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Food Control 12 (2001) 165±173

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Technical barriers to Hazard Analysis Critical Control Point


(HACCP) q
Pedro Javier Panisello a,*, Peter Charles Quantick b
a
Ashial ± Centro de Estudios Alimentarios S.L. Montcada, 7, entlo. Tortosa, Spain
b
Faculty of Social and Life Sciences, University of Lincolnshire & Humberside, Main Academic Building, Byford Pool, Lincoln LN6 7TS, UK
Received 5 June 2000; received in revised form 28 September 2000; accepted 2 October 2000

Abstract
During the last three decades, Hazard Analysis Critical Control Point (HACCP) has been progressively introduced and applied
for the bene®t of the food industry. However, it should be recognised that HACCP systems have not been homogeneously im-
plemented across all food industry sectors. Reasons for not implementing, maintaining and updating HACCP programmes cannot
be explained purely in terms of unwillingness by manufacturers but rather by the presence of technical barriers that may impede the
application of the system. Technical barriers represent all those practices, attitudes and perceptions that negatively a€ect the un-
derstanding of the HACCP concept and hence the proper and e€ective implementation and maintenance of the HACCP principles.
This paper describes the potential barriers that may impede the correct use of HACCP before it has been implemented, during the
process of implementation and after it has been implemented. Until barriers impeding HACCP have been resolved, HACCP systems
will not be implemented throughout the whole food chain and it will not be able to reach its full potential as prerequisite for the
international trade of foodstu€s. Ó 2001 Elsevier Science Ltd. All rights reserved.

Keywords: HACCP implementation; Technical barriers

1. Introduction food safety management systems throughout the whole


food chain; (3) apply product/process technologies to
In recent years, there have been numerous advances reduce the contamination of raw foodstu€s; and (4) in-
in our understanding of foodborne pathogens, but crease the level of education and training of food han-
foodborne disease incidents are still increasing or at least dlers and consumers in the safe handling of foods.
not diminishing world-wide (Todd, 1994; O'Brien, In the late 1960s, the Hazard Analysis Critical Con-
Rooney, Stanwell-Smith, & Handysides, 1998; Motarj- trol Point (HACCP) concept was developed. This is a
emi & K aferstein, 1999). Similarly, there have also been systematic approach to the identi®cation, evaluation
numerous developments in process/product control and control of hazards (whether biological, physical or
technologies aimed to produce hygienic, wholesome chemical) in a particular food operation (Codex Ali-
food. However, it seems that our e€orts have not suc- mentarius, 1997). In the 1970s, except for the low-acid
ceeded in preventing food poisoning incidents suggest- canned industry and large corporations, the concept was
ing that control of foodborne disease is far more not widely adopted into daily food operations. During
complicated than imagined. This justi®es the continua- the 1980s, the concept evolved and gained acceptance
tion of e€orts by the industry, food control ocials and throughout the world and in the 1990s, re-emerged to
consumer associations aimed to: (1) improve the appli- become the primary approach to assure the safety of the
cation of good hygiene practices; (2) reinforce the use of food supply (Buchanan, 1990). Since then, there have
been considerable e€orts to harmonise the use of HA-
CCP from national and international institutions to
q
Paper presented at the First International Conference in Food manage food safety hazards in the food industry world-
Safety in Travel and Tourism. Conference organised by NSF Inter- wide.
national, Barcelona 12±14 April 2000.
*
Corresponding author. Tel.: +34-977-44-4943; fax: +34-977-44-
Despite the fact of the mandatory HACCP systems in
1886. the regulations of many countries, it seems that is not
E-mail address: ashial@intersoft.net (P. Javier Panisello). properly and fully implemented and/or understood by

