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Level 3 - 4 HACCP

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Level 3 - 4 HACCP

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Intermediate HACCP A text for Level 3 & Level 4 HACCP courses and Mote alamo) UNM n) (nal 1 ele ae ee Salsa © Tuan se lierola) Carol A. Wallace Highfield Se a Improving Food Safety qo Intermediate HACCP A text for Level 3 and Level 4 HACCP courses and a reference for the implementation of HACCP Carol A. Wallace PhD, BSc (Hons), PGCE, CSci, FRSPH, FIFST, FHEA First published November 2005 6th Edition August 2018 PUBLISHED BY © 2019 Highfield Products Limited Highfield Place, Shaw Wood Business Park, Shaw Wood Way, Wheatley Hills, Doncaster, DN2 5TB, UK +44 0845 2260350 +44 01302 363277 [email protected] hfield.co.uk www.highfieldelearning.com ISBN 978-1-912633-19-7 www. hi (() Highfield ghfield gk [ Products" ‘llrightsreserved. No part of this publication may be reproduced, stored ina retrieval system, or transmitted in any form or by ‘any means, electronic, photocopying, recording or otherwise, without the prior permission of Highfield Products Ltd. ‘The publisher ofthis book has made every effort to ensure the accuracy ofthe information contained in this book. Neither the author, Highfield Products Lid nor anyone involved in the creation of this publication accepts responsibilty for any inaccuracies or fllue to implement cortectly, however caused, Disclaimer of Endorsement Reference to or any image of any specific commercial or non-commercial product, process or service by company name, trade name, trade mark, service mark, manufacturer or otherwise does not constitute or imply endorsement or recommendation by Highfield Products Lid. Contents Pym Me UN cers Ca oa 8 Sane ee Sce ur Cee re Osa ere en caterer re ene cate lash aes Preface The hazard analysis and critical control point system (HACCP) is a systematic way to manage food safety and prevent foodborne illness. Promoted by the World Health Organization (WHO) and by governments and legislators worldwide, HACCP is the system of choice to protect consumer safety. Building on the successful textbooks HACCP - a practical approach (Mortimore & Wallace 1994, 1998, 2013), HACCP (Mortimore & Wallace, 2001 and 2015) and Hygiene for Management (Sprenger, 2017), this book tackles the practical requirements for HACCP in food operations. It is designed as a coursebook to accompany both Level 3 and Level 4 HACCP training and covers the syllabus requirements for the main UK food industry awarding bodies. It will also be useful pre-course reading for HACCP. training programmes. About the author Carol Wallace is Co-Director of the International Institute of Nutritional Sciences and Applied Food Safety Studies and Professor of Food Safety Management Systems at the University of Central Lancashire. Carol is well known in the HACCP field and, in addition to this book, is co-author of the highly successful textbooks HACCP: a practical approach (Springer) and Food Safety for the 21st Century and HACCP (both Wiley Blackwell). She has been involved in HACCP training both at national and international level, including direct involvement in the development of UK HACCP training standards and examinations in HACCP. Through this work, Carol has assisted a wide range of organisations in the development, implementation and verification of their HACCP Systems. Carol's background is in microbiology and food safety. Her career spans over 30 years in the food industry; in food manufacturing, retailing and consultancy, and more recently in academia, where she has been instrumental in setting up post-graduate e-learning programmes in HACCP and Food Safety Management and leading food safety research. She is a Fellow of the Royal Society for Public Health, the Institute of Food Science and Technology and the Higher Education Academy and a Member of the International Association for Food Protection. Her key research interests include HACCP training effectiveness and its link to effective HACCP implementation within the broader field on food safety culture and management. Disclaimer ‘The material in this book is presented after the exercise of care in its compilation, preparation and issue. However, it is provided without any liability whatsoever in its application and use, The contents reflect the personal views of the author and contributors and are not intended to represent those of the University of Central Lancashire or its affiliates HACCP learning objectives When attending a HACCP course or doing your own self-directed study, there are a number of things you should learn. These are your HACCP learning objectives. Typically, training providers and awarding bodies will list the learning outcomes that are intended from their courses. Several Level 3/Level 4 HACCP courses are available. Course content and learning outcomes may be viewed on awarding body websites, for example: Highfield Qualifications www.highfieldqualifications.com The Royal Society for Public Health (RSPH) www.rsph.org.uk The HACCP learning objectives for this book fall into the following broad areas: the background to food safety management and the role and importance of HACCP systems; legal requirements pertaining to HACCP and food safety, particularly in the UK; the essential hygiene prerequisites as foundations for effective HACCP; the seven principles of HACCP; different approaches to the use of HACCP; how to develop HACCP; carrying out hazard analysis and defining control measures; ¢ — identifying critical control points (CCPs); # — control of CCPs - limits, monitoring and corrective action; and @ how to manage HACCP; application, implementation, verification and maintenance of HACCP; % roles, resources, communication, training and development requirements; and challenging HACCP effectiveness. eS eoeoe Readers of the book should be able to gain an understanding of these areas and, therefore, a working knowledge of how HACCP systems are employed in current food safety management practice. However, this is an introductory text and it is not intended that readers will become experts from this book alone. It is strongly recommended that personnel who develop and manage HACCP systems attend suitable HACCP training. Definitions of key terms Contamination The presence or introduction of a hazard. In practice this means the introduction of something harmful (a hazard) or objectionable to food. Control measures Actions or activities required to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Control point Astep in the process where control may be applied, but a loss of control would not result in an unacceptable health risk. Corrective action The action to be taken when