towards; for example, all microbiologically sensitive foods (such as poultry and meat) to be cooked to an internal (geometric centre) temperature of at least 74°C for a given period of time etc. The most important thing, however, is that staff charged with the responsi-
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bility of monitoring temperature are trained in the tasks assigned and are made to understand the rationale for the controls. In fact, reports abound of instances where food handlers assigned the task of temperature monitoring and documentation continue to fill in temperature charts for refrigerators, days after they have been switched off at the mains (e.g. Ehiri and Morris, 1995). Such practices can be prevented to a large extent by adequate training and supervision. Considerable literature exists which provides guides on the identification and control of other important critical control points in catering operations, for example, sections of the ICMSF (1988) monograph, HA CCP in Microbiological Safety and Quality, the Campden Food and Drink Research Association (1991) Technical Manual No. 19, Guidelines for the Establishment of Hazard Analysis Critical Control Points, and other published materials, e.g. Bryan (1992), Bryan (1981) etc. Small businesses and even sole proprietorships can implement HACCP. In this case, the sole operator should undertake the planning, implementation and control, but the system has to be simple to reflect the operation. The important thing is that hazards are thoroughly identified, and that effective control and monitoring are applied at critical control points. Time and cost constraints
Time constraints and resource requirements of HACCP implementation have been cited as crucial factors influencing acceptance and implementation of the system by food operators. There is limited information on the constraints of economic factors on HACCP implementation. In a study of attitudes and opinions of food operators regarding HACCP implementation in the USA (Karr et al., 1994), over 40% of the respondents stressed that the regulatory authority has not presented convincing enough evidence of research to justify HACCP, and in particular, the costs of the strategy as opposed to its impact on food safety. The three major economic concerns highlighted by the respondents were: (i) high cost of laboratory facilities; (ii) high cost of training employees; and (iii) high cost of operating the system. It is perceived that it will be a further incentive if calls for the implementation of HACCP are backed with a clear demonstration of its advantages using evidence from cost-benefit studies on the strategy. Although the health of consumers should always be paramount in any debate on safety and the cost of its achievement, it is germane that these concerns are evaluated against such potential benefits as high confidence in safety of products, improved sales, increased profits, extended shelf-life of products etc. A shift from traditional approaches to the hazard and risk centred methods prescribed by HACCP will undoubtedly have some initial resource implications. Powell and Atwell (1994) report on a compliance cost assessment of implementation of the new UK Food Safety (General Food Hygiene) Regulations undertaken by the Department of Health (1995) where it is
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estimated that initial staff training will cost the food industry between £35-42 million. Huge as this may seem, it is pertinent to argue that the long-term benefits of having such an effective preventive strategy as HACCP will certainly outweigh the cost of its initial establishment. It is well acknowledged (e.g. Moy et al., 1994) that a functional HACCP system can save time and cost by focusing attention and resources not on generalities, but on those stages, procedures and practices that are critical to achieving food safety. In addition, it can facilitate optimal, cost-effective, hazard and risk specific approaches to inspection of food premises and operations. It also ensures optimal hygienic design and construction of food processing facilities by predicting potential hazards, CCPs, and recommending preventive measures. Moreover, once a HACCP system is in place, all that will be necessary is to review it periodically, especially when changes are made to suppliers, ingredients, staffing or equipment. Again, where HACCP is effectively implemented, product recall as a result of spoilage or contamination is likely to be minimal. Saving time and resources in this case, means getting things right in the first instance. Most importantly, HACCP implementation can help to promote foreign earnings from food trade by enhancing international acceptability of products. The W H O and the International Committee on Microbiological Specification for Foods (Silliker et al., 1982) have strongly advocated its application in both developed and less developed countries as a basis for the prevention of food safety problems. In the USA, the food code released by the FDA in 1993 now requires state regulatory officials to implement their programmes based on the principles of HACCP. The requirement for a mandatory application of HACCP to meat and poultry slaughtering and processing plants has also been proposed by the Food Safety and Inspection Service (FSIS) of the US Department of Agriculture (USDA, 1993). With the adoption of HACCP by the Codex Alimentarius Commission in 1993 (Codex, 1993), the system has gained international acceptance as a viable approach to the prevention of food-borne diseases. It is also being incorporated into the Codex Code of Practice for a number of food commodities. Developments in these directions mean that foodstuffs and ingredients from food businesses or countries which have not embraced HACCP will have to face increasing scrutiny and possible rejections, with consequent economic implications. Development of a HACCP system in food operations can be made simple and less time consuming by spreading the entire procedure over a period of time. A caterer for instance, can start with auditing of suppliers and establishment of control and monitoring procedures for receiving of products. This may only take a fortnightly meeting of the catering manager, chefs and designated food handlers for a given period of time. In addition, this will help to ensure that one step is functioning effectively before the next is embarked upon. To cut down costs associated with use of private consultants, food businesses may train some staff in the
Implementation of HACCP in food businesses: Ehiri et al.
