When attending a BRC conference in 2009 given by one of the leading certification bodies, I came across the following information that struck a chord with me as I believed it summarised in a nutshell the weaknesses in many a HACCP system.
Lack of risk assessments: Most Food Business Operators, (FBOs), have undertaken some form of risk assessment, however when challenged they are not confident in explaining the outcomes. This is because they are not familiar with the methodologies used and do not understand how risk is calculated based on probability and severity.
Confusion of hazard: When asked what hazards exist in the food environment a frequent response is ‘temperature’. Temperature is not a hazard, it’s the exact opposite to a hazard as it is a control measure. When asked what is the hazard in cooking, another common answer given is inadequate time/temperature. This again is not a hazard, it is the cause of the hazard. The actual hazard in cooking is biological survival. Hence hazard, cause, and control are three totally different concepts.
Confusion of Control and Monitoring: As Control is Principle 1 and Monitoring is Principle 4 of the seven HACCP principles, they need to be viewed as two separate elements of a Food Safety Management System, (FSMS). In a cooking process, control is the heat that kills the bug and monitoring is the means by which we prove that the control has worked. Historically there has been excessive focus on monitoring to the detetriment of understanding what control measures actually are.
Lack of Prerequisite programmes: As food safety is currently on a move towards ‘Back to Basics’ a strong robust prerequisite programme is essential to the manufacture of safe food. BRC lists 9 prerequisites yet FSSC requires 15. In my view 15 is the definitive list and companies should strive to develop a Prerequisites programme in compliance with FSSC (Food Safety System Certification).
Poor CCP Identification: How many Critical Control Points, (CCPs)? Too many or too few? When faced with this challenge, FBOs tend to identify excessive numbers of CCPs so that they can’t be accused of leaving some out. This is not always necessarily a good thing as it can dilute the focus from the truly ‘life or death’ process steps which if they fail, human health will be seriously affected.
Lack of Validation: As validation is not listed as one of the seven HACCP principles unlike verification, many Food Safety professionals are very uncomfortable when asked for validation data or validation studies. As validation is essentially generating proof that something ‘can work’, and verification is generating data that something ‘is working’, validation comes first hence with the ‘Back to Basics’ approach to food safety, auditors are now looking for the validation data.
Failure to record decision making: As current Food Safety legisation and voluntary Food Safety standards are written to allow FBOs make their own decisions pertaining to CCP identification, identification of hazards and risk assessment, the reason for such decisions must be recorded as otherwise the basis for such decisions may be lost over time due to personnel change, memory lapses etc. It is not satisfactory for a Technical Manager to explain that a particular process step is a CCP ‘because it was so before I arrived’.
If as a Food Safety professional you are confident that your FSMS is designed in such a way that the seven problems mentioned above are addressed, you can be confident of a successful outcome in any HACCP audit.