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New Revision of the Food Hygiene & Safety Gospel in the Pipeline

Posted by Tony-C, in Food Safety Standards 15 October 2015 · 2,939 views

codexhaccp food hygiene
New Revision of the Food Hygiene & Safety Gospel in the Pipeline

In November 2014, the 46th committee session agreed to establish an EWG led by France and Thailand, to review the General Principles of Food Hygiene (GPFH) including the Annex on HACCP and identify any need for updating and review.

 

The CODEX COMMITTEE ON FOOD HYGIENE 47th Session takes place in Boston, Massachusetts, United States of America on 9 - 13 November 2015. Agenda Item 8 of this meeting is CX/FH 15/47/9 DISCUSSION PAPER ON THE REVISION OF THE GENERAL PRINCIPLES OF FOOD HYGIENE (CAC/RCP 1-1969) AND ITS HACCP ANNEX which has been prepared by an Electronic Working Group led by France and Thailand.

 

It is not surprising that after review this working group has recommended that the committee should consider starting new work on the revision of the General Principles of Food Hygiene and its Annex: Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application (CAC/RCP 1-1969), with an introduction and two distinct parts (General Principles of Food Hygiene and an annex on HACCP and seven HACCP principles.

 

The working group has recommended that the revision should be applicable to as wide a range stakeholders as possible, as simple as possible and provide more flexibility to small and medium enterprises in order to achieve wider application while maintaining consumer safety. The working group also advises that during the revision relevant parties need to consider if the document should instruct Food Business Operators (FBOs) on how to manage their quality and safety system and address management of suppliers, auditing, contract manufacturing, storage, change management, continuous improvement and Good Agricultural Practices.

 

The working group has identified the need to distinguish validation from verification within Principle 6 and this seems sensible as confusion between validation and verification is a major problem I encounter with HACCP Systems I have seen implemented and an issue I have discussed in my blog previously.

 

Another consideration is whether the GPFH include primary production, and address the safety aspects of foods that go directly to the consumer as ready-to-eat and of final delivery to the consumer (e.g. retailers). This is probably a reflection of the number of food safety incidents in recent years related to product particularly. There have been major incidents related to salad items and fruits including Salmonella in cucumbers1, Listeria monocytogenes in melons2 and E. coli O104:H4 in bean sprouts3. The CDC has published data showing the Contribution of Different Food Commodities (Categories) to Estimated Domestically-Acquired Illnesses and Deaths, 1998-2008, 46% of Illnesses are attributed to produce and 23% of deaths.

 

A review of definitions is recommended including clarification of clean & potable water and the use of “essential” and “critical” in relation to HACCP.

 

It is suggested that the sequence of implementation should be establishing a preliminary list of potential hazards independently of consideration of GHP implementation, and then determining a shorter list of significant hazards to be addressed in the HACCP plan that takes into account the GHP measures implemented. This is something that we teach in the IFSQN HACCP Training which we believe gives a better understanding of the role and importance of hygienic practices and prerequisite programmes. This is also reflected in the eWG recommending the project examines the need for a class of control measures essential to control hazards for which management as CCPs presents challenges.

 

There are recommendations to include references to relevant guidelines such as microbiological criteria, validation and drinking water quality. It has also been identified that further guidance on the control of chemical contaminants including (allergens and mycotoxins), the use the current decision tree or alternative trees and the establishment of science based critical limits for CCPs and their proper use.

 

The electronic working group has submitted a proposed project document with five-year timeline proposed for the completion of the revision of the General Principles of Food Hygiene (CAC/RCP 1-1969) and its HACCP Annex. A draft would be ready for discussion at in 2016, with finalization in 2018 and publication in 2019; further details of the project can be seen in the discussion paper. I am sure there will be further debate and discussion on what should be included such as food defence and crisis management, I personally see the need to have a common general section then sector specific sections for the general principles of food hygiene and a common HACCP Annex. Plenty of room for discussion on this subject!

