Contact: Dr Andreas Klieber, aklieber@qualityassociates.com.au, +61 438 356 394
Codex HACCP Update is coming to a workplace near you
Dr Andreas Klieber – Managing Director QAPartners & QATraining
Codex HACCP has recently celebrated its 50th anniversary. To stay up-to-date and relevant the FAO and WHO Codex Committee on Food Hygiene has signed off on a significant number of amendments. Australia as a member nation participated in the redrafting.
These amendments were about to be signed off by the Codex Commission, but due to the COVID 19 crisis that has been somewhat postponed.
As QAPartners Director Dr Andreas Klieber foreshadows, “now is a good time to get ready for the coming Codex HACCP changes and to make the transition as easy as possible”.
Specific changes that will need to be addressed are associated with changes to definitions, with extended guidance being added to the Codex HACCP Code of Practice and with changes to the 7 Principles of HACCP.
Keeping in mind that the Codex HACCP system has to be applicable across the world and to micro as well as global businesses, the first change expands the Code of Practice into 2 chapters. The first chapter is about Good Hygiene Practices (GHPs). The GHPs are basically pre-requisite programs and consider suitable what facilities and equipment are. While they are split out from HACCP (chapter 2), there is also significant overlap between the two chapters.
GHPs require the description of products and processes (HACCP Preliminary Step 2), monitoring (Principle 4), corrective actions (Principle 5) and consideration of the effectiveness of GHPs (Principle 6). The new guidance in the Code of Practice states “some key aspects of GHPs could be considered as control measures applied at CCPs in the HACCP system.”
What has not changed in the guidance is that the food safety hazards are listed as biological, chemical and physical. Allergens can still be considered under chemical, but best practice would separate this out in modern HACCP plans.
Looking at the proposed changes for HACCP steps (in bold), these effect the Principles of HACCP. The preliminary step wording remains the same.
- Principle 1 – Conduct a hazard analysis and identify control measures
- Principle 2 – Determine the Critical Control Points (CCPs)
- Principle 3 – Establish validated critical limits
- Principle 4 – Establish a system to monitor control of CCPs
- Principle 5 – Establish the corrective actions to be taken when monitoring indicates a deviation from a critical limit at a CCP has occurred
- Principle 6 – Validate the HACCP plan and then establish procedures for verification to confirm that the HACCP system is working as intended
- Principle 7 – Establish documentation concerning all procedures and records appropriate to these principles and their application
In practice, Principle 1 and 3 wording changes only reflect what is happening currently in practice already.
Principle 5 wording changes indicate a change in definition where ‘deviation’ will be used instead of ‘loss of control’.
The key change is to Principle 6. Rather than a newly developed HACCP plan being implicitly being expected to operate smoothly, the HACCP plan will need to be validated when first implemented. This means that data needs to be gathered that shows consistent and compliant operation during manufacturing implementation.
Notable is also that Food Safety Culture will be included in the Code of Practice.
However, the Code of Practice remains focussed on unintentional food safety hazards and is not venturing into related areas of deliberate actions such as food fraud or attacks on the food supply chain (food defence).
The deliberate actions are typically captured through TACCP and VACCP systems, but in reality, should be considered together with HACCP as a comprehensive, modern food safety program.
According to Dr Andreas Klieber, “our HACCP as well as TACCP and VACCP training can bring you up to date with best food safety practice as well as a more comprehensive view of the upcoming changes. Specifically, our new Online HACCP Refresher course provides you with great flexibility while providing an in-depth view of recent developments.”
The online HACCP Refresher course can be accessed at onlinetraining.qualityassociates.com.au/courses/haccp-refresher
Disclaimer: Please note that the considerations in this paper are of a general nature only and should not be seen as a recommendation to act in specific ways.
For more information, please contact QAPartners – info@qualityassociates.com.au; 1300 737 193.