practical skills of HACCP so that such staff can undertake in-house preparation of HACCP plans and training of line staff.
Cliver, D.O. (1990) Food-Borne Diseases. Academic Press, San Diego, CA
Codex (1993) Guidelines for the Application ~f the Hazard Analysis Critical Control Point (HACCP) System. Codex Alimentarius Commission, Rome, FAO
CONCLUSION Regulations requiring the implementation of the HACCP strategy in food operations are important, but will not be sufficient to prevent the occurrence of food-borne diseases unless food operators have a full understanding of the concept, and of the need to apply it. The place of hygiene training of food handlers as part of an effective hazard analysis system is explicit in the Revised Code of Practice on Food Hygiene Inspections (Department of Health, 1995). Thus, 'where there is a satisfactory hazard analysis system and/or adequate management controls, it should not be necessary for authorized officers to assess training levels in businesses, or levels of hygiene awareness among staff, other than as confirmation of the discussion about hazard analysis system with the food business proprietor or representative'. In a study of HACCP implementation in New York state, USA (Guzewich, 1986), it was found that both regulatory officials and food operators who had been reluctant to embrace the approach became enthusiastic after having actual experience of it. This underscores the need for HACCP training and orientation of not only food operators, but also food regulatory officials through workshops, seminars and course centre training. Training and education of regulatory officials in the principles and application of HACCP will also equip them better to undertake their role of verifying that HACCP plans developed by food businesses are correctly implemented and effective. Finally, since most food businesses have limited understanding of HACCP and of the procedures to implement it, it is necessary that every regulatory authority clarifies the goals of the strategy, and provides effective education and information to ensure uniformity in the application of its principles.
REFERENCES Bryan, F.L. (1981) Hazard analysis of food service operations. Food Technology 35: 2, 78--87 Bryan, F.L. (1988a) HACCP: what the system is and what it is not. Journal of Environmental Health 50: 7, 400--401 Bryan, F.L. (1988b) Risks of practices, procedures and processes that lead to outbreaks of food-borne diseases. Journal of Food Protection 51,663-673 Bryan, F.L., Michanie, S., AIvarez, P. and Paniagua, A. (1988) Critical control points of street-vended foods in the Dominican Republic. Journal of Food Protection 51:5,373-383 Bryan, F.L. (1992) Hazard Analysis Critical Control Point Evaluation: a Guide to Identifying and Assessing Risks Associated with Food Preparation and Storage. WHO, Geneva Bryan, F.L., Teufel, P., Riaz, S., Roohi, S., Qadar, F. and Malik, Z. (1992) Hazards and critical control points of vending operations at a railway station and a bus station in Pakistan. Journal of Food Protection 55:7,534-541 Campden Food and Drink Research Association (1991) Guidelines for the Establishment of Hazard Analysis Critical Control Points (HACCP), Technical Manual No. 19
Davey, G.R. (1985) Food-poisoning in New South Wales, 1977-84. Food Technology Australia 37, 453-456 Department of Health (1995) Food Safetv (General Food Hygiene) Regulations. HMSO, London Doyle, M.P. (ed) (1989) Food-Borne Bacterial Pathogens. Marcel Dekker, New York
