Food Safety Tools and Techniques
An overview of prerequisite programs:
The World Health Organization (WHO 1999, 4) defines a prerequisite program (PRP) as the “practices and conditions needed prior to and during the implementation of HACCP [hazard analysis critical control point (HACCP)] and which are essential for food safety.” PRPs provide a foundation for effective HACCP systems. They are often facility-wide programs rather than process or product specific. They aim to prevent or reduce the likelihood of food safety hazards. PRPs are outside the hazard control plan, but still within the HACCP system.
International Organization for Standardization (ISO) 22000:2018 defines a PRP as the “basic conditions and activities that are necessary within the organization?.?.?. and throughout the food chain?.?.?. to maintain food safety.”
Food business operators (FBOs) can meet their food safety responsibilities by implementing food safety management systems (FSMSs) along the food production chain. PRPs are the initial controls established by an FBO. The PRPs needed by an FBO depend on the segment of the food production chain in which the operator is active and the type of the food business. Examples of PRPs include good agricultural practice (GAP), good distribution practice, good hygiene practice, good manufacturing practice (GMP), good production practice, good trading practice, good veterinary practice, and good warehouse practice.
General information on PRPs
PRPs support the HACCP plan
PRPs deal with the good housekeeping concerns of individual establishments, whereas an HACCP manages specific process hazards.
FBOs must provide all documentation, including written programs, records, and results of all PRPs that support an HACCP system. For example, an establishment may conclude that Escherichia coli O157:H7 is a hazard that is not reasonably likely to occur during the establishment’s processing because the establishment has a PRP with purchase specifications addressing Escherichia coli O157:H7.
PRP supporting documentation must be maintained. Without this documentation, the auditor of the Global Food Safety Initiative (GFSI) would question the adequacy of the establishment’s HACCP system and hazard analysis. GFSI auditors expect the PRP supporting documentation to include the program’s procedures and operational controls in written form. In addition, GFSI auditors expect the documentation to include records that demonstrate that the program is effective and that Escherichia coli O157:H7 is not reasonably likely to occur. Generally, an FBO’s own food safety inspectors are required to review testing and PRP records at least once a week.
Differences between CCPs in establishment hazard control plans and in PRPs
PRPs are outside the hazard control plan, but still within the HACCP system. FBO auditors cannot apply the same criteria as they would in verifying the regulatory requirements of the hazard control plan. Inspection program personnel should evaluate PRPs and determine if they continue to support the decision in the hazard analysis. So, what is the difference between a CCP in an establishment’s hazard control plan and a PRP? A CCP is designed to control a food safety hazard that has been determined to be reasonably likely to occur. A PRP may prevent a food safety hazard from occurring.
PRPs set the stage for a hazard control plan and provide ongoing support for an FBO’s FSMS. They keep potential hazards from becoming sufficiently serious to affect adversely the safety of the foods produced. Thus, if an establishment fails to follow its PRP addressing the occurrence of Escherichia coli O157:H7, there is a significant food safety concern.
The role of PRPs
FBOs should revise their PRPs, as necessary, to ensure their effectiveness, and they should take appropriate corrective actions if they determine that their PRPs may have failed to prevent the contamination or adulteration of a food product. Suppose an establishment addresses Escherichia coli O157:H7 in a PRP, but not in a hazard control plan. If the establishment produces an Escherichia coli O157:H7–positive product, this would be considered a deviation not covered by a specific corrective action or an unforeseen hazard. The establishment would therefore be required to take the corrective action, including reassessment. The PRP was not effective in reducing the likely risk in the processing environment.
The review of records generated by PRPs
PRP implementation must be associated with supporting documentation, such as records verifying implementation if this is referenced in the hazard analysis, hazard control plan, or sanitation standard operating procedure (SOP). Records on monitoring and testing may include instances of less than perfect control without resulting in a threat to food or product safety. However, records generated by PRPs must support the decisions made in the establishment’s hazard analysis. When GFSI auditors review PRP records, they should review the records, results, and supporting documentation of the FBO’s hazard control plan. Hence, if the FBO is reviewing the results and records on a weekly basis, it may identify trends, missing records, and so on indicating that a PRP may no longer support the decisions made in the hazard analysis, which would represent noncompliance.
Planning, developing, and managing PRPs
During the identification and development of PRPs, it is essential to consider information on statutory and regulatory requirements; industry standards and codes of practice; CAC principles and codes of practice; and international food safety standards, for example, Food Safety System Certification (FSSC) 22000, BRC Global Standards, Safe Quality Food Programs, GLOBAL G.A.P., and so on. Customer requirements include historic data, such as audit reports and customer complaints.
