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/ Food Control, Vol. 6. No. 6. pp. 341-345. 1995Copyright © 1996 Elscvier Science Ltd

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PAPER

Implementation of HACCP infood businesses: the way ahead

John E. Ehiri, *t George P. Morris" andJames McEwen§

Food-borne diseases constitute an important public health problem in bothdeveloped and developing countries. Although their health and economic aspectsare often obscured by insufficiency of data, available evidence on incidence andassociated costs of medical care indicates that they are a major cause of morbidity,and a drain on resources. A joint WHO/FAO expert committee on food safetyasserts that illness due to contaminated food is probably the most widespreadhealth problem inthe contemporary world, and an important cause of reducedeconomic productivity. Given the inadequacies of traditional approaches to foodsafety control, viz. inspection and end-product testing, there is a need to apply suchother strategy of proven effectiveness as. the Hazard Analysis Critica I ControlPoints (HACCP) system which has been described as the most viable means forthe prevention of [ood-borne diseases yet devised. While there is an extensiveliterature suggesting the effectiveness of HACCP in preventing food-borne dis-eases, food operators have yet to embrace it with the anticipated enthusiasm. Thispaper examines factors that are likely to hinder wider acceptance and practicalimplementation of HA CCP in food operations and discusses measures to over-come them. It is concluded that HACCP training and education offood operatorsand food regulatory officials is a conditio sine qua non for the realization of lhefullest benefits of the strategy.

Keywords: HACCP, food safety control

INTRODUCTION

The basic principie underlying the HACCP system isthat it is possible to identify potential hazards andfauIty practices at an early stage in a food operation.These can then be controlIed in order to prevent themfrorn constituting risks to the consumer or economicburden on the operator as a result of spoilage or recaIl

"Department of Public Health, University of Glasgow, 2Lilybank Gardens, Glasgow G12 8RZ, Scotland, UK. tCon-sultant in Environmental Health, Scottish Centre for Infec-tion & Environmental Health, Ruchill Hospital, BilslandDrive, Glasgow G20 9NB, Scotland, UK. §Henry MechanChair & Head, Department of Public Health, University ofGlasgow, 2 Lilybank Gardens, Glasgow G12 8RZ, Scotland,UK. "To whom correspondence should be addressed.

of marketed items. This is a key advantage of HACCPover other reactive approaches such as inspection andend-praduct testing, where a negative result can onlycaIl for remedial action by the operator or regulatoryauthority but does not prevent the occurrence of thehazards in the first place. Preventing problems frornoccurring is the paramount goal underlying theHACCP system (NACMCF, 1992).

While the effectiveness of the HACCP has beenhighlighted in a plethora of reports (e.g. Easter et ai. ,1994; Ehiri and Morris, 1994; Moy et al., 1994), foodoperators have not embraced the strategy with theanticipated enthusiasm. It is felt that legislation requir-ing food businesses to implement the strategy willprovide the much needed impetus to secure its wideracceptance and practical application. However, the

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Implementation of HACCP infood businesses: Ehiri et aI.

inadequacies of legislation as a means of bringing aboutchanges in environmental health behaviour have beenhighlighted in literature in the general area of environ-ment and health (e.g. OECD, 1993). The concept ofHACCP was brought into food legislation in the Euro-pean Union (EU), following the adoption of the EUFood Hygiene Directive in June 1993. Under thedirective, food business operators are required to iden-tify steps in their processes and, activities that arecritical to achieving food safety, and to ensure thatadequate safety procedures are identified, im-plemented, maintained and reviewed based on theprincipIes of the HACCP system. The directive is beingimplemented in the UK through the Food Safety(General Food Hygiene) Regulations which took effecton the 15 September 1995. The Regulations requirefood businesses to assess and control potential hazards'on the basis of the principIes used to develop theHACCP system' (Department of Health, 1995).Although the implementation of a complete and fullydocumented HACCP system is not a mandatory re-quirement under the Regulations, especially with re-gard to small businesses, the Regulations have estab-lished HACCP as a key food safety managementphilosophy in the UK. In the absence of a legalcompulsion, however, voluntary adoption of HACCPwill require a full understanding of the strategy, theprocedures to implement it, and the benefits of itsapplication. In the following sections, an account offactors likely to hinder wider acceptance and practicalimplementation of HACCP in food businesses andsuggested steps to overcome them is presented.

