Contact: Dr Andreas Klieber, firstname.lastname@example.org, +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 – email@example.com; 1300 737 193.
Need HACCP Refresher Training?
Want to know more about the up-coming changes to HACCP?
Our online HACCP Refresher course includes a module on the changes
In this webinar, our director Dr Andreas Klieber discusses the impact of coronavirus on current food processing and its implications for future business continuity planning in the Australian food industry.
A note from Andreas
“We really want to see the food industry continue to function as normal. This is why we are eager to share our knowledge through these presentations and why we have created our Coronavirus support services. We have created a robust simulated business systems pressure test and short term staff cover for any ill/ quarantining quality or food safety staff.”
Implication of Novel Coronavirus (2019-nCoV) on Food Processing
Dr Andreas Klieber – Managing Director QAPartners
Contact: firstname.lastname@example.org, +61 438 356 394
The current Coronavirus Disease 2019 (Covid-19) outbreak is caused by the SARS-CoV-2 virus (Severe Acute Respiratory Syndrome 2 coronavirus). Management of the crisis is heavily focussed on medical intervention, and rightly so. Containing the outbreak and preventing further spread is the highest priority. It should also be noted that there are still many unknowns about this virus.
Dr Andreas Klieber, Director of QAPartners, sees the spread of the SARS-CoV-2 virus as a threat to the food industry that must be actively managed through business continuity and food safety systems. He further elaborates that “understanding the properties of this virus is crucial to its management.”
There are, however, also some things known by now including that it may transmit from human to human before symptoms occur, that it is largely genetically similar to the SARS-CoV and that it may survive in human faecal matter and be transmitted through aerosols. From a food safety point of view, this leads to a number of considerations regarding the potential risks to raw materials and foods associated with the SARS-CoV-2 virus.
1. The survival of the SARS-CoV-2 virus in human specimens is still being researched, but it appears to survive in faecal samples. Research on SARS-CoV indicates that this virus is relatively hardy and survives in serum, sputum and faeces for at least 96 hours. In urine, it could remain alive at least 72 hours with a low level of infectivity. (Duan et al., Stability of SARS coronavirus in human specimens and environment and its sensitivity to heating and UV irradiation. Biomed Environ Sci. 2003 Sep; 16(3):246-55.)
2. Therefore, excellent personal hygiene practices are required to limit the risks of food and raw materials to human pathogens including viruses. This is extensively addressed in modern food safety systems and includes focus on handwashing, suitable toileting facilities, personal protective equipment (PPE), exclusion of food handlers with symptoms of illness including sore throats, coughs and fever above 37.8 °C (US Centre for Disease Control and Prevention, https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/guidance-businessresponse.html, accessed 25/02/2020), return to work sign off by a qualified doctor and so on.
3. There is indication that simple surgical face masks will not stop the transmission of the SARSCoV-2 virus as they are too thin and not well fitting. (Geggel L., https://www.livescience.com/face-mask-new-coronavirus.html, accessed 10/02/2020.) In addition, infection can also occur through the eye or if contaminated hands are used to touch the face. Face masks may contain a sneeze to some degree, but to deal with aerosols, sufficient air changes are required to remove the aerosols rapidly from the environment. Minimum air changes in a food processing environment should be 6 air changes per hour.
4. If alcohol-based sanitisers are used following hand washing, ‘ethanol, the most common alcohol ingredient, appears to be the most effective against viruses’, with 95% ethanol being more effective than 80% for hardy viruses such as Hepatitis A. WHO formulations I and II (ethanol-based and isopropanol-based respectively) were effective against SARS-CoV, and Middle East respiratory syndrome coronavirus (MERS-CoV). (Gold N.A. and Usha A., Alcohol Sanitizer, updated December 16, 2019, https://www.ncbi.nlm.nih.gov/books/NBK513254/ accessed 3/02/2020.) The US CDC recommends hand sanitisers with at least 60-95% ethanol to control SARS-CoV-2 (US Centre for Disease Control and Prevention, https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/guidance-businessresponse.html, accessed 25/02/2020.)
