Implementation of HACCP principles in small food producing

establishments, AGR 32375, Croatia, April 2009

Milorad Radakovic BVSc, Cert VPH(MH), MRCVSVeterinary Adviser

Food Standards Agency

Practical HACCP implementation in meat sector

How to identify and solve problems

Some problems How to solve them? and who?

1. Lack of training

2. Product not clearly defined e.g ready to eat or not ready to eat.

3. Bad process flow diagram e.g. not updated

4. Too simple ( incomplete) e.g. not distinguishing GHP and HACCP

5. Too complicated (not understandable), a lot of useless documents

General problems with implementation of procedures based on HACCP principles

Today • A brief introduction – FSA, Hygiene Regulations and HACCP. Some questions! Easy to identify/control realistic hazards? Does controlling mean preventing hazards, eliminating or reducing to an acceptable level? Who is responsible for HACCP? etc.

• Practical problems! – How to identify and solve problems? An example – small slaughterhouse.

FSA - Non-ministerial Government DepartmentFSA - Non-ministerial Government DepartmentWhen? Why? Who? What? How?When? Why? Who? What? How?

open - consumer firstUK’s CCA for food/feed

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E x per t commit t eesA CM S F , A CN F P,S A CN

T he Boar dChair man, D eput y Chair and 12 ot her memb er s

Official controller e.g.Veterinarian

Differences; economic, social, religion, language, tradition, agricultural farming, approach to official controls etc……

In common; food/feed/animal health,welfare rules and regulations

“Hygiene Regulations”(17 Directives - simplified & consolidated into)

• Regulations (EC) No 852/2004 On the hygiene of the foodstuffs; (EC) No 853/2004 Specific hygiene rules for POAO; (EC) No 854/2004 Specific rules for the organisation of official controls on POAO; Directive 2002/99/EC - Animal health rules; Links with other relevant Regs, eg Zoonoses Directive, Welfare, Animal by products etc.

• Other rules Regulations (EC) 178/2002 - On General principles of food law, (EC) 882/2004 - On Official Controls to ensure compliance with Food & Feed law (EC) 2073/2005 on Microbiological criteria, (EC) 2074/2005 Implementing measures, (EC) 2076/2005 Transitional arrangements, (EC) 2075/2005 - Trichinella and Amending Regulation (EC) 1662/1663/1664/1665/1666……..

•“Buzzwords” from farm to table/fork, from production to consumption, relevant, risk based, transparent, precautionary principle, adequate, flexible, improved traceabilty…etc….

Guidance documents (some draft, some finished?)

“Guidance”, “guideline”, Oxford Dictionary “help or advice given”, “official organisation telling you how to do something” or “something that can be used to help you to make a decision or form an opinion”

•EC guidance documents On the Implementation of Hygiene Regulations, Import requirements, Official controls, HACCP principles and facilitation of the implementation of HACCP principles etc.•UK Guidance documentsIndustry Guides – Sector specific, e.g. meat, milk, treated stomach, bladders, minced meat, meat products , ABP, etc.etc. HACCP (Diary for small businesses)• Enforcers Guides and Codes of Practice Local Authority and Meat Hygiene Service (DARD in NI) HACCP

In common; law, guidance, code..

To respect basic principles of WHO, OIE, WTO, SPS agreement - not compromising food safety, animal health and possibly animal welfare;

• Clear FBO’s responsibility for production, including primary producers for the first time;• Flexible approaches to production and enforcement that are less prescriptive taking into consideration small/traditional business using precautionary principle

Be reasonable !!!

“ The reasonable man adapts himself

to suit the world, while the unreasonable

man seeks to adjust the world to suit him.

Therefore all progress depends on the unreasonable man.”

George Bernard Shaw

Man and Superman

Are you competent to perform required task?

Competent person?

One with adequate and appropriate skills and knowledge to perform required tasks effectively

This room is full of competent people in food production, legislative procedures, enforcement. Combined “competency level” (skills and knowledge) is frightening - hundreds years of experience etc….

You are here - moving from general introduction to HACCP

Developing/implementing HACCP?

Depends on many factors (size, product etc, however general requirements are: • a will and knowledge - theoretical, practical, operational, managerialthen simply• Define the scope of HACCP plan ( from the beginning till the end of process, including description and intended use of product)• Produce a process flow diagram and • Apply logical step by step approach

HACCP in ‘defined’ meat sector? The objectives are the sameThe objectives are the same

Establishments – Slaughterhouses, Cutting plants, MM, MPREP, Meat products, Cold stores, Edible co- products, Butcher shops etc

Products – not ready to eat (fresh meat) or ready to eat (fermented sausages, canned meat) etc.

Species – cattle, sheep, turkeys, chicken, snails, horses, deer etc.