Easter, M.C., Mortimore, S.E. and Sperber, W.H. (1994) The role of HACCP in food safety and quality. Journal of the Society of Dairy Technology 47: 2, 42-43 EC Directive 93/43/EEC on Hygiene of Food Stuffs (1993) Official Journal of the European Community No. L175/1. 19 July 1993 Ehiri, J.E. and Morris, G.P. (1994) Food safety control strategies: A critical review of traditional approaches. International Journal of Environmental Health Research 4: 4, 254-263 Ehiri, J.E. and Morris, G.P. (1995) Implementation o| HACCP strategy: A study of food businesses in Glasgow. Department of Public Health, University of Glasgow Griffith, C.J. and Worsfold, D. (1994) Application of HACCP to food preparation in domestic kitchens. Food Control 5: 3, 200204 Guzewich, J.J. (1986) State-wide implementation of a HACCP regulatory programme. Journal of Environmental Health 49: 3, 148-152 ICMSF (1988) Micro-Organisms in Food, 4 Application of Hazard Analysis Critical Control Point (HACCP) System to Ensure Microbiological Safety and Quality. Blackwell Scientific Publications, Oxford Jackson, G.L (1990) Parasitic protozoa and worms relevant to the United States. Food Technology 44: 5, 106-112 Karr, K.J., Maretzki, A.N. and Knabel, S.J. (1994) Meat and poultry companies assess USDA's hazard analysis and critical control point system. Food Technology 48: 2, 117-222
Michanie, S., Bryan, F.L., Fernandez, N.E., Vizcarra, M.M., Taboada, D.P., Navarros, O., Alonso, A.B. and Santillan, L. (1988) Hazard analyses of food prepared by inhabitants along the Peruvian Amazon River. Journal of Food Protection 51: 4, 293-302 Mortajemi, Y., Kaferstein, G. and Quevedo, F. (1991) Rationale for the education of food h~ndlers. Presented at the regional conference on Food Safety and Tourism for Africa and the Mediterranean, Tunis, 25-27 November 1991 Moy, G., Kaferstein, F. and Mortajemi, Y. (1994) Application of HACCP to food manufacturing: some considerations on harmonisation through training. Food Control 5: 3, 131-140 NACMCF (1992) Hazard analysis critical control points. International Journal of Food Microbiology 16: 1-23, National Advisory Committee on Microbiological Criteria for Foods, Washington, DC OECD (1993) Economic Instruments for Environment Management in Developing Countries. OECD, Paris Pierrson, M.D. and Corlett, D.A. (eds) (1992) H A C C P - Principles and Application. AVI, New York Powell, S. and Atwell, R. (1994) Food hygiene legislation - a new framework. International Food Hygiene 5: 3, 15-17 Sheard, M.A. (1986) HACCP and Microbiological Quality Assurance in Catering. Society of Food Hygiene Technology, Hertfordshire
Silliker, J.H., Baird-Parker, A.C., Bryan, F.L., Olson Jr, J.C., Sorrinsen, B. and van Schothorst, M. (1982) Hazard analysis critical control point in food hygiene. Report of a WHO/ICMSF Meeting on Hazard Analysis Critical Control Point in Food Safety, 9-10 June. WHO Document VPH/82.37, WHO, Geneva
Teufel, P., Bryan, F.L., Qadar, F., Riaz, S., Roohi, S. and Malik, Z. (1992) Risks of salmonellosis and staphylococcal food poisoning from Pakistani milk-based confectioneries. Journal of Food Protection 55:8,588-594 USDA (1993) United States Department of Agriculture announces food safety offensives. Release No. 0417.93, United States Department of Agriculture, Washington, DC
Wall, P.G., Adok, G., Evans, H., Le Baigue, S., Ross, D., Ryan, M. and Cowden, J. (1995) Outbreak of food-borne infectious intestinal disease in England and Wales 1992-1993. Proceedings of the Conference on Food-borne Diseases: Consequences and Prevention. Oxford Brooks University, Oxford, 3(/-31 March 1995 WHO (1990) Report of the Task Force on Integrated Approaches to Health Education in Food Safety. (WHO Document: HPP/FOS/ 90.3) WHO, Geneva.