results of monitoring at a critical control point indicate loss of control, i.e. a critical limit is breached. Critical control point (CCP) Astep in the process where control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Critical (safe) limit Accriterion which separates acceptability from the unacceptability (Codex). A maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a food safety hazard (NACMCF). From a practical viewpoint, a critical limit is a proven safe limit that ensures food can be eaten safely, e.g. cooking food to 75°C. Cross-contamination The transfer of hazards, e.g. bacteria, allergens or physical contaminants, such as metal, to food. Transfer may be from raw food to ready-to-eat food, from equipment, personnel and the food handling environment. Deviation A failure to meet a critical (safe) limit. Flow diagram (chart) A systematic representation of the sequence of steps or operations involved with a particular food item or process. This may be a single diagram from receipt of raw ingredients to the consumer or a set of modular diagrams that add up to cover the entire process, WP Ur ao Food hygiene The measures and conditions necessary to control hazards and to ensure fitness for human consumption of a foodstuff taking into account its intended use. Food poisoning Any disease of an infectious or toxic nature caused by the consumption of food or water. This includes all food and waterborne illness regardless of signs or symptoms, (Chief Medical Officer and used by FSA). Also known as foodborne illness. Food safety management The policies, procedures, controls and documentation that ensure the food sold by a food business is safe to eat and free from contaminants. HACCP (hazard analysis critical control point) A food safety management system which identifies, evaluates and controls hazards which are significant for food safety. HACCP plan A document (or set of documents) 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. HACCP team A group of people with appropriate expertise, experience and training who work together to develop and implement a HACCP system. Hazard A biological, chemical’ or physical agent in, or condition of, food with the potential to cause harm (an adverse health effect) to the consumer. Hazard analysis (Codex) The process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for food safety and should therefore be addressed in the HACCP plan. High-risk food Ready-to-eat foods which, under favourable conditions, support the multiplication of pathogenic bacteria and are intended for consumption without treatment which would destroy such organisms. Maintenance (HACCP) Maintaining the supporting elements and resources to ensure the HACCP plan remains valid over time and doesn’t become out of date. Monitoring The planned observations or measurements of control parameters to confirm that the process is under control, and that critical (safe) limits are not breached. Am | in control? ‘Tpeaigaletsteed heen leirchurle-alimenane Pathogen A biological agent that can cause disease to its host. Pathogens include bacteria, protozoa, fungi and viruses. Bacterial pathogens can be vegetative, e.g. salmonella, or spore-forming, e.g. C/. botulinum. Spore-forming pathogens can survive pasteurisation-type cook processes while vegetative pathogens generally cannot. Prerequisite programmes The good hygiene practices and conditions a business must have in place before and during implementation of HACCP, which are essential to food safety. Review A reassessment of the HACCP system to ensure its continued validity. Risk The likelihood of a hazard occurring in food. Risk (danger) zone of bacteriological growth The temperature range within which the multiplication of food poisoning bacteria is possible. Scientifically this is -2°C (Listeria monocytogenes) to 55°C (Bacillus cereus). Most rapid growth is usually from 20°C to 50°C. The range 8°C to 63°C has in the past been referred to as the danger zone but does not fit with the definition. It is more of a‘risk-zone’ If food is stored within this temperature zone, there is a risk of multiplication of food poisoning bacteria and risk of prosecution depending on the time involved. Unlike the ‘scientific danger zone’ this range varies with different countries depending on the law. Risk evaluation The process of identifying hazards, assessing likelihood of occurrence and severity and evaluating the significance. Safe food Food which is free of contaminants and will not cause illness, harm or injury. Target level Control criterion that is more stringent than the critical limit, i.e. it provides a buffer zone, and which can be used to reduce the risk of a deviation. Tolerance The specified degree of latitude for a control measure, which, if exceeded, requires immediate corrective action. Validation Obtaining evidence that elements of the HACCP plan are effective, especially the critical control points and critical limits. Will | achieve control? Verification The application of methods, procedures and tests, and other evaluations, in addition to monitoring, to determine compliance with the HACCP plan (including prerequisite Droqrammec) Wac! in control? An introduction to HACCP 1 An introduction to HACCP We will start with some general information about food safety management to provide an introduction to HACCP and an understanding of why these systems are necessary in manufacturing, catering and retailing operations today. CHAPTER TOPICS Whatis food safety management? ¢ Lessons from food safety incidents Causes of foodborne illness @ = What is HACCP? History and background to HACCP) ~=Why HACCP fails # Success with HACCP What is food safety management? It is a fundamental requirement of any food process that the food produced should be safe for consumption. Food safety is such a basic consumer expectation that it is ‘taken as read' when we choose our meal from the menu options or buy products from the retailer. However, there is a very real danger to consumers if necessary control measures are overlooked or mismanaged in a busy food operation. In any food operation, food safety management is achieved through the application of system ‘building blocks' - safe recipe/process design, prerequisite programmes and HACCP - operating under the framework of the overall operations management. Crna acne paris ec micue caus eee eeu Food safety management model ‘1d ONC: rae RCL ae TL For effective food safety management, all three 'building blocks’ need to be adequately designed and their implementation verified. We will discuss each of these in more depth in the following chapters. Lessons from food safety incidents Food safety incidents cause much suffering, including mild to severe illness and even death. This