SQT Blog

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.

As per BRC Global Food Safety Standard Revision 6, Corrective Action and Root Cause Analysis are viewed as two different things.

Corrective Action is defined as ‘Action to eliminate the cause of a detected non-conformity deviation’

Root Cause is defined as ‘Underlying cause of a problem which if adequately addressed will prevent the recurrence of the problem’

As both definitions are remarkably similar, it is quite difficult to understand one from the other. Applying both terms to a metal detection scenario …

If metal is detected in the product

Corrective Action initially focusses on the removal of the hazard from the product and the identification of where the hazard originated from.

Root Cause Analysis will look at how we allowed the hazard to contaminate the product in the first place …
– Why did our Preventive Maintenance programme fail?
– Have we committed sufficient resources to the maintenance department?
– Do the maintenance personnel fully understand their vital role in hazard control?
– Had our process risk assessment identified the hazard as a reasonable hazard?
As per the Root Cause definition, these are the underlying causes which if addressed will prevent the recurrence of the problem.

As the TESCO Food Manufacturing Standard, (TFMS), requires as an aspiration under section one, that food safety team leaders be trained in advanced HACCP, (FETAC level 6), the need for competency, and confidence in risk assessment, legislation, validation and verification has never been greater.

As the contemporary approach to food safety is to ensure hazards are controlled at factory floor level, by production and maintenance/engineering personnel, technical management by your traditional Quality Assurance Manager is changing. When the TFMS defines the make-up of the food safety team it mentions production, engineering and technical personnel, but there is no mention of Quality. The responsibility for the delivery of a quality product lies primarily with production, with technical personnel providing support, via validation and verification protocols. The requirement on 2nd and 3rd party audits for “validation studies” is becoming a common request, a request that is often met with a blank face.

This Advanced HACCP course (FETAC level 6), will provide those who have already attended the Intermediate HACCP course (FETAC level 5), with the additional level of knowledge, skill and know-how, to lead their food safety team through the demanding process of risk assessment, thus ensuring that their FSMS, (Food Safety Management System), is developed, implemented, validated and verified to the best practice standard.

Our next Advanced HACCP course, (FETAC Level 6), is scheduled for 11-12 February. Our next Intermediate HACCP course, (FETAC Level 5), is scheduled for 22-23 January. Both will be held in Dublin.