Through a notification the FSSAI has invited suggestions, views and comments from stakeholders on the proposed draft revision of the General Principles of Food Hygiene (CAC/RCP 1-1969) and its HACCP Annex which must reach FSSAI by 31 August, 2017.
These revisions were first suggested at the 48th session of the CODEX COMMITTEE ON FOOD HYGIENE (CCFH48) that decided to set up an Electronic Working Group (EWG) that would work on the revision of the General Principles of Food Hygiene. Based on the recommendations of the EWG the FSSAI has also proposed a draft revision of the General Principles of Food Hygiene (GHPs) and the Hazard Analysis and Critical Control Point (HACCP) system. In the revision notes have been provided for explaining major changes and where further discussion is required.
There has also been consideration on whether all FBOs need to carry out HACCP or if advanced GHPs would suffice for smaller businesses. Codex has also outlined a Decision Tree Diagram which can be used to determine GHP. Also a comparison table has been created for Comparison of GHPs, [Control Measures at Places Other than CCPs][Enhanced GHPs] and HACCP Control Measures.
It is natural for people to expect that the food they consume is safe and free of those hazards that cause foodborne illnesses and which can have a negative or even fata impact. On a more global scale, while international food trade and travel is increasing and brings economic benefits it can also spread of illness around the world. The eating habits have undergone major changes in many countries and new food production, preparation, storage, and distribution techniques have been developed. Therefore there is a requirement to have in place effective food hygiene practices to prevent any adverse human health and economic consequences of foodborne illness, foodborne injury, and food spoilage. Everyone, including primary producers, importers, manufacturers and processors, food warehouse/logistics operators, food handlers, retailers, and consumers, has a responsibility to assure that food is safe and suitable for consumption.
Chapter 1 deals with Good Hygiene Practices
SECTION I deals with ESTABLISHMENT DESIGN AND FACILITIES
Establishments should not be located anywhere where there is a threat to food safety or suitability and hazards cannot be controlled by reasonable measures. The location of a food establishment including temporary/mobile establishments should not introduce any hazards from the environment that cannot be controlled. In particular, food establishments should normally be located away from areas that
- are environmentally polluted and where industrial activities pose a serious threat of contaminating food
- have flooding unless sufficient safeguards are provided
- are prone to infestations of pests
- have wastes, either solid or liquid which cannot be removed effectively
Design and layout of food establishment [and equipment]
The internal design and layout of food establishments and equipment should permit good food hygiene practices, permit adequate maintenance and cleaning, and protect from cross-contamination.
Clean and dirty areas should be separated to minimize cross-contamination with the help of walls or partitions, redirecting airflow and distancing from traffic.
Internal structures and fittings
- should be of durable and non-toxic material preferably impervious, smooth and easy to maintain and disinfect this includes, walls, floors, doors, windows and work surfaces
- floors should have adequate drainage and cleaning
- and ceilings, overhead fixtures should minimize build-up of dirt and condensation and shedding of particles
- windows must be fitted with removable and cleanable insect-proof screens
Temporary/mobile food establishments and vending machines including tents and marquees, market stalls must be constructed to avoid as far as possible the contamination of food, the harbouring of pests and control of food hygiene hazards specific to these establishments to ensure the safety and suitability of food.
Under this head it is proposed that the water supply section be moved to the water section and could be changed further after deliberation.
Drainage and waste disposal facilities remain the same except that there is a proposal to use only trained personnel where appropriate to remove for collection and disposal of waste. Containers with hazardous substances should be easily identifiable.
There must be adequate cleaning facilities, both for utensils and equipment including provision for hot and cold water.
Personal hygiene facilities and toilets
- adequate means of cleaning, washing and drying hands, including soap, wash basins, a supply of hot and cold water
- Hygienically designed lavatories
- adequate changing facilities for personnel
- Such facilities should be suitably located and designated.
- Where necessary, separate sinks should be available for hand washing and food washing
Temperature control must be provided depending on the nature of the food operations. Accordingly there must be facilities for heating, cooling, cooking, refrigeration and freezing food and storing and monitoring of refrigerated and frozen foods in appropriate temperatures.