has a major effect on the sufferers themselves and their families, and can ruin food businesses. If we look at the causes of historical food safety incidents, we can see that they could have been prevented. This is particularly true if the food businesses concerned had implemented a food safety system based on HACCP and prerequisite programmes, and had continued to verify that it was working effectively in practice. Implications of food safety incidents UK - Salmonelia Ealing 1985 Dried baby milk (Farley Health Products) resulting in 60 cases and 1 death. Caused by a allowing moisture to provide suitable multiplication conditions. Business value reduced from £40 million to £18 million. England - Clostridium botulinum 1989 Hazelnut yogurt resulting in 27 cases and 1 death. Caused by failure to undertake a risk assessment when producing new product. (Sweetener instead of sugar (higher ayy) and hazelnut pH not low enough to prevent ‘growth - failure to increase processing temperature which could have prevented an outbreak). France - Listeria monocytogenes 1992 Pork tongue in aspic resulting in 279 cases, 63 deaths and 22 abortions. Scotland - E. coli0157 1996 Cooked cold meats and cooked steak/gravy (ohn Bart). Mainly cross-contamination, resulting in 500+ cases and 21 deaths. (3 major outbreaks and sporadic cases) USA - E. coli 0157 May & February 1998 ‘May - Odwalla Inc, 5 children (apple juice) - $1,200,000. February - Jackin the Box restaurant choi 4 customers died, many more ill. Accepted $58,500,000 from 9 beef suppliers (hamburgers). Wales - E. coli 0157 2005 ‘Cooked meats supplied to school meals and care homes (John Tudor). Cross-contamination caused >150 cases and 1 death. Business closed and proprietor jalled for 12 months. UK- Salmonella 2006 ‘Salmonella Montevideo in chocolate results in 37 cases and costs >£30 million. Major manufacturer accused of not having effective HACCP system in place. Canada - Listeria monocytogenes 2008 Listeria monocytogenes in sliced cooked meat products - 23 deaths. Cross-contamination during slicing. INTERMEDIATE HACCP An introduction to HACCP Causes of food poisoning By studying previous outbreaks of food poisoning we can understand their causes and take action to prevent them recurring. The main causes of food poisoning are: ¢ preparing food too far in advance @ — cross-contamination; and storage at ambient temperature; ¢ improper hot holding; inadequate cooling; infected food handlers; inadequate reheating; 4 raw food consumed; and ¢@ undercooking; contaminated processed inadequate thawing/inadequate food used (contamination heat processes; from earlier in the food supply chain). In order to prevent food poisoning, it is important that these causes are understood and that control measures are in place to prevent their occurrence. 1g the main causes of food poisoning Rete baice) Panne + Prepared food stored at below 5°C or above 63°C + Prepare minimum amount of food + Time at ambient temperature minimised 1.Preparing food too far in| Multiplication of pathogens advance and storage at ambient temperature Zinadequate cooling Multiplication of pathogens | - Blast chilling - food cooled from 60°C to 10°C due to elevated temperature in 1.5 hours and 10°C to 5°C in 1.5 hours + Use of heat exchangers for rapid cooling of liquids + After cooling, food stored at below 5°C + Weight/thickness of, e.g.joints of meat controlled to facilitate cooling + Dimensions, e.g.depth of food containers controlled to facilitate cooling + Staff training Survival of pathogens- spore | + Reheat to >75°C at the coolest part of the formers that survived the initial | the product cooking or contaminants 3.Inadequate reheating * Centre temperature of at least 75°C, or product achieves 2 minutes at 70°C at the coolest part or proven equivalent temperature/time combination + Equivalent process temperatures and times for pasteurisation of liquid products,e.g. milk at 71.7°C for 15 seconds + Frozen items thawed before cooking + Staff training 4, Undercooking Survival of pathogens - particularly vegetative pathogens, e.g. salmonella spp. ~ Use of appropriate facilites, e.g. thawing cabinet/room, to ensure items properly thawed + Knowledge of time to thaw specific weights/dimensions of materials + Cooking toa safe core temperature rather than 5.Inadequete thawing Allows survival of pathogens during subsequent cooking simply a predetermined time in the oven. + Staff training 6,Cross-contamination 7.Improper hot holding 8, Infected food handlers i Peedi) Contamination with pathogens, chemical (e.g, allergens) or physical hazards ‘Multiplication of pathogens Contamination with pathogens INTERMEDIATE HACCP An introduct + Effective pest control Da tea hat Segregation of raw and ready-to-eat food or allergens from nor-allergen-containing food at all times Segregation (zoning) of production rooms, facilities, equipment and personnel Separate food-contact surfaces and equipment (colour coding) (zoning) Scheduling use of allergens separately from non-allergenic foods Effective cleaning and disinfection High standards of personal hygiene Staff training All food maintained above 63°C Prepare minimum amount of food Staff training Pre-employment medical questionnaire/screening Screening of staff and visitors High standards of personal hygiene Staff training, especially reporting of illness and handwashing Appropriate facilities provided 9.Raw or undercooked food consumed Inherent contamination - normally pathogens or chemical hazards Hazardous raw food not included in menu offering Refrain from serving undercooked food, eg, burgers,or advise consumers of health risks Only use reputable suppliers Staff training (re:suspect food) 10.Contaminated ingredients/processed food used Inherent contamination present may be pathogens or chemical or physical hazards - due to fault earlier in the food supply chain Purchase all food from reputable/approved suppliers Do not use damaged cans or packages Staff training In order to manage these issues effectively, a food safety management system needs to be developed, implemented and maintained. eae HACCP: A food safety management system which identifies, evaluates and controls hazards which are significant for food safety. What is HACCP? Hazard analysis critical control point requires development of the HACCP plan, a document that states how food safety hazards will be controlled in the operation. It is normally developed by a multidisciplinary HACCP team, including several personnel from the food operation. The HACCP system comprises the HACCP plan plus associated monitoring and verification records, which demonstrate that the HACCP plan is working in practice at all times. HACCP systems are developed through the application