FOOD SAFETY COMPLIANCE IS NO MORE AN ADVANTAGE RATHER A BARE MINIMUM REQUIREMENT- HACCP BASED PREVENTIVE RISK MANAGEMENT SYSTEM  

There is no shortcut to success and prevention is better than cure (an ounce of prevention is better than pounds of cure) and we need to/ are coming out of dual approach of dealing with export and domestic manufacturing and with FSSAI in place, this CHALTA HAI attitude is/has to move out of the industry.

HACCP (Hazard Analysis and Critical Control Point) based terminology introduced by Codex Allimentarius Commission (CAC) a joint commission of FAO and WHO is a bench mark practices to access the Organization’s capability to produce safe products and for ensuring on-going continual improvement in the same. In the current scenario HACCP based Preventive approach is part of Food Safety Legislation in all the countries. Although HACCP technique was developed initially to deal with microbiological hazards that affect product safety and also those leading to microbial spoilage. Increasingly, it became accepted that the technique was primarily applicable to issue of product safety associated with biological, chemical (including allergen) or physical hazards. Nowadays, HACCP technique is applied to identify product quality defects (e.g. particle size, color, taste, texture) and to define appropriate “control measures” and hence HACCP technique (i.e identify potential hazards and control measures are implemented to prevent occurrence/re-occurence) is equally applicable to both product safety and quality issues (including microbiological spoilage). In packaging industries the risk to product safety, functional integrity, legality, chances of malicious intervention and unintended migrations related aspects are additionally considered while conducting HACCP studies. It is essential to ensure that use of HACCP for assuring safety of food is not diluted, or confused by attempts to derive CCPs for such topics as product quality attributes. It is recommended that HACCP is targeted at product safety issue sand where quality and other issues are included a clear distinction between safety and quality must be established. 

Control measures or preventive measures referred as Pre Requisite Programs expected to be in place as recommended by all standards including codex and schedule IV of FSSA also addressing- adequate plant design/layout, staff facilities, good personal hygiene standards, good housekeeping and hygiene standards, proper pest control, proper maintenance, appropriate waste management, supplier control but this is just an indicative list.

In addition to the above indicated PRPs, sites involved in manufacturing of food/packaging materials should consider putting additional specific measures to prevent foreign matter contamination, as follows:

Glass and Brittle Plastic Control- All glasses to be protected to prevent breakage and shattering. Numbered properly, regular monitoring for breakages and procedures including correction/corrective actions shall be in place. Lights of Insect-o-cuters shall also be adequately protected. Placement of Insect-o-cuters is also very crucial aspects as it is do be done considering it is as monitoring devise rather than controlling device.

Wood Control- Restricted usage of wooden if complete elimination is not possible. Proper treatment of wooden articles (heat treatment or fumigation) prior to use and regular monitoring for integrity including damages and infestation should be in place.

Sharp Object Control- Control on usage of blades and other sharp objects in all processes involved in factory should be in place. No snap off blades shall be used.

Temporary Engineering (tapes/card boards/threads etc)- Ideally no temporary engineering should be permitted in process areas (this may lead to additional sources of contamination, not taken in to consideration while conducting risk assessment), but certain limitations of operations need to be considered as an exception. Situation of temporary engineering may arise becuase of running operations, which can’t  be stopped in between or  non availability of spare part  or as result of non availability of trained maintenance staff In such cases, temporary engineering in required to continue running the process. This can be permitted after assessing the risk and can be executed in adequately defined manner by well trained staff with clearly documented correction date. You must have seen, in factories, temporary arrangement quite often become permanent and can impact the safety of the product being manufactured.

Post maintenance hygiene clearance – All preventive/breakdown maintenances should always be followed by hygiene clearance including removal of spares/tools/lubricants and then followed by cleaning of machines and associated areas. The activity shall be verified by Production/Quality personnel before completion of maintenance job.

Personal Hygiene and related Control- PPEs are worn to protect food from contaminations from personnel and not to protect personal cloth from getting dirty. Proper protective clothing to prevent cross contamination of products. protective clothing are to be worn in work areas only  and not to be worn in outside areas including wash rooms, canteen etc. Protective clothing should not have sewn in buttons and no pockets. Control over jewellery is also seen a very big challenge in Indian scenario as social and cultural requirements become problem, Jewellery Policy shall be decided based on risk assessment and implemented with clarity on No exposed jewellery allowed. 

• Proper hand washing mechanism are must- Hand wash station with sufficient supply of warm water, enough number of non-hand operated taps, soap dispenser with appropriate soap solution, adequate number of effective hand dryers and a sanitizing arrangement is MUST.
• Proper Medical Inspection for all- All employees shall be checked for contagious diseases and inoculation shall be done for enteric group of diseases.

Regular Training of all employees including casual workers- It is observed that most obvious root cause of any complaint/problem is lack of awareness or negligence of personnel (especially the casual workers) working in the area. But one question we need to answer before concluding, are they properly trained for doing their job and in most of the cases  the answer would be “No” and we justify no training to casual workers by saying they keep on changing. The permanent solution to this issue could be regular mechanism of training to all workers at the time of joining/re-assigning of job.

To achieve absolute safe product, the right interpretation of the standards requirement is MUST and the intent of the statement is to be understood by each individual of the team for sustainable preventive systems in place

Benefits of HACCP

Key benefits of HACCP includes

HACCP is a systematic approach that can cover all aspects of food production from raw materials, growth, harvesting and purchase to final product use to assure safe food.

Use of HACCP will move a company from a solely retrospective end product testing approach towards A Preventive Quality Assurance approach.

HACCP provides cost-effective controls for food-borne hazards.

A correctly applied HACCP study should identify all currently conceivable hazards, including those which can realistically be predicted to occur.

When supported by generic food hygiene control measures (prerequisite programmes), the use of HACCP focuses technical resources in to critical parts of the process.

The use of preventive approaches like HACCP leads to reduced product losses.

HACCP is complementary to other Business/Quality Management Systems.

Implementation of HACCP will be useful in supporting a defence of “Due Diligence” described in Food Safety legislations.

HACCP facilitates International trade.

HACCP helps in compliance to legal requirements.