5. Research on SARS-CoV showed that these viruses stayed stable at 4 °C and at room temperature (20 °C) for at least 2 hours on a range of surfaces and in water. (Duan et al., Stability of SARS coronavirus in human specimens and environment and its sensitivity to heating and UV irradiation. Biomed Environ Sci. 2003 Sep; 16(3):246-55.) Preliminary information on the SARS-CoV-2 virus shows that it may persist on surfaces for a few hours or up to several days. (WHO, https://www.who.int/emergencies/diseases/novel-coronavirus2019 accessed 25/02/2020.)Z
6. SARS-CoV virus was inactivated by heat treatments of 90 minutes at 56 °C, 60 minutes at 67 °C or 30 minutes 75 °C. UV irradiation for 60 min inactivated the virus in culture. (Duan et al., Stability of SARS coronavirus in human specimens and environment and its sensitivity to heating and UV irradiation. Biomed Environ Sci. 2003 Sep; 16(3):246-55.)
The data points at some food industries that may be more exposed to this threat than others. Any foods that are not cooked to a significant degree are more at risk; this is even the case for foods processed with a ‘Listeria-cook’ of 72 °C for 2 minutes. Also, chilling and most likely freezing is not readily going to destroy this virus and therefore chilled and frozen foods sourced from major outbreak zones should be risk assessed.
Risk assessment should include the regional source, personal hygiene practices at source, production date pre or post December 2019 when Covid-19 was first detected and further or prior heat processing of the raw material.
Also, there is a risk that regional output of raw materials disappears due to illness in the wider population leading to plant closures. This is particularly a risk for modern just-in-time supply chains that are common in the food industry. Alternative sources will need to be identified in these cases.
The above information gives us an indication of how the SARS-CoV-2 virus may behave in human hosts and the environment and specific interventions that could be taken. Much of these are already considered and implemented in modern food safety systems.
However, a thorough review of food safety systems in light of this emerging issue is required to ensure a food business’ preparedness. As QAPartners Director Dr Andreas Klieber states, “a rigorous review of the risks posed by the SARS-CoV-2 Coronavirus within the existing food safety management framework will ensure continued safe supply of food.”
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 – email@example.com; 1300 737 193.
Global Food Fraud Snapshot: April & May
'Another Missouri Man Charged in Fake Organic Grain Scheme' - USA
'Dangerous Fake JW Whisky Heading for BKK' - Thailand
'North Korea Launches Investigation to Track Down Counterfeit Liquor Production' - North Korea
"Australian fake tequila fire sale ‘could cause injury’" - Australia
'Examination Reveals Vegetable Oil In Five Brands of Sour Cream' - Armenia
Statistical Process Control (SPC) is more important than ever. Standards such as SQF and BRC have mandated that testing procedures and practices provide a statistically robust measure for compliance with requirements.
Non-conformances for lacking SPC implementation are on the rise. Our quick quiz below will test your knowledge and explain some key concepts of SPC.
[HDquiz quiz = “29”]
Could your business need assistance with SPC?
Our full Statistical Process Control Training Course is delivered on-site for the whole team, allowing everyone to have the knowledge they need to comply with your standard. Read more about the course here.
Call us on 1300 73 71 93 (option 1) or contact us at firstname.lastname@example.org to organise a quote.
The impact in Australia has been extremely widespread. What started as an issue from one farm has led to cases nationwide. It is not yet known if the initial crime was an individual acting alone or a group acting together. It is not even known exactly where in the supply chain the crime occurred. To compound the problems for the industry, there have been multiple cases of copycats committing the same crime. This has exasperated the issues and prolonged the media coverage, growing fear in the public. This case has exposed to the general population the complexity of the food supply chain and demonstrated how wide an impact cases like this can have.
The fallout from the scandal has seen strawberries pulled from the shelves in major retailers across the country. The price of the strawberries that are still on sale has been slashed. The prices are being slashed from the already low price due to the season’s glut. Farmers are currently dumping excess stock or scrambling to find inventive ways to use the unwanted strawberries. The economic impact of the extreme reduction in sales will have lasting impacts on all growers in Northern New South Wales and Queensland. Their season has just ended and without the capacity to sell products when confidence returns in the market, many growers in these areas will be left with debt to take into next season.
Attention now turns to South Australia, Western Australia and Victoria as their seasons are about to begin. If sale levels continue to be poor, the growers in these areas will face the same financial burden as the farms up north. For the seasons of these growers and next year’s critical season for those up north, consumer confidence must return. Scandals such as this can have lasting effects on the industry.