0956-7135/01/$ - see front matter Ó 2001 Elsevier Science Ltd. All rights reserved.
PII: S 0 9 5 6 - 7 1 3 5 ( 0 0 ) 0 0 0 3 5 - 9
166 P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173

many companies (Panisello, Quantick, & Knowles, 1997). The NACMCF (1998) also highlighted the im-
1999; Mortlock, Peters, & Grith, 1999). Reasons for portance of commitment in enhancing the e€ectiveness
not implementing HACCP seem far more complicated of HACCP. If this commitment is not forthcoming, then
than ever imagined, and cannot be solely explained inadequate resources will be made available to provide
purely in terms of unwillingness by manufacturers but the basic prerequisites essential to develop the HACCP
rather by the presence of several technical barriers that plan. In order to overcome this problem, it has been
may impede the bene®ts of the application of the HA- suggested to integrate HACCP systems into quality
CCP system. All sectors involved in the safety of the management systems such as the ISO 9000 series. This is
food chain (e.g. industry, food control agencies, con- because within the elements of the ISO 9000 standards,
sumer associations) must be aware of these barriers and management responsibility clearly appears. Integrating
may allocate resources to overcome them in order to HACCP and ISO 9000 provides businesses with the
facilitate (or reinforce) the introduction of the HACCP opportunity to bene®t from the food safety aspects of
approach in sectors that are particularly known to be HACCP and the additional bene®ts of the management
problematic, such as the small manufacturer, processors responsibilities within the ISO 9000 standards. It also
of raw agricultural products, catering and restaurants requires that food businesses who are certi®ed to the
and the tourism and travelling industries. ISO 9000 series will be forced to include HACCP in their
Considering the international consensus on the im- quality management systems, only in those countries
portance of safety on the production of foods, it is where the legislation demands it, as under this standard
necessary to make a deeper analysis of the barriers that all relevant legislation must be complied with in full
food businesses may encounter on their way to achiev- (Mortimore & Wallace, 1998).
ing a fully implemented HACCP system. Today's bar-
riers in the developed world will be tomorrow's barriers 2.2. Education and training
in developing countries that are trying to reach the in-
ternational marketplace. This paper discusses the po- Food hygiene training and the use of educational aids
tential technical barriers in the food and catering (videos, training seminars, guidelines, manuals, etc.)
industry that may impede the use of HACCP before it assist in the implementation of the HACCP system,
has been implemented, during the process of imple- providing HACCP teams, managers and food handling
mentation and after it has been implemented. sta€ with the additional technical skills required in im-
plementing HACCP. Ideally, training courses should be
developed speci®cally for groups of personnel depending
2. HACCP pillars on their level of technical expertise and their degree of
responsibility in the overall HACCP process. This
For a successful HACCP programme to be properly would allow employees to apply HACCP principles to
implemented, managed and maintained, the HACCP their particular situation in the process line. The Codex
plan must be built on four basic `pillars'. These are: Alimentarius (1997) and NACMCF (1998) guidelines
commitment, education and training, availability of re- also recognise that the need for training of personnel in
sources and external pressures. However, it should be the industry is essential for the e€ective implementation
noted that anyone of these pillars may be included of HACCP. This was demonstrated in a national survey
within the seven principles of HACCP and therefore it in the UK of 254 businesses by Mortlock et al. (1999).
may be dicult to measure them or for to be seen as According to the authors, the use of HACCP and
priorities by the food industry. The key to successful proper implementation of the seven principles was
implementation of HACCP will depend on how these found to be signi®cantly higher in businesses with higher
pillars are prioritised. quali®ed managers than in businesses without any for-
mal trained managers.
2.1. Management commitment
2.3. Availability or resources
Commitment must be the driving force towards the
acquisition of all basic prerequisite programmes, which Adequate resources such as money, time, manpower,
represents the foundation of HACCP, the application of monitoring equipment and training aids, must be facil-
the seven principles of the system and its continuous itated to supervisory personnel in order to develop,
maintenance. The need for management commitment monitor and verify an e€ective HACCP plan. The 1994
was identi®ed in the 1997 Codex Committee on Food Expert Technical meeting of the Food and Nutrition
Hygiene guidelines for application of HACCP system division of the Food and Agriculture Organization
where it states: `The successful implementation of HA- (Kvenberg, Schwalm, & Stingfellow, 1994) identi®ed
CCP requires the full commitment and involvement of some of the costs incurred in the development of HA-
management and the workforce' (Codex Alimentarius, CCP systems (FAO 1994). These included: (1) the initial
P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173 167