Air quality and ventilation
- Minimum contamination form aerosols and condensation droplets
- Control of odours that might affect food
- Control of humidity
- Ventilation systems should be designed and constructed so that air does not flow from contaminated areas to clean areas and, where necessary, they can be adequately maintained and cleaned.
There must be provision for adequate natural and artificial light so operations can be carried out hygienically.
- Should be such as to permit maintenance and cleaning
- Avoid pest harbourage
- Effective protection from contamination
- Must be such so as to minimise deterioration
Food control and monitoring equipment
Equipment used to cook, heat treat, cool, store or freeze food should be designed to achieve the required food temperatures as rapidly as necessary in the interests of food safety and suitability, and maintain them effectively. Where appropriate, equipment should be calibrated to ensure that food processes are monitored consistently and accurately.
Equipment should be designed to allow temperatures to be monitored and controlled. They should be equipped with effective means of controlling and monitoring humidity, air-flow or any characteristics that are detrimental to food safety.
SECTION II deals with CONTROL OF OPERATION
NOTE: This section has been recently developed and could be further amended as it is developed. The objectives of this section are as follows
- formulating design requirements with respect to raw materials, composition, processing, distribution, and consumer use to be met in the manufacture and handling of specific food items
- designing, implementing, monitoring and reviewing effective control systems
The FBO must document the
- details of food products either individually or in groups so that the identification and analysis of food safety hazards or other factors such as suitability of product is not compromised
- intended use of the food and if appropriate identify
- specific consumer groups e.g.: infants, elderly, immuno-compromised individuals
- whether it is ready-to-eat or further processing is intended
- any relevant specifications or important characteristics associated with the food
- any relevant acceptable hazard levels required for the food by the competent authority, or set by the FBO.
FBOs should develop a flow chart to cover all steps in the operation for a specific product. The same flow chart may be used for a number of similar products (see product description above) that are produced using similar processing steps. The process steps should be confirmed as accurate by checking against the actual process.
FBOs should document procedures for monitoring control measures as relevant to the business. Procedures could include names of personnel responsible, method of monitoring including frequency and sampling and monitoring records need to be kept. The frequency of monitoring should be appropriate to ensure consistent process control.
VALIDATION OF GHP
Preventative and Corrective actions
The FBO would have to document preventative and corrective action procedures as relevant to the business. These will be implemented when a non-compliance is identified. Procedures could include:
- who is responsible
- immediate action to be taken
- any product disposition to be considered
- any escalating response needed
- any action to prevent reoccurrence
- records to be kept
Verification of GHP
The FBO should document verification procedures as relevant to the business, which ensure that GHP has been implemented effectively, monitoring is occurring and that appropriate corrective action is taken when requirements are not met. Procedures could include:
- who is responsible
- review of GHP procedures, monitoring, corrective actions and records
- review when any changes occur to the product, process and other operations associated with the business
- the verification records to be kept
CONTROL OF FOOD HAZARDS
The EWG has agreed that a guidance on carrying out of basic hazard analysis must be developed and included in the guidance and support section.
GHPs control most of the food hazards which could contaminate food like incoming raw material and ingredients, food handlers and environment. However, if more significant hazards are identified then there is a need for hazard specific control measures like cleaning a meat slicer to control Listeria monocytogenes. Any ‘enhanced’ GHPs should be subject to monitoring, corrective actions and verification.
FBO can control food hazards through a basic hazard analysis system that involves
- Describing the Product
- Applicable regulatory requirements
- Identifying the intended usage – Ready to eat or as a product that would undergo further processing
- Constructing a flow chart
- Conducting a basic hazard analysis for identifying the food safety hazards as microbiological, chemical or physical at each step of the flow chart
- Identifying and defining the Good Hygienic Practices for controlling these hazards
- Categorizing the GHP controls as generic or hazard-based controls to be managed as either Enhanced GHPs or by application of principles of HACCP using a Decision Tree Model
- Validating / effectiveness of the Enhanced GHPs: Enhanced GHPs should be validated to obtain evidence that GHP control measures are capable of controlling hazards.