When listeria was found in rockmelon earlier this year, sales dropped across the nation. Whilst this was not a deliberate attack on the food, it demonstrates how public fear can impact sale levels significantly across an industry. The outbreak was only linked to one farm, however, sales of rockmelon at the time fell by 90%. The industry is still crippled and required a government grant in July to attempt to bring it up from its knees.
The most important next step for the strawberry industry is to restore consumer trust. They must be seen to be implementing steps to protect the consumer. These steps can serve a dual purpose of protecting the company’s brand and owner’s personal liability as well as gaining back the consumer’s trust. Currently, the industry is attempting to do this by advertising the use of metal detectors. Metal detectors are commonplace in other food industries, particularly food factories, but are not mandatory for fruit packing. There is now a rush to implement the detectors across the strawberry industry. However, this is not a guaranteed approach to foil tampering and sabotage. The metal detectors will ensure that no tampering or accidental metal contamination has occurred the during the picking and packaging process. It will not ensure that the product is sabotage free when it leaves the site. There is ample opportunity for sabotage of the product after it has been through a metal detector. The best way to assess the true risk to the business is with a full threat and vulnerability assessment.
A full TACCP and VACCP (Threat Assessment and Critical Control Points and Vulnerability Assessment and Critical Control Points) review and action plan is the most comprehensive means of preventing attacks on food. While a metal detector may be a threat control point, it cannot be the only one. The initial strawberry sabotage is thought to have been conducted by a disgruntled employee. HR management, staff interviews, fair working conditions and site monitoring must all be included in the TACCP and VACCP plan to minimise the risk of a similar attack. Structured staff interaction is needed. When the interaction is conducted by outside interviewers, it allows the staff to feel free to speak openly and honestly. All threats and vulnerabilities must be assessed with critical risks being controlled. Customer facing security solutions can also be included in overall plans to increase faith from the market. Security solutions such as tamper-proof packaging is a tangible means of displaying the increase in security.
While the needles have mainly affected strawberries in this instance, this form of attack is not new. It has been seen in the industry before and can impact any industry. Getting an independent and comprehensive review of your business’s TACCP and VACCP plan goes a long way to completing your due diligence. Doing this work before a scandal breaks out can maintain trust with your consumers and keep yourself ahead of your competitors.
Food Police Agency coming for food manufacturers in France?
This year has seen multiple recalls on products containing dairy ingredients due to Salmonella. Most notable has been contaminated baby formula in France. The impact of this case has been widespread across the globe and affected many families. At least 37 babies have been infected and a very messy recall was carried out in 66 countries. Fear had also spread around the world as consumers still clearly remember the Chinese Melamine scandal of 2008. Public outrage always follows when they fear for the safety of their loved ones.
These issues highlight the risk of post-process contamination for the dairy industry, the importance of a diligent approved supplier program and robust recall procedures. The aftermath of the baby formula contamination has been a state-run investigation into the affair that is recommending strong measures to clean up the recall process and reduce the risk of these events occurring again.
How Salmonella was detected
The factory implicated has had Salmonella issues in the past before the current owners purchased the factory. Then in August of 2017, the company’s own tests returned positive results for Salmonella. The company attempted to deal with the issues internally. However, on the 1st of December 2017 government tests found Salmonella in their product when attempting to find the source of multiple Salmonella infections. This was when the first recall was issued.
From here a very messy recall process began. Over the course of the next two months twelve million cans of baby formula were recalled. A second recall was needed in mid-December to ensure that all affected products were recalled as the breadth of the recall widened.
The recall began on the 1st of December however, the factory wasn’t shut down until the 8th of December when a thorough and comprehensive audit of the site commenced. The situation was exasperated by unclear communications between the supplier and retailers during the recall process. The end result was that consumers were sold over 2,000 units of the recalled product across France after the recall was announced. These issues, coupled with public outrage, triggered a state-run investigation that has gained the attention of the French President Emanuel Macron who stated that those responsible must face punishment.