cost of developing a HACCP plan; (2) cost of moni- will be essential to defend due diligence in the case of
toring and record-keeping; (3) costs of training; (4) liability (Mortimore & Wallace, 1998).
management costs to oversee HACCP implementation
and operation; (5) costs of monitoring equipment; (6)
2.5. Prioritising `HACCP pillars' for improvement
costs of corrective actions when the critical limit is ex-
ceeded; and (7) costs of any consultant who may be
Success in implementing and maintaining HACCP
required. Therefore, availability of resources to cover
systems will largely depend on how these four pillars are
the costs of HACCP is fundamental to succeed in its
prioritised and organised in a company. Fig. 1 depicts
implementation and maintenance. Thus, management
two pyramids that represent two opposite situations.
should take a pro-active attitude to provide sta€ with all
Fig. 1(a) depicts a stable pyramid, illustrating a sus-
resources needed to maintain the operation under
tainable model for the process of HACCP implemen-
control.
tation. The ®rst pillar, at the base of the pyramid, is
management commitment, representing a managerial
2.4. External pressures
understanding and commitment towards the HACCP
system and its ongoing success. The next pillar of this
The food industry may be forced to implement the
model is to provide education and training for manag-
HACCP system due to the action of di€erent sectors of
ers, supervisors and food handlers. Adequate sta€
pressure. These are: government, customers, authorised
training and education is fundamental to obtain expe-
ocers and media (Mortimore & Wallace, 1998). Gov-
rience and practice of the HACCP concept and it
ernments across the world are increasingly adopting
may also facilitate the diligent management of the
mandatory HACCP-based regulations as the best sys-
available funds for the implementation of the HACCP
tem to ensure the safety of foods (Lupin, 1999). In Eu-
system. This is the third pillar and consists of proper
rope, this was emphasised by the European Union (EU)
Council Directive 93/43 (1993) on the Hygiene of
Foodstu€s that states that food business operators shall
identify any step in their activities critical to ensuring
food safety and ensure that adequate procedures are
identi®ed, implemented, maintained, and reviewed on
the basis of HACCP principles.
Companies are closely monitored by their customers
because they want to be con®dent that the food being
purchased is safe. In this regard, companies are usually
asked to pass an independent audit to check whether
good manufacturing practice (GMP), good hygiene
practice (GHP) and HACCP principles are fully im-
plemented and strictly followed in each step of the
process.
Authorised ocers are also a source of pressure to
companies since they are responsible for inspecting
premises to check compliance with the law. In the UK,
all food businesses are required to be registered with the
local environmental health department. Inspection fre-
quencies vary depending on the nature of the business
with high-risk premises being inspected more frequently
than low-risk premises. Environmental Health Ocers
(EHOs) have wide powers under the UK Food Safety
Act 1990 and regulations made under it to enter food
businesses at any reasonable time. They can examine
food, equipment and documentation and take samples
of food for analysis (Rooney, 2000).
Last but not least of the sources of pressure to food
companies is represented by the media. Food safety
scares are always covered by the press and consumers
Fig. 1. Schematic of models to prioritise the HACCP pillars. (a) Sus-
feel encouraged to go to the press, lured by both the tainable model: adequate prioritisation of pillars that sustain HACCP
publicity and the cash rewards. Documentation of showing a stable pyramid. (b) Unsustainable model: inadequate pri-
HACCP systems and e€ective maintenance of records oritisation of HACCP pillars showing an unstable pyramid.
168 P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173