of the internationally agreed HACCP principles. PRINCIPLE 1 Conduct a hazard analysis PRINCIPLE 2 Determine the critical control points (CCPs) PRINCIPLE 3 Establish critical limitis) PRINCIPLE 4 Establish a system to monitor control of the CCP PRINCIPLE 5 Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control PRINCIPLE 6 Establish procedures for verification to confirm that the HACCP system is working effectively PRINCIPLE 7 Establish documentation concerning all procedures and records appropriate to these principles and their application History and background to HACCP HACCP is not new. It has been used in the food manufacturing industry since the 1960s and is widely accepted as the most effective way of preventing foodborne illness. It is worth considering the history of HACCP to understand where we are today with the application of food safety management systems. The HACCP system was developed in the late 1950s/early 1960s as part of the American manned space programme. At this time the Pillsbury Company was working with NASA and the United States Army laboratories to develop suitable foods for the astronauts in space. Up until this time, most food control systems had been based on end-product testing. However, it was thought that this would not give enough assurance of food safety - the only way to ‘guarantee’ safety would be to test 100% of the product, leaving none for use. Instead, a preventive approach was sought and it was found in the engineering system Failure Mode and Effect Analysis (FMEA). Taking the FMEA approach as a starting point, the team adapted this into the basis of the HACCP system that we know today, a system that looks at what can go wrong at each step in the process and builds in control to prevent the problem from occurring. The HACCP system was presented in public for the first time in 1971 at a food protection conference in the USA. This led to a number of large manufacturers starting to use the approach and word gradually spread around the world, Uptake of HACCP by food companies was initially slow, partly because the approach was not fully defined (there were no ‘how to’ guides) and partly because HACCP was not required by regulators nor promoted internationally. This started to change in the 1980s when the US National Academy of Science recommended that HACCP be used by food factories and the International Commission for Microbiological Criteria for Foods (ICMSF) recommended its use and published a guide to the application of HACCP. It wasn’t until the 1990s there was full international acceptance of HACCP, when the World Health Organization's (WHO) Codex Alimentarius Committee on Food Hygiene published its HACCP principles. This document and the virtually identical US version (National Advisory Committee on Microbiological Specifications for Foods - NACMCF) became the international HACCP ‘standards’, and their updated versions are still the accepted approach to HACCP today. The inclusion of HACCP principles in food safety legislation has also been increasing around the world. In the UK and EU several HACCP principles were required by the EC directive on the Hygiene of Foodstuffs (93/43) that was implemented in the UK through the Food Safety (General Food Hygiene) Regulations 1995. On 1st January 2006 most food businesses in the EU were required to implement a food safety management system based on the Codex HACCP principles when Regulation (EC) No 852/2004 on the Hygiene of Foodstuffs became law, however the law allows some flexibility in approach. HACCP timeline Increasing inclusion of HACCP in legislation & external audit/ certification schemes. Codex Hacc Principles first published. The HACCP HACCP US National system was presented Academy of developed in public in Sciences in the late 1971. and ICMSF 1950s/early recommend 1960s. HACCP use. INTERMEDIATE HACCP An introduction to HACCP Why HACCP fails In theory, the HACCP system should be the best way of controlling foodborne illness because it is based on preventing problems from occurring. Experience from industries that have implemented HACCP correctly show us that it is a proven system that does prevent food incidents. This is illustrated by the few instances of food poisoning outbreaks where a company has fully implemented a HACCP system. Studies have also been done showing a general improvement in microbiological contamination within food operations that have implemented an Reasons for HACCP failure ere Core eee) Poor hygiene practices Ensure operation has basic prerequisite programmes working to support HACCP. (prerequisites) Lack of management ‘Operation manager(s) must understand and commit to the HACCP process at the commitment or poor start of the project. Understand and promote a positive food safety culture, food safety culture Externally imposed “The HACCP system needs to be owned by the food business that operates it. Ifitis externally imposed, eg. by a customer or regulatory body, without the ‘commitment and ownership of business management the system is unlikely _| to be successful Lack of resources, especially| Management commitment to make resources available. time for implementation, | Effective planning, e.g. scheduling appropriate time for monitoring, monitoring etc. TToo complex - unnecessary | Avoid jargon and keep language simple. Staff training. jargon makes the system hard to understand Lack of knowledge ‘Appropriate training for groups of staff, e.g, those involved in HACCP development and those involved in every-day control of the operation. Seek expert help if necessary. Poor records too little or | Need to identify what types of records are essential to food safety and keep these. too much paperwork System not‘lve’-sitsin | HACCP is nota paperwork exercise. Control and monitoring procedures identified managers office during the HACCP study need to work every day in practice. Training and supervision of staff essential. Badly defined CCPs and __| Effective training of personnel involved in developing HACCP Plans. control systems CPs need to be: + science based + for food safety only (not quality) Monitoring needs to be: + focused on CPs (and prerequisites) + capable of detecting loss of control of CCP Critical limits need to be: + science based + achievable + relevant to the particular hazard Corrective action needs to: + address the process problem + deal with the food produced while the CCP was out of control a effective food safety management system (hygiene and HACCP controls). However, not all companies have been successful with HACCP and it is important to understand where there have been problems to avoid the same pitfalls The path to successful food safety management through HACC! isi Pp programmes follows several steps: z