The food safety management system known as HACCP has come a long way since its development for the American space program. It has become an integral part of the country’s entire food safety system. “HACCP has had the biggest impact on ensuring the safety of food ever since it was implemented,” says Jenny Scott, senior advisor to the director of the Food and Drug Administration’s Center for Food Safety and Applied Nutrition. The acronym stands for Hazard Analysis and Critical Control Points and refers to the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. Scott puts it more simply: “Let’s figure out what could go wrong first, figure out what we need to control to prevent these things from going wrong, and then we’re going to have much better assurance that the foods we’re producing are safe.” In the late 1950s, the National Aeronautics and Space Administration (NASA) took on the critical control points system used by munitions factories and developed it with the help of Pillsbury to ensure the safety of the food they were sending into space. Sickening an astronaut with a foodborne pathogen was not an option. HACCP is in widespread use today. It’s almost a necessity for doing business with food, Scott says. In the 1990s, HACCP became a requirement for seafood and juice producers, as well as meat and poultry slaughter and processing establishments. In addition to requiring meat processors to have a HACCP plan in place, the Department of Agriculture’s Food Safety and Inspection Service has been working on an inspection system based on HACCP. Last summer, FSIS released the New Poultry Inspection System based on the HACCP-Based Inspection Models Project (HIMP), which requires facility personnel to conduct carcass-sorting before agency inspectors conduct online carcass inspection. John Munsell, who ran his family’s meatpacking plant for three decades, criticizes HACCP by saying that it transfers too much of the meat inspector’s authority to the plant owners and was never intended to be used for raw food. “HACCP is no longer primarily involved in a pathogen chase, but a paper chase,” Munsell has written. On the FDA side of things, finalization of the Food Safety Modernization Act rules will lead to what some call an “institutionalizing” of HACCP. The way Scott explains it, FSMA puts in place a broader set of preventive controls, of which HACCP is a part. HACCP can’t cover everything; there are some foundational principles that are managed differently. “You don’t want sick employees handling food, but you don’t deal with that as if it’s a critical control point in a HACCP plan. It’s a basic foundational element,” Scott says. “You’ve got to have a plant you can clean, and you have to have good sanitation practices.” Along the Food Chain When thinking about farm-to-fork, HACCP is not as commonly used by farmers or chefs in restaurant kitchens. HACCP principles don’t work as well in restaurants, Scott says, so they’ve come up with a different approach that focuses more on operations such as cooking, cooling and holding instead of addressing particular food types. “The HACCP system is more geared towards manufacturers,” she says. “That being said, the HACCP principles can be applied fairly broadly.” Roy Costa, founder and owner of the consulting firm Environ Health Associates, argues that restaurants should employ HACCP. “Unfortunately, the restaurant industry has been stuck in what I call ‘compliance culture,’” he says. “They only do what the inspector tells them to do. They don’t take initiative on their own or go beyond the minimum requirements.” Costa adds that, “in order to do HACCP, you have to take the responsibility on yourself.” Expanding Principles There are seven principles to HACCP laid out by the U.S. National Advisory Committee on Microbiological Criteria for Food (NACMCF) when it developed, updated and approved a standardized HACCP system in 1997. They are:
- Principle 1: Conduct a hazard analysis.
- Principle 2: Determine the critical control points (CCPs).
- Principle 3: Establish critical limits.
- Principle 4: Establish monitoring procedures.
- Principle 5: Establish corrective actions.
- Principle 6: Establish verification procedures.
- Principle 7: Establish record-keeping and documentation procedures.
Separate from her role at FDA, Scott is the U.S. delegate to the Codex Committee on Food Hygiene. That committee is now looking at whether it needs to revise its HACCP annex, which she says is very similar to the NACMCF document. As HACCP has been implemented over the years, there have been some areas of confusion, and the Codex committee is now asking whether there are areas that should be changed or clarified. “A particular area of concern has been the issue of verification and validation,” Scott says. Validation has previously been considered a component of verification — it’s all part of making sure that the system is controlling the hazards. But people have started thinking of “validation” as the scientific basis for the entire plan — what is it capable of controlling instead of verifying it’s being implemented. Scott says Codex is discussing whether verification and validation should be separated into individual principles or simply clarified within the verification principle. The General Principles of Food Hygiene (where the HACCP annex is located) may also be updated more broadly to incorporate HACCP principles. “We’ll have to see how it evolves, but I don’t think HACCP is going away,” Scott says.
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