HACCP (Hazard Analysis Critical Control Points) is a tool for minimising risks within a food safety management system.

There is no legal requirement to use HACCP but there is a legal requirement on all food businesses to have some sort of food safety system.

The Food Safety (General Food Hygiene) Regulations 1995 say that caterers must identify the steps in activities that are critical to ensuring food safety.

The principles of HACCP

Caterers must make sure adequate food safety procedures are identified, implemented, maintained and reviewed using the following principles:

• Analysis of the potential food hazard in a food business operation
• Identification of the points in those operations where food hazards may occur

• Deciding which points are critical to ensuring food safety
• Identification and implementation of effective control and monitoring procedures at critical points
• Reviewing the analysis of food hazards and, critical control points and monitoring procedures periodically and whenever the operations change.

HACCP is referred to in the Catering Industry Guide to Good Hygiene Practice, published by the Chartered Institute for Environmental Health, and as such would be deemed to be a best practice tool by an environmental health officer during routine inspection and enforcement activities. HACCP can be useful in demonstrating that "all reasonable precautions have been taken" in establishing the due diligence defence.

Other guidance for caterers is given in publications such as "Assured Self Catering" published by the Department of Health and "Systematic Assessment of Food Environment" published by the British Hospitality Association.

HACCP is a risk assessment procedure. Further information on risk assessment procedure and methods is set out in the document on risk assessment.

How to undertake HACCP

HACCP comprises five stages:

1. Identify and analyse hazards - a hazard is anything that could cause harm to a consumer.

Hazards comprise contamination from:
• Biological sources: pathogenic micro-organisms (bacteria and viruses that cause illness, such as food poisoning)
• Chemical sources: chemicals include pesticides, solvents, compounds absorbed from packaging materials, cleaning materials
• Foreign matter: this includes fragments of glass or metal contaminating food during manufacturing.

2. Identify and determine Critical Control Points

Critical control points (CCPs) are points in operations where food hazards may occur. Steps where hazards can be effectively controlled should be identified as CCPs. These operations should be controlled to ensure any biological, chemical or physical hazard is eliminated or reduced to a safe level. Examples of critical control points include:

• purchase and delivery
• storage, including chilled storage
• preparation
• cooking
• cooling
• re-heating.

3. Develop control measures

Operating procedures and equipment (engineering controls) can be used to assist in the development of control measures. Controls should be as precise as possible. For example: certain foodstuffs should be stored at a particular temperature. A control target should be set for every CCP that has been identified.

There are specific regulations which are relevant to developing and designing control measures. Such regulations are set out in articles on storage/temperature control, training, personal hygiene, and premises and equipment.

4. Monitor and record

Once Critical Control Points have been set, the effectiveness of control measures should be monitored. Monitoring can be undertaken by checks at intervals. Checks should be recorded.

5. Take corrective action and review the system

If monitoring indicates that controls are not working, corrective action should be taken. Such action may involve retraining staff and updating operating procedures. If any change in food type, preparation method or equipment is made then the HACCP procedure should be reviewed. In addition, the system should be audited as a way of verifying it is operating effectively. Audits should be conducted on a routine frequency.

EXAMPLE:
These are some of the HACCP features that apply to storage:

What is the hazard?

While food is being stored it is possible that it may become contaminated by the growth of micro organisms or cross-contamination with foreign material or chemicals.

How can that be controlled?
Hazards which occur during storage can be controlled by storing food at the correct temperatures.

Other precautions include:
• storing high risk foods separately
• rotating the locations where food is stored
• covering food during storage.

How can these controls be monitored, recorded, and reviewed?
It is important for checks to be done on chiller/refrigeration temperatures.

The person checking should know:
• the normal temperature/operating range
• the procedure for reporting a malfunction
• how to handle the food which may have been stored incorrectly.
• sell by dates.

In addition, written records of the checks made should be kept.

Implementation of HACCP

If the company is of sufficient size, the best way to implement an HACCP system is by using a team of appropriately experienced staff within the organisation. If necessary, food safety consultants can be commissioned to assist with specialist areas such as use of particular equipment or foodstuffs.

Roy Tozer is a Partner in the Regulatory Group of DLA Piper Rudnick Gray Cary UK LLP. roy.tozer@dlapiper.com


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