Issues related to development of ISO 22000 and HACCP

Dear All,


I would like to open a new discussion on thoughts about ISO 22000 and HACCP. I am a FSMS and QMS Lead auditor. I used to be an auditee too. So I am trying to look from both views.

First of all , born of ISO 22000 is the beginning of a new age in assurance of food safety at food organizations because,


1- There was no internationally accepted standard for a food safety management system. There were local HACCP standards.


2- Certifications were non-accredited mainly, others were accredited by some local accreditation bodies such as ESYD, DANAK and RVA.


3- Although ISO 9001 is the most populer written standard of all times, lack of a risk analysis methodology unlike ISO 14000 and OHSAS 18000 do (those are risk analysis-RA based standards.) resulted in new seekings from food producers of a new food quality system equipped with risk analysis.


A paranthesis about HACCP:
HACCP had been already widely used by the sector as a TOOL not a management system at the beginning.

Because of an obvious need to a risk analysis based QM system, HACCP is forcedly turned into a management system by sector.

HACCP management system is a composition of HACCP tool integrated with typical management system requirements such as internal audits, document control, training, management review etc. However, main purpose of HACCP was not to serve as a management system but to help users as both a scientific and practical tool for food safety.

HACCP was mainly derived from FMEA (Failure Mode and Effect Analysis) which had been widely used by automotive and pressure tanks sectors.

FMEA has been improved and still widely used by most of sectors but not turned into a management system unlike HACCP.


Among discussions about a need for a real management system for food industry, ISO 22000 has emerged. This standard is a new hope for food processors and service providers.

However there are issues that I can remember for the time being :

1- Lack of process based approach unlike ISO 9001 does
2- Quality attributes of a food other than food safety are excluded from the standard.
3- Language is too heavy for many of operators,
4- Despite too many argumentation about hazard analysis (even more than a scientific study), PRPs have been summarized, compacted and even sequeezed.
5- A very new concept not discussed by all parties even adequately (OPRPs)
6- Scope of supply chain is very pretentious, however there are a few but noncomprehensive guides available about many of the sectors such as agriculture, packaging, fishing, livestock growing, fertilizers, nurseries, cleaning, cleaning chemicals, pest management, water treatment sectors etc.

Moreover beyond the other things, still there is a doubt in minds in implementing an ISO 22000 based FSM system because many people still think that a good planned ISO 9001 system equipped with an effectively implemented FMEA study could be still a good choice for also food safety because ISO 9001 standard is already referencing to legal and customer requirements, and almost all prerequisite programs are integral parts of those legal and customer requirements. When we compare ISO 9001 and ISO 22000, it is obvious that process based approach is not present in ISO 22000. Additionnaly, guidance of ISO 9001 is still needed if the organisation is aiming to improve customer satisfaction as well as to maintain an acceptable quality level.

I am planning to open a wish list here in this forum for this purpose.


(to be contd.. )

Kara

Dear Kara,

Thks for a very thoughtful post. i certainly agree regarding "ISO-speak" terminology.

I am not a direct user of ISO 22000 ( use HACCP only) so I will refrain from being over-critical. Previously I tried to clarify my own confusion after reading the standard with (I thought) some simple but direct queries on this forum but the feedback plus my brainpower did not achieve any particular conclusion. (Maybe people thought the answers were obvious and were just being polite. ) (Can see thread here if interested - http://www.ifsqn.com...?showtopic=7196 )

I will excuse I22k a bit due to newness - HACCP has also gone through many arguments on application issues (eg the original HACCP included quality issues and was saturated with CCPs causing prioritisation difficulties.) I believe the fact that the extensive availability of HACCP material in the public domain (free!), esp. through the IT, had / has a major benefit on its development. Perhaps this is something for yr wish (dream?) list. As you say, ISO 9000 has very wide usage (correctly or otherwise) and this has at least promoted the existence of discussion forums containing considerable practical material. Maybe ISO22000 in another 10 yrs ?

Rgds / Charles.C

Hello Kara,

I do agree with you, 22000 is a fantastic tool to improve the way of understanding food safety, and the food safety management too. If it runs, it will be easier for us and for everybody to clarify all of those existing quality management systems. Some very very big firms decide to apply ISO 22000 whereas they didn't want to set other systems.

ISO 22000 allows us to improve the ancient level of Haccp. For instance, european factories have to set a serious Haccp study thanks to 22000 in order to acquire an establishment approval - 853/2004. A good way for the food safety.

Last, that's quite difficult to set a new system, but let's bet 22000 will win its battle!

Regards,

Emmanuel.

Hello Kara,

I do agree with you, 22000 is a fantastic tool to improve the way of understanding food safety, and the food safety management too. If it runs, it will be easier for us and for everybody to clarify all of those existing quality management systems. Some very very big firms decide to apply ISO 22000 whereas they didn't want to set other systems.

ISO 22000 allows us to improve the ancient level of Haccp. For instance, european factories have to set a serious Haccp study thanks to 22000 in order to acquire an establishment approval - 853/2004. A good way for the food safety.

Last, that's quite difficult to set a new system, but let's bet 22000 will win its battle!

Regards,

Emmanuel.

Emmanuel I was talking to a group technical guy from a very large UK food manufacturer the other day. All his sites have BRC or IFS or both. We discussed ISO 22000 and he said it would not get anywhere in the UK supply chain. Regardless of the potential of ISO 22000, do you actually see it making it in other parts of Europe?

Regards,
Simon

Hi Simon,

Very interesting!A canadian inspector said me 2 years ago the most interested people in the building of the 22000 - and Haccp - were american people...because they were late compared to Europ!