All PRPs should be documented, regularly audited, reviewed periodically, and modified whenever necessary. As a general rule, PRPs and hazard control plans are managed separately. However, certain parts of PRPs may sometimes be integrated into a hazard control plan.
There are three challenges in PRP development: (1) developing and implementing effective PRPs, (2) maintaining the PRPs once they have been implemented, and (3) ensuring that the programs will stand up to auditor scrutiny.
Establishing an effective PRP is a good start, but FSMSs that are proscriptive may be too restrictive to be effective. Proper PRP maintenance is often overlooked. In the field, PRPs may appear beautifully designed and written, but they are simply not being followed in FBO operations. FBO operations must match the documented procedures.
In building PRPs, FBOs should seek to realize the following elements: responsibility, development, documentation, implementation, training, monitoring and recording, verifying and auditing, and reviewing and updating.
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General Information on HACCP:
History of HACCP
In the 1960s, the Pillsbury Corporation developed the HACCP system with the U.S. National Aeronautics and Space Administration to ensure food safety aboard the first manned space missions. The HACCP system and application guidelines were defined by the CAC, which implements the Food Standards Program of the Food and Agriculture Organization of the United Nations and the World Health Organization.
Following an outbreak of Escherichia coli 0157 in Scotland in 1996, the Pennington Report recommended that HACCP be adopted by all food businesses to ensure food safety (Pennington 1997). All global food safety initiative scheme standards—BRC Global Standards, FSSC 22000, Safe Quality Food Programs, GLOBALG.A.P., and so on—have established specific requirements for the incorporation of HACCP into FSMSs. An effective HACCP has become invaluable in supporting any food safety due diligence defense.
HACCP principles
An FSMS represents a systematic approach to identifying and controlling hazards, whether microbiological, chemical, or physical, that could pose a threat to the production of safe food. This involves identifying what could go wrong in a food system and planning how to prevent this occurrence.
An FSMS must be based on HACCP principles, which enable FBOs to identify and control hazards before they threaten the safety of food or of consumers. There are seven principles of HACCP, as follows:
First, identify the hazards. This requires that FBOs examine each stage—purchasing, delivery, storage, preparation, cooking, refrigeration, and so on—in their food operations and identify what might go wrong. This might involve Salmonella in a cooked chicken product because of cross contamination with raw meat (biological hazard), the contamination of uncovered food by detergent (chemical hazard), or a piece of broken glass that has fallen into an uncovered food (physical hazard).
Second, determine the critical control points. FBOs need to identify the points in their operations that ensure their control over the hazards, For instance, cooking raw meat thoroughly will kill pathogens, such as Escherichia coli O157.
Third, establish critical limits. FBOs must set limits to enable them to identify when a CCP is out of control. Thus, during cooking, the centre of a beef burger patty must reach a minimum temperature of 75°C or an equivalent time temperature combination, such as 70°C for two minutes, to ensure that pathogens are destroyed.
Fourth, establish a system to monitor the control over the CCP. In identifying CCPs and critical limits, FBOs should possess a method to monitor and record what is happening at each CCP. Typically, monitoring involves measuring parameters, such as temperature and time. However, the method and frequency of this monitoring often depends on the size and nature of the FBO operations. However, in any case, the monitoring process should be simple, clear, and easy. For example, refrigerated food might be probed to ensure that the temperature is maintained at 5°C or less.
Fifth, establish the corrective action to be taken if monitoring indicates that a particular CCP is not under control. Thus, if the temperature of a food in a refrigerator rises to 10°C because of a technical failure in the appliance, the corrective action might be to discard the food and repair the unit according to the manufacturer’s instruction manual to ensure the correct temperature of 5°C is achieved.
Sixth, establish verification procedures to confirm that the HACCP system is effective. FBOs should review and correct their FSMSs periodically and whenever they alter their operations. For instance, after replacing an oven, an FBO should, by probing food, determine that the time and temperature settings of the new appliance are accurate and achieve the minimum safe cooking temperature for the particular dish.
Seventh, establish documentation on all procedures and records appropriate to these principles and to the application of these principles. For the successful implementation of an FSMS based on HACCP, appropriate documentation and records must be kept and be readily available. It is unrealistic to operate HACCP or to demonstrate compliance with current legislation without providing evidence, such as written records. As with the FSMS itself, the complexity of the recordkeeping will depend on the nature and complexity of the FBO’s business. The aim should be to ensure that control is maintained without generating excessive paperwork.
The benefits of hazard control and HACCP
Hazard control or HACCP provides businesses with a cost-effective system for controlling food safety, from ingredients through production, storage, and distribution to sales and service among final consumers. The?preventive approach of hazard control or HACCP not only improves food safety management, but also complements other quality management systems. It promotes the following main benefits: