From NASA to the takeaway – does HACCP overburden small businesses?

I was fortunate to have the opportunity to attend the Sixth National HACCP Conference – The New HACCP Regulation on Catering and Retail: One Year On, in London in June this year. This was a great insight into the people and science involved in caring for my well being when eating out or taking away from any of my local catering establishments.

The backbone of the protection is the Hazard Analysis and Critical Control Points (or HACCP) approach to risk assessment and control. Developed to provide safe food to astronauts in the NASA space program in the 1960s, the approach is equally applicable to the familiar kebab vans providing nourishment to tired souls after a culture-filled evening in any given town centre. This adaptability is part of the success of HACCP, which is now widely accepted throughout the world as providing the principles that should be adopted in assuring food safety. Furthermore, it can be applied throughout the food management chain from animal feed manufacture, through to supermarket storage and distribution operations, to your favourite local Chinese takeaway.

In the EU, since 1 January 2006, Regulation (EC) 852/2004 has legislated that food business operators put into place, implement and maintain a permanent procedure based on the principles of HACCP. However, in May this year, the European Commission (EC) initiated a consultation on a proposal to exclude from the HACCP requirements of the Regulation, small food businesses (fewer than 10 employees) that predominantly sell food to the final consumer. This proposal has been put forward as part of the EC’s Strategic Review of Better Regulation in the EU, which aims to reduce administrative burdens on business.

The problems small businesses face in implementing safety regulations without being over-loaded with procedures and paper work has been recognised for some time. The problem was tackled jointly by the FAO and WHO, culminating in the publication in 2006 of FAO Food and Nutrition Paper 86, ‘FAO/WHO Guidance to governments on the application of HACCP in small and/or less-developed food businesses’. This report addresses the most important principles of HACCP-based schemes and describes approaches that can be used by governments to ensure that these principles are upheld in regulated assurance without over-burdening smaller businesses.

The Food Standards Agency (FSA) in the UK has tackled the problem of safety regulation of small food businesses by the ‘Safer Food Better Business’ (SFBB) approach to food safety management, aimed at businesses with fewer than 10 employees (almost 90% of catering businesses in the UK). This scheme has been rolled out through local authorities across the country, each of which have devised and implemented their own methods for engaging, educating and working with the catering business community. A number of resources are available to caterers through the scheme as a “tool kit” to assist their compliance with HACCP-based safety assurance. A number of these resources are available from the FSA website.

So what of the EC’s latest proposal to remove the obligation of small food businesses adhering to HACCP principles? The FSA put out a call for input to consultation on this proposal in May 2007 . In this statement it is clear that, although supporting the EC’s move to reduce the administrative burden on small businesses, at present, a redrafting of the proposal would be required before acceptance by the FSA. Apart from maintaining the view that “current legislation provides both the necessary level of public health protection while not placing a disproportionate level of burden upon food businesses”, a major concern is that the proposal bases the criteria for exemption on size of business rather than risk to consumers. The Agency also voices concern that the proposal might provide a competitive advantage to smaller businesses against only slightly larger ones and would therefore act as a pressure against business expansion. There is also the question of the relationship between enforcers and food businesses. A HACCP approach provides a sound record base for audit; without this, greater reliance will have to be placed on inspection in order to assess compliance to regulations. The results of this consultation should be published by the end of next month.

The outcome of EC’s proposal to exempt small businesses from HACCP-based regulation could have serious implications for the high street and, indeed, for all EU citizens partial to a bite to eat whether from the local crêperie, tapas bar or my favourite Oxford kebab house (which I am pleased to say has an SFBB certificate proudly displayed above the counter). At the time of writing I am not aware of any further developments on this consultation; if anyone can give further information, please post a comment – otherwise, let’s watch this space and see what happens.

CABI’s Nutrition and Food Sciences Database returns nearly 1400 records when searched using the term ‘HACCP’. CABI also has a strong book portfolio in the field of human nutrition and health, including food safety, and the imminent 2007 Edition of the Animal Health and Production Compendium is to be enhanced with information on the safety and quality of foods derived from livestock and poultry, including the application of HACCP principles in these areas.

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