But U.S food industry is not the only one! The same inspector told me too about canadian industry...eventually, I realized it was true - for meat industry, slaughters for example.
Even if the establishment approval in Europ wasn't as efficient as we could think before the new regulations, that wasn't so bad; regulation has changed, I hope it will be better.

Concerning some other official hygien programs, it seems to be a very hard, strong and expensive work for factories to set, build and live with these programs - BRC, IFS, ISO 9001 as you said. So I think things won't changed now, but in the next few years. For instance, Nestlé want to get it before the end of 2008; some of its factories were ISO 9001, with an internal qualtiy system too...

To conclude : on the one hand USA - such a very powerful economy - and on the other hand big factories can change our way of thinking quality system, it could be quite interesting for all of us!

That's only my opinion; last, actually, some factories look for guys in order to establish ISO 22000 in France, that's much more important now for 22000 than few years ago for BRC and IFS. We'll go and see!

Simon, what is your own opinion about the future of 22000?

Regards,

Emmanuel.

Simon, what is your own opinion about the future of 22000?

Regards,

Emmanuel.

My opinion is based on anecdotal evidence.

In countries where food safety standards have not taken root I believe ISO 22000 will do well. The power and persuasion of Certification Body marketing coupled with the lure and promise of business opportunities will see to that.

In other countries such as France, Germany and UK where we have BRC /IFS in food manufacturing I doubt it will take off to any great extent. If some big global food players push it down the supply chain (e.g. nestle) I can see poor old food safety managers having to manage another food safety management system.

In other areas of the food industry such as catering, hotels, restaurants, hot dog sellers etc. they will go down he HACCP root as per the EU legislation.

Just my opinions.

Regards,
Simon

Dear All,

I suppose we are looking at the interplay between concerns regarding the best way to scientifically / economically / (politically) achieve a safe food supply (eg a combination of constraints as per Codex type philosophy). Business / marketing overlaps (corrupts?) all three of course. Or is it the other way round ?

I haven’t yet noticed any significant feedback from the general scientific community that the risk assessment procedures in ISO22000 (the Benitez Approach?) offer a significant improvement to achieving food safety per se compared to the existing methodology of applying “traditional” HACCP via “Farm-to-Table”.

Inertia to change is a well-proven phenomenon but I wonder if the silence may also be due to simple inability to understand the ISO text. One appropriate example could be worth a thousand words.

Rgds / Charles.C

Hi Simon and Charles,

Right, quality systems are so hard to set that you have sometimes to be under pressure to do it. Most of factories have to set and apply these expensive systems, required by the willingness of their customers - supermarkets etc.... Only few of them were really decided to - that's what I could see on french quality forums, many other examples too.
Consequently you have on the one hand 'the paper' and the involvement of the management, all the efforts done to obtain the certification, on the other hand the reality on ground - not only in food industries.
This kind of certification involves real changes that management is not always ready to apply. Fortunately things change and mentalities too little by little!

So when a quality system is done and set, I think factories don't want to build another QS!

From the time being evidence Simon saw can be understood - interesting evidences! I don't know the ratio factories which QS vs without QS, in Europ, Asia, North and South America etc..., but I think big efforts can be made. The reason why establishment approval in Europ inspired by 22000 - OPrP, PrP, CCP is a good thing to my mind for factories which are 'afraid' of all those QS. A good thing for a first step! But I think you're right Simon, it will be difficult and very long for food industry to acquire this system, if it goes right with 22000 (we don't know at all at the moment its achievement!)

Charles, you're right too when you say it would be more simple to understand ISO with easier words...

Such an interesting topic!

Emmanuel.

I would like to get the views of the original topic starter...are you still there Kara?

Yes Simon, I was out of office for nearly 2 weeks. Sorry for being late.

Well this topic turned to a discussion which FSM will be more popular one in the future by analysis of current market demands. Why not, While we discuss main weaknesses of ISO 22000/HACCP , we can also discuss projections about those systems in comparison with BRC and IFS.

I am totally agree with Emmanuel with it is a matter of mentality change to establish an effective QMS in any kind of organisation.

However, if we turn to our technical discussion assuming a fairly good mentality of company owners and staff , I can tell following in summary:
- HACCP is a good tool that was originally derived from FMEA (Failure Modes and Effects Analysis)
- It was turned to a management system by adding different annexes from legislation and QMS standards.
- ISO 22000 is a new hope but currently its kernel is somehow this HACCP approach. Although in real life processes are raw material reciept, purchasing, design and development, sales and marketing, production, storage, packaging , delivery etc., Processes of ISO 22000 are thought to be preliminary steps, PRPs, OPRPs, hazard analysis , HACCP plan etc. Nevertheless, those things are not processes indeed but important and scientific concepts.
For example ISO 22000 standard talks about raw material descriptions (a preliminary steps), but never talks about "Purchase only from reliable suppliers. or Evaluating them.". Where is purchasing process?
OR for example :"Use only reliable additives in permitted ratios or amount" --> Design and development process is missing.For example, shelf life is also important for food safety, molding in a cake before shelf life is a food safety issue, after shelf life it is another thing.Shelf life studies is not an explicit requirement in standard.



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Many examples can be given.

I will try to approach BRC/IFS system this way in a next message.

Kind regards.

Kara

Thanks for replying Kara. It's no problem to be late - we all have jobs to do. As moderator my job is to sometimes prompt the original question asker to provide feedback to the members who have taken the time to answer their query. More often than not somebody will ask a question, receive lot's of great answers, but never make another post. As you can imagine this is disappointing for the members who have taken the time and energy to help out.

Anyway this clearly does not apply to you Kara. I think you make some great points on important missing requirements from ISO 22000, perhaps you should have been on the working committee.

Regards,
Simon