HACCP importance recognised but implementation criticised
However, in all Member States there is a reasonable level of implementation of Hazard Analysis and Critical Control Points (HACCP) based procedures.
HACCP is a science based and systematic approach to identification of hazards and assessment of related risks, implementation of measures for control and monitoring compliance with set standards.
National frameworks for implementing HACCP-based systems vary between and within Member States leading to inconsistencies of interpretation and implementation.
Some core concepts are not always understood, particularly by small food and beverage operators (FBOs), and are not applied in a consistent manner, according to the report.
‘Widespread lack of understanding’
There is a widespread lack of understanding by food business operators and competent authorities of the difference between prerequisites and HACCP and their respective roles.
“The main difficulties observed by MSs concerned the implementation of HACCP without a prerequisites being in place and the setting of Critical Control Points (CCPs) for hazards which should be controlled through the prerequisites," said the FVO.
“Examples were seen of excessive emphasis being placed by some control authorities on the HACCP part of Food Safety Management System (FSMS) with prerequisites being largely ignored.
“This is problematic as risks covered by prerequisites could potentially involve greater hazards.”
Most member states reported businesses had difficulties with hazard analysis.
“There is a widespread lack of understanding of how to undertake a hazard analysis correctly and this process creates difficulties particularly for Small FBOs due to lack of available expertise," according to the report.
“In general, operators were better equipped to address microbiological hazards. However, hazard analysis of chemical hazards was either absent or only partially addressed, thus chemical hazards were frequently overlooked. New and emerging risks, particularly in the feed sector, were rarely considered.”
‘No criticism of HACCP – just implementation’
The HACCP approach provides business operators the ability to make control measures which can reduce to an acceptable level or eliminate hazards along the production chain.
“There was no criticism of the HACCP approach from any source, only criticism of implementation," said the FVO.
“HACCP is inherently flexible and consequently it is impossible to devise prescriptive guidelines. Overly prescriptive guidance could undermine the scope to apply flexibility on a case by case basis.
“In addition to differences of interpretation, there are also differences of approach between and within MSs on flexible implementation and on official controls.”
Article 5 of Regulation (EC) No. 852/2004 on hygiene of foodstuffs requires FBOs put in place, implement and maintain permanent procedure(s) based on HACCP principles.
A previous report (2009) identified issues including use of (unsuitable) generic plans not reflecting reality and the level of documentation required.
The project aimed to assess the approach, to get an overview of the state of implementation and control of procedures based on the principles across Member States and across sectors and to identify and exchange good practice and common approaches to addressing problems.
It involved fact-finding missions to nine Member States, a questionnaire to competent authorities (CAs) in the non-visited Member States (19) and a stakeholder consultation.
Ireland, Belgium, Czech Republic, Denmark, France, Germany, Netherlands, Slovenia and UK were visited.
Stakeholders included European Dairy Association, FoodDrinkEurope, the French confederation of butchers, charcutiers and caterers and German Bakers' Confederation.
The Commission consulted with Member State experts on results of the project at a meeting last month and a roadmap for a better implementation of HACCP based procedures was developed.