management of the available resources. At the top of the food hazards or they were prioritised after others which
pyramid, the fourth pillar is represented by external posed minimum risks to the nature of their operations.
pressure. In a sustainable system, this pillar should al- Acceptance of risk is in¯uenced by factors such as de-
ways have less importance than the others but it should gree of voluntariness, familiarity and personal control
always be present. It is necessary because a certain level associated with the activity (Slovic, 1987). Thus, people
of external pressure, from di€erent sectors, continuously tend to underestimate the risks involved with familiar
challenges the operational practices and controls, as well activities. Also, risks judgements are often `optimisti-
as it serving as a stimulus for continuous improvement cally biased' and individuals believe that they have
of the HACCP plan. On the other hand, Fig. 1(b) de- greater control over a potentially hazardous situation
picts an inverted pyramid (with the top down), illus- (and hence are at reduced risk from the hazard) than a
trating an unsustainable model. This model may not comparable other one (May & Burger, 1996; Frewer,
allow the successful implementation of HACCP, as it is Howard, Hedderley, & Shepherd, 1998). The more
mainly driven by a high level of external pressure (no- people feel they know about a hazard, the more they feel
tably customer pressure) with minimally or untrained they have control over it. Thus managers and food
sta€, and little commitment towards the use of HACCP handlers may think that they can make food completely
systems. safe by using particular cleaning and cooking methods.
In that case, people will be less motivated to adopt risk-
reduction tools such as HACCP. People often make
3. Technical barriers their risk evaluations based on what they believe to be
true which may not be necessarily based on complete or
The introduction of HACCP has been achieved correct information. Even when they have access to an
through industry acceptance and the assistance of en- accurate source of information (such as government
forcement ocers or external consultants. However, warnings), whether the message is believable or not will
there are a number of factors that have impeded or depend on the perceived credibility of the source (May &
delayed the use of HACCP in many businesses. These Burger, 1996).
factors are described as technical barriers and represent
all those practices, attitudes and perceptions that nega- 3.1.2. Company size
tively a€ect the understanding of the HACCP concept While relatively big companies will ®nd it easier to
and hence the proper and e€ective implementation of ®nd resources and technical assistance, small businesses
the HACCP principles. Technical barriers may occur at ®nd it more dicult because they lack appropriate re-
all stages of the HACCP programme: prior to imple- sources, technical knowledge and experience to put
mentation, in the process of implementing it, and after it HACCP into practice. Particularly, small food proces-
has been implemented. sors tend to employ the sta€ that they need to carry out
production tasks, to think in terms of productivity
3.1. Barriers prior to HACCP implementation rather than safety and to see the system as complicated
and unnecessary to produce foods. Thus the introduc-
Barriers prior to implementation refers to the illusion tion of HACCP into these companies is more dicult
of control, the size of the company, the type of product than in larger sites. Industry surveys in the UK em-
and industry sector and the company's customer(s) food phasised the fact that small food processors were less
safety requirements. likely than large companies to use HACCP (Panisello
et al., 1999; Mortlock et al., 1999). Larger companies,
3.1.1. Illusion of control however, can direct resources and funds in training and
Managers, without appropriate training, may well consultancy for successful implementation of the sys-
think that as long as the product looks normal and there tem. The latter point was con®rmed by a study in the
is no evidence of spoilage, the product is alright to dis- European countries that found that small companies
tribute. They have had good results in using `common were less likely to invest in hygiene and food safety
sense' manufacturing practices during the past and they than larger ones (Gormley, 1995). The size of the
do not see the need for HACCP systems. This is because businesses, in terms of turnover and number of sta€,
they may be unaware of the risks involved with the represents a barrier to HACCP because normally, these
handling of their raw materials and processing opera- businesses do not provide sucient resources to im-
tions. The Mortlock et al. (1999) survey found that the plement the system. Small business may prefer to invest
majority of businesses surveyed identi®ed themselves as in other areas to improve the quality or quantity rather
low-risk and were signi®cantly less likely to use HACCP than the safety of foodstu€s (Forsythe & Hayes, 1998).
than businesses perceived as high-risk by their manag- These type of industries will need assistance in order to
ers. Findings by Panisello et al. (1999) in a survey sug- make the necessary changes to adopt the HACCP
gested that companies either did not correctly identify concept.
P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173 169

