HACCP in the United Kingdom [复制链接]

1. Background

1.1. A formal government initiative to encourage the implementation of HACCP-based food safety control systems began in the early 1990s. The programme was in response to key recommendations from a UK Expert Committee¹ which examined the rise in UK food poisoning during the 1980s. It recommended that:

• Food processes should be designed on HACCP principles;

• Enforcement staff should seek to encourage HACCP through their inspection activities;

• Environment staff should receive appropriate training in HACCP and its application.

1.2. A series of measures were subsequently taken by the government, a number of which were focused directly on the training of food control officials. 1.3. Food control officials. The professional core curriculum for local government environmental health officers (who constitute the major part of the Food Safety Inspectorate) was examined to ensure that an appropriate level of training was provided to equip inspectors carry out assessments of risk and HACCP based systems. Department of Health and Ministry of Agriculture Fisheries and Food officials also funded and undertook a nationwide programme of training seminars for industry and enforcement officials. During 1991–1993 over 40 HACCP training seminars were carried out. The basis of the training was the Codex HACCP Guidelines which were in the process of being elaborated. 1.4. HACCP materials. Government took steps to encourage and support the production of a range of HACCP materials, training aids and computer packages to facilitate HACCP implementation in food businesses. A HACCP training standard² was subsequently developed to help control the consistency of training. 1.5. Industry. During this period, HACCP systems were increasingly being used as the basis for supplier specifications and contracts to secure improved standards and control. Prior to 1993 HACCP-based food safety control systems were not a requirement of UK law. However, companies with HACCP in place, particularly within (ISO) quality control systems, were more able to sustain the defence of "due diligence", available in UK law, in the event of a food safety problems. As such, enforcement authorities were increasingly being required to assess the adequacy of HACCP systems on a legal basis, where these systems were being put forward by businesses, as part of a 'due diligence' defence.

2. European requirements for HACCP based systems

2.1. From 1993 onward, as part of the European legislative framework to support the single market, HACCP-based controls were required in UK law through the implementation of a range of EU food hygiene directives. The Hygiene of Foodstuffs Directive 93/43EEC (covering food retailers, caterers and manufacturers of non-animal origin products) required hazard analysis to be carried out by food businesses. The directive does not require the application of all HACCP principles and there is no requirement for documentation or verification. 2.2. A range of veterinary hygiene directives (covering the manufacture of products of animal origin such as meat products, fish products and milk products) were also introduced which have provisions for HACCP-based "Own Checks" controls. These directives do require establishments to document procedures, such as the identification of critical points, monitoring arrangements and sampling regimes. 2.3. This new legislation resulted in a series of statutory Codes of Practice for enforcers and additional specific training seminars on the new requirements, particularly the new legal provisions relating to HACCP-based controls. Training was provided on the basis of a funded place for one local authority official (≈500). Cascade training materials were also made available, with the remit that those trained would be responsible for training other officials within their departments. It was recognised at an early stage, that HACCP assessment required a different enforcement approach from the more traditional inspection techniques, albeit the UK legislation also contained more specific requirements to ensure satisfactory hygiene standards were in place for structure, equipment, personnel and processes. Compliance with these basic hygiene requirements would also be checked during general inspections. 2.4. It is anticipated that the EU review and consolidation exercise of food hygiene legislation which is currently taking place, will recommend that the seven principles of HACCP are applied in all food businesses. The UK supports this approach and recognises the benefits of documentation for official control purposes.

3. Government guidance

3.1. A range of official government guidance has been issued relating to the training, qualifications and competence of officials carrying out assessment of HACCP controls. This guidance material also contains an inspection rating system, based on risk, for determining the frequency of official inspections of premises. The guidance helps to ensure a consistent enforcement approach is taken across the numerous local authorities engaged in food control activities throughout the UK and the wide range of food businesses. 3.2. Statutory Official Codes of Practice have been issued and enforcement officials must have regard to the guidance they provide. The primary Code relating to food hygiene inspections is Code of Practice No. 9³ which specifies that food hygiene inspections have two main purposes. One of these being:

"to identify risks arising from the activities carried on and the effectiveness of food businesses' own assessment of hazards and control of risks."

3.3. The code also contains the inspection rating scheme to determine the inspection priorities and frequencies. The system is based on

• the potential hazards;

• level of compliance with regulations;

• confidence in management/control systems.

Sub-classifications are provided which draw out issues such as; the type of food handled; method of processing; consumers at risk; and the food safety management system (including HACCP or similar systems) in place.

4. Assessing HACCP based systems

4.1. Guidance on assessing the adequacy of HACCP-based controls in a food business is provided for officials in a range of government codes or official guidance from the Local Authorities Coordinating Body on Food & Trading Standards (LACOTS), developed in conjunction with government.^3,4,5 Paragraphs 4.2–4.7 summarises from this guidance, some of the issues which enforcers are advised to consider when assessing HACCP based systems. 4.2. Confidence in management controls

Consider

• Track record of the company, its willingness to act on previous advice and enforcement, complaint history;

• attitude of present management towards hygiene, level of food hygiene training;

• technical knowledge within or available to the company;

• existence of external third party quality assurance accreditation, satisfactory documented procedures and food safety management systems.

4.3. Assessing the adequacy of the HACCP arrangements

Consider

• Product description – is it detailed/accurate;

• Expertise – sufficient in-house, external or generic guidance;

• Flow chart – is it accurate and checked.

4.4. Hazard analysis

Consider

• Have all reasonable hazards been identified? Has regard been paid to relevant statutory industry guides;

• expert industry guidance;

• expert reports;

• any published information;

• relevant government reports;

• predictive modelling, where appropriate.

4.5. Competent assessment of risk

Consider

1. History of problems/complaints;

2. severity and imminence of hazard;

3. critical customer groups.

4.6. Assessment of controls

Consider

• The specific controls in place;

• are (all) critical controls identified;

• are they operating to recognised/legal standards;

• have critical limits been identified;

• are critical limits realistic, measurable, relevant;

• how are critical limits determined;

• are they sufficient to control all the hazards;

• what monitoring is in place;

• does it adequately identify loss of control in time for remedial action;

• are staff engaged in monitoring adequately instructed/trained;

• are corrective actions sufficiently identified, understood and operated;

• are records, where appropriate, maintained correctly.

4.7. Verification procedures

Consider

• What are they;

• are the in-house verification procedures adequate;

• are the procedures reviewed;

• are external verification/audits carried out.

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