HACCP enforcement in New Zealand
5. Other information most likely to be accessed on-site
9.4 Conclusion
9.4.1 Progress with HACCP
HACCP implementation has done much to increase food safety awareness in New Zealand. HACCP training and the introduction of competency standards have dramatically improved industry knowledge from managers to operators on-line. Industry personnel at many levels now have a much greater understanding of how their operation actually works. This same attention to attaining HACCP competency has seen a dramatic improvement in the HACCP knowledge levels among MAF personnel as well.
MAF’s relationship with the food industry sectors continues to grow. This last decade has seen a dramatic increase in the need to consult with food industry sectors as they have moved into HACCP mode, both voluntarily and in a mandatory environment. Some 18 months of mandatory HACCP implementa-tion for the export meat and seafood industry has given clear insight as to how HACCP is working, both from a regulatory and industry perspective. Audit findings have highlighted weaknesses in HACCP implementation, particularly
in relation to setting food safety objectives, validating HACCP plans and providing adequate documentation and record keeping. These issues have been discussed and reviewed in consultation with all stakeholders and, where necessary, changes to mandatory HACCP requirements have been made to clarify requirements further.
Increased consultation also has occurred with the Ministry of Health (as the administrator of food legislation for the domestic market), reflecting govern-ment’s desire to harmonise the approach to food safety across all food industry sectors in New Zealand. As HACCP principles become more integrated into food safety and risk-based programmes under New Zealand legislation, they will assist industries to achieve food safety outcomes for their products consistent with fitness for purpose.
Consumers are slowly increasing their awareness of food safety, realising the importance of good hygienic practice when handling and preparing food or eating out. They are beginning to apply that knowledge to what they buy and eat.
Consumer representatives also are playing a more active role in food industry councils, which will also assist general consumer understanding of food safety issues, including those associated with the application of HACCP.
9.4.2 Outstanding issues
Some outstanding issues are inevitable given the desire to improve continually the practical application of HACCP. These issues include the following:
• HACCP application across the food chain
• hazard identification and analysis including for PRPs
• setting food safety objectives in line with developments in risk analysis
• validating HACCP plans in line with achieving food safety objectives
• skill maintenance for HACCP-competent persons
• application of HACCP to small business.
HACCP application across the food chain
Ideally, HACCP application is expected across the food chain to all types of foods in an equivalent manner, giving appropriate food safety assurance to all consumers. Reality, however, is far from this ideal.
Some segments of the food chain lend themselves to easier application of HACCP than others. Often application of HACCP principles to primary production is limited and food safety hazards can be better addressed by supplier quality assurance systems.
Processors of raw foods often find themselves in difficulties when endeavouring to apply HACCP to their products, especially if they already have good hygienic practice well established. Application of HACCP over and above this often provides little improvement in food safety outcomes as measured by achievement of food safety objectives. Thus HACCP should not be the only answer to achieving desired levels of food safety assurance if other means can demonstrate equivalent results.
Hazard identification and analysis
Hazard identification and analysis must continue to improve with the emphasis on sound science and risk analysis. PRPs (or their equivalent), underpinning HACCP, are likely to come under increasing scrutiny and will ultimately have HACCP principles applied to them in a transparent manner, where this application fits and is relevant. This detail could be expected to be captured in food industry codes of practice, providing a sound basis upon which individual food operators can develop their own documented PRPs, giving added value to the HACCP plans. New Zealand’s requirements under the Animal Products Act 1999 will go a considerable way towards addressing these concerns.
Food safety objectives
Food safety objectives will continue to become more meaningful to HACCP exponents as risk analysis improves food safety linkages to human health.
Increasing interest is already occurring internationally as food safety objectives are promoted as an essential component of equivalency agreements between trading countries to express the ‘expected/desired extent of control of foodborne hazards resulting from application of a sanitary measure’.9
Validation
Validation continues to provide a challenge both to regulatory and industry personnel, as further clarification of requirements is sought. Statistical sampling regimes must play a significant part in this determination of what is enough supporting evidence to demonstrate consistent achievement of food safety objectives.
Skill maintenance for HACCP-competent persons
As HACCP knowledge expands and improves with time, so must the skill level of HACCP-competent people. Food industry training organisations and regulators are grappling with this issue at present, developing strategies to deliver a continuing education programme.
Application of HACCP to small business
Application of HACCP principles to all activities surrounding food production has also had its limitations. HACCP does not work well in small food businesses with limited resources. Not only is the regulator often faced with a limited skill base at this level of operation, but the limitations are particularly evident when trying to apply the principles of verification and record keeping. Unless the small operator can coopt other similar operators to partake in a verification programme designed to encompass a food group rather than individuals, the regulator may have to confine application of verification requirements to extrinsic involvement only. Record keeping must be minimal but enough to support HACCP application at this level.
9.4.3 The international perspective
HACCP is not applied in a similar manner world-wide. Given the Codex Alimentarius Commission’s HACCP guidance document, individual countries have interpreted these seven HACCP principles in a variety of ways that best fit their country’s needs, both practically and politically. Consequently, exporting countries must replicate these HACCP requirements or endeavour to demonstrate an equivalent programme according to the provisions of the World Trade Organisation sanitary and phytosanitary agreement. The problem is that global experience with HACCP across all food sectors, particularly involving raw foods and small businesses, is still very limited and many gaps remain in the scientific knowledge needed to underpin food safety assurances.
International understanding of HACCP and its application will continue to grow, not without intense debate, especially over issues described above. With time this should lead to a more consistent and realistic application of HACCP globally as advances in science and practical experience influence the trends.
Advances in risk analysis are destined to play the most significant part in the evolution of HACCP across the food chain as more information becomes available to strengthen linkages between individual food safety hazards, types of food and intended consumers.
Finally, expect HACCP plans to become the new PRPs of the future. As science advances and technology changes, food production will change and improve, and what is HACCP today will become the basis of, or prerequisite to, new advanced HACCP plans tomorrow.