HACCP principles and microbiological testing

CFG 05/02

Consultation on the implementation of Commission Decision 2001/471/EC – the application of HACCP principles and microbiological testing in licensed meat plants

This Decision will affect some 1004 fresh and poultry meat plant operators licensed to produce meat for human consumption. They will be required to apply the seven principles of the Hazard Analysis and Critical Control Point (HACCP) system in establishing their regular check procedures. We also understand the Decision sets out certain standard procedures for microbiological testing in red meat slaughterhouses and cutting plants.

The consultation mainly concerns technical details of how the Decision will be implemented in England (with similar approaches being expected in Scotland, Wales and Northern Ireland). Foodaware is not in a position to comment on much of this technical detail. However, we have a number of comments concerning HACCP that we feel are pertinent to this consultation. These are set out below and we hope they will be of interest.

Foodaware has previously welcomed the Commission's proposals for a simplification of the regulation on the hygiene of foodstuffs and its harmonisation with the veterinary hygiene legislation in the context of the farm to fork approach to food and consumer health. In particular we have welcomed the traceability approach through the food chain as an essential tool in identifying food hazards quickly in order to protect consumer health.
While we have supported the implementation of HACCP, which gives food producers primary responsibility for food safety by using self-checking procedures and modern hazard control techniques, we are concerned that it has not, in itself, proven to be an effective hygiene control solution. For example, recent events and problems in the industry have shown that the motive of profit can encourage some to take short cuts and these put the public health at risk.
We see HACCP as an additional layer of responsibility for food safety and as a preventative measure, in addition to official food inspection. It is a tool to assist food businesses in achieving a high degree of food safety, and not a means for self-regulation or a substitute for official controls. We consider it important for all parties concerned that this distinction is made.
Foodaware believes that, alongside the requirement for HACCP, it is essential that a more proactive external and robust inspection and verification system be developed. This should include the inspection of premises and reviews of the necessary documentation to ensure that HACCP is being implemented effectively.
Provided that HACCP is flexible enough to be adapted to small and medium sized businesses, there should be no reason for exemptions. A problem arising in a small plant can reek as much havoc as from a large plant. However, Foodaware is concerned that the administrative burden of implementing HACCP may have a negative effect on the economic viability of small businesses. If these are forced to close due to their inability to meet HACCP administrative requirements, this will have a detrimental effect on consumer choice. From a consumer perspective, what is important is that staff should understand the principles of good food hygiene and carry them out in their work. Small and medium sized businesses should therefore be given extra support (and probably time) to implement an effective HACCP system.
For example, Foodaware is concerned about the need for adequate staff training before HACCP can be implemented. All workers in the relevant food business should be trained in HACCP principles, where applicable to their work, and made aware of the critical points in their area of operation. It is important to remember that HACCP focuses on the procedures and actions which staff carry out every day, and that it is not just the domain of supervisors.
Finally, Foodaware considers that there must be a clear commitment to implement a tighter system of control and surveillance over food hygiene procedures in the industry, so that consumers can be confident that producers are implementing HACCP effectively. In particular, it is of vital importance that there are official controls for the surveillance, auditing and monitoring of the implementation of HACCP and that there are enforcement measures to ensure that Community procedures are followed. Official controls over HACCP are essential to ensure consumer confidence in food safety.

11th March 2002