3.1.3. Type of product the importance of CCPs and monitoring operations,


Some processes and products are more dicult to rather than strictly complying with the seven principles
keep under control than others. For example, HACCP de®ned for the food industry.
plans for the canning industry have a fewer number of
critical control points (CCPs). These are the lethality of
3.1.5. Company's customer(s) food safety requirements
the thermal process and the integrity of the packaging
Company customers such as supermarket and hotel
system that prevents recontamination. Both CCPs are
chains, airlines and large manufacturers require their
relatively easy to monitor and keep under control.
suppliers to provide evidence that HACCP (or a com-
However, products that are processed without a ®nal
parable system) is being complied with on a day-to-day
lethal step (raw agricultural or animal products) may be
basis. Normally this means going through an inspection
more complicated to control and monitor. This is be-
or audit process. During supplier inspections, auditors
cause these types of products are processed relying on
will assess the competence of the management, evaluate
the additive impact of a series of operations or practices
the understanding of the personnel, review documents
that prevent or decrease contamination and limit mi-
and records to ensure that the CCPs are being moni-
crobial growth (Buchanan & Whiting, 1998). Conse-
tored and veri®ed and also that the overall mainte-
quently there will be more CCPs and control points (CP)
nance of the system is achieved (Mortimore & Wallace,
to monitor. For example, a sandwich maker, due to the
1998).
diversity of raw materials used, will have more hazards,
Therefore, companies supplying customers that de-
CCPs and monitoring tasks to do in order to maintain
mand the use of HACCP will be more prepared to im-
the safety of the product than a food manufacturer that
plement the system than others that are not regularly
uses a single lethal step to eliminate or reduce the haz-
audited. This was con®rmed in the UK by di€erent
ards present in the product. Results of the Mortlock
surveys about food hygiene and HACCP in the food
et al. (1999) survey showed that businesses handling
industry. Results of the study by Panisello et al. (1999),
both raw and cooked meat or ®sh products were less
showed that companies supplying supermarkets were
likely to be using HACCP than companies handling
more likely to have HACCP systems implemented and
other types of products. Thus the introduction of HA-
fully operative that those that did not supply super-
CCP system in the processing of raw agricultural and
markets. Results of the Mortlock et al. (1999) survey
animal products can only prevent the increase of con-
showed similar results, indicating that large businesses
tamination or minimally reduce it.
that are part of local, national, or multinational chain
are signi®cantly more likely to use HACCP than others
3.1.4. Industry sector
that are independent or are a franchise organisation. It
HACCP systems were initially designed and applied
is expected that suppliers that have been asked to
to the food-manufacturing industry (e.g. low-acid
comply with HACCP may be encouraged to pass their
canned products). Consequently, food manufacturers
disciplines back through the supply chain to their own
are more likely to ®nd it easier to use a system that
suppliers, and so on. Thus, if a company is not using
was speci®cally designed for their sector than retailers
HACCP it will probably not request the use of HACCP
and caterers (hotels, restaurants, public houses, can-
to their suppliers resulting in a breakage on the safety of
teens etc.). According to the Mortlock et al. (1999)
the supply chain. Businesses that are not aware of the
survey, food manufacturers were ®ve times more likely
bene®ts of HACCP will then have less opportunities for
than retailers and four times more likely than caterers
improvement.
to be using HACCP. The application of HACCP sys-
tems to these sectors presents unique challenges due to
the lack of well-de®ned product ¯ow, the wide diver- 3.2. Barriers during the process of HACCP implementa-
sity of the work force, the constant turnover of em- tion
ployees with di€erent levels of education and language
facility, the diversity of foods served and methods of As mentioned above, establishing priorities between
food preparation and service and the variations in the pillars that sustain the HACCP programme was the
potential demand and workloads (Bernard, Gavin, & key problem to succeed on the initial stages of the im-
Scott, 1994). Lack of resources such as time and plementation of HACCP. However, even after expressed
manpower in these particular sectors as well as the management commitment and providing resources in
diculty of training sta€ are the main barriers a€ecting terms of ®nancial support, manpower and training,
the use of HACCP. Consequently in these industry there are a number of di€erent barriers that will need to
sectors, HACCP must be ¯exible to adapt to the dif- be overcome during the process of implementation.
ferent types of industries and methods of food pro- Barriers which are linked with the process of imple-
cessing. Thus, in these situations, HACCP should be mentation may be considered under the following
used as a means of managing food safety, highlighting headings: management, personnel and infrastructure.
170 P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173

