When consumers purchase a product, they have a very fundamental expectation that the food they are about to consume or feed to their families will not cause illness or injury. To find a foreign object in food or to suffer a bout of poisoning due to contaminated food is unacceptable. As a consumer, how would you react if you found a piece of glass in a sandwich or ended up with a case of vomiting and diarrhea after a take-away meal?
Food is not intrinsically safe. It provides the ideal nutrients for growth. There is also the potential for the introduction of hazards at various stages of producing and handling products. Foods may ordinarily contain food poisoning bacteria (ie potential for E.coli on raw meat), toxic chemicals (from spays used on produce) and foreign objects (bones in meat). Some people have allergies and intolerances to specific foods or ingredients which are not considered food poisoning; however reactions can be very serious, and products that contain undeclared allergens are potentially life threatening for these people.
The NSW Food Authority estimated 4.1 million cases of food poisoning in Australia in 2015. Most food poisoning is caused by harmful bugs (pathogens) getting into food. The most common types of food poisoning are:
- bacterial eg Salmonella, Campylobacter, E.coli and Listeria
- viral eg Norovirus, Rotavirus and Hepatitis A
intoxication caused by the toxins produced by some bugs such as Staphylococcus aureus, Bacillus cereus and Clostridium perfringens.
Here are some recent examples of recalls due to microbiological contamination…
- Mar 2017, The Pork Pie Shop Pies – potential Salmonella contamination
- Aug 2016, Rockmelons – Salmonella Hvittingfoss cases, a rare strain of Salmonella (with 86 cases reported nationally)
- June 2016, Organic Mung Beans – contaminated with Salmonella
- Mar 2016, Pate – contaminated with Listeria Monocytogenes
- Feb 2016, Leafy Salads – contaminated with Salmonella
- Feb 2015, Frozen Berries – contaminated with Hepatitis A.
HACCP (pronounced HASSUP)
In the 1960’s, it was identified very early in the US space program that a significant risk to a mission was an astronaut becoming ill with food poisoning. Food scientists and engineers from the Pillsbury Corporation developed a system, in partnership with NASA, to ensure the safety of food being provided for the first manned space missions. This system and concept was the basis for HACCP. Since then, HACCP has been modified to make it easier to implement and maintain a system, and to make it more effective. HACCP adoption was driven more by industry than regulation, which saw the widespread adoption of the system by food suppliers and processors.
HACCP stands for Hazard Analysis and Critical Control Points. It is a preventative food safety system in which each step of the manufacture, storage and distribution of a food product is scientifically analyzed for microbiological, physical, chemical and allergen hazards. It is aimed at prevention and elimination of contamination, instead of relying on end-product testing as an assurance of product safety. It is a risk-based approach, requiring companies to assess the steps under their control and determine which parts of the process must be controlled to prevent a food safety issue occurring.
A Critical Control Point (CCP) is defined as ‘a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level’. Examples of CCPs may include:
- Cooking ie cook chicken to an internal temperature of 74°C
- Addition of preservatives to a product in order to achieve the required shelf life
- Addition of a chemical sanitiser in water used to wash bagged leafy greens prior to packing
- Metal detection of finished product or ingredients
- Confirming a product is packed into correct packaging (ensuring the correct allergen declaration).
If a site identifies a CCP within its process, it must then ensure it defines the criterion which separates acceptability from unacceptability. This is known as the Critical Limit. Behind the example listed above (Cook chicken to an internal temperature of 74°C), there is scientific literature that states that poultry should be cooked to 74°C to destroy the types of food poisoning bacteria associated with poultry. This is a validated critical limit. Cooking to 73°C is not acceptable.
The HACCP Plan also captures processes for monitoring compliance to critical limits, corrective actions in the event of a breach of a critical limit, and a process for verification which may include finished product testing and system audits.
Whilst there is a significant amount of legislation pertaining to Food Safety, the implementation and ongoing management of an HACCP based system is not a regulatory requirement. However, from my experience, the majority of ingredient suppliers, manufacturing companies, distributers and suppliers to retailers, will at a minimum have a certified HACCP Program. For many, it is a condition of sale that they have HACCP Certification, which is achieved by being audited by an Independent Certification Body.
HACCP is a basic Food Safety program; it is fair to say, a significant number of businesses have upgraded and expanded their Food Safety programs to a GFSI (Global Food Safety Initiative) Standard. Examples of current GFSI Standards include BRC, SQF, GlobalGap and FSSC22000.
Retailers such as ALDI, Coles and Woolworths will accept a GFSI Standard as part of their Vendor Approval Criteria, and dependent on the nature of the product being supply to them, will require some additional criteria to be audited that are specific to each retailer.
PwC’s Compliance Services is an accredited Certification Body offering certification to various industries across multiple standards including HACCP and GFSI Standards – helping our clients build more dependable food trust.
PwC Training Academy also deliver virtual Food Safety Management Systems training courses.