Practical Implementation of HACCP system in small companies.

Practical Practical Implementation of Implementation of HACCP system in HACCP system in small companies.small companies.

Sofia, 10 February, 2006Sofia, 10 February, 2006

Brendan Lawlor. H.S.E. Galway , Ireland

Lost ?

YOU ARE NOT ALONE !!

Imagine getting food poisoning Imagine getting food poisoning here!here!

HACCP is intended as a HACCP is intended as a permanent permanent guarantee of guarantee of

Safe FoodSafe Food Its based on preventionIts based on prevention Assures customer in advance, included in price!Assures customer in advance, included in price! Better than sampling food afterwardsBetter than sampling food afterwards Best brains biggest bucks produced it…….it Best brains biggest bucks produced it…….it

worksworks Used in other businessesUsed in other businesses Intelligent Intelligent Varies with size & type of businessVaries with size & type of business It’s a global brandIt’s a global brand Only as good as the people operating the systemOnly as good as the people operating the system

HACCP….Reservations HACCP….Reservations

Is a Is a highly complexhighly complex food safety food safety assuranceassurance system,system,

developed by developed by scientistsscientists, , supervised by supervised by quality-control quality-control

managersmanagers operated by operated by technicianstechnicians, , in in space-age environmentsspace-age environments..

Classical HACCP is an excellent system Classical HACCP is an excellent system for cost effective production of safe food for cost effective production of safe food …..…..

from large manufacturing companies,from large manufacturing companies, consistent processing lines, (e.g. meat consistent processing lines, (e.g. meat

processing plants with veterinary processing plants with veterinary supervision), supervision),

supermarket chains,supermarket chains, franchises with generic solutions, etcfranchises with generic solutions, etc can be useful in Hospitals & Nursing can be useful in Hospitals & Nursing

HomesHomes

It is an altogether It is an altogether different matter for different matter for the vast majority of the vast majority of European food European food businesses, which are businesses, which are small (96%), small (96%), sometimes isolated sometimes isolated and lacking technical and lacking technical knowledge, (e.g. knowledge, (e.g. catering).catering).

Imagine implementing Imagine implementing HACCP here !HACCP here !

HACCP & CATERINGHACCP & CATERING

Most operators of Most operators of small companies can small companies can produce safe foodproduce safe food

(Risk is the issue, (Risk is the issue, not size)not size)

but cannot produce but cannot produce documented hazard documented hazard analysis analysis (bacteriological, (bacteriological, chemical & physical) chemical & physical) and scientific control and scientific control systems. Don’t see systems. Don’t see the need for it.the need for it.

The Reality

Does it work for Does it work for us ?us ?

Joined EEC in 1973Joined EEC in 1973 FSAI set up in FSAI set up in

1998 (47 Agencies)1998 (47 Agencies) HACCP became a HACCP became a

legal requirement legal requirement for us in 1998for us in 1998

HACCP Compliance in Irish HACCP Compliance in Irish Food Businesses (2000)Food Businesses (2000)

Of 510 premises surveyedOf 510 premises surveyed74%74% claimed to have a food claimed to have a food safety management system safety management system 52%52% had heard of the term had heard of the term HACCPHACCPonlyonly 38% 38% believed that they believed that they were responsible for were responsible for developing their own food developing their own food safety management systemsafety management system42% thought their inspector 42% thought their inspector was responsible!was responsible!

High Risk Butcher shops High Risk Butcher shops 20052005

961 examined961 examined 27% are compliant27% are compliant 60% have started the process60% have started the process 13% …….yet to start13% …….yet to start

Was it us ? Are we Was it us ? Are we stupid?stupid?

1998 First country in Eu to have 1998 First country in Eu to have I.S.O. accreditation in food I.S.O. accreditation in food controlcontrol

2000 First accredited national 2000 First accredited national standard for HACCP in Europestandard for HACCP in Europe

2004 We succeeded in 2004 We succeeded in eliminating smoking in the eliminating smoking in the workplace overnight workplace overnight

Publish and be damned !!!Publish and be damned !!!

Is it working elsewhere ?Is it working elsewhere ? In many places HACCP has lost its In many places HACCP has lost its

credibilitycredibility In places it is ignored (soft cheeses)In places it is ignored (soft cheeses) Food workers and inspectors did not Food workers and inspectors did not

understand it. understand it. Who gives what training ?Who gives what training ? Risk identification is difficult with Risk identification is difficult with

familiarityfamiliarity Until 2006 it did not have to be Until 2006 it did not have to be

documenteddocumented

Where we went wrongWhere we went wrong

Inexperienced, inconsistent, Inexperienced, inconsistent, inspectors, did not auditinspectors, did not audit

Files (not systems) were not Files (not systems) were not practical: large and bought off the practical: large and bought off the shelf. Pigs might fly !shelf. Pigs might fly !

Documents were faked; Irish jailDocuments were faked; Irish jail

A paper exercise: GalwayA paper exercise: Galway

Young inspectorate enforcing guides

Food businesses are moving Food businesses are moving into the new millennium, so into the new millennium, so

must we!must we!

Consultants Consultants

Are part of the problem, and part of the Are part of the problem, and part of the solutionsolution

Charged by the sheetCharged by the sheet Wrote plans in their language. Were not Wrote plans in their language. Were not

around for audits: HACCP maintenance around for audits: HACCP maintenance contracts.contracts.

Should be part of HACCP teamShould be part of HACCP team FSAI gave guidanceFSAI gave guidance In many cases, good ones, are essential.In many cases, good ones, are essential.

We were not alone !We were not alone !

