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HACCP: international developments

Rolf Uys, Manager AIB International - South Africa, speaks to The Baker about Hazard Analysis Critical Control Point (HACCP) and the latest developments emanating from the European Union (EU).

There are two recent EU laws relevant to food hygiene and safety, says Uys, a new General Food Law and a new Labelling Directive.

Recent developments

The General Food Law, which came into force in January 2005, introduces mandatory, documented traceability at all stages of production, processing and distribution. If a food safety risk is suspected or known, there must be an immediate initiation of withdrawal procedures, as well as notification to the competent authorities, and consumers must be informed appropriately.

The new Labelling Directive prescribes mandatory product labelling for ingredients that produce adverse reactions in sensitive individuals, including food allergens. In addition, there is a requirement to label EU specified ingredients and their derivatives. The EU is also preparing list of derivatives, which pose no hypersensitivity risk and these will be exempt from labelling.

The implementation date in EU countries was the 25th of November 2004 and from the 25th of November this year, the sale of non-compliant products is prohibited.

Existing food regulations in the EU

The UK Food Safety Act of 1990 contains a commonly cited Due Diligence Defence. This part of the act specifies that no person or company should be guilty of a criminal offence for an act or omission, which could not be reasonably avoided. In addition, it holds parties “guilty until proven innocent”, requires more than just verbal evidence needed and gives greater power to Environmental Health Officers.

Due diligence extends to ensure reliance cannot be placed on warranties and general assurance from suppliers alone. Active participation by a food company is needed.

This legislation also requires that the due diligence system is captured in writing and that training is given to all appropriate staff. In addition, the system should be challenged and the results documented.

The system should further be based on a pro-active approach, thus being capable of detecting faults and correcting them. Consumer complaints should be recorded and analysed to detect trends and then provoke an appropriate response.

The responsibilities of directors, managers and employees should be stated in writing and acknowledged by them, while the whole due diligence system should be reviewed periodically and the results documented.

E.U. General Food Hygiene

Various directives currently in force covers all stages of preparation, processing, manufacturing, packaging, storing, transportation, distribution, handling and offering for sale or supply (excluding primary production - agriculture or products of animal origin). Food companies are responsible for compliance.

EU member states are to encourage the development of guides to good hygiene practice including training. There is no minimum training stipulated but the training must be “commensurate with the work activity”.

Food business operators must also apply the principles of hazard analysis, in which identification of steps are critical to ensure adequate safety procedures are identified, implemented, maintained and reviewed.

EC Developments

17 directives have been issues since 1964, and these have not been drawn up in a harmonious manner. The current general guidelines do not cover primary

production of foodstuffs and there are inconsistencies between product-specific

hygiene directives.

The EU White paper on Food Safety 2002 proposed the establishment of a European Authority to regulate the feed industry and oversee veterinary legislation, GMO’s, Allergens etc. Yet the BSE and Foot & Mouth disease highlighted weaknesses in EU legislation.

EC Developments for Contamination Controls

A regulation setting maximum levels for certain contaminants, such as nitrates, heavy metals, aflatoxins and patulin, was published in 2001.

Various directives set maximum levels for pesticide residues in and on cereals, foods of animal origin (including dairy and meat products), as well as fruit and vegetables.

EC Developments - Packaging Hygiene

Current legislation requires that: “Wrapping and packaging materials must be manufactured, transported and supplied to food businesses in such a manner that they are protected from any contamination that may present a risk to health.’

HACCP and GMP

Says Uys: “The food industry has been struggling with the Hazard Analysis Critical Control Point (HACCP) system for the past decade. The problem is, HACCP cannot work unless Good Manufacturing Practices (GMP) are fully functional first.”

The AIB will be hosting a seminar about GMP and how to integrate this with HACCP in order to create a world class Food Safety System. The seminar will also focus on the AIB approach to food safety, new international legislation and practical sessions on food safety auditing and advanced HACCP. The seminar will be held on the 6,7,8 of April 2005 at the Constantia Hotel in Midrand.

The presenters include Deryck Tremble – Regional General Manager: AIB International Europe; Stuart Lee – Vice President European Operations: Eastbalt Europe; Eileen Engelbrecht – Managing Director: Ecofirst Pest Prevention and Hygiene Services; Brett Osrin – Managing Director: Ecowize Specialized Hygiene Solutions.

The cost is R2700 for 3 days and for information is available from ruys@aibonline.org or eileen_engelbrecht@hotmail.com.