HACCP in the Next Decade
February 01, 2010
by Richard F. Steir
The food safety program known as Hazard Analysis and Critical Control Point (HACCP) is a half-century old. For all of you who have taken a HACCP class, you most likely remember how the instructors talked of it being a collaboration of the National Aeronautics and Space Administration (NASA), the US Army Laboratories at Natick, MA, and Pillsbury.
Paul Lachance, PhD, a retired nutritionist from Rutgers University, was one of the principals with NASA at the time HACCP was created to ensure that foods used in the space program were safe. He said he wanted to be assured that NASA’s chief medical officer would not be calling him to say that “his astronaut or astronauts were sick and had stomach problems.” It was this fear and a systems evaluation that indicated the traditional quality control method — end product testing — was not adequate to ensure production of safe food. This same concern is why such measures continue to be used today. No one wants to hear that its products have made someone sick.
However, the original HACCP program is not the program used today. Its focus was to control salmonella in space foods. The original system that was created by Pillsbury in 1973 and used as a training tool for Food and Drug Administration people had only three principles:
• The Identification and assessment of food hazards
• Documentation of critical control points to control identified hazards
• Establishment of a system to monitor the critical control points.
Since its inception, HACCP’s basic goal has never changed. However, it has undergone a gradual evolution, which has helped ensure food processors have a tool to develop strong and robust food safety management systems.
In the US, HACCP received its biggest boost in 1985 from the National Academy of Sciences (NAS) report “An Evaluation of the Role of Microbiological Criteria for Foods and Food Ingredients.” This report stated that HACCP “provides a more specific and critical approach to the control of microbiological hazards than that achievable by traditional inspection and quality control procedures.”
The report also concluded that testing of finished products was not an effective strategy to protect customers and assure that food was free of pathogens. This is something that many people seem to forget today.
This report helped jump-start HACCP systems in the US and around the world. The National Advisory Committee for Microbiological Criteria for Foods (NACMCF) issued the seven principles of HACCP in 1992. This prompted prerequisite programs in a HACCP regulation in 1995, which was the impetus behind the principles including the five preliminary steps that were harmonized in 1997 by NACMCF and Codex Alimentarius (See “HACCP Preliminary Steps and Principles” on Page 106). And this eventually led to the creation of ISO 22000 in 2005.
Many people believe that more regulations are the answer to everything. In 2007, the US Congress enacted legislation that resulted in the Reportable Food Registry, which is now part of doing business for the food industry. Pending legislation also is targeted at further enhancing food safety. The question is, “Will more regulations make our food supply safer?” HACCP is mandatory for the US meat and poultry industry, and the plants are under continuous inspection. Yet that industry continues to have issues and recalls.
While there is talk about mandating HACCP for all food and ingredient processors, the reality is, that is almost the case now. Regulations have not driven food safety and HACCP in food sectors such as the baking and snack industry, but food safety is motivated by a desire to produce safe food and current market requirements.
The basic tenet in today’s market is rather simple: If you wish to compete and sell foods and ingredients, your company must have a HACCP plan. The program is mandated by almost every buyer throughout the country. In other words, get with the program or lose your customers.
The bottom line is that economic incentives are a more powerful and effective tool for change than mandating food safety programs through the regulatory process.
Most products manufactured in the baking and snack industry are considered quite safe. Fried snacks, cookies, cakes, pies and breads are not the foods one thinks about when hazardous products are discussed.
However, the industry has encountered problems through the years. An unexpected outbreak occurred in Germany in 1993. More than 1,000 persons developed salmonellosis from consuming potato chips. Potato chips are fried in hot oil at temperatures in excess of 300°F. How could these be a source of a foodborne outbreak? It turned out that the chips were seasoned with paprika found to be contaminated with the pathogen. The spice came from South America and was distributed by a manufacturer in Germany as a seasoning for fried snacks.
In 2007, Veggie Booty snacks were recalled due to salmonella contamination attributed to the spice blend. Spices are a ready-to-eat product in most cases, so buyers should purchase products not only from reputable suppliers but should also consider mandating that they be processed in some way to reduce microbial risk.
The US also experienced outbreaks that were traced to a breakfast cereal. Malt-O-Meal conducted a recall in 1998 when epidemiological evaluations determined that its cereals were causing salmonellosis. Again, how does a toasted breakfast cereal end up contaminated? Like the potato chip issue, post-process contamination was the source.