a iran) Ui teeiar War Cd on aed We will discuss prerequisite programmes in more detail in chapter 3 and HACCP systems in chapters 4 to 6, At this stage it is useful to consider the outline process that a food operation needs to go through to apply HACCP. This involves a number of interlinked stages that lead to the development and implementation of HACCP plans, through the application of the Codex HACCP principles, as shown below. HACCP application process (reproduced from Wallace, et al 2005) retro ce] Pie HACCP plan Chena Principle 5 Cee) ae Ces) Picard Crea rare Perea As shown in the diagram, the seven Codex HACCP principles are applied at different stages in the process. Codex also includes a number of preliminary step: that cover the preparation needed for HACCP, including commitment and training. Benefits of HACCP Many and varied benefits of HACCP have been described, including: better understanding of the processes and rationale for food safety controls; @ personnel understand their roles better and are better trained; provides a systematic approach; An introduction to HACCP % control is tightened up, which may also lead to quality benefits; proactive strategy means that controls are built in to prevent problems and these are continuously managed; real-time monitoring so problems are quickly identified and can be actioned straight away; and cost effective by targeting resource to the essential areas. Before closing this chapter let's look at how HACCP links both with other aspects of food safety management and with business responsibilities under the law. All businesses operate to their own policies and objectives. For example, it might be company policy to use the freshest ingredients or to source material locally or to provide nourishing food at value for money prices. It is also important to consider a food safety policy for the business. At its simplest, this might be a commitment to provide safe food to the consumer, and this can be delivered through the application of systems and procedures such as HACCP and prerequisite programmes. Implementation and management of these systems and procedures will allow the company to achieve its own food safety policy and to meet the requirements of food safety legislation. The following figure shows the interrelationship of food safety management systems within the food operation. Although this diagram may seem complicated at first sight, the individual elements are straightforward and will be covered in more depth in later chapters. | The inter-relationship of food safety management systems (adapted from Sprenger) CR OTe systems one aaa yong bestia ear ee oa ea KEY POINTS Food safety management is the application of systems and processes in a food operation in order to prevent food poisoning and protect consumer health. In any food operation, food safety management is achieved through the application of system ‘building blocks' - safe recipe/process design, prerequisite programmes and HACCP. Hazard analysis critical control point is a preventive approach to food safety management. The HACCP system was developed for food manufacturers in the late 1950s/early 1960s as part of the American manned space programme. HACCP was developed from the engineering system, failure mode and effect analysis (FMEA). By studying previous outbreaks of food poisoning we can understand their causes and take action to prevent them recurring. Experience from industries that have implemented HACCP correctly show us that it is a proven system that does prevent food safety incidents. Wet Naf or Cl Uren RUC mnt cr) 2 An introduction to food hazards and their control Food safety hazards are contaminants that may cause a food product to be unsafe for consumption. Hazards may enter a food product from its ingredients or may contaminate the food during processing or handling. e y rae) a i) What are hazards? Biological, chemical and physical hazards Controlling hazards Hazards and safe recipe/process design Allergens - an emerging area of concern eeoeoeoe What are hazards? DEFINITION Abhazard is defined by Codex as: Abiological, chemical’ or physical agent in, or condition of food with the potential to cause harm (an adverse health effect) to the consumer. Hazards affect the safety rather than the quality of food. Biological hazards are generally concerned with the presence, cross- contamination, multiplication and survival of \' micro-organisms. Chemical hazards involve the presence or contamination of foods with toxic chemicals or allergens, and physical hazards are items that might be _ present or might enter food that are either sharp, hard or of dimensions that can cause choking. Causing consumers burns due to extreme high temperatures of food/drink served {A may also be considered as an example of a physical hazard in a catering operation. In this case, the hazard is related to the ‘condition of food’ as per the Codex definition above. The following table shows examples of common hazard types for consideration. Me ues ste Cie en EE Cac eT Prarie lF Organisms that can couse harm through infection or intoxication Considerations Examples of food safety hazards' (adapted from Wallace, 2005) for) ‘Chemicals that can cause harm through toxic effects, either immediate or long- term Cer) Items that can cause harm through direct injury or choking Pathogenic bacteria, e.g Escherichia coli Bacillus cereus Campylobacter jejuni Clostridium botulinum Clostridium perfringens Listeria monocytogenes Salmonella spp. Staphylococcus aureus Vibrio parahaemolyticus Viruses, e.g. norovirus Protozoan parasites, e.g Cryptosporidium parvum Giardia intestinalis yclospora cayetanensis Examples Mycotoxins, e.g. Aflatoxins Patulin Vomitoxin Fumonisin Pesticides Allergenic materials Heavy metals PCBs Dioxins Cleaning chemicals Natural poisons, e.. Ciguatera fish poisoning or toxic mushrooms Industrial chemicals, e.g. refrigerants Glass Metal Stones Wood Plastic Pests Intrinsic natural materiale. bone, nut shell String and fibres Building fabric.e.g. paint flakes, cladding, etc, Items from personnel.eg. hair clothing, buttons, jewellery, pens/pen tops, smoking materials ‘This table provides examples only and is not intended to be an exhaustive list of food safety hazards. Controlling hazards Hazards are controlled by control measures, defined by Codex as: or reduce it to an acceptable level. + + + ea of allergens. Control measures: Actions or activities required to prevent or eliminate a food safety hazard Control measures may take a wide variety of forms and may be part of HACCP where they control food safety hazards, or part of prerequisite programmes where tht control the general operational conditions that provide a foundation for food safety. Control