3.2.1. Management always proves positive for the businesses because EHO
3.2.1.1. Lack of HACCP programme leadership. Food can inform, educate and support businesses, particularly
safety managers must lead by example, during the pro- small food premises, that need information on HACCP
cess of implementation. They will need to reinforce systems and help in determining what hazards and
awareness, refresh training if it is necessary, review the which CCPs are needed to control the operation (Roo-
e€ectiveness of controls, and double check records and ney, 2000). The adoption of HACCP will be impeded
documents to assure that CCPs are being monitored and unless there is mutual understanding and agreement
the HACCP system is being followed as planned. The between the food industry and the enforcement au-
main role of food safety managers is to encourage and thorities.
motivate supervisory sta€ and food handlers on di€erent
aspects of the HACCP concept. Consequently, they will
3.2.2. Personnel
need to attribute responsibilities between personnel in-
3.2.2.1. Persistence of old habits and attitudes. When new
volved with the implementation of the system. This must
HACCP principles are introduced to small food pro-
be done in accordance to the diculty of the operation
cessors, they do not see the need to change to a system
and the capabilities of the person who is going to be
that involves them in what they consider too compli-
responsible for it. Without leadership, food handling
cated and beyond the capabilities of their sta€. They
and supervisory personnel will become less motivated
take the view that there is no justi®cation in changing
and committed towards the new programme and will
their current procedures when those procedures have
return to their old habits and practices (see below).
worked well during years and enabled them to produce
Consequently, the HACCP system will be progressively
`safe' food products. Robbins and McSwane (1994)
abandoned or will not be properly applied.
con®rmed this point after the introduction of a new,
more extensive, sanitation programme in a retail food
3.2.1.2. Lack of co-operation between industry and
store meat department. The authors, during the post-
enforcement authorities. According to the NACMCF
training period of the exercise, found that many em-
(1994), it is the responsibility of the food industry to
ployees did not read a sanitation manual given to them
develop and implement HACCP plans and for en-
during the training sessions arguing that they did not
forcement authorities to facilitate this process. Thus
have time to read the material. There was also some
regulatory authorities can facilitate this process by as-
resistance to the newly implemented sanitation pro-
sisting the food industry in establishing the correct
gramme with sta€ complaining that they did not receive
HACCP principles and verifying that HACCP plans are
any additional pay to read the manual and complete
working as intended. Also in the majority of countries,
data collection sheets. At the end of the study, the au-
an authorised ocer of a regulatory authority has the
thors observed that some employees did not follow the
powers to inspect a food premises for the purpose of
newly explained sanitation practices. Therefore, it is
ascertaining whether there is or has been any contra-
possible that the problem of breaking old habits and
vention of the provisions of the food legislation in that
learning new behaviours in a food business represents an
particular country. In the UK, EHOs follow codes of
impediment during the implementation of new pro-
practice (e.g. Code of Practice No. 9: Food Hygiene
grammes such as the HACCP system. These perceptions
Inspections) that give advice on the approach that o-
directly a€ect some of the HACCP pillars, particularly
cers should take where a food business has or has not a
managerial commitment, accessibility to training and
hazard analysis system in place or a HACCP system. If a
education and availability of resources, resulting in in-
food business has no hazard analysis system in place, the
sucient awareness of the bene®ts of HACCP and
overall aim of the inspection is to encourage a preven-
failing in its implementation.
tative approach to food safety. The hazard analysis re-
quirement is explained and advice is provided to enable
the business itself to assess its activities. If a hazard 3.2.2.2. Sta€ lack of time to accomplish HACCP. In a
analysis system is already in place, the role of inspector fast-moving environment such as a processing plant or a
is to audit the system and verify the scope of the system catering establishment, time is always limited. Therefore
and implementation of e€ective controls. If a food it is not surprising that people always prioritise tasks
business has implemented a HACCP system, the role of according to their own perception of importance. HA-
the inspector is to audit the system, the process by which CCP requires `time' speci®cally in the early stages of
it was developed and the appropriateness of CCPs and implementation. All personnel directly involved with the
to verify the monitoring procedures. If problems with HACCP process have to spare time to review and study
the hazard analysis system are found, the inspector training notes in order to develop hazard analysis, de-
should discuss solutions to the problems with the pro- termine CCPs, establish monitoring schedules and cor-
prietor of the food business and agree on timescales for rective actions, as well as to contribute to the
any intended action. Therefore, collaboration with EHO documentation of the system. This reinforces once more
P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173 171