Food Control 1995 Volume 6 Number 6
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l;bod Control, Vol. 6, No. 6, pp. 341-345, 1995 Copyright © 1996 Elsevier Science Ltd Printed in Great Britain. All rights reserved o'456-7135/95 $10.00 + O.(X)
N
0956-7135(95)00045-3
PAPER
Implementation of HACCP in food businesses: the way ahead John E. Ehiri, *t George P. Morris* and James McEwen § Food-borne diseases constitute an important public health problem in both developed and developing countries. Although their health and economic aspects are often obscured by insufficiency of data, available evidence on incidence and associated costs of medical care indicates that they are a major cause of morbidity, and a drain on resources. A joint WHO/FAO expert committee on food safety asserts that illness due to contaminated food is probably the most widespread health problem in the contemporary world, and an important cause of reduced economic productivity. Given the inadequacies of traditional approaches to food safety control, viz. inspection and end-product testing, there is a need to apply such other strategy of proven effectiveness as the Hazard Analysis Critical Control Points (HA CCP) system which has been described as the most viable means for the prevention of food-borne diseases yet devised. While there is an extensive literature suggesting the effectiveness of HACCP in preventing food-borne diseases, food operators have yet to embrace it with the anticipated enthusiasm. This paper examines factors that are likely to hinder wider acceptance and practical implementation of HACCP in food operations and discusses measures to overcome them. It is concluded that HA CCP training and education of food operators and food regulatory officials is a conditio sine qua non for the realization of the fullest benefits of the strategy. Keywords: HACCP, food safety control
INTRODUCTION The basic principle underlying the HACCP system is that it is possible to identify potential hazards and faulty practices at an early stage in a food operation. These can then be controlled in order to prevent them from constituting risks to the consumer or economic burden on the operator as a result of spoilage or recall *Department of Public Health, University of Glasgow, 2 Lilybank Gardens, Glasgow G12 8RZ, Scotland, UK. *Consultant in Environmental Health, Scottish Centre for Infection & Environmental Health, Ruchill Hospital, Bilsland Drive, Glasgow G20 9NB, Scotland, UK. §Henry Mechan Chair & Head, Department of Public Health, University of Glasgow, 2 Lilybank Gardens, Glasgow G12 8RZ, Scotland, UK. *To whom correspondence should be addressed.
of marketed items. This is a key advantage of HACCP over other reactive approaches such as inspection and end-product testing, where a negative result can only call for remedial action by the operator or regulatory authority but does not prevent the occurrence of the hazards in the first place. Preventing problems from occurring is the paramount goal underlying the HACCP system (NACMCF, 1992). While the effectiveness of the HACCP has been highlighted in a plethora of reports (e.g. Easter et al., 1994; Ehiri and Morris, 1994; Moy et al., 1994), food operators have not embraced the strategy with the anticipated enthusiasm. It is felt that legislation requiring food businesses to implement the strategy will provide the much needed impetus to secure its wider acceptance and practical application. However, the
Food Control 1995 Volume 6 Number 6
341
Implementation of HACCP in food businesses: Ehiri et a/.