measures can be, for example: process steps such as cooking or cooling; application of procedures such as handwashing or metal control; inherent in the recipe for the food item, e.g. pH or acidity preventing the growth of micro-organisms; segregation practices to prevent cross-contamination; and % effective labelling practices, e.g. to show the presence or potential presené ene Peeled oll MEME Ruel ic | When developing prerequisite programmes and HACCP it is important to consider the most appropriate control measures. In many catering and retail operations, the majority of controls for chemical and physical hazards will be in the prerequisite programmes. This is also true in manufacturing, although online control systems such as sieving and metal detection can also be used. Hazards and safe recipe/process design In chapter 1 we considered the food safety management system model, requiring safe design, prerequisite programmes and HACCP. Most new food development and design work relies on variations to existing recipes and processes. As such, there are unlikely to be any major changes in the types of hazards or processes to control them. However, when more novel development work is being done, perhaps using new types of ingredients or different approaches to cooking or processing, it is vital to think about new hazards that may be presented. At the recipe design stage it is important to understand the likely hazards that might be encountered in the chosen ingredient types, or that might be present in the processing environment. This allows the manager/HACCP team leader to identify the best ways to control these hazards, either by preventing their entry to the process, destroying them or reducing the contamination to a level where it would not pose a food safety risk. This information on likely hazards and proposed control options should link with the prerequisite good manufacturing/good hygiene practice programmes and HACCP systems to ensure everyday control is established in the operation. Consideration of likely hazards at an early stage in the development process can also, in some cases, help to design these hazards out of the product, either through careful choice and sourcing of ingredients or through identification of appropriate processing technologies and/or equipment. For example, if there is a concern about physical hazards gaining entry to a food item during processing due to the use of open vessels, the redesign of the equipment to use enclosed vessels would prevent this hazard from ever occurring at that processing step. Similarly, if there is concern about pathogen contamination in a raw ingredient, e.g. salmonella spp. contamination in coconut that is to be used as a topping ingredient after heat Processing, it may be possible to replace this ingredient with a pre-processed ingredient, in this example pasteurised coconut. The use of prepared vegetables, replacing frozen chicken with fresh, and finding replacements for allergenic ingredients are further examples of reducing hazards or their causes by design. Further information on typical hazards and their control in catering can be found in appendix 1. INTERMEDIATE HACCP An introduction to food hazards and their control Allergens - an emerging area of concern Control of food allergens is a serious issue for the food industry since allergens can cause serious illness and death in susceptible individuals. The main challenges are to identify and manage the presence of food allergens and to provide accurate information to consumers about their presence in foods. Perhaps the greatest danger to food allergy sufferers is the presence of an allergen in a product where it is not labelled/identified. In order to manage the risks of allergens to consumers, food processors and caterers must: 1. Identify potentially allergenic ingredients and foods containing them. 2. Develop and implement an allergen control system based on HACCP and prerequisite programmes. This needs to include strategies for the prevention of cross-contamination risks, such as cleaning and segregation. 3. Label the presence of allergens in the end product and/or identify on the menu. The lists of allergens that must be labelled in retail food products are detailed in EC Regulation 1169/2011. These are: Cereals containing gluten, namely: wheat, rye, barley, oats, spelt, kamut or their hybridised strains, and products thereof, except: 4 wheat based glucose syrups including dextrose; ~~ wheat based maltodextrins; % glucose syrups based on barley; cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin; 4 Crustaceans and products thereof; Eggs and products thereof; Fish and products thereof, except: % — fish gelatine used as carrier for vitamin or carotenoid preparations; % fish gelatine or Isinglass used as fining agent in beer and wine; oe Betas h cl Ere Ur RuCl 4 Peanuts and products thereof; ¢ Soybeans and products thereof, except: fully refined soybean oil and fat (1); natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soybean sources; ¢ ~~ vegetable oils derived phytosterols and phytosterol esters from soybean sources; * plant stanol ester produced from vegetable oil sterols from soybean sources; % Milk and products thereof (including lactose), except: ¢ ~~ whey used for making alcoholic distillates including ethyl alcohol of agricultural origin; ¢ — Iactitol; ~Nuts,namely:almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoinensis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia), and products thereof, except for nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin; Celery and products thereof; Mustard and products thereof; Sesame seeds and products thereof; Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers; Lupin and products thereof; and % Molluscs and products thereof. aM teooe ° Guidance on food allergy legislative requirements and further helpful information on managing food allergens can be found at: www.food.gov.uk/business- : industry/guidancenotes/allergy-quide/#.UVA5pFfSByk The Food Standards Agency has also provided an online training tool on food allergy and this can be accessed at: http://allergytraining.food.gov.uk/english/ ACCP An introduction to food hazards and their control Previously, there was a lack of legal requirements for many catered food products to be labelled in the same way as retailed products. This made it extremely difficult for allergic consumers to shop for these products safely. To overcome this there has been a move over the last few years towards improving the labelling in catering environments. At the end of 2014, new legislation was introduced that requires food businesses to provide allergy information on food sold unpackaged - the EU Food Information for Consumers