HACCP principles
and implementation
by Ron Dwinger,
VWA
Head office of VWA
Outline
• prerequisite requirements
• guides to good practice
• HACCP
• guidance document (flexibility)
• implementation in NL
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Regulation (EC) No 852/2004
 Article 4
 Annex I
 Annex II
 Article 5
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Article 4
 general hygiene requirements
 microbiological criteria
 temperature control requirements
 cold chain
 sampling and analysis
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M.C. Escher
guides to good practice
 national guides (Article 8)
• developed by the sectors
• validated by the competent authority
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Guide to Good Hygiene Practice
Issued by the National Standards Authority of Ireland
Issued by the
Food Standards
Agency (UK)
Farm sales
 manufactured and sold at the farm
 or at a local market
 to the final consumer
 Regulation (EC) No 852/2004
 national measures (flexibility!)
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Annex I: guides to good practice
 examples of hazards and measures
in primary production:
mycotoxins, heavy metals, fertilisers, plant
protection products, veterinary medicinal
products, feed additives, traceability of
feed, disposal of dead animals, pest control,
clean animals, record keeping, etc.
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record keeping for farmers
(Annex I)
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feed
veterinary medicinal products
diseases
analyses
plant protection products
plant diseases
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Cross compliance
Farmers are paid with EU funds
provided they comply with:
• veterinary rules
• animal welfare rules
• hygiene rules
• environmental rules
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Annex II: general hygiene requirements
 infrastructure, layout and equipment
 raw materials
 (pre-) operational hygiene
 personal hygiene
 water quality
 pest control
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guides to good practice
 Community guides (Article 9)
• procedure
• food sector: wholesale
cold stores
egg products
hunters
catering
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HACCP
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•
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Article 5 of Regulation (EC) No 852/2004
all food business operators shall:
implement a “permanent procedure based
on the HACCP principles”
except primary producers
(farmers, fruit and vegetable producers,
fishing vessels)
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The 7 HACCP principles
 identify hazards
 identify CCP’s
 establish critical limits
 establish monitoring procedures
 establish corrective actions
 establish verification procedures
 documentation and records
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HACCP
all food business operators shall:
• provide CA with evidence of compliance
• ensure that documents describing
procedures are up-to-date at all times
• retain documents for an appropriate period
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regulatory HACCP assessment
officials must verify HACCP-system being:
correctly established
correctly implemented
effectively and consistently applied
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How to implement HACCP?
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pre-requisite hygiene programmes
generic guides for HACCP
guides to good practice
develop your own plan
or adapt the generic one
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HACCP for small businesses
flexibility
 define small business
- size
- output
- type of product
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HACCP for small businesses
flexibility
no HACCP, but prerequisite hygiene requirements:
 market stalls, mobile sales
 bars, coffee shops
 small retail shops (grocery)
 pre-packed foods
 storage, transport
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HACCP for small businesses
flexibility
 hazard analysis
 critical limits
 proportionate monitoring
 simplified recording (diary, checklist)
 verification, validation, certification
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Implementation in NL -1
Started in meat products/meat preparations and fish
sector in 1995
• first audit in establishment: is HACCP in place and
correctly implemented
• follow-up audit: every six months
• audit whole system again after three years in each
establishment
 inspection authorities not satisfied: initiate withdrawal
of approval
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Implementation in NL - 2
Decision 2001/471/EC for meat sector:
1. is HACCP plan available and correctly implemented in establishments?
2. focus on level of implementation
official control is done by VWA auditors
3. publication of audit results on www.vwa.nl
- regular official control during production using checklists
(verification CCP’s, etc):
- on a weekly basis: verification on correctly and effectively functioning of
HACCP system
- official audits every 6 months or once a year (retail)
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Training in NL - 3
- auditors: training in HACCP principles and verification methods
special training in audit techniques (100 auditors)
- other official inspectors in meat establishments:
training in HACCP principles and verification methods
- government: continues training in audit techniques for OV
- industry: training included in codes for good practice
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Implementation in BE
Business to business:
> 2 personnel  HACCP
< 2 personnel
no transformation  GHP
transformation  HACCP light
Business to consumer:
surface area max 400 m2 or
max 5 fte
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Same as above
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Implementation in UK
an example of flexibility
 Safer food, better business for retailers
 Safer food, better business for caterers
 Safer food, better business supplement for care
homes
http://www.sfbbtraining.co.uk/
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Questions
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•
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How is HACCP implemented in Croatia?