Limited understanding ofthe HACCP strategy amongfood operators

There is evidence which suggests that most managers inthe food industry have limited understanding of theprincipIes and application of the HACCP strategy. Arecent study which evaluated HACCP implementationin Scotland, reports that over half of the food operatorssampled were not aware of the strategy (Ehiri andMorris, 1995). It is of vital importance that availableinformation on principIes and application of HACCPare effectively communicated to those whose duty it isto act upon them. Targeting information aboutHACCP on mainly experts, academics and regulatorybodies, while many managers in the food industry(especially small businesses) remain unaware of thestrategy, and of the procedures to implement it, islikely to lead to a situation where the strategy is seen bymany food operators as an approach, the knowledgeand skills of which rest only with specialist privateconsultants. The unfortunate tendency is that manyfood operators will rely solely on such consultants todevelop HACCP schemes that may be unrealistic inpractical terms.

An important point which has to be noted whencommunicating HACCP to those who should imple-ment it, is the fact that it is neither a new approach, nOr

342 Food Control 1995 Volume 6 Number 6

a new terminology. Neither the hazards addressed northe preventive measures prescribed by the strategy arenecessarily new (Bryan, 1988a). For example, there is .considerable information on microbial, chemical andphysical hazards which cause food contamination andfood-borne diseases (e.g. Pierrson and Corlett, 1992;Cliver, 1990; Doyle, 1989; Jackson, 1990). Similarly,available data (e.g. Wall et al., 1995; Bryan, 1988b;Davey, 1985) indicate that most outbreaks/incidence offood-borne diseases occur as a result of food mishand-ling in homes or food establishments, including res-taurants, catering. businesses, canteens (in schools,hospitais, nursing homes, prisons etc. ),conveniencestores, or in street food vending operations. Among themost frequently cited causes are:

• inadequate cooking or re-heating;• preparation of food far ahead of consumption, and

inadequate temperature control during cold andhot storage of foods;

• cross contamination in food premises;• use of contaminated raw materiais; and• infected food handlers.

Other factors which increase the risk of food con-tamination and food-borne diseases in developingcountries include (Mortajemi 'et aI., 1991):

• use of untreated nightsoil for crop cultivation;• poor standards of hygiene and lack of basic sanita-

tion facilities;• contaminated water supply;• inadequate, or lack of, food safety infrastructure;• climatic conditions favouring the multiplication of

micro-organisms; and• lack of food technology and quality assurance

techniques.

The HACCP strategy is built upon the fact that it isbetter to concentrate safety control efforts on potentialhazards and faulty practices as against the approachhitherto whereby time and resources are wasted mostlyon issues which may ~ot be critical to achieving safety,viz, cracked tiles, dirty walls and ceilings, blown bulbsetc. Given this premise therefore, it is clear that theconcept of HACCP is mainly a shift of emphasis fromstructure and layout of food premises to raw materialand process control. It clearly delineates ways in whichalready known procedures can be applied in a logicalorder to:

(i) facilitate effective assessment of hazards and theseverity of their risks; and

(ii) establish priorities for control and monitoring atcritical safety stages.

To realize the fullest potential of HACCP, these basicprincipies underlying it must be effectively communi-cated to food operators at alllevels, and to the generalpublico As Woodrow Wilson, one time president of the

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USA (1913-21) rightly observed, 'the man who has thetime, the discrimination, and the sagacity to collect andcomprehend the principal facts, and the man who mustact upon them, must draw near to one another and feelthat they are engaged in a common enterprise'.