inadequacies of legislation as a means of bringing about changes in environmental health behaviour have been highlighted in literature in the general area of environment and health (e.g. OECD, 1993). The concept of HACCP was brought into food legislation in the European Union (EU), following the adoption of the EU Food Hygiene Directive in June 1993. Under the directive, food business operators are required to identify steps in their processes and activities that are critical to achieving food safety, and to ensure that adequate safety procedures are identified, implemented, maintained and reviewed based on the principles of the HACCP system. The directive is being implemented in the UK through the Food Safety (General Food Hygiene) Regulations which took effect on the 15 September 1995. The Regulations require food businesses to assess and control potential hazards 'on the basis of the principles used to develop the HACCP system' (Department of Health, 1995). Although the implementation of a complete and fully documented HACCP system is not a mandatory requirement under the Regulations, especially with regard to small businesses, the Regulations have established HACCP as a key food safety management philosophy in the UK. In the absence of a legal compulsion, however, voluntary adoption of HACCP will require a full understanding of the strategy, the procedures to implement it, and the benefits of its application. In the following sections, an account of factors likely to hinder wider acceptance and practical implementation of HACCP in food businesses and suggested steps to overcome them is presented. Limited understanding of the HACCP strategy among food operators There is evidence which suggests that most managers in the food industry have limited understanding of the principles and application of the HACCP strategy. A recent study which evaluated HACCP implementation in Scotland, reports that over half of the food operators sampled were not aware of the strategy (Ehiri and Morris, 1995). It is of vital importance that available information on principles and application of HACCP are effectively communicated to those whose duty it is to act upon them. Targeting information about HACCP on mainly experts, academics and regulatory bodies, while many managers in the food industry (especially small businesses) remain unaware of the strategy, and of the procedures to implement it, is likely to lead to a situation where the strategy is seen by many food operators as an approach, the knowledge and skills of which rest only with specialist private consultants. The unfortunate tendency is that many food operators will rely solely on such consultants to develop HACCP schemes that may be unrealistic in practical terms. An important point which has to be noted when communicating HACCP to those who should implement it, is the fact that it is neither a new approach, nor
342
Food Control 1995 Volume 6 Number 6
a new terminology. Neither the hazards addressed nor the preventive measures prescribed by the strategy are necessarily new (Bryan, 1988a). For example, there is considerable information on microbial, chemical and physical hazards which cause food contamination and food-borne diseases (e.g. Pierrson and Corlett, 1992; Cliver, 1990; Doyle, 1989; Jackson, 1990). Similarly, available data (e.g. Wall et al., 1995; Bryan, 1988b; Davey, 1985) indicate that most outbreaks/incidence of food-borne diseases occur as a result of food mishandling in homes or food establishments, including restaurants, catering businesses, canteens (in schools, hospitals, nursing homes, prisons etc.), convenience stores, or in street food vending operations. Among the most frequently cited causes are: •
•
• • •
inadequate cooking or re-heating; preparation of food far ahead of consumption, and inadequate temperature control during cold and hot storage of foods; cross contamination in food premises; use of contaminated raw materials; and infected food handlers.
Other factors which increase the risk of food contamination and food-borne diseases in developing countries include (Mortajemi et al., 1991): • • • • • •
use of untreated nightsoil for crop cultivation; poor standards of hygiene and lack of basic sanitation facilities; contaminated water supply; inadequate, or lack of, food safety infrastructure; climatic conditions favouring the multiplication of micro-organisms; and lack of food technology and quality assurance techniques.
The HACCP strategy is built upon the fact that it is better to concentrate safety control efforts on potential hazards and faulty practices as against the approach hitherto whereby time and resources are wasted mostly on issues which may not be critical to achieving safety, viz. cracked tiles, dirty walls and ceilings, blown bulbs etc. Given this premise therefore, it is clear that the concept of HACCP is mainly a shift of emphasis from structure and layout of food premises to raw material and process control. It clearly delineates ways in which already known procedures can be applied in a logical order to: (i) facilitate effective assessment of hazards and the severity of their risks; and (ii) establish priorities for control and monitoring at critical safety stages. To realize the fullest potential of HACCP, these basic principles underlying it must be effectively communicated to food operators at all levels, and to the general public. As Woodrow Wilson, one time president of the
Implementation of HACCP in food businesses: Ehiri et al.
