Those working in the field of food safety management for any length of time will be familiar with the story of HACCP. In the 1960’s a US President by the name of John F Kennedy thought it would be a good idea to send three men in a hermitically sealed can, measuring 12 feet in diameter, quarter of million miles across space to walk on the moon (Presumably the astronauts were of the low acid variety). Food safety puns aside, it is a compelling story and as a fanatic of the Apollo space program, one I personally love.
It all started with a mission
Back to food safety – the issue was simple but potentially very serious. If a member of the crew was to fall ill from eating contaminated food it could cause serious consequences for the individual concerned, his crew mates and the mission. The option of pulling in to the next inter-planetary hospital did not exist. How could NASA guarantee the safety of the food provided to crew members?
To do this the food would need to be tested. However such testing would render the food unfit for human consumption. Testing is at best a sampling exercise and therefore could not provide full assurance. Another approach would be required. In a triumph of lateral thinking, it was suggested that if the food itself could not be guaranteed as safe, then perhaps the conditions under which the food was produced could be guaranteed and therefore lead to a safe food product. The logic was beautifully simple and as far as I am aware, no member of the Apollo moon missions became ill from eating contaminated food.
In the context of placing men on the moon, the significant step forward represented by adopting this approach to producing safe food was understandably overshadowed. However in subsequent years the principles of HACCP evolved and found widespread acceptance in legislation and private food standards. Few would argue with the positive impacts this has had on public health. It moved food safety from the realms of sampling and testing to a truly scientific based system complete with clear principles and a standardized methodology. Moreover it could be audited and in time certified.
Fast-forward 30 years and now HACCP is the core of most food safety standards and legal acts. It is cited in GFSI standards, EU and USA legalisation. HACCP has earned its place in the food safety hall of fame and rightly so.
However in recent years there has been a shift and steady undermining of HACCP and its center stage, spot lit status. This has been a gradual process and has almost gone unnoticed. But every day in the food sector the effects of this are being felt by auditors and food safety manager.
This is not to say it is a bad thing or indeed unwarranted. In some ways HACCP has been a victim of its own success and the failure of those responsible for its principles to keep pace with the changing food safety landscape. Let me explain. When first introduced, HACCP was a massive step forward. It provided the food sector with a framework to conduct a systematic and scientific assessment of hazards. It was a relative and qualitative improvement on what existed before it. For this reason it became the standard for all risk based food safety standards and regulations and when something is a massive improvement users will tolerate and endure its weaknesses – for a time! While conscious of its benefits as we used it more and more we began to recognize is was not always logical, effective and in some cases usable.
Chief among its weaknesses was the risk assessment and CCP decision tree. When applied according to the rules it often yielded too many or too few CCP’s. The decision tree in particular worked well with some hazards but completely broke down for others. Practitioners in order to develop some sort of workable HACCP plan needed to suspend the rules and principles and then retrospectively apply the decision tree to ‘make it fit’ for the auditor. Painful stuff but we have all done it, the auditor knows we do it and for years we have all being dancing a merry dance pretending HACCP always makes sense.
A plethora of standards
Proof of this is the recent proliferation of other risk based models and systems which many food companies now have to implement to address food safety hazards – independent and in addition to HACCP. For example GFSI now requires PRP’s to be risk assessed, controlled and planned like CCP’s. Allergenic hazards are now addressed separately from the HACCP study (e.g. Allergen Bureau). FSMA now requires vulnerability assessments (VA) and food safety defence plans to be put in place.
These are all risk based systems, like HACCP, but additional in their requirement. Common principles and methods but separate systems. In practice we have now introduced disparate risk based models for different types of food safety hazards resulting in a situation where practitioners are being exposed to an inconsistent and fluid framework to identify, assess and control what are essentially food safety hazard.
Where now for HACCP?
HACCP has now been relegated to focusing on specific hazards at process level. External threats and specific hazards which produce an allergic reaction in the consumer now have their own specific approach and as this takes place no one appears to be asking the simple question – why? For me the answer is simple. HACCP, its principles, scope of application and steps have long since been unable to address all the hazards which can potentially find their way in to food and the industry and regulators have begun to abandon it in practice. CODEX has not undertaken the required revisions, re-development or redesign of HACCP which would have allowed it become a robust and useful model to be used by practitioners. This has also lead to confusion whereby VA’s for example now assess and control the circumstances giving rise to a hazard as opposed to the hazard itself which is inconsistent with good risk management.
It is now time that the situation is addressed. As already mentioned, these systems of control all share the same characteristics and objectives. If we can send men to the moon surely it is not beyond the wit of the food safety community here on Earth to develop a common model for the analysis, risk assessment and management of various food safety hazards. HACCP is dead – long live HACCP?