Regulation 1169/2011. This affects food sold in, for example, sandwich shops, catering outlets, deli counters, bakeries, etc. Given the likely constraints regarding kitchen design and layout, process control and technical knowledge/capability in this sector, it is still likely that information given on labels or menus in catering establishments could be wrong or misleading. It is, therefore, important that food business proprietors take steps both to understand the ! legislation and to understand and manage the risks within their businesses. i828) ED Food safety hazards are contaminants that may cause a food product to be unsafe for consumption. ¢ Hazards may enter a food product from its ingredients or may contaminate food during processing or handling. % Hazards affect the safety rather than the quality of food. % Control measures are actions and activities that can be used to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Control measures are involved in both prerequisites and HACCP. % — Itis important to have an understanding of likely hazards when developing new recipes and processes, and to keep up-to-date with knowledge in emerging areas such as allergens. Se aa ea Se FT ROC a 3 HACCP and the law Around the world, governments and enforcement authorities are increasingly recognising HACCP as the most effective means of managing food safety. CHAPTER TOPICS 4 EU/UK legislation 4 The international situation EU/UK legislation In the UK, as in other EU countries, the legislative position regarding HACCP is governed by Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs. The key sections of the regulation are Article 5 and Annex Il - see below. Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs Hazard analysis and critical control points Article 5 1. Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles. 2. The HACCP principles referred to in paragraph 1 consist of the following: (a) _ identifying any hazards that must be prevented, eliminated or reduced to acceptable levels; (b) _ identifying the critical control points at the step or steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels; (¢) _ establishing critical limits at critical control points which separate acceptability from unacceptability for the prevention, elimination or reduction of identified hazards; (d) _ establishing and implementing effective monitoring procedures at critical control points; (e) _ establishing corrective actions when monitoring indicates that a critical control point is not under control; (f)__ establishing procedures, which shall be carried out regularly, to verify that the measures outlined in subparagraphs (a) to (e) are working effectively; and (g) 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). iis ieee Ce eT Rae When any modification is made in the product, process, or any step, food business operators shall review the procedure and make the necessary changes to it. Paragraph 1 shall apply only to food business operators carrying out any stage of production, processing and distribution of food after primary production and those associated operations listed in Annex |. Food business operators shall: (a) provide the competent authority with evidence of their compliance with paragraph 1 in the manner that the competent authority requires, taking account of the nature and size of the food business; (b) ensure that any documents describing the procedures developed in accordance with this Article are up to date at all times; and (¢) _ retain any other documents and records for an appropriate period. 4 a Annex II Chapter XII Training Food business operators are to ensure: 1. that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity; 2. that those responsible for the development and maintenance of the procedure referred to in Article 5(1) of this Regulation or the operation of relevant guides have received adequate training in the application of HACCP principles; and 3. compliance with any requirements of national law concerning training programmes for persons working in certain food sectors. Annex !l also contains general hygiene requirements for all food business operators, ie.the prerequisite programme requirements. So what does this mean? Essentially, all food business operators need to implement a food safety management system based on the HACCP principles and have appropriate training to do so. However, the flexibility allowed, especially for small businesses, means that a range of food safety management systems will be acceptable from the implementation of good hygiene practices for small low-risk businesses to the requirement for Codex HACCP to be applied to large food manufacturers. Although the Codex HACCP principles are not reproduced word for word, paragraph 2 (a-g) of article 5 has the same general meaning. Some commentators have noted that the legislation requires identification of hazards while Codex requires analysis of hazards, However, it could be argued that the only way to know which hazards must be prevented, eliminated or reduced to acceptable levels is to analyse them. A key point in the legislation is the requirement to review the food safety system and make any necessary changes whenever ‘any modification is made to the product, process of any step'. This essential requirement of Codex HACCP ensures that the system remains ‘live’ and up-to-date with any new information on hazards and their control. HACCP and the law The international situation HACCP is not governed by international legislation, but is being increasingly included in or inferred by the food control legislation of many countries around the world. For example, the Food Safety Modernisation Act in the USA requires analysis of hazards that are reasonably likely to occur and development of a preventative food safety control plan, in essence a requirement to apply HACCP principles. Internationally, HACCP is promoted by the World Health Organization (WHO) as the most effective way of controlling food poisoning. The joint WHO/FAO? Codex Alimentarius Commission provides the international HACCP 'standard' through its Food Hygiene Committee’s HACCP principles. Codex is able to influence food regulation world wide and uses food safety best practice standards from member governments in compiling Codex standards. This has been helpful in international standardisation. In 1995, as part of the General Agreement on Tariffs and Trades (GATT) and establishment of the World Trade Organisation (WTO), the concept of mutual agreement of standards or equivalence was established. This means that equivalence of food safety systems of each trading partner must be established before trading can commence. Use of the Codex HACCP principles around the world should help to facilitate