USA (1913-21) rightly observed, 'the man who has the time, the discrimination, and the sagacity to collect and comprehend the principal facts, and the man who must act upon them, must draw near to one another and feel that they are engaged in a common enterprise'. One way by which information on HACCP can be made widely accessible to food operators at all levels of the food chain is to build hygiene certification training programmes around the concept of HACCP. An important advantage of this is that it ensures that data on high-risk hazards and preventive measures at critical control points are translated to training and education messages (Griffith and Worsfold, 1994; WHO, 1990). The use of HACCP data to inform food safety education is particularly relevant in situations where adequate food-borne disease surveillance programmes may be lacking as is often the case in many developing countries. The idea of HACCP is no longer new to many large food manufacturing/processing businesses, especially those that are major suppliers to leading food retailers who now encourage the application of HACCP by their suppliers. There is need for collaboration among food businesses, and with regulatory authorities, so that HACCP data and expertise available in these larger businesses can be used in the effective promotion of better understanding and implementation of the strategy in smaller ones. Concern about the applicability of HACCP to some operations
There is concern that the HACCP system does not readily lend itself to application in certain types of operations, especially small businesses and food service operations. For example, it is perceived that HACCP is not readily adaptable to the catering industry where a large variety of foods may be prepared in one operation, and with usually no uniform standard procedures for processes. It is argued (Sheard, 1986) that there is often a wide scope for variation and improvization in the food service sector, and that processes depend not only on the desire to meet customer demands, but also on prevailing circumstances and the skills of employees on duty at a particular time. However, these concerns are not only unfounded (both on scientific and practical grounds), but may equally be linked to limited understanding of the principles and applications of HACCP. Procedures for the application of the strategy to food service operations, street food vending operations, domestic kitchens and cottage industries have been identified by the WHO (Silliker et al., 1982), and clearly described by Bryan (1992). These procedures have been field-tested in a number of countries (e.g. Teufel et al., 1992; Bryan et al., 1992; Michanie et al., 1988). HACCP is, in fact, a commonsense approach to food safety control. It requires every one involved in food processing, manufacturing, preparation or service at whatever level of the food chain to reflect on the following questions:
(i) What is my process? (ii) What hazards are associated with the process? (iii) At what stages of the process are these hazards likely to occur? (iv) What is the likelihood that these hazards will constitute a risk to my customers, and what is the severity of such risk? (v) What must I do to prevent or control these hazards in order to ensure the safety of my customers? Once the hazards are known, where they occur identified, and the means to prevent or control them devised, the next important step is to implement the controls at those stages of the process where their application is critical to achieving safety, and to keep records of all important actions. An objective consideration of the above facts will surely concede to the applicability of HACCP in any operation, size notwithstanding. Most catering operations observe more or less similar steps, from purchasing/receiving of foodstuffs and ingredients through storage, preparation, cooking and chilling/freezing, hot/cold holding, re-heating to serving (hot or cold). It is simple to apply effective controls at critical control points in catering operations. For example, receiving of ingredients and foodstuffs is an important critical control point which can be simply monitored and controlled in catering operations. First, it has to be realized that checking temperature of supplied products (the usual practice in many catering operations) has little practical value if the products have already been contaminated from the supply point. For example, cooking may destroy bacteria or other organisms in supplied foodstuffs, but may not destroy toxins. The starting point, therefore, is to ensure that foodstuffs and ingredients are purchased from safe and reputable sources. Auditing of suppliers' (or potential suppliers') operations is thus, a vital element of monitoring at the receiving stage, since this is an important step on which decision for selection of new suppliers or suspension of those that do not meet specified safety criteria can be based. It is equally essential that criteria for accepting foodstuffs and ingredients are identified, documented and strictly followed on a daily basis. Permissible levels of temperatures can be set as appropriate; for example, frozen foods at -18°C (critical limit = -14°C); chilled foods at +5°C (critical limit = +8°C), etc. When such criteria are specified, it becomes easy to work towards them, and goods failing to comply with the critical limits can easily be identified and rejected accordingly and records of actions kept. Temperature and time of cooking, re-heating, cold and hot storage of foods are also important critical control points that can be easily controlled and monitored in a catering operation. Temperature control criteria for processes can be set and strictly worked towards; for example, all microbiologically sensitive foods (such as poultry and meat) to be cooked to an internal (geometric centre) temperature of at least 74°C for a given period of time etc. The most important thing, however, is that staff charged with the responsi-