One way by which information on HACCP can bemade widely accessible to food operators at alllevels ofthe food chain is to build hygiene certification trainingprogrammes around the concept of -HACCP. An im-portant advantage of this is that it ensures that data onhigh-risk hazards and preventive measures at criticalcontrol points are translated to training and educationmessages (Griffith and Worsfold, 1994; WHO, 1990).The use of HACCP data to inform food safety educa-tion is particularly relevant in situations where ade-quate food-borne disease surveillance programmes maybe lacking as is often the case in many developingcountries.

The idea of HACCP is no longer new to many largefood manufacturing/processing businesses, especiallythose that are major suppliers to leading food retailerswho now encourage the application of HACCP by theirsuppliers. There is need for collaboration ar,nongfoodbusinesses, and with regulatory authorities, so thatHACCP data and expertise available in these largerbusinesses can be used in the effective promotion ofbetter understanding and implementation of thestrategy in smaller ones.

Concern about the applicability of HACCP to someoperations

There is concern that the HACCP system does notreadily lend itself. to application in certain types ofoperations, especially small businesses and food serviceoperations. For example, it is perceived that HACCP isnot readily adaptable to the catering industry where alarge variety of foods may be prepared in one opera-tion, and with usually no uniform standard proceduresfor processes. It is argued (Sheard, 1986) that there isoften a wide scope for variation and improvization inthe food service sector, and that processes depend notonly on the desire to meet customer demands, but alsoon prevailing circumstances and the skills of employeeson duty at a particular time. However, these concernsare not only unfounded (both on scientific and practicalgrounds), but may equally be linked to limited under-standing of the principies and applications of HACCP.Procedures for the application of the strategy to foodservice operations, street food vending operations,domestic kitchens and cottage industries have beenidentified by the WHO (Silliker et al., 1982), andclearly described by Bryan (1992). These procedureshave been field-tested in a number of countries (e.g.Teufel et al., 1992; Bryan et al., 1992; Michanie et al.,1988). HACCP is, in fact, a commonsense appraach tofood safety control. It requires every one involved infood processing, manufacturing, preparation or serviceat whatever levei of the food chain to reflect on thefollowing questions:

Implementation of HACCP in food businesses: Ehiri et aI.

(i) What is my process?(ii) What hazards are associated with the process?(iii) At what stages of the process are these hazards

likely to occur?(iv) What is the likelihood that these hazards will

constitute a risk to my customers, and what is theseverity of such risk?

(v) What must I do to prevent or control these hazardsin arder to ensure the safety of my customers?

Once the hazards are known, where they occur identi-fied, and the means to prevent or control them devised,the next important step is to implement the contrais atthose stages of the process where their application iscritical to achieving safety, and to keep records of aliimportant actions. An objective consideration of theabove facts will surely concede to the applicability ofHACCP in any operation, size notwithstanding.

Most catering operations observe more or less similarsteps, from purchasing/receiving of .foodstuffs and in-gredients through storage, preparation, cooking andehilling/freezing, hot/cold holding, re-heating to serving(hot or cold). It is simple to apply effective controls atcritical control points in catering operations. For exarn-pie, receiving of ingredients and foodstuffs is an impor-tant critical control point which can be simply moni-tored and controlled in catering operations. First, it hasto be realized that checking temperature of suppliedproducts (the usual practice in many catering opera-tions) has little practical value if the products havealready been contaminated from the supply point. Forexample, eooking may destroy baeteria or other organ-isms in supplied foodstuffs, but may not destroy toxins.The starting point, therefore, is to ensure that food-stuffs and ingredients are purehased from safe andreputable sourees. Auditing of suppliers' (or potentialsuppliers') operations is thus, a vital element of moni-toring at the receiving stage, since this is an importantstep on which decision for selection of new suppliers orsuspension of those that do not meet specified safetycriteria can be based. It is equally essential that criteriafor accepting foodstuffs and ingredients are identified,documented anel, strictly followed on a daily basis.Permissible levels of temperatures can be set asappropriate; for example, frozen foods at -18°C (cri-tical limit = -14°C); chilled foods at + 5°C (criticallimit = +8°C), ete. When such criteria are specified, itbecomes easy to work towards them, and goods failingto comply with the critieallimits can easily be identifiedand rejected accordingly and records of actions kept.