the importance of leadership, supervision and co-oper- of handling of food materials to the minimum possible.
ation with food authorities. Equipment should also be designed and constructed so
that cleaning, maintenance and inspection are facilitated.
3.2.2.3. Sta€ lack of motivation and supervision. Sta€ Well designed and structured premises with well
motivation is an important element in maintaining the designed, reliable equipment, will help in protecting in-
HACCP system `alive'. Supervision is necessary for gredients and food products, maintaining hygienic
employees at every level if HACCP is to work. Process conditions, improving cleanliness and cleaning e€ec-
control measures, CCP monitoring charts, critical limit tiveness and controlling pest infestations (Forsythe &
violations, corrective actions adequacy and product/ Hayes, 1998; Shapton & Shapton, 1991). The design and
process record sheets will need to be continuously su- layout of factories and equipment is also important to
pervised in order to ensure that employees follow all eliminate, prevent or control hazards (e.g. temperature-
instructions and that the HACCP system is fully oper- or pressure-controlled areas) and reduce the amount of
ational. As mentioned by Tompkin (1994), plant per- CCPs by e€ective control of the plant environment.
sonnel must be `active participants' which gives them a Also, computer-assisted equipment helps in keeping
sense of ownership and judgement of the work on hand. CCPs within critical limits, and when provided with
Motivation of the HACCP team members, or personnel automated monitoring devices, facilitates veri®cation
involved with HACCP, will also contribute greatly to and documentation steps. However, food premises with
implementing and maintaining a HACCP system, es- congested and unhygienically designed food preparation
pecially regarding those principles where continuous rooms are frequently found. Normally, this is the case in
monitoring and documentation are required. small businesses that have been increasing their pro-
ductivity without the consequent expansion of their fa-
3.2.2.4. Paper work/completion of forms. Records related cilities and installations, or businesses that are crowded
to di€erent steps and procedures of HACCP must be with sta€ and machinery to satisfy seasonal or occa-
fully completed and signed by their responsible person, sional workloads (notably food service establishments).
which adds an extra task to the routine work of food In those situations, the implementation of HACCP is far
processing. Managers and sta€, particularly in small more complicated due to the diculty of controlling
businesses, are responsible for several tasks that are not basic sanitary standards resulting in an increased num-
merely related to food processing (purchase, sales, ®- ber of CCPs and CPs to prevent or reduce risks of cross-
nance administration etc.) that also require a great deal contamination and recontamination of foodstu€s.
of paper work. In these cases, personnel normally tend
to complete forms and deal with paper work that they 3.3. Barriers after HACCP systems have been imple-
are used to, leaving HACCP documents as a second mented
priority.
Once implemented, an e€ective HACCP system must
3.2.3. Infrastructure be properly maintained and updated. As stated in
3.2.3.1. Lack of equipment. In order to develop, monitor principle 6, veri®cation activities are focused on deter-
and validate procedures it is necessary to make use of mining that all health hazards are controlled and that
monitoring equipment and instrumentation. Instru- the HACCP system is working and maintained as
mentation, especially in small businesses, may not be planned. Therefore, those businesses that are currently
adequate to support on-line monitoring, e.g. refrigera- producing foods having HACCP systems in place but
tors, cookers etc., may not have temperature-measuring have no means to properly validate and verify their
devices or they may have not been calibrated. In such programmes or they are not equivalent to those in the
operations, discontinuous monitoring is more appro- importing country, will soon ®nd themselves with
priate. Monitoring instrumentation must be user- greatly reduced opportunities in the international trade
friendly and based on easy-to-record parameters such as of foods. Barriers after the implementation of HACCP
temperature, sensory characteristics of foods, etc. relate to the diculties of veri®cation and the diculty
However, this type of monitoring requires employer of ®nding a measurable `target' (or food safety objec-
time, training and responsibility on taking and recording tive) that food processors must comply with to have
data correctly. Therefore, managers should be aware of equivalent HACCP systems.
the limitations of their operations and realistically de-
sign monitoring procedures and schedules commensu- 3.3.1. Diculties in veri®cation and validation of HACCP
rate with their operations. plans
The Codex Alimentarius de®nes veri®cation as the
3.2.3.2. Incorrect plant layout and poorly designed application of methods, procedures, tests and other
equipment. Food factory layout must be designed to evaluations in addition to monitoring to determine
achieve a smooth ¯ow of operations keeping the amount compliance with the HACCP plan. Also the text states
172 P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173