Quantity – establishment’s size/throughput

– large industrial

– small processing a few animals, small quantities small processing a few animals, small quantities of productof product

HACCPmeans procedure(s) based on HACCP principles

PERAPERA pravilo Principles – Hazards that must be PreventedEliminated or Reduced to Acceptable levels

REALISTICALLY

•

Perceptions and dilemmas“normal or abnormal”, “fit or unfit”, “safe or not

safe”, “clean or not clean” “adequate or not adequate” acceptable or not acceptable”…….

Different perceptions!

Problems Why is that a problem? Who can solve it? How?

Biological, Chemical, Physical hazards

not recognised or

not considered at all

Lack of understanding. It should be simple with naming a few most important specific hazards.

Are physical hazards realistic?

Chemical hazards might be controlled by GHP?

Unrealistic hazards chosen –

usually too many without a logical explanation

Theoretically many hazards, but practically a few

Wrong advice given

Unnecessary copying from the text books

1. Identifying any hazards that must be prevented, eliminated, or reduced to acceptable levels

Hazards in cattle may be in/on live cattle or in/on meat

• Biological (some examples) Salmonella serotypes, Campylobacter spp, Clostridiums species (perfringens), Listeria, Enterohaemoragic Escherichia Coli 0 157, Staphylococcus aureus, Brucella, TSE, Tb, aflatoxin, some viruses, yeasts, fungi, parasites C.bovis- etc………

Which are realistic? Consequences for public health?

Hazards in cattlemay be in /on live cattle, or in/on meat

• Chemical (some examples)Residues of antimicrobials, antıectoparasıtıcs, pesticides (DDT, dieldrin), haevy metals (lead, mercury…),other environmental chemicals (dioxins), hormones or hormone like substances, mycotoxins etc…• Physical Foreign bodies (bone , glass, metal , plastic)

All potential, but which are significant?

How might we know about hazards in cattle?

It is not easy – not visible unless symptoms observed • Epidemiological reports etc.

How our mind works?• We know• We do not know• We suspect

Please suggest 2 significant Please suggest 2 significant hazards in cattle?hazards in cattle?

Problems Why is that a problem? Who can solve it? How?

CCPs either not present at all

Is there any that is critical in/sh? A philosophical question!!!

However, they must be controlled

i.e. reduce to an acceptable level rule applies

Too many CCPs

FBOs are putting more CCPs just to satisfy customers and CA, but in reality uncontrollable.

Wrong advice

2. Identifying the critical control CCPs points at the step or steps at which control is essential to prevent, eliminate or reduce to an acceptable level.

Controlling hazards1. Farm, includes loading2. Transportation3. Slaughterhouse - Acceptance of animals - Unloading - Slaughtering - Dressing - Evisceration - Chilling

At which points At which points more control more control could/should be could/should be applied?applied?

Choose 3 most Choose 3 most important?important?

Problems Why is that a problem? Who can solve it? How?

Not distinguished

Acceptable/unacceptable

Not clear

No need to be numerical –

can be visual

Not clear with the terminology

“ Acceptable & Unacceptable”

“ Visual & Numerical”

Hygiene controls set as Critical limits

There is a difference - GHP from critical limits.

3. Establishing critical limits at critical control points which separate acceptability from unacceptability for the PERA of identified hazards;

Problems Why is that a problem? Who can solve it? How?

Monitoring procedures not performed

Ignorance, lack of knowledge

If HACCP plan too complicated then it is impossible to monitor it

Too much meaningless monitoring

Monitoring everything – mixing with QC.

If there are a few CCP – it should not be a problem

4. Establishing and implementing effective monitoring procedures at critical control points;

Problems Why is that a problem? Who can solve it? How?

Corrective actions not recorded

Because there is no adequate monitoring.

Afraid to put down mistakes, errors etc..

Acknowledgment that mistakes do occur ( human nature) e.g. spill the guts on line etc.

5. Establishing corrective actions when monitoring indicates that a critical control point is not under control

Problems Why is that a problem? Who can solve it? How?

Difference between

Validation

Verification

Review

and

Either not done or not documented

Lack of understanding of this terminology

Microbiological testing is a part of verification

procedures

6. Establishing procedures, which shall be carried out regularly, to verify that the measures outlined in subparagraphs (a) to (e) are

working effectively;

Problems Why is that a problem? Who can solve it? How? e

Either

Very few incomprehensive records or

Many meaningless records

Lack of knowledge.

Objective is to have understandable documents and records,

Why not to use a SIMPLE DIARY?

Exception reporting is OK.

7. Establishing documents and records commensurate with the nature and size of the food business to demonstrate the effective application of the measures outlined in subparagraphs(a) to (f)

OV’s role under Hygiene Regs

• Inspection tasks – to detect abnormalities (visible and not visible) that are relevant to public health, animal health and animal welfare, links with HACCP?, LIMITATIONS?LIMITATIONS?

• Auditing tasks (GHP and HACCP procedures) – to verify that FBOs apply procedures continuously and properly. LIMITATIONS?LIMITATIONS?

useful websites• http://ec.europa.eu/•http://www.food.gov.uk/