Temperature and time of eooking, re-heating, coldand hot storage of foods are also important criticalcontrai points that can be easily controlled and moni-tored in a eatering operation. Temperature controlcriteria for processes ean be set and strictly workedtowards; for example, ali microbiologically sensitivefoods (sueh as poultry and meat) to be cooked to aninternal (geometric centre) temperature of at least 74°Cfor a given period of time etc. The most importantthing, however, is that staff eharged with the responsi-

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Implementation of HACCP in food businesses: Ehiri et aI.

bility of monitoring temperature are trained in the tasksassigned and are made to understand the rationale forthe controls. In fact, reports abound of instances wherefood bandlers assigned tbe task of temperature rnoni-toring and documentation continue to fill in tempera-ture charts for refrigerators, days after they have beenswitched off at the mains (e.g. Ehiri and Morris, 1995).Such practices can be prevented to a large extent byadequate training and supervisiono Considerable litera-ture exists whicb provides guides on the identificationand control of otber important critical control points incatering operations, for example, sections of thelCMSF (1988) monograph, HACCP in MicrobiologicalSafety and Quality, the Campden Food and DrinkResearch Association (1991) Technical Manual No. 19,Guidelines for the Establishment of Hazard Analysis

. Critica I Control Points, and other publisbed materiais,e.g. Bryan (1992), Bryan (1981) etc.

Small businesses and even sole proprietorships canimplement HACCP. In this case, the sole operatorshould undertake the planning, implementation andcontrol, but the system has to be simple to reflect theoperation. The important thing is thatIiazards arethoroughly identified, and that effectivecontrol andmonitoring are applied at critical control points.

Time and cost constraints

Time constraints and resource requirements ofHACCP implementation have been cited as crucialfactors influencing acceptance and implementation ofthe system by food operators. There is limited informa-tion on the constraints of economic factors on HACCPimplementation. In a study of attitudes and opinions offood operators regarding HACCP implementation inthe USA (Karr et al., 1994), over 40% of the respon-dents stressed that the regulatory authority has notpresented convincing enough evidence of research tojustify HACCP, and in particular, the costs of thestrategy as opposed to its impact on food safety. Thetbree major economic concerns highlighted by therespondents were: (i) high cost of laboratory facilities;(ii) high cost of training employees; and (iii) high costof operating the system. lt is perceived that it will be afurther incentive if calls for the implementation ofHACCP are backed with a clear demonstration of itsadvantages using evidence from cost-benefit studies ontbe strategy. Althougb the health of consumers shouldalways be paramount in any debate on safety and thecost of its achievement, it is germane that these con-cerns are evaluated against such potential benefits ashigh confidence in safety of products, improved sales,increased profits, extended shelf-life of products etc.

A shift from traditional approaches to the hazard andrisk centred methods prescribed by HACCP will un-doubtedly have some initial resource implications.Powell and Atwell (1994) report on a compliance costassessment of implementation of the new UK FoodSafety (General Food Hygiene) Regulations under-taken by the Department of Health (1995) where it is

344 Food Contrai 1995 Volume 6 Number 6

estimated that initial staff training will cost the foodindustry between f35-42 million. Huge as this mayseem, it is pertinent to argue that the long-term benefitsof having such an effective preventive strategy asHACCP will certainly outweigh the cost of its initialestablishment. lt is well acknowledged (e.g. Moy et al.,1994) that a functional HACCP system can save timeand cost by focusing attention and resources not ongeneralities, but on those stages, procedures and prac-tices that are critica I to achieving food safety. Inaddition, it can facilitate optimal, cost-effective, hazardand risk specific approaches to inspection of foodpremises and operations. lt also ensures optimalhygienic design and construction of food processingfacilities by predicting potential hazards, CCPs, andrecommending preventive measures. Moreover, once aHACCP system is in place, ali that will be necessary isto review it periodically, especially wben changes aremade to suppliers, ingredients, staffing or equipment.