`where possible, validation activities should include ac- man disease (Buchanan & Whiting, 1998; Orris, 1999).
tions to con®rm the ecacy of all elements of the HA- However, to establish some level of equivalence between
CCP plan'. Mayes (1999) has recently clari®ed both two HACCP plans will be very dicult unless they both
concepts. According to the author, validation is pri- relate on a common measurable food safety objective
marily concerned with those activities that evaluate the (FSOs) (Jouve, 1999; Hathaway, 1999a,b) such as to
scienti®c and technical content of the HACCP plan, reduce the risk of foodborne illness to the consumer.
whereas veri®cation focuses primarily on procedures FSOs assist to verify the e€ectiveness of HACCP plans
required to determine compliance with the operational in di€erent countries because they delineate the food
HACCP system. Validation should be carried out at the safety goals that should be achieved through the use of
completion of the HACCP plan prior to implementation appropriate control measures (Jouve, 1999). Scienti®-
and it involves the review of scienti®c data and other cally, HACCP plans validated in terms of achieving
relevant information in order to ensure that the HACCP de®ned FSOs can ensure the level of equivalence be-
plan is appropriate to guarantee product safety. Veri®- tween countries during their trade relationships.
cation includes all activities (e.g. auditing, food analysis The food industry, apart from large corporations,
and tests) that can be used to determine if the HACCP will it ®nd very dicult to base their decisions on
system is working correctly. Thus, the role of the food quantitative risk assessment since it involves a certain
industry is to validate the HACCP plan in light of the level of technical information. However, recent ad-
best scienti®c information available and the role of the vances in dynamic risk assessment simulation techniques
food control authorities is to verify that the validation will soon provide user-friendly software that will allow
process has been carried out correctly. the manufacturer make decisions in a more quantitative
As part of the validation process, food manufacturers manner. Integrating quantitative risk assessment into
would ®nd it extremely useful to review scienti®c litera- HACCP plans will have the bene®t of establishing the
ture such as reports on surveillance of foodborne disease equivalent level of risk that every HACCP plan must
and surveillance of foods (national food surveys). This achieve. Thus, government agencies, international bod-
information will provide them with a clear insight into ies and food control ocials will have a common target
the hazards that are relevant to their operations as well as (acceptable risk) to assess the equivalence of di€erent
the factors that have caused foodborne disease incidents HACCP plans.
in the past. This will enable them to validate their hazard
analysis, CCPs and critical limits of their HACCP plan.
However, both types of information are costly and hence 4. Conclusions
only a few countries routinely report them. Therefore,
limited access to reference literature and material is a HACCP is becoming the exchange currency, in terms
major constraint on the validation of HACCP pro- of safety, used by importing and exporting countries,
grammes. Similarly, veri®cation is also dicult due to the both developed and developing alike, to facilitate the
scarce ®nancial and human resources that are normally trade in food products by providing evidence that
allocated by governments to food control authorities. If products in the international market meet regulatory
food authorities need to verify the e€ectiveness of HA- requirements for which governments assume responsi-
CCP, they will need to be trained and skilled in HACCP- bilities. The apparent lack of HACCP implementation in
based systems. The costs of training are also substantial several businesses may be due to the existence of several
and thus the number of quali®ed ocials to attend to technical barriers. As the food market becomes more
industry' needs are limited and insucient to cope with intricate, and new developing countries are becoming
the high number of businesses in their districts. exporters, the importance of HACCP between trading
countries seems vital for the safety of the global trade.
3.3.2. Lack of equivalence What has been said for small food processors in devel-
Throughout the world, food safety is achieved using oped countries may also be valid for large food proces-
di€erent types of HACCP programmes, representing the sors in developing countries. This is because industries
diversity of industries, countries and people managing may lack technical resources to validate HACCP plans at
the safety of foodstu€s. Therefore HACCP plans are the plant level and governments may lack sucient re-
tailor-made and ®t within the necessities and capabilities sources to verify HACCP plans at national level.
of every industry sector. To establish equivalence be- In the meantime, HACCP barriers should be clearly
tween two similar plans or programmes, it is necessary de®ned, their importance assessed and their impact
to be capable to measure their e€ectiveness. In order to evaluated over the implementation of HACCP. This is,
measure HACCP e€ectiveness, it is necessary to incor- according to the authors, one of the priorities that new
porate quantitative risk-based decisions during the food safety agencies across EU member countries and
process of implementation and to relate HACCP plans the future EU Food Standards Authority will need to
to public health goals such as reducing foodborne hu- address in order to: (1) reinforce the principles outlined
P.J. Panisello, P.C. Quantick / Food Control 12 (2001) 165±173 173

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lence between di€erent HACCP plans. Until barriers 459±471.
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