- FBOs may not always need to commission studies themselves to validate GHP control. They could be based on existing literature , guidance from competent authority or carried out by a third party e.g. cleaning products validated for effective use by the manufacturer etc. (Aligned with new text created in the Section II for HACCP)
- Establishing a GHP Plan for monitoring, initiating corrective actions, verification of GHPs and Enhanced GHPs.]
Where hazard control measures [GHPs or enhanced GHPs] are identified as being unable to reduce the food hazard to an acceptable level, a food hygiene system [food safety control system] based on HACCP should be implemented as given in chapter II.
KEY ASPECTS OF HYGIENE CONTROL SYSTEMS
- The key points that FBOs need to keep in mind for hygiene control are given here briefly
- Time and temperature control as appropriate according to the nature of the food, intended shelf life, packing and processing and intend of use.
- Formulation must be correct when adding acids, salts, preservatives, etc.
- Control of Microbiological cross –contamination
- Control of physical contamination with foreign bodies like metal, rubber, bones, glass, etc.
- Control of chemical contamination of food with harmful chemicals
- Allergenic contamination should be controlled as some foods are cause allergies like certain nuts, eggs, milk, certain grains and should be identified in the raw materials as well before their use and processing as well as storage.
- Incoming materials should be used only according to regulations and must be inspected before processing and should not be accepted in case they are known to contain physical, chemical or microbiological contaminants
- Packaging design and material needs to be food grade and should provide adequate protection to minimize contamination, prevent damage and provide for labelling requirements.
- Water is a key ingredient and so there must be adequate supply of water. Non-potable water can be sued for fire control, steam production, cleaning
- Water that comes in contact with food must be potable like that used for processing, for making ice and steam. .Any water that is re-circulated must be treated
FBOs must have in place and maintain
- Documents and records
- Recall procedures must be laid out so that there can be comprehensive, rapid and effective recall if food safety hazard is identified. Recalled products must be held only under supervision.
SECTION III deals with ESTABLISHMENT MAINTENANCE, SANITATION AND PEST CONTROL
Complete cleaning procedures and methods have been outlined including how to clean debris from surfaces, visible dirt, applying detergent solution for bacterial dirt. Chemical disinfectants must be used when appropriate.
Sanitation [Cleaning and disinfection] Programmes and monitoring the effectiveness of all cleaning procedures is also outlined.
Complete PEST CONTROL SYSTEM has been outlined including
Harbourage and infestation
Monitoring and detection
SECTION IV deals with PERSOANL HYGIENE
The health status of food handlers should be known so they do not transmit a disease or illness and need for medical examination is outlined.
Illnesses and injuries that need to be reported to the management are jaundice, diarrhoea, vomiting, fever, sore throat and fever, visible skin lesions like boils and cuts and discharge form ear or nose.
Guidelines for personal cleanliness and behaviour have been detailed.
SECTION V deals with TRNASPORT
Use and maintenance of transport has been given in detail
SECTION VI: PRODUCT INFORMATION AND CONSUMER AWARENESS
The important points in this section include
- Lot identification is essential as it important for product recall and stick rotation
- Product information to enable appropriate handling is a must
- Product labelling that has clear instructions is important
- Consumer Education should be imparted so they are aware of general hygiene requirements. Such programmes must educate consumers so they understand product information, labelling and instructions for use.
SECTION VII: TRAINING
Food handlers and those in food operations must be aware of food hygiene. The section outlines guidelines for building
Awareness and responsibilities
Adequate training programmes
Instruction and supervision
Refresher training programmes
HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM AND GUIDELINES FOR ITS APPLICATION
This chapter contains the definition of important words that are appropriate for the understanding of these guidelines like control, control measure, corrective action, etc.
PRINCIPLES OF THE HACCP SYSTEM
The HACCP system consists of the following seven principles:
PRINCIPLE 1: Conduct a hazard analysis.
PRINCIPLE 2: Determine the Critical Control Points (CCPs).
PRINCIPLE 3: Establish critical limit(s).
PRINCIPLE 4: Establish a system to monitor control of the CCP.