What were the problems facing implementation?
What is the CA currently focusing on?
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contact
e-mail: ron.dwinger@vwa.nl
telephone: +31-70-448 41 46
additional info:
http://ec.europa.eu/food/food/biosafety/hygienelegislation/index_en.htm
http://europa.eu.int/eur-lex/lex/
http://www.food.gov.uk/foodindustry/regulation/hygleg/hyglegresources/sfbb/sfbbretail/
www.vetimpleg.eu
Summary
• flexibility
• implementation in MS
• guidance documents
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Flexibility
derogations to facilitate SME’s
national measures adapting the requirements for:
 continued use of traditional methods
 special geographic constraints
 establishments with low throughput
 construction, layout, equipment
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national measures taken by MS
AT and SI: small slaughterhouses
LU: slaughter on farm
FI and SE: reindeer meat
BG: raw-dried and raw-smoked meat
products
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National measures (AT)
• lairage facilities or waiting pens
• sterilising equipment
• slaughter room and cutting room
• storage of detained meat
• minced meat at 4ºC (national market)
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National measures (LU)
• slaughter on the farm
• 30 well-equipped farms
• slaughter of 1200 pigs/year
• slaughter of 4500 piglets/year
• slaughter of 250 calves/year
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National measures (FI and SE)
• local sale (“near food”)
• without veterinary supervision at p.m.
• only in Lapland (Sami)
• sale directly to consumer
• 200.000 kg of meat/year
• national stamp (FI) or 3 villages (SE)
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National measures for foods with traditional
characteristics1
MS
product
derogation
ES
cheese, sausages, olive oil,
infrastructure, equipment
bakery products, alcoholic drinks
PL
list of products; register of
establishments
infrastructure, equipment
DE
sausages, fruchtaufstriche,
eintöpfe, milk products, etc.
infrastructure, equipment
1 using Art.
7 (3) of Commission Regulation (EC) No 2074/2005
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action points: national legislation - 1
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slaughter for private domestic consumption
slaughter on the farm (poultry, rabbits)
examination of game meat (wild boar)
continuation of traditional methods
(or ethnic trade)
• retail (e.g. approval procedure: SE)
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action points: national legislation - 2
• supply of small quantities directly to final
consumer or local retail:
 primary products (honey)
 meat slaughtered on farm
 wild game (meat)
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Regulation (EC) 853/2004
Article 1,5,b,ii
derogations to facilitate SME’s
 853 does not apply to storage, transport (temp)
 853 does not apply to retail
 except for the large retailers (supply of food
from retail to another retail establishment)
 unless supply is marginal, localised and
restricted
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Implementation of Article 1,5,b,ii
1
1
MS
marginal
localised
restricted
AT
< 5 tons/week
no km
no delivery to big retail or
approved est.
UK
< 2000 kg
county
Max 25%
IE
< 500 kg
BE
< 800 kg
80 km
FR
< 800 kg
80 km
DK
< 3000 kg deboned meat
region
< 25%
Regulation (EC) No 853/2004
< 30%
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Guidance documents 1
 Regulation (EC) No 178/2002*
 Regulation (EC) No 852/2004*
 Regulation (EC) No 853/2004*
 HACCP (2 parts)*
- how to implement (Codex)
- flexibility
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Guidance documents 2
 import requirements (2)*
 auditing (Commission Decision 2006/677/EC)
 multi-annual control plans (2007/363/EC)
 official controls of microbiological
criteria*
 CD-ROM*
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Training - 1
Regulation (EC) No 882/2004 includes:
 assisting LDC (Art. 50)
 training (Art. 51)
budget: € 4 M (2005), € 7,5 M (2006),
€ 9,5 M (2008)
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Training - 2
in 2009:
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HACCP and auditing
training for BIPs
animal by-products
food hygiene and controls
prevention and control of TSE
plant health controls
avian influenza
EU food standards in third countries
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