HazardHazard AnalysisAnalysis CriticalCritical ControlControl PointPoint

The Letters of the Law

Or, have a cup of coffee and Or, have a cup of coffee and pray! pray!

To To promotepromote HACCP at national and HACCP at national and regional levelregional level

To To demystifydemystify the concept of HACCP the concept of HACCP To To targettarget specific premises specific premises To help To help industryindustry in its own development of in its own development of

HACCPHACCP To develop a To develop a consistentconsistent approach to approach to

implementing HACCP.implementing HACCP. To develop a To develop a consistent consistent approach in approach in

enforcing HACCPenforcing HACCP

HACCP Strategy HACCP Strategy ObjectivesObjectives

Food Poisoning Food Poisoning Outbreaks Outbreaks

1999-20011999-2001 (n=159)(n=159) Hotel/guest houseHotel/guest house 39 (25%)39 (25%) Hospital/residential instHospital/residential inst 30 (19%)30 (19%) Restaurant/café/take awayRestaurant/café/take away 28 (18%)28 (18%) Private HomePrivate Home 23 (14%)23 (14%) Staff canteenStaff canteen 7 (4%)7 (4%) CrècheCrèche 7 (4%)7 (4%) OtherOther 25 (16%)25 (16%)

Haccp Strategy + Local Haccp Strategy + Local InitiativesInitiatives

3 assessments 3 assessments carried out; carried out; targeted approachtargeted approach

Doubling in Doubling in HACCP HACCP compliance in compliance in HotelsHotels

Focus is now on Focus is now on ButchersButchers

The Galway ApproachThe Galway Approach

Introduced on a Introduced on a gradual basis from gradual basis from 1998 – to date1998 – to date

Consultation with Consultation with all inspectorsall inspectors

Galway

HACCP Training courseHACCP Training course

Three day course developed, 9 hours, one Three day course developed, 9 hours, one session a weeksession a week

For proprietors, managers and supervisorsFor proprietors, managers and supervisors Participatory - lots of homework Participatory - lots of homework Attendees have a System for €100 .Attendees have a System for €100 . Over 250 small/medium sized food Over 250 small/medium sized food

businesses have attended and successfully businesses have attended and successfully completed course.completed course.

Solution to Solution to the problem ?the problem ?

The Hygiene Package The Hygiene Package

! or ?! or ?

‘‘Hygiene Package’; Hygiene Package’; Flexibility introducedFlexibility introduced

Article 5 of Reg 852 is Article 5 of Reg 852 is the legal positionthe legal position

Guidance document from Guidance document from Sanco may be solutionSanco may be solution

‘‘Two types of HACCP’ ? Two types of HACCP’ ? Annexe 1; Classic Annexe 1; Classic

systems: no flexibilitysystems: no flexibility Annexe 2; Explores Annexe 2; Explores

extent of flexibility (2 extent of flexibility (2 types); Pre requisites or types); Pre requisites or guidesguides

852/2004 – Chapter III 852/2004 – Chapter III Guides to Good PracticeGuides to Good Practice

Article 7:Article 7:

““Member States shall encourage the Member States shall encourage the development of national guides to development of national guides to good practice for hygiene and for good practice for hygiene and for the application of HACCP principles”the application of HACCP principles”

What has happened What has happened since?since?

Authorities have panicked. Authorities have panicked. Fortunes spent on consultants Fortunes spent on consultants

(everywhere). (everywhere). Businesses closed down Businesses closed down Large meaningless plans purchased Large meaningless plans purchased

(pigs fly) (pigs fly) 92% success claimed by some !!!92% success claimed by some !!! Over-elaborate Systems (Ireland) jail !Over-elaborate Systems (Ireland) jail ! Simplified System for small caterers Simplified System for small caterers

(G.B) (G.B)

The 4 C’s G.B.The 4 C’s G.B.

‘HACCP’ or ‘HAZARD’ not mentioned

What's needed now?What's needed now?

Simplify! As much as necessary, not Simplify! As much as necessary, not as much as possibleas much as possible

Pre-requisites, Training, Management Pre-requisites, Training, Management commitmentcommitment

A Food Safety Management System A Food Safety Management System incorporating HACCP is incorporating HACCP is your your responsibilityresponsibility

A Simple, flexible systemA Simple, flexible system

Identify risks: difficult; eliminate Identify risks: difficult; eliminate complaintscomplaints

Put controls in place to deal with Put controls in place to deal with risksrisks

A clear procedure if things who A clear procedure if things who wrongwrong

Keep this up to dateKeep this up to date Record procedures and checksRecord procedures and checks

In other words !In other words !

This is management of This is management of risk !risk !

HACCP applied !!

Guides to the FutureGuides to the Future Our national standards authority has designed a Our national standards authority has designed a

Haccp plan with flexibility (5 CCP’s) in IS 340/06Haccp plan with flexibility (5 CCP’s) in IS 340/06 May be applied to all catering establishmentsMay be applied to all catering establishments FSAI has produced detailed guidelines for the FSAI has produced detailed guidelines for the

development of Industry Guides to Good Practice, development of Industry Guides to Good Practice, incorporating HACCP. incorporating HACCP.

Guides need to be simple, (in food workers Guides need to be simple, (in food workers language)language)

They also may finish collecting dust on a shelfThey also may finish collecting dust on a shelf They must be applied to each premises, They must be applied to each premises,

individuallyindividually Be updatedBe updated

HACCP ‘Brand’ will HACCP ‘Brand’ will succeedsucceed

Food businesses are striving for excellence not just for minimum legal standard.

ISO 22000; PAN EUROPEAN STANDARD

Good luck in the futureGood luck in the future

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