HACCP System: A Tool for Ensuring Food Safety

The HACCP (Hazard Analysis and Critical Control Points) system is a science-based and systematic approach designed to manage food safety risks throughout the food production and supply chain. It not only helps ensure that food products are safe for consumers but also ensures compliance with legal requirements.

Codex Alimentarius CXC 1-1969 “General Principles of Food Hygiene” highlights the importance of Good Hygiene Practices (GHP), emphasizing the need to focus on these practices to eliminate significant identified hazards. Certain GHP measures may require additional attention to address food safety issues and ensure food safety. Enhanced measures may include increased frequency of application, monitoring, and verification of specific GHPs.

To address this gap, the ISO 22000 standard, introduced in 2005, established Operational Prerequisite Programs (oPRPs). These are control measures implemented to prevent significant food safety hazards or reduce them to an acceptable level. During hazard analysis, these measures are identified as essential for controlling certain significant hazards.

Examples of GHP and/or oPRPs:

• Cleaning of equipment and surfaces in contact with finished food should be prioritized over areas like walls and ceilings, as improperly cleaned contact surfaces can directly contaminate food with pathogenic bacteria.

• Enhanced cleaning and disinfection, as well as stricter personal hygiene, in high-risk areas such as open product zones and finished food packaging areas.

• Inspection of raw materials upon receipt if the supplier does not guarantee the desired level of quality and/or safety.

• Effective cleaning to control cross-contamination between production batches containing different allergens. The severity of health impacts can be high, and the risk of cross-contamination must be minimized.

The Benefits of HACCP Procedures: HACCP-based procedures not only enhance food safety but also provide additional benefits such as facilitating inspections or audits by regulatory authorities and promoting international trade by strengthening confidence in food safety.

The Seven Principles of HACCP: As outlined in Article 5(2)(a–g) of Regulation (EC) No. 852/2004, HACCP-based procedures rely on the following seven principles:

a) Identification of hazards that need to be prevented, eliminated, or reduced to acceptable levels (hazard analysis) and determination of control measures.

b) Determination of critical control points (CCPs) in the process where control is essential to prevent, eliminate, or reduce significant hazards to acceptable levels.

c) Establishing critical limits for CCPs to distinguish between acceptable and unacceptable levels, ensuring the prevention, elimination, or reduction of identified hazards.

d) Establishing and implementing effective monitoring procedures for each CCP.

e) Defining corrective actions when monitoring indicates that a CCP is out of control.

f) Validating the HACCP plan and regularly verifying that the measures outlined in principles 1–5 are effectively implemented.

g) Establishing appropriate documentation and records to demonstrate effective application of measures outlined in principles 1–6, tailored to the nature and size of the food handling business.

When developing and implementing HACCP-based procedures as outlined in the HACCP plan, food business operators should consider the intended use of the final product (e.g., whether it will undergo thermal processing), vulnerable consumer groups, and reliable epidemiological data on food safety.

Purpose and Application of HACCP-Based Procedures: The purpose of HACCP-based procedures is to control CCPs. These procedures should be applied separately to each specific operation or stage. Any changes to the product, process, or any stage of production require a review of the HACCP-based procedures and necessary adjustments. These procedures should be applied flexibly, considering the nature and scale of the operation.

The Relationship Between HACCP and GHP/GMP in Preparing an HACCP Plan: The HACCP program is closely tied to Good Hygiene Practices (GHP) and Good Manufacturing Practices (GMP), which form the foundation for all HACCP procedures. These are prerequisite programs, including:

• Personnel hygiene management.

• Sanitation assurance.

• Infrastructure maintenance.

• Equipment maintenance.

• Raw material, ingredient, and finished product monitoring.

• Product retention and market recall.

GHP/GMP and HACCP Connection: GHP/GMP ensures that food safety issues are addressed before reaching critical control points (CCPs). In other words, GHP/GMP are the "prerequisite programs" that prepare the ground for the HACCP plan.