Those Responsible Must Be Punished
The report’s findings have suggested a raft of 49 changes to be applied to the food industry in France. The most notable of this is the call to formulate a Food Police Agency. The report suggests the agency would be funded by an extra tax on food manufacturers. The Agency would manage issues throughout the supply chain and enforce stronger penal and financial sanctions for companies at the origin of a crisis.
Calls have also been made for superior and well-rehearsed withdrawal and recall procedures. The case demonstrated that despite having a recall procedure, the system broke down and exposed consumers to unnecessary risk post the recall. Having a plan that is looked at each year is not enough, it needs to be practised, validated by outside eyes to spot weak points and have key personnel knowing exactly what their role is. This will make the recall as efficient as possible, reducing the risk to the consumer and the overall impact on the business. A poorly executed recall, especially when the consumers in question are highly vulnerable, can lead to public outrage and governmental policy changes.
Quality Associates offer expert Recall Training by experienced recall managers and sponsors – Learn how to set up an appropriate recall program, how to manage an actual recall, how to effectively conduct a mock recall and how to recover your business after a recall.
Please find links below to further Quality Associates Services that can greatly reduce your risk of similar issues occurring in your business.
Contact Us for more information or to organise a consultation.
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As the food industry looks to combat the estimated $40 billion a year issue of food fraud, attention is shifting to pre-empting food fraud threats and taking a proactive approach to stopping fraudulent behaviour. The food industry, historically, has taken a reactionary stance to food fraud. However, there is now a major effort to control fraud before it is instigated.
A legislative push has begun for a proactive approach to be taken to food fraud. The latest version of the British Retail Consortium’s food standard (BRC7), addresses the foresight needed by all that contribute to the supply chain.
“The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials” (BRC7)
The new directive ensures companies have an outward focus to the wider industry. Risks can be identified that could impact the business and preventative action can be taken to secure their supply chain. The information tracking can be taken further and developed with the use of horizon scanning.
Horizon scanning is a holistic analysis of the market. It factors in market trends, product shortages, new products, high margin products, ease of access to counterfeit goods, prices of goods and level of regulation in different markets. All this information together can identify profitable markets for fraudulent behaviour and the markets most at risk. The information must then be acted upon to ensure that the fraudulent raw materials never make it into the supply chain. Key indicators can lead to the identification of spikes of fake products entering the supply chain. When many factors align, it almost makes it a certainty that fraud will occur.
The Cumin Industry
The Cumin industry in India between 2012 and 2014 is a key example of this. During this period drought and extreme temperatures hit the growing areas. Coupling this with unpredictable monsoon seasons, the price of cumin doubled in this period. The high price lead to a very profitable situation for millers of cumin to increase their stocks by introducing foreign materials to increase weight. This combined with low levels of regulatory oversight and easy access to cheap counterfeit materials lead to fraudulent cumin being produced.
The situation manifested in peanuts and almonds, amongst other goods, being introduced into the cumin supply. A serious threat to allergy sufferers was created for a wide range of products. Horizon scanning would have raised red flags to the issues facing the cumin industry during this time. Manufacturers would have had time to take preventative measures such as testing and implementing stricter traceability systems. However, the scandal was not dealt with until it was too late and over 700 products were recalled across the US alone.
Another method that is being implemented in the food industry to identify potential vulnerabilities to fraud is forensic accounting. This method treats food fraud as what it is, fraud. Pro-actively using accounting techniques to review the practices and supply chain of the business can expose risks that were once hidden in mass data. Forensic accounting follows the money trail and exposes inconsistencies that could be the result of fraud, or potential areas where fraud can occur. Part of the process is a review of supplier prices against the commodity price and the costs of production. Anomalies in the price can be indicative of kickbacks paid to an employee, which raises the price, or fraudulent goods in the supply chain lowering the price from the benchmark.
The money trail can also pinpoint where exactly the raw materials have come from and if new and unapproved suppliers have been introduced. However, this may prove difficult if the supplier is unwilling to be fully transparent with the reviewers. To counter this, random paperwork checks can detect abnormalities with suppliers, which can lead to the detection of fraud. Implementing accounting techniques can use the wealth of data big businesses have and expose gaps that are not easily visible, allowing management to act upon them and mitigating future risk.
If your business needs assistance with Threats and Vulnerability systems or training, contact Quality Associates today for a free phone consultation on 1300 73 71 93 or firstname.lastname@example.org.