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bility of monitoring temperature are trained in the tasks assigned and are made to understand the rationale for the controls. In fact, reports abound of instances where food handlers assigned the task of temperature monitoring and documentation continue to fill in temperature charts for refrigerators, days after they have been switched off at the mains (e.g. Ehiri and Morris, 1995). Such practices can be prevented to a large extent by adequate training and supervision. Considerable literature exists which provides guides on the identification and control of other important critical control points in catering operations, for example, sections of the ICMSF (1988) monograph, HA CCP in Microbiological Safety and Quality, the Campden Food and Drink Research Association (1991) Technical Manual No. 19, Guidelines for the Establishment of Hazard Analysis Critical Control Points, and other published materials, e.g. Bryan (1992), Bryan (1981) etc. Small businesses and even sole proprietorships can implement HACCP. In this case, the sole operator should undertake the planning, implementation and control, but the system has to be simple to reflect the operation. The important thing is that hazards are thoroughly identified, and that effective control and monitoring are applied at critical control points. Time and cost constraints
Time constraints and resource requirements of HACCP implementation have been cited as crucial factors influencing acceptance and implementation of the system by food operators. There is limited information on the constraints of economic factors on HACCP implementation. In a study of attitudes and opinions of food operators regarding HACCP implementation in the USA (Karr et al., 1994), over 40% of the respondents stressed that the regulatory authority has not presented convincing enough evidence of research to justify HACCP, and in particular, the costs of the strategy as opposed to its impact on food safety. The three major economic concerns highlighted by the respondents were: (i) high cost of laboratory facilities; (ii) high cost of training employees; and (iii) high cost of operating the system. It is perceived that it will be a further incentive if calls for the implementation of HACCP are backed with a clear demonstration of its advantages using evidence from cost-benefit studies on the strategy. Although the health of consumers should always be paramount in any debate on safety and the cost of its achievement, it is germane that these concerns are evaluated against such potential benefits as high confidence in safety of products, improved sales, increased profits, extended shelf-life of products etc. A shift from traditional approaches to the hazard and risk centred methods prescribed by HACCP will undoubtedly have some initial resource implications. Powell and Atwell (1994) report on a compliance cost assessment of implementation of the new UK Food Safety (General Food Hygiene) Regulations undertaken by the Department of Health (1995) where it is
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estimated that initial staff training will cost the food industry between £35-42 million. Huge as this may seem, it is pertinent to argue that the long-term benefits of having such an effective preventive strategy as HACCP will certainly outweigh the cost of its initial establishment. It is well acknowledged (e.g. Moy et al., 1994) that a functional HACCP system can save time and cost by focusing attention and resources not on generalities, but on those stages, procedures and practices that are critical to achieving food safety. In addition, it can facilitate optimal, cost-effective, hazard and risk specific approaches to inspection of food premises and operations. It also ensures optimal hygienic design and construction of food processing facilities by predicting potential hazards, CCPs, and recommending preventive measures. Moreover, once a HACCP system is in place, all that will be necessary is to review it periodically, especially when changes are made to suppliers, ingredients, staffing or equipment. Again, where HACCP is effectively implemented, product recall as a result of spoilage or contamination is likely to be minimal. Saving time and resources in this case, means getting things right in the first instance. Most importantly, HACCP implementation can help to promote foreign earnings from food trade by enhancing international acceptability of products. The W H O and the International Committee on Microbiological Specification for Foods (Silliker et al., 1982) have strongly advocated its application in both developed and less developed countries as a basis for the prevention of food safety problems. In the USA, the food code released by the FDA in 1993 now requires state regulatory officials to implement their programmes based on the principles of HACCP. The requirement for a mandatory application of HACCP to meat and poultry slaughtering and processing plants has also been proposed by the Food Safety and Inspection Service (FSIS) of the US Department of Agriculture (USDA, 1993). With the adoption of HACCP by the Codex Alimentarius Commission in 1993 (Codex, 1993), the system has gained international acceptance as a viable approach to the prevention of food-borne diseases. It is also being incorporated into the Codex Code of Practice for a number of food commodities. Developments in these directions mean that foodstuffs and ingredients from food businesses or countries which have not embraced HACCP will have to face increasing scrutiny and possible rejections, with consequent economic implications. Development of a HACCP system in food operations can be made simple and less time consuming by spreading the entire procedure over a period of time. A caterer for instance, can start with auditing of suppliers and establishment of control and monitoring procedures for receiving of products. This may only take a fortnightly meeting of the catering manager, chefs and designated food handlers for a given period of time. In addition, this will help to ensure that one step is functioning effectively before the next is embarked upon. To cut down costs associated with use of private consultants, food businesses may train some staff in the
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practical skills of HACCP so that such staff can undertake in-house preparation of HACCP plans and training of line staff.