Identifying Critical Control Points (CCPs) and Their Differences from Control Points (CPs): Critical Control Points (CCPs) are process stages where significant hazards can be eliminated or reduced to acceptable levels. CCPs are essential stages requiring control to prevent, eliminate, or reduce food safety hazards to acceptable levels. For example:

• Microbiological hazard control often involves temperature requirements, such as time and temperature conditions for pasteurization to reduce or eliminate risks.

• Checking canned food for micro-damage or using metal detectors for physical hazards are other CCP examples.

Control Points (CPs), on the other hand, are less critical as the risks identified at these points are not significant. For instance, temperature control during storage is important but not critical.

Establishing Critical Limits for CCPs: Critical limits must be defined for monitoring each CCP. These limits ensure that the acceptable level of food safety risk in the final product is not exceeded. Critical limits must be measurable.

Traceability System: Organizations must implement a traceability system that allows the identification of product batches and their links to used raw materials. Article 18(1) of Regulation (EC) No. 178/2002 stipulates that traceability must be ensured at all stages of production, processing, and distribution of food, feed, food-producing animals, and any substances intended for inclusion in food or feed. Food business operators must have systems and procedures to identify suppliers and customers linked to their food and feed products.

Corrective and Adjustment Actions: Even with a well-developed and implemented HACCP program, errors can occur. Therefore, an effective corrective action plan is necessary, including:

• Identifying non-conformities: What to do if a critical limit is exceeded?

• Solving the problem: For example, improperly pasteurized milk is returned to the system and re-pasteurized.

• Analyzing causes: Why did the error occur, and how can it be prevented in the future?

Food Safety Culture (FSC): In the fall of 2020, the review of the “General Principles of Food Hygiene” (CXC 1-1969) highlighted the importance of creating and maintaining FSC for the successful operation of any food hygiene system. With the adoption of Commission Regulation (EU) 2021/382 in March 2021, which defines FSC elements, a new Section XIa on FSC was added to Annex II of Regulation (EC) No. 852/2004. Therefore, food business operators, excluding primary production and related operations, must comply with this requirement.

FSC Elements as Defined in Section XIa of Annex II of Regulation (EC) No. 852/2004:

• Commitment from management and all employees to ensuring the safe production and distribution of food.

• Leadership to ensure safe food production and adherence to food safety rules by all employees.

• Ensuring that all employees are informed about food safety hazards and the importance of food safety and hygiene.

• Open and clear communication among all employees, including reporting deviations and setting expectations.

• Awareness of the scope of communication within the organization concerning food safety.

• Adequate resources to ensure safe and hygienic food handling, including time, personnel, infrastructure, education, training, and procedures.

Internal Audits and HACCP Effectiveness Evaluation: Internal audits are essential to verify the proper implementation of the HACCP plan. They should be conducted periodically and cover the following aspects:

• Are all CCPs monitored as described in the HACCP plan?

• Are personnel following established requirements and aware of their responsibilities?

• Are documents updated and maintained as required? Internal audits also assess the effectiveness of corrective actions and their proper documentation.

Practical Tips for Implementing HACCP:

• Team Formation: Assemble a qualified team knowledgeable about processes, products, and equipment maintenance.

• Systematic Approach: Use scientific data to accurately assess risks.

• Documentation: Documentation is not only a legal requirement but also an effective communication tool.

• Continuous Review: Risks can change due to new technologies or production changes, so HACCP plans must be reviewed whenever there are changes in production, raw materials, or technological processes.

Conclusion: HACCP is an essential component of the food industry, helping protect consumer health and enhance business competitiveness. Combined with a strong food safety culture and GHP, HACCP becomes the key tool for ensuring high-quality and safe food products.

Sources:

• Codex Alimentarius CXC 1-1969: General Principles of Food Hygiene (2023). Link

• European Commission Communication on the Application of HACCP and GHP in Small Enterprises (2022/C 355/01). Link

• Regulation (EC) No. 852/2004.

• Regulation (EC) No. 178/2002.

• ISO 22000:2018: Food Safety Management Systems – Requirements for Any