|HACCP (Hazard Analysis and Critical Control Points)
Paper by Matthias Neumeier
The HACCP strategy deals with health hazards for consumers emanating from foodstuffs. The strategy is used to identify health hazards and assess the likelihood of the hazard actually occurring. This then forms the basis for drawing up preventive measures. (1)
Alongside the HACCP strategy, there are a large number of other approaches that should generally be seen as complementary rather than independent. These include the International Food Standard (IFS), Food Defense and the Storage regulations of the British Retail Consortium (BRC).
The international transport of foodstuffs between nations that have ratified the ATP treaty is governed by the provisions of the ATP (French: Accord relatif aux transports internationaux de denrées périssables et aux engins spéciaux à utilisier pour ces transports, English: Agreement on the International Carriage of Perishable Foodstuffs and on the Special Equipment to be used for such Carriage).
Furthermore, the relevant Standards and any national legislation apply within the European Union.
This paper, however, only discusses the HACCP strategy in its wider sense.
Food hygiene in general and the HACCP strategy in particular address the entire lifecycle of the individual products, i.e. from harvest or rearing, through processing and right up to delivery and provision to the end consumer. It should be noted that the „end consumer“ here explicitly refers not only to consumers in a supermarket, but also to customers in a company canteen or a restaurant.
The HACCP strategy dates back to 1959, when the American Pillsbury Company was commissioned by the space agency NASA to produce food for astronauts that was suitable for consumption in space and that was absolutely safe. Pillsbury applied the FMEA (failure mode and effects analysis) methodology developed in 1949 by the US military for technical applications to the foodstuffs industry and, together with NASA, further developed this preventive approach. This was published as the HACCP strategy in the USA in 1971. In 1985, the US National Academy of Sciences recommended the use of the strategy. As a consequence of this, it was trialled and further developed across the world. The Codex Alimentarius, published by the Food and Agriculture Organization of the United Nations (FAO), has also recommended the use of the HACCP strategy since 1993.(2)
- Establish and implement „good hygiene practices“
- Establish and implement a self-inspection system on the basis of HACCP
- Annual temperature recorder inspections as per EN 13486
- Documentary evidence (3)
To start with, we should clarify what is meant by „good hygiene practices“.
The need for traceability of foodstuffs from supermarket shelves right back to an original producer, such as an individual farmer, means that the documentation chain is extremely long. Foodstuffs must be correctly processed, stored, transported and presented. In order to prevent any hazards such as contamination, interruption of the cold chain, and physical damage, it is necessary for all hygiene regulations to be adhered to. The transport of foodstuffs is an essential component of the value-added chain.
Good hygiene practice along the entire value-added chain involves far more than simply focusing on cleaning and disinfecting (4) tools and equipment in production.
As a discrete discipline within medical science, hygiene is concerned with taking specific preventive measures to prevent disease and to maintain and improve people’s wellbeing. By the term „hygiene“, we mean that all safeguards are put in place to ensure that the foodstuffs that are produced are completely safe. The transport process must be seen as a fundamental element of the production process.
To ensure that hygiene is upheld throughout the chain, it is necessary for all those involved in the delivery chain to have developed and implemented a coherent hygiene strategy. To speak metaphorically, we can call this a „house of hygiene“. (5)
The foundations of the house are the premises and technical facilities of the transport companies and carriers. The goods that are being transported are often put into temporary storage by logistics providers before they are sent out to the customers, and this means that it is necessary to look at the condition of the storage facilities and the equipment used there, and at the vehicles used to transport the goods. Processes must be controlled and monitored in such a way that the hygiene regulations are adhered to. Which, to stick with our metaphor, brings us to the ground floor of the house of hygiene. Here, we must ensure that:
- the climatic and temperature conditions required for the products are maintained,
- regular cleaning and disinfection are carried out, including pest control.
Personal hygiene in production, processing, and even transport is also an important aspect. In this context, it is vital to note that the job of the driver has changed in that he/she is no longer simply responsible for driving the goods from A to B. Instead, contracts very often cover loading and unloading, and sometimes even transfer of the goods to the recipient’s warehouse, and specify that this is the job of the driver. Unfortunately, some drivers are unaware of this or prefer to ignore it. We do not dispute that this can be the result of faulty or possibly deliberate planning that results in weeks on the road and a life in a truck cab, but that is not the point at issue here. In this context, it comes as some surprise that the owners of the transport companies often fail to take decisive action, even though contracts demand an HACCP strategy. In the UK, on the other hand, it is not unusual for drivers to be issued with company uniforms. Although it serves to reinforce the corporate identity, this measure undoubtedly also contributes to an awareness of hygiene.
Quite apart from the outward appearance of the drivers, it is necessary for each driver to work through the critical points in the HACCP strategy that apply to them. The vehicle (trailer) must also comply with the necessary standards. A refrigerated trailer, for instance, could be subject to the following requirements:
- valid ATP certificate (if required)
- clean and free of odor
- joints and edges must be free of germs and mold
- the refrigeration unit must be in perfect working order
Cleanliness applies to the entire trailer. For example, when transporting hanging meat, the meat must not come into contact with the walls. Nevertheless, a trailer would probably not be loaded if the walls are dirty. Furthermore, if a trailer smells of cleaning agents, it may be clean, but it is not free of odor. Which means that it is not necessarily suitable for transporting foodstuffs, As it is possible for odor to be transferred to the goods that are loaded.
The requirements „clean“ and „free of odor“ also apply to tarpaulin vehicles used to transport foodstuffs. Of course, the tarpaulin, the sidewalls, and so on must show no signs of damage.
When accepting the goods, the driver should take note of the following:
- Precooling of the vehicle used to transport the goods
- Steps to ensure the circulation of air in the trailer (of particular importance on vehicles with double-decker beams, two-level loading and tall loads)
- Product temperatures on accepting the load
- Checking of the required transport temperatures (logical and appropriate to the load)
Possible measures during transport:
- Regular checking of the temperature indicators on the trailer
- Selection of an appropriate parking space (avoid the midday sun in high summer)
Notes on unloading:
- Keep the doors of the trailer shut for as long as possible
- Driver and recipient should measure the temperature of the goods
- Ensure confirmation of correct delivery
As the comments above show, temperature-controlled transport is a complex topic, covering much more than merely getting goods from one place to another.
A coherent HACCP strategy requires:
- that a company analyze any hazards for the safety of the foodstuffs in its area of responsibility,
- that the critical points for the safety of the foodstuffs be determined,
- that critical limits be established for each critical control point,
- that critical control point monitoring procedures are introduced,
- that correction actions are defined in the event of deviation from an established critical limit,
- that monitoring be carried out to check that the system for ensuring food safety as per the HACCP guideline is working as intended and
- that all measures are documented. (6)
The HACCP strategy was incorporated into German legislation for the first time in the 1998 Food Hygiene Regulations. EC Regulation 852/2004 also requires the HACCP strategy to be used in all companies involved in producing, processing and selling foodstuffs. On the 1st of January, 2006, the EU Hygiene package, that was passed in 2004, came into force. This stipulates that only foodstuffs that comply with the HACCP guidelines can be sold in and imported into the European Union.
Even before this legislation came into force, all companies that produce foodstuffs or handle foodstuffs in any way had to have an HACCP strategy. Since 2006, this strategy has had to be documented. In the case of large companies in which there are many hazards and a high risk potential, detailed records are required. For small companies, cleaning plans, evidence of verification or staff instructions are sufficient. (7)
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