PRINCIPLE 5: Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control.
PRINCIPLE 6: Establish procedures for verification to confirm that the HACCP system is working effectively.
PRINCIPLE 7: Establish documentation concerning all procedures and records appropriate to these principles and their application.
The following are steps that you need to follow for the APPLICATION of HACCP
Assemble HACCP Team (Step 1)
FBO should assure that appropriate product specific knowledge and expertise are available for the development of an effective HACCP plan. Optimally, this may be accomplished by assembling a multidisciplinary team. Other sources must be used if expertise is not available like regulatory authority, HACCP literature and guidance. Externally developed systems may also be used. Scope must be identified and must describe which part of the food chain has caused the hazard.
Describe product (Step 2)
A full description of the product should be drawn up, including relevant safety information such as composition, physical/chemical characteristics (including Aw, pH, etc.), microbiocidal/static treatments (heat-treatment, freezing, brining, smoking, etc.), packaging, [durability/shelf life] and storage conditions and method of distribution.
Identify intended use (Step 3)
The intended use should be based on the expected uses of the product by the end user or consumer. In specific cases, vulnerable groups of the population, e.g. institutional feeding, may have to be considered.
Construct flow diagram (Step 4)
The flow diagram/chart should be constructed by the HACCP team. The flow diagram should cover all steps in the operation for a specific product.
On-site confirmation of flow diagram (Step 5)
Steps should be taken to confirm the processing operation against the flow diagram during all stages and hours of operation and amend the flow diagram where appropriate.
List all potential hazards associated with each step, conduct a hazard analysis, and consider all measures to control identified hazards (Step 6)[Note: This section needs to be developed following further discussions on the extent to which all businesses need to carry out a hazard analysis and should build on text provided in the GHP Section.]
The HACCP team should list all of the hazards that may be reasonably expected to occur at each step according to the scope of the food business operation and identify which of the potential hazards are present so that they can be eliminated or reduced to acceptable limits.
Determine Critical Control Points (Step 7)
Once the hazard has been identified then FBOs must determine which CCP can be applied to address the hazard and there may be more than one CCP. It is recommended to use a decision tree as that will suggest a logical approach. If a hazard has been identified at a step where control is necessary for safety, and no control measure exists at that step, or any other, then the product or process should be modified at that step, or at any earlier or later stage, to include a control measure.
Establish critical limits for each CCP (Step 8)
Critical limits should be specified for each Critical Control Point which separates acceptable procedures and products from unacceptable ones. Critical limits should be scientifically validated to obtain evidence. Where HACCP guidance developed by experts has been used to establish the critical limits, care should be taken to ensure that these limits fully apply to the specific operation, product or groups of products
under consideration. These critical limits should be measurable or observable.
Establish a monitoring system for each CCP (Step 9)
The monitoring procedures should be able to detect loss of control at the CCP. Where possible, process adjustments should be made when monitoring results indicate a trend towards loss of control at a CCP and should be taken before a deviation occurs. All records and documents associated with monitoring CCPs should be signed by the person(s) doing the monitoring and by a responsible reviewing official(s) of the company.
Establish corrective actions (Step 10)
Specific corrective actions should be developed for each CCP in the HACCP system in order to deal with deviations when they occur and actions should ensure that CCP has been controlled.
Establish verification procedures (Step 11)
Establish procedures for verification of the HACCP system as a whole, as well as individual control measures. Verification should be carried out by someone other than the person who is responsible for performing the monitoring and corrective actions.
Establish documentation and record keeping (Step 12)
All HACCP procedures should be documented. Documentation and record keeping should be appropriate to the nature and size of the operation and sufficient to assist the business to verify that the HACCP controls are in place and being maintained.
As an aid in developing specific training to support a HACCP plan, working instructions and procedures should be developed which define the tasks of the operating personnel to be stationed at each Critical Control Point.
Cooperation between primary producer, industry, trade groups, consumer organisations, and responsible authorities is vitally important. Opportunities should be provided for the joint training of industry and competent authorities to encourage and maintain a continuous dialogue and create a climate of understanding in the practical application of HACCP.