pretreatment
6.8 Future trends
Many developments concerning the nature and use of HACCP and in relation to the application of HACCP can be expected over the next decade. Mayes (2001) recognizes the continued globalization of the world’s food industry as one of the driving forces for the increased use of HACCP in the food supply chain. He suggests that HACCP will become the benchmark method for food safety
management, as advocated by Codex Alimentarius, and that World Trade Orga-nization (WTO) member countries that adopt Codex standards will not have to justify their sanitary measures under the WTO’s Sanitary and Phytosanitary (SPS) agreement. There would, then, seem to be advantages in working to Codex stan-dards, but as Mayes indicates, the global acceptance of HACCP as the standard for food safety management raises issues about standardized methods of appli-cation, and assessment of the effectiveness of implementation and the ability to control foodborne hazards.
With the development of global food supply chains the potential for the movement of foodborne pathogens (foodborne disease organisms and food poi-soning organisms) from one country to another is increased, with the possibility of increasing the risk of harm from ‘alien’ pathogens for sensitive groups in populations and, possibly, populations themselves. Owing to the speed at which the globalization of food supply is being encouraged by Western governments, international food production and manufacturing businesses and major super-marketing companies, some urgency would seem to be justified in establishing a standardized, water-tight approach to food safety management at all levels of the international food supply system. The circumstances and history of the UK’s BSE disaster demonstrate how a major threat to public health can appear almost from nowhere, with consumer protection lagging behind the occurrence of the hazard.
In this respect, the disaster illustrates a severe limitation of HACCP, especially when applied to food safety in the context of the global food supply chain.
The effectiveness of HACCP systems is contingent on the identification of known hazards, yet, by definition, the unpredicted hazard is the hazard that we do not expect and will not plan to control. In recent years we have become acutely aware of the problem of ‘emergent pathogens’ and that, in some instances, we need to accumulate a body of scientific knowledge and experience concerning such organisms before we can properly establish food safety controls. The global movement of foodstuffs, particularly unprocessed and minimally processed foods, such as fresh vegetables and meat sold through supermarkets, has the potential to expose consumers to new and possibly virulent foodborne pathogens which will not always be accounted for in HACCP plans. How the world’s public health experts deal with such threats remains to be seen.
The development and implementation of HACCP systems relies on the correct interpretation of the seven principles of HACCP. Different businesses and dif-ferent HACCP teams can make very difdif-ferent interpretations and create systems which fail to control hazards as comprehensively and as effectively as they might.
One only has to look at the way the requirements of the EU Directive 93/43 on the hygiene of foodstuffs are dealt with in the UK’s Food Safety (General Food Hygiene) Regulations 1995, and then interpreted by food businesses and local food law enforcement officers, to see what kind of variation is possible in the management of food safety based on standard guidelines. The development of a standardized interpretation of the principles of HACCP and their application in different food sectors is needed (avoiding the inherent problems and limitations of generic HACCP plans), as are standardized approaches to conducting HACCP
studies, implementing and maintaining HACCP systems, documenting HACCP plans and HACCP training. The Codex Alimentarius Commission is tackling the issue of standardized approaches to the use of HACCP and many of the Codex publications on HACCP, for example the document on training in food hygiene and HACCP (FAO, 1998), serve as valuable guides in this.
Alongside the issue of standardizing the use of HACCP is that of standardiz-ing the assessment of HACCP systems. Businesses that implement HACCP systems are generally responsible for assessing the suitability and effectiveness of their own systems. Questions inevitably arise about the consistency of approach to auditing HACCP systems and this is a matter that is likely to receive attention in the future. A factor that impinges on this issue is that of third party audit. In some instances customers, for example supermarkets, require their sup-pliers’ HACCP systems (and quality management systems) to be audited inde-pendently. A number of organizations whose business is the assessment of quality management systems (e.g. Lloyds Register Quality Assurance), also provide third party HACCP system audit services, and many food businesses have their system audited as part of the overall assessment of quality and food safety management against, for example, the BRC and EFSIS standards. The growth in organizations offering third party HACCP system audit services would seem to demand the development of nationally, and internationally, accepted methods of HACCP system approval and audit.
