Putting a HACCP System in Place

There are many different processes involved in food production and a lot of steps between farming and consumption. At each process step, dangerous things may enter our food (and drink), which are known as hazards.

Food hazards are contaminants that have the potential to cause harm. You wouldn’t think of eating and drinking as a risky activity, but if our food is contaminated it can cause illness, injury and allergic reactions in some individuals. The harm from unsafe food can range from minor to severe, and in some cases, can be life-threatening.

An estimated 600 million globally (almost 1 in 10 people in the world) fall ill after eating contaminated food, and 420,000 die every year (World Health Organisation). Even though food allergy deaths (anaphylaxis) are rare, there are still around ten deaths every year in the UK (Imperial College London).

To prevent contaminants from entering our food, HACCP was introduced. It has become an internationally accepted system for controlling food hazards. Let’s now look at what HACCP is and what is involved in further detail.

What is a HACCP system?

HACCP is an acronym, which stands for:

• Hazard
• Analysis &
• Critical
• Control
• Point

HACCP is a system that identifies, evaluates and controls significant food safety hazards (Codex Alimentarius Commission). It looks at the different contaminants that could enter food production processes and how these can be controlled and managed to prevent illness and injury to consumers. It can be applied throughout the whole supply chain, i.e. from farm to fork.

HACCP was conceived in the USA in the 1960s when NASA and the Pillsbury Company collaborated to design and manufacture safe pre-packaged food for space flights. Over the decades, HACCP has continued to develop and is now used globally as a framework for food safety.

Who needs a HACCP system in place?

All food operators must implement and maintain a food safety management system based on the principles of HACCP. Therefore, any business that produces, manufactures, prepares, processes, handles, transports, supplies and sells food and drink will need to have a HACCP system in place.

It will include (this list is not exhaustive):

• Food manufacturers, e.g. mills, processing plants and packing facilities.
• Food transporters.
• Food wholesalers.
• Caterers.
• Restaurants.
• Cafes.
• Takeaways.
• Pubs.
• Hotels and bed & breakfasts.
• Residential care homes.
• Childminders.
• Retailers, e.g. supermarkets, convenience stores, corner shops, confectioners and newsagents.

The type of HACCP system, and its size, will depend on how large a business is, what it involves and the risks to consumers. Smaller low-risk operators, e.g. retailers selling pre-packaged foods, will have far simpler HACCP systems than large manufacturers and caterers.

The Food Standards Agency (FSA) and other regulators have guidance to help businesses with their food safety management procedures and HACCP systems.

For example:

• Smaller, low-risk and/or non-complex food businesses:
  – Safer food, better business (SFBB) – England and Wales.
  – CookSafe and RetailSafe – Scotland.
  – Safe catering – Northern Ireland.
• Larger, high-risk and/or complex food businesses:
  – MyHACCP.
  – ISO 22000:2018 food safety management system.

What is the main purpose of a HACCP system?

HACCP’s main purpose is to prevent, control and manage food hazards throughout the entire supply chain so that consumers are not made ill or injured as a result of contaminants in food, such as:

• Biological – Microorganisms, e.g. bacteria, viruses, fungi and parasites. These can cause food poisoning.
• Physical – Natural and non-natural physical objects, e.g. stones, pips, bones, hair, glass, plastic and metal. These can cause injuries to the mouth and teeth and can be a choking hazard.
• Chemical – Naturally occurring, human-made or intentionally added, e.g. natural toxins, chemicals, drugs, pollutants and additives. These can cause intoxication and even long-term health effects.
• Allergenic – One or more of the 14 food allergens, e.g. sesame, milk, egg, fish and nuts. These can cause allergic reactions and anaphylaxis in some individuals, which can be life-threatening.

In a nutshell, HACCP aims to prevent contaminants from entering food in the first instance and identify and remove any that enter during food processes.

What is the first step in creating a HACCP system?

Prerequisites

Before a food business creates a HACCP system, there have to be the necessary prerequisite programmes (prerequisites for short) in place. Without these, a HACCP system will not work. Therefore, they are a mandatory requirement.

So what are prerequisites? They are basic hygiene measures that all food businesses must have in place and are essential for food safety. They are areas that could adversely affect food safety if not controlled.

Prerequisites are also known as good hygiene practices (GHPs) or good manufacturing practices (GMPs).

Some examples include:

• The food premises.
• Cleaning and disinfection.
• Personal hygiene of workers.
• Pest control.
• Staff training.
• Waste management.

For small, low-risk businesses, fully implemented prerequisites will sometimes be enough to satisfy the law, as there is a certain level of flexibility. This will depend on the complexity of the business, the type of food operation and the risks.

Many food businesses will require a full-blown HACCP system, i.e. a food safety management system based on the HACCP principles. Therefore, once the prerequisites are in place, a HACCP plan is the next step in creating a HACCP system.

HACCP plan

A HACCP plan is defined in CODEX as “a document prepared in accordance with the principles of HACCP to ensure control of hazards which are significant for food safety in the segment of the food chain under consideration”.