Cliver, D.O. (1990) Food-Borne Diseases. Academic Press, San Diego, CA
Codex (1993) Guidelines for the Application ~f the Hazard Analysis Critical Control Point (HACCP) System. Codex Alimentarius Commission, Rome, FAO
CONCLUSION Regulations requiring the implementation of the HACCP strategy in food operations are important, but will not be sufficient to prevent the occurrence of food-borne diseases unless food operators have a full understanding of the concept, and of the need to apply it. The place of hygiene training of food handlers as part of an effective hazard analysis system is explicit in the Revised Code of Practice on Food Hygiene Inspections (Department of Health, 1995). Thus, 'where there is a satisfactory hazard analysis system and/or adequate management controls, it should not be necessary for authorized officers to assess training levels in businesses, or levels of hygiene awareness among staff, other than as confirmation of the discussion about hazard analysis system with the food business proprietor or representative'. In a study of HACCP implementation in New York state, USA (Guzewich, 1986), it was found that both regulatory officials and food operators who had been reluctant to embrace the approach became enthusiastic after having actual experience of it. This underscores the need for HACCP training and orientation of not only food operators, but also food regulatory officials through workshops, seminars and course centre training. Training and education of regulatory officials in the principles and application of HACCP will also equip them better to undertake their role of verifying that HACCP plans developed by food businesses are correctly implemented and effective. Finally, since most food businesses have limited understanding of HACCP and of the procedures to implement it, it is necessary that every regulatory authority clarifies the goals of the strategy, and provides effective education and information to ensure uniformity in the application of its principles.
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Davey, G.R. (1985) Food-poisoning in New South Wales, 1977-84. Food Technology Australia 37, 453-456 Department of Health (1995) Food Safetv (General Food Hygiene) Regulations. HMSO, London Doyle, M.P. (ed) (1989) Food-Borne Bacterial Pathogens. Marcel Dekker, New York
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Silliker, J.H., Baird-Parker, A.C., Bryan, F.L., Olson Jr, J.C., Sorrinsen, B. and van Schothorst, M. (1982) Hazard analysis critical control point in food hygiene. Report of a WHO/ICMSF Meeting on Hazard Analysis Critical Control Point in Food Safety, 9-10 June. WHO Document VPH/82.37, WHO, Geneva
Teufel, P., Bryan, F.L., Qadar, F., Riaz, S., Roohi, S. and Malik, Z. (1992) Risks of salmonellosis and staphylococcal food poisoning from Pakistani milk-based confectioneries. Journal of Food Protection 55:8,588-594 USDA (1993) United States Department of Agriculture announces food safety offensives. Release No. 0417.93, United States Department of Agriculture, Washington, DC
Wall, P.G., Adok, G., Evans, H., Le Baigue, S., Ross, D., Ryan, M. and Cowden, J. (1995) Outbreak of food-borne infectious intestinal disease in England and Wales 1992-1993. Proceedings of the Conference on Food-borne Diseases: Consequences and Prevention. Oxford Brooks University, Oxford, 3(/-31 March 1995 WHO (1990) Report of the Task Force on Integrated Approaches to Health Education in Food Safety. (WHO Document: HPP/FOS/ 90.3) WHO, Geneva.
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