During the 30 years or more that it has taken for HACCP to become widely used by the food industry, the organizations that have been most active in adopt-ing this approach to food safety management have tended to be larger food busi-nesses. Small and medium sized enterprises (SMEs) have found HACCP a difficult concept to grasp (often because of a lack of scientific and technical ability within the businesses) and the requirements of HACCP difficult to implement (often because of a lack of human and physical resources). Developments in HACCP are likely to take into account the variable nature of food businesses and their varying ability to utilize the methodology.
As the concept of a global, integrated food supply system generating an inte-grated food supply chain – ‘from field to fork’ – develops, the use of HACCP by all food businesses in the supply chain will be advocated by public health author-ities and by certain businesses within the food supply chain. For instance, super-markets will require their suppliers to use HACCP for consumer protection, and to enable them to demonstrate that they have acted diligently when sourcing prod-ucts from suppliers. Such developments will, of course, take HACCP into busi-nesses which, traditionally, have not been overly concerned with matters of human food safety, such as farms and agricultural inputs businesses, because food safety was formerly seen as mainly a province of food processors and manufac-turers. Incidents such as the BSE disaster have emphasized the fact that actions and occurrences in one part of the food supply chain (e.g. in animal feed pro-duction) can have dramatic and disastrous consequences for other parts of the chain (e.g. consumers and farmers). The assurance of food safety throughout the whole food chain must, therefore, be addressed by the businesses that constitute
the food supply system. This will, of course, result in HACCP being used in many kinds of food business where it has not previously found application and where interpretation will raise difficulties. For instance, following a serious outbreak of E. coli O157:H7 poisoning in Lanarkshire in 1996/97, UK abattoirs and raw meat processors are now required to implement HACCP systems. As a result abattoirs and meat cutting plants have been advised (MLC, 1999) that a number of CCPs for bacterial pathogen control exist at points in the process involving hide removal, evisceration and carcass dressing. By definition, hazards are either prevented, eliminated or reduced to acceptable levels at CCPs. Given the nature of abattoir operations some contamination of carcasses is inevitable.
Patently, the kinds of controls operated in abattoirs will not prevent, eliminate or reduce pathogens (such as E. coli O157:H7) to acceptable levels. Indeed, abat-toirs do not normally have appropriate, rapid methods even to monitor levels of pathogen control. Logically, cooking meat properly is the way to control meat-borne pathogens, such as E. coli O157:H7. It would seem that the UK’s meat industry has been poorly advised, through a misinterpretation of HACCP, to implement control measures which, rightly, belong to GMP and not HACCP.
Growers of fruit and vegetables can learn from the experiences of other food businesses, such as abattoirs and meat cutting plants, and save themselves from the creation of over-complicated HACCP systems, with all the operating costs entailed.
As stated earlier in this section there are likely to be developments concerned with standardizing the interpretation of HACCP and such developments should yield benefits in the clearer understanding of HACCP for businesses where this approach to food safety management has not normally been used. Alongside developments in standardized approaches, we are also likely to see work which stresses the importance of GMP (or GAP, in the case of farmers and growers) for establishing sound management practices and prerequisites for the development of HACCP plans. Clearly, GMP (or GAP) can provide a firm foundation for HACCP systems, but its importance in creating sensible systems which are cost effective to operate should not be overlooked, and, possibly, needs stressing through work which emphasizes the integration of GMP (or GAP) with HACCP.
In relation to such developments we can also expect to see developments which further the food industry’s understanding of how to integrate beneficially HACCP with quality management systems developed against the ISO 9001: 2000 quality system standard. Finally, it is important to raise the issue of risk assessment. This is, perhaps, one of the most difficult issues to contend with during the develop-ment of HACCP plans. When faced with the possibility of a hazard occurring in the production of a food, stating the likelihood of its occurrence and deciding, therefore, whether it is a hazard that must be controlled can be a difficult and, at times, worrying task. Consequently, HACCP plans are often written that take into account every hazard conceivable, irrespective of whether or not they are likely to occur. Establishing preventive measures, CCPs and monitoring systems for hazards that are highly unlikely to occur only adds to the costs and complexity of implementing and maintaining HACCP systems. Improvements are needed in
how to understand risks and carry out risk assessments that lead to effective, prac-tical HACCP systems which do not suffer from over-design and unnecessary complication.