Before a food business looks at the seven HACCP principles, they should put a plan in place. Which involves the following five preliminary tasks:

1. Assembling a HACCP team – Choosing a multi-disciplinary team responsible for the development, management and implementation of the HACCP system and defining the scope for the HACCP study.
2. Describing the product – Preparing a full description of each product, including specification information, food properties, processes, packaging, storage, shelf-life, labelling etc.
3. Identifying the product’s intended use – Considering the intended use of the finished product, e.g. will it need to be cooked before consumption?
4. Constructing a flow diagram – Describing the product process, e.g. a flow chart showing the steps from delivering raw ingredients to serving cooked food.
5. Confirmation of the flow diagram – Verifying the flow diagram is correct and reflects all of the steps in the process.

Once the preliminary steps of the HACCP plan are complete, the next involves applying the seven principles of HACCP.

What are the seven principles of the HACCP system?

The law states that food businesses must have a food safety management system (FSMS) in place, which is based on the principles of HACCP. The principles of HACCP have been developed and revised over the years.

There are currently seven recognised principles, which are:

1. Identifying hazards by conducting a hazard analysis – What potential biological, chemical, physical and allergenic hazards are expected to occur throughout the process? It includes the evaluation of hazards and specifying control measures to prevent or reduce the risk.
2. Determining the critical control points (CCPs) – Which process steps need strict controls to prevent or eliminate a food safety hazard or reduce it to an acceptable level? For example, a raw chicken needs to be cooked thoroughly to prevent food poisoning.
3. Establishing critical limits – What would be acceptable and unacceptable values, i.e. what are the limits for safe and unsafe food? For example, when cooking chicken, it needs to be cooked at a certain temperature for a specific time to be safe to eat.
4. Establishing a monitoring system – How will the control measures be observed or measured? How will hazards be controlled at CCPs? For example, monitoring may include taking temperatures.
5. Establishing a corrective action plan – What corrective actions will be required if monitoring identifies a loss of control at CCPs? For example, if a refrigerator is over 8°C.
6. Establishing validation, verification and review procedures – Is the HACCP system working effectively so that the product is safe? It includes verifying that checks are complete.
7. Establishing record-keeping procedures – How will HACCP documentation and records be kept? It should be based on the nature and the size of the business.

Why is it important to monitor a HACCP system?

HACCP principle 4 requires food businesses to establish a monitoring system, but why is this important? According to the FSA, “the purpose of monitoring is to confirm that the critical limits are being continuously achieved and to detect any loss of control to enable effective corrective action to be taken”.

HACCP aims to prevent, eliminate or reduce food hazards. If a system is put in place and not monitored, hazards may be missed resulting in potentially unsafe food reaching the consumer.

Monitoring is an essential part of any management system (food, health and safety or quality) to show it is working.

When should a HACCP system be reviewed?

For the HACCP system to be effective, it should be up to date and reflect current practices. If it doesn’t, there is a risk of food hazards not being identified and controlled, potentially causing harm to consumers.

Reviewing the HACCP system will ensure there are no significant changes that could affect food safety. An annual review should be carried out, by the HACCP team, as a minimum. Schedule routine reviews so that they don’t get missed.

When carrying out the review, the reasons why it is necessary should be detailed in the HACCP plan. For example, a business may have introduced a new product or changed the ingredients, which triggered a review.

Any reviews of the HACCP system should be documented, even if there are no changes. This demonstrates the business’s commitment to food safety, and it is also important for due diligence purposes.

Which laws govern the use of the HACCP system?

The legal requirement for HACCP comes from a European Union (EU) law. In January 2006, the EU Regulation (EC) 852/2004 on the hygiene of foodstuffs was introduced. As it was an EU Regulation, the UK had to comply as a previous member state.

EU Regulation (EC) 852/2004 Article 5 relates to HACCP, which states “food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles”. For this reason, it is known as the HACCP law or HACCP regulation.

Even though the UK has now left the EU, HACCP still applies to food businesses, as it is an internationally recognised system for controlling food hazards. There are currently no details about the changes from the EU Regulation to a UK Regulation. However, food safety and hygiene regulations for each of the different countries within the UK cover the enforcement of hygiene and the HACCP principles.

They are:

• The Food Safety and Hygiene (England) Regulations 2013.
• The Food Hygiene (Scotland) Regulations 2006 (as amended).
• The Food Hygiene (Wales) Regulations 2006.
• The Food Hygiene Regulations (Northern Ireland) 2006.

These regulations, and the Food Safety Act 1990 (Great Britain) and the Food Safety (Northern Ireland) Order 1991, will continue to apply.

Having an effective HACCP system ensures that businesses are compliant with food safety laws. Non-compliance can result in prosecutions, fines and even imprisonment. Consumers can also claim compensation under civil law if they have been made ill or injured by unsafe food.

Summary

HACCP is an internationally accepted system, as it works. If a food business has an effective HACCP system implemented fully and correctly, it can reduce the risk of hazards entering food and harming consumers. It will keep food businesses on the right side of the law and protect their reputation. Consumers are less likely to purchase food from an establishment with a poor food safety record, especially if someone has been made seriously ill or worse.

Overall, having a HACCP system will save businesses money. HACCP can increase efficiency, save wastage, and prevent the costs associated with customer complaints, the recall of products and the destruction of stock. It will also prevent legal costs, compensation claims and a loss of custom.

Putting a HACCP system in place and implementing it is not as difficult as some may think. There is plenty of guidance out there on how to create an effective system. You could also enrol on one of our HACCP courses (level 2 or 3) to learn more.