this equivalence. The current version of the Codex HACCP. principles and guidelines are published in the Codex Food Hygiene Basic Texts, 4th edition. www.fao.org/docrep/012/a1552e/a1552e00.htm However, at the time of writing, the Codex documents were being updated with a view to providing better and easier to understand guidance on the application of HACCP principles. Because of the relatively slow speed of Codex updates, it may be several years before the new document is published but the progress can be monitored on the Codex Alimentarius website. www.fao.org/fao-who-codexalimentarius/en/ ACCP HACCP and the law KEY POINTS The legislative position in the EU/UK regarding HACCP changed on 1 January 2006 with the introduction of Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs. All food business operators need to apply HACCP principles to their operations and persons responsible for the implementation of the HACCP system must have appropriate training to do so. The HACCP principles are listed in the EU regulation, and documentation and verification, including review, are now required in all businesses. The training requirements have also been strengthened. HACCP is increasingly being included in the food control legislation of many countries around the world. Codex Alimentarius Commission provides the international HACCP. ‘standard! through its Food Hygiene Committee’s HACCP principles. The concept of mutual agreement of standards or equivalence was established as part of the General Agreement on Tariffs and Trades (GATT) and establishment of the World Trade Organisation (WTO). 25A0 = Food and Agriculture Organisation of the United Nations. 4 Essential hygiene foundations - the prerequisite programmes In order for food safety management to be effective, it is essential that HACCP be supported by good hygienic practices (GHP) or prerequisite programmes that control the general hygiene and environmental conditions in a food operation. Tati ake) 4 What are prerequisite programmes? ¢@ Prerequisite programmes - the essentials Control of physical and chemical hazards in catering and retail What are prerequisite programmes? These systems and procedures include a number of topics as shown below. cory oe Coe End Cera laa Hygiene prerequisites for HACCP (adapted from Mortimore & Wallace 2001) INTERMEDIATE HACCP Essential hygiene foundat The terms ‘prerequisite programmes’, ‘good manufacturing practice’ and ‘good hygienic practice’ are used interchangeably in different parts of the world but have the same general meaning. We will use the term prerequisite programmes. Several groups have suggested definitions for the term prerequisites - whilst there is no single international definition, the wording of the commonly used definitions can be seen to be very similar: Prerequisite programmes: eam Practices and conditions needed prior to and during the implementation of HACCP and which are essential to food safety. WHO? 1999 Ean Universal steps or procedures that control the operating conditions within a food establishment, allowing for environmental conditions that are favourable for the production of safe food. CFSA* 1998 DEFINITION = Procedures, including good manufacturing practice (GMP), that address operational conditions, providing the foundation for the HACCP system. NACMCF> 1997 PE Food safety basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain suitable for the production, handling and provision of safe end products and safe food for human consumption. ISO* 22000 2005 The internationally accepted requirements for prerequisites are defined in the Codex General Principles of Food Hygiene. This document is published along with the Codex HACCP Principles and Guidelines in the ‘Codex Alimentarius Food Hygie! Basic Texts' and is available to download online from the FAO Corporate Document Repository at: www.fao.org/docrep/012/a1552e/a1552e00.htm The requirements of the EC Food Hygiene Regulation (852/2004) are closely aligned with the Codex document, as shown in the following table. This Food Hygiene Regulation covers all prerequisite programme areas mentioned in Codex, with the exception of the product information and consumer awareness section. The requirements of these topics are covered separately in other legislation on labelling and traceability. 3 WHO = World Health Organization 4cFSA = Canadian Food Safety Agency. SNACMCE = The USA National Advisory Committee for Microbiological Criteria for Foods. Se nt Reese Cu CCRC Cis REGULATION (EC) No 852/2004 on the Hygiene of Foodstuffs ANNEX I General hygiene requirements for all food business operators, General requirements for food premises (chapter |) Specific requirements in rooms where foodstuffs are prepared (chapter 1) Requirements for movable and/or temporary premises (chapter Il} Equipment requirements (chapter V) General requirements for food premises (chapter ) Specific requirements in rooms where foodstuffs are prepared (chapter I) Requirements for movable and/or temporary premises (chapter I!) Water supply (chapter Vil) Provisions applicable to foodstuffs (chapter IX) .gement and supervision Provisions applicable to the wrapping and packaging of jecumentation and records foodstuffs (chapter X) I procedures Heat treatment (chapter X!)- only applies to food placed on the market in hermetically sealed containers, e.g. cans, pouches ishment: Maintenance & Sanitation | Food waste (chapter VI) intenance and cleaning Provisions applicable to foodstuffs (chapter IX) | Cleaning programmes Pest control systems | Waste management Monitoring effectiveness [ Establishment: Personal Hygiene Personal hygiene (chapter Vill) | Health status lines and injuries Personal cleanliness Personal behaviour Visitors Transportation ‘Transport (chapter |V) General Requirements | Use and maintenance Product information and Consumer Not included in 852/2004. Covered separately in a number of Awareness different pieces of legislation, the significant ones for food safety Lotidentification being Product information Labelling DIRECTIVE 2000/13/EC - on the approximation of the laws of the ‘Member States relating to the labelling, presentation and ‘Consumer education advertising of foodstuffs REGULATION (EC) No 178/2002 - General Food Law Regulation. Includes traceability requirements under article 18 DIRECTIVE 2003/89/EC - amending Directive 2000/13/EC as regards indication of the ingredients present in foodstuffs - includes allergen control list DIRECTIVE 2006/142/EC - amending Directive 2000/13/EC - includes update to allergen control list Training Training (chapter Xil) Awareness and responsibilities Training programmes Instruction and supervision Refresher training

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