Food safety is of primary concern to the food industry and the appropriate organisation and documentation of this is key to regulatory and enforcement, due diligence and insurance requirements.
Each food business operator is responsible for food safety of every food imported, produced, processed or placed on the market at his level. The acronym HACCP (Hazard Analysis and Critical Control Point) denotes an internationally recognised method of managing food safety and protecting consumers. It is a requirement of EU food hygiene legislation that applies to all food business operators except farmers and growers.
All food businesses should regularly review their checks and measures to ensure compliance with this and other regulatory requirements, such as traceability, as part of their due diligence and crisis management processes.
A brief overview of the requirements of HACCP and Good Hygiene Practices (GHP) is set out below:
Hygiene and HACCP
The main legal act relevant to food hygiene is EU Regulation 852/2004, Article 5 of which requires food business operators to implement and maintain hygiene procedures based on 7 key HACCP principles:
- identify any hazards that must be prevented eliminated or reduced
- identify the critical control points (CCPs) at the steps at which control is essential
- establish critical limits at CCPs
- establish procedures to monitor the CCPs
- establish corrective actions to be taken if a CCP is not under control
- establish procedures to verify whether the above procedures are working effectively
- establish documents and records to demonstrate the effective application of the above measures
The HACCP approach provides a systematic way of identifying food safety hazards and making sure that they are being controlled on a day-to-day basis. This involves the following four steps: Plan, Do, Check, Act.
Hazards
The seven principles aim to focus attention on the identification and control of microbiological, as well as chemical and physical food safety hazards during production. The hazard assessment and the regular monitoring of critical control measures must be documented to provide the basis for audit checks and may provide evidence of due diligence in the event of legal action.
Conscientious implementation of HACCP principles by plant operators demonstrates their commitment to food safety; improves employee awareness of their role in protecting consumers, and emphasises management's responsibility for safe production.
Controls
Food safety management is achieved by a combination of good hygiene practices (legal requirements for which are in Regulation 852/2004) and operational hygiene procedures (legal requirements for meat production are in Regulation 853/2004).
Documentation
Documentation is an important part of good food safety management and providing evidence of this in practice. Documentation should be commensurate witht the nature and size of the food business. Records that show what the procedures are and that they are working should be stored and kept up to date. It is recommended that documents are easy to keep up to date to assist staff in achieving this.
Where visual monitoring is necessary, for example to ensure carcasses are free of visible faecal contamination, records can be limited to 'exception reporting'. This means making a record only when there is a problem or something unusual happens and noting the corrective action taken as a result.
Staff and training
Food business operators need an understanding of HACCP principles so that they can set up and maintain HACCP-based procedures. Staff should also be aware of the importance of the procedures they carry out in minimising the spread of food-borne hazards, which may be biological (e.g. E.coli O157 or campylobacter); physical (e.g. wool, metal); or chemical (e.g. veterinary medicine or cleaning product residues).
This article was written for Law-Now, CMS Cameron McKenna's free online information service. To register for Law-Now, please go to www.law-now.com/law-now/mondaq
Law-Now information is for general purposes and guidance only. The information and opinions expressed in all Law-Now articles are not necessarily comprehensive and do not purport to give professional or legal advice. All Law-Now information relates to circumstances prevailing at the date of its original publication and may not have been updated to reflect subsequent developments.
The original publication date for this article was 06/10/2010.