What these outbreaks say is that anything can happen. This is why HACCP is a system that includes prerequisite programs, emphasizes issues such as vendor quality and stresses the importance of properly assessing potential hazards. Failing to maintain these programs in actual processing operations is what can lead to a failure of the system and perhaps foodborne illness.
People have always assumed that bakery and snack foods are safe. Most of the processes to make these products have been used for many years. Given the events of the past few years, processors are seriously re-evaluating or revalidating their cooking processes, whether they are oven baked, dry roasted or oil roasted/fried. Are these heating processes adequate to kill potential pathogens?
One of the basic principles of thermobacteriology is that the heat resistance of microorganisms increases as the water activity of a product decreases. In addition, materials such as fats and oils can protect microorganisms and further increase their heat resistance. This is why it would be almost impossible to impart enough heat to peanut butter to kill a pathogen like salmonella. If it is not destroyed on the raw peanut, it will not be inactivated in the butter.
The cooking process for baked and fried foods is essentially a dehydration operation. As the product is heated and cooks with accompanying drying, the water activity drops, which could adversely affect the lethality imparted to the process. In addition, validation of thermal processes used as kill step or critical control point (CCP) is an integral part of a company’s HACCP plan.
Validation of cooking processes could be a challenge for the baking and snack industry. Other challenges also include validating cleaning processes and prerequisite programs deemed essential for food safety.
Several issues must be addressed in the area of process validation: People who are process authorities, a need for surrogate microorganisms and development of methods to complete these studies. The low-acid canned food regulations found in 21 CFR Part 113 mention “competent process authorities” but really do not define what skills and knowledge such a person should have. The Almond Board of California (ABC) initiated a program to approve process authorities as part of its program to ensure that all almonds sold are given a process sufficient to ensure microbiological safety. ABC had to write its own definition of a process authority so that it would have guidelines to evaluate prospective applicants.
Surrogates, the nonpathogenic microorganisms whose characteristics mimic that of target organisms, were also mentioned. In the canning industry, nontoxic Clostridial or bacillus sp. are used in lieu of Clostridium botulinum. The reason surrogates are so important is that one never wants to bring a known pathogen into a food processing environment. As an example, the surrogate organism for Salmonella enteriditis specified by the ABC, Enterococcus faecium NRRL B-2354, for almond roaster validation is also being used for peanut and other tree nut validations. The questions being, Is this the best organism to use as a surrogate for Salmonella for validating all processes for low-moisture products?
ISO 22000 EMERGES
Third-party audits are a fact of life in today’s food industry. Processors must meet audit requirements mandated by their customers. HACCP is an integral part of all audits, including SQF (Safe Quality Foods), BRC (British Retail Consortium), IFS (International Food Standard) and Dutch HACCP. These audit formats have been approved by the Global Food Safety Initiative (GFSI) and FSCC 22005 (ISO 22000).
Unfortunately, third-party audits are not standardized. In fact, some processors have separate manuals for different audit firms. More companies, however, are moving toward ISO 22000. This is an auditable food safety standard that was issued on Sept. 1, 2005, and it was reviewed this past September by the technical committee that developed the standard. Processors, especially multinationals, like the discipline of the standard and have been developing their food safety programs using this document. What many people do not realize is that one can use a standard yet not spend the time and money required for a certification. Among the firms that are moving toward adoption of ISO 22000 are Cargill and Nestle.
ISO 22000 defines what is expected to ensure the production of safe food. It is up to the company that implements the system to properly define the prerequisite programs and the HACCP plan.
ISO 22000 mandates that organizations “establish, implement and maintain prerequisite programs (PRPs) to minimize the potential of introducing hazards into the processing environment, control potential food hazards and reduce the potential of biological, chemical and physical hazards being introduced into the food or beverage. The processor must verify that the PRPs are effective as part of the food safety management system and modify them as needed.” This kind of discipline is implied but not mandated in many HACCP programs. It gives processors the flexibility to develop programs that directly meet their needs, rather than implement programs to meet the requirements of a more proscriptive audit like SQF. The key word is effective. ISO 22000 mandates that the systems that are developed, implemented and maintained be effective.
The ISO standard provides reference material to assist a company in the proper selection, implantation and documentation of the prerequisite programs. This strategy was intentional. In addition, ISO and the International Trade Centre published an additional reference that further elaborates on the standard. It allows the development of a food safety management system that is customized to the culture and operations of the food processing company. ◾