Again, where HACCP is effectively implemented,product recall as a result of spoilage or contamination islikely to be minima!. Saving time and resources in thiscase, means getting things right in the first instance.Most importantly, HACCP implementation can help topromote foreign earnings from food trade by enhancinginternational acceptability of products. The WHO andthe International Committee on Microbiological Speci-fication for Foods (Silliker et al., 1982) have stronglyadvocated its application in both developed and lessdeveloped countries as a basis for the prevention offood safety problems. In the USA, the food codereleased by the FDA in 1993 now requires state regula-tory officials to implement their programmes based onthe principies of HACCP. The requirement for amandatory application of HACCP to meat and poultryslaughtering and processing plants has also been pro-posed by the Food Safety and Inspection Service (FSIS)of the US Department of Agriculture (USDA, 1993).With the adoption of HACCP by the Codex Alimentar-ius Commission in 1993 (Codex, 1993), the system hasgained international acceptance as a viable approach tothe prevention of food-borne diseases. lt is also beingincorporated into the Codex Code of Practice for a num-ber of food commodities. Developments in these direc-tions mean that foodstuffs and ingredients from foodbusinesses or countries which have not embraced HACCPwill have to face increasing scrutiny and possible rejec-tions, with consequent economic implications. _

Development of a HACCP system in food operationscan be made sim pIe and less time consuming by spread-ing the entire procedure ave r a period of time. Acaterer for instance, can start with auditing of suppliersand establishment of control and monitoring proce-dures for receiving of products. This may only take afortnightly meeting of the catering manager, chefs anddesignated food handlers for a given period of time. Inaddition, this will help to ensure that one step isfunctioning effectively before the next is embarkedupon. To cut down costs associated with use of privateconsultants, food businesses may train some staff in the

pra rical skills of HACCP so that such staff can under-- ce in-house preparation of HACCP plans and train-ing of line staff.

CONCLUSION

Regulations requiring the implementation of theHACCP strategy in food operations are important, butwill not be sufficient to prevent· -the occurrence offood-borne diseases unless food operators have a fullunderstanding of the concept, and of the need to applyit. The place of hygiene training of food handlers aspart of an effective hazard analysis system is explicit inthe Revised Code of Practice on Food Hygiene Inspec-tions (Department of Health, 1995). Thus, 'wherethere is a satisfactory hazard analysis system and/oradequate management contraIs, it should not be neces-sary for authorized officers to assess training levels inbusinesses, or levels of hygiene awareness among staff,other than as confirmation of the discussion abouthazard analysis system with the food business pra-prietor or representative'. In a study of HACCP imple-mentation in New York state, USA (Guzewich, 1986),it was found that both regulatory officials and foodoperators who had been reluctant to embrace theappraach became enthusiastic after having actual ex-perience of it. This underscores the need for HACCPtraining and orientation of not only food operators, butalso food regulatory officials thraugh workshops, semi-nars and course centre training. Trainingand educationof regulatory officials in the principIes and applicationof HACCP will also equip them better to undertaketheir role of verifying that HACCP plans developed byfood businesses are correctly implemented and effec-tive.

FinaUy, since most food businesses have limitedunderstanding of HACCP and of the procedures toimplement it, it is necessary that every regulatoryauthority clarifies the goals of the strategy, and pra-vides effective education and information to ensureuniformity in the application of its principIes.

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