 

1. CDC Update: 4 Deaths, 767 Salmonella Cases in 36 States Linked to Cucumbers
http://www.foodsafet...s/#.Vh-b0CsjmHE

 

2. 2011 United States Listeriosis Outbreak
https://en.wikipedia...riosis_outbreak

 

3. 2011 Germany E. coli O104:H4 outbreak
https://en.wikipedia...104:H4_outbreak



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Hi tony,

 

Does the above also mean that the HACCP-related text which has appeared in the various Revisions published up to 2009 (I think) is still identical to the 1969 1st edition ?

 

A Codex Winner perhaps.

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Hi Charles,

 

It is still available/published so I'm a bit confused by your question?

 

Either way IMO this COP is the Oracle for Food Safety/Hygiene.

 

Kind regards,

 

Tony

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Hi Tony,

 

Codex have a tendency to blur their chronologies.

The quoted title suggests that the Annex has officially existed for ca.46 years. Obviously decades in error.

For HACCP itself, I find NACMCF has more clarity and current relevance for some key aspects. But tree-wise, not so much. It's all subjective of course. And maybe about to change in another 5years or so.

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There have been revisions since 1969 Charles, please point out any errors and why you think NACMCF has more clarity and relevance as this blog was intended to encourage debate ....

 

Kind regards,

 

Tony

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Hi Tony,

 

Happy to oblige. Yr blog is of considerable value.

 

Afaik, the Annex first "publically" appeared in 1997. Subsequent changes (see below) have been pretty minute. The Annex has no references.

NACMCF afaik has never been revised since adoption in 1997.

 

I have selected 3 items to illustrate based on, IMO, their haccp importance.

 

(1)

IMO the procedure whereby a hazard analysis is used to determine CCPs is poorly done in Codex, ie para.6 . The basic reason, IMO, is that an explanation of the key word “essential”  is absent.  The curious part is that Codex's first Annex already provided an excellent working definition of "hazard analysis" in terms of ‘significant” hazards but then seemed to forget about it in the main text. The operational consequence, IMO, has been that many people implement a CCP tree at every step of a process. This IMO defeats the point of a preliminary risk assessment. NACMCF have a near-identical definition and avoid a pitfall by using clearer text in the main body although, ironically, in Appendix E it is the text attached to the first of its 2 trees,  now more or less obsolete, that clarifies the usage  rather than the following, now mostly used (Codex) decision tree.

NACMCF additionally  provides an interesting practical example of its thinking (unlike Codex) but some of the content has probably been overtaken by time. (the checklist of potential hazards is still relevant).

 

 

(2)

As far as I can see from hard copy, Codex Annex 1997 was either unaware of, or chose not to use the term  “Prerequisites”. The word eventually appeared in the 2003 revision, and was re-iterated as being equivalent to “good hygienic practices” in 2009 version. But no haccp-specific Prerequisite details are given in the Annex.

In comparison, NACMCF (1997) already had considerable detail on “Prerequisite programs” (main body and appendix A).

Currently, other than "Regulatory" situations, both sources may have been eclipsed by the ISO 2002 series.

 

(3) Here are the respective Codex/NACMCF definitions of Validation.

 

Validation Obtaining evidence that the elements of the HACCP plan are effective.

 

Validation: That element of verification focused on collecting and evaluating scientific and technical information to determine if the HACCP plan, when properly implemented, will effectively control the hazards.

 

The red text is important and its absence encourages a miscellany of interpretations (eg, from memory, SQF). The red addition constituted a key element (ie chronology) in Codex’s  later excellent Draft publication (2008) on the same topic, a mere 11 years late. Strangely, this Draft is mentioned in places in the 2009 Codex Hygiene publication but not in the Annex itself.

So I suppose this one is a draw.

 

Summarising, the truth is that both viewpoints are probably urgently in need of revision.

 

PS - ISO 22000 currently  may contain one of the conceptually clearest short  introductions to implementing a generic haccp plan. Prior to the paragraph on OPRP anyway.

 

Kind Rgds / Charles

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Thank you for the contribution Charles, appreciate it.

 

Kind regards,

 

Tony

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Interesting post!

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