Hygiene is of great importance in food production. To comply with hygiene regulations, food business operators must have a food safety system in place based on the Hazard Analysis and Critical Control Points (HACCP) system. An HACCP food safety plan allows companies to identify the risks per link in the chain and to describe how those risks should be controlled. That can be done using the business’s own food safety plan, or a sector-wide hygiene code that sets out a company’s HACCP plan.
In this blog, we address five points for attention when drawing up an HACCP plan, to avoid fines being imposed by the Netherlands Food and Consumer Product Safety Authority (NVWA).
Point 1: Bear in mind the seven HACCP principles
The HACCP plan is a food hazard identification plan based on seven basic principles described in the World Health Organisation’s Codex Alimentarius. These basic principles are as follows:
- Identify any potential hazards that must be prevented, eliminated or reduced to acceptable levels.
- Identify the Critical Control Points (CCPs) at the step(s) at which control is essential to prevent, eliminate or reduce a hazard to acceptable levels.
- Establish the critical limits for each CCP, such as a certain temperature.
- Establish and implement monitoring procedures at CCPs.
- Determine what should be done if it is established during an inspection that the CCP does not meet the critical limits. These corrective actions may be required for the process or the product, or both, and should restore the safety.
- Establish verification procedures to determine whether the HACCP approach is working effectively, by way of periodic monitoring.
- Establish documents and records.
The Voedingscentrum (Netherlands Nutrition Centre) defines a ‘hazard’ as a danger or potential danger that may be present in a product and may pose a threat to consumer health at a later time, such as bacteria in meat that may lead to a food infection. In addition to the hazard identification, possible CCPs should also be investigated. These are crucial points in the production process where specific hazards must be kept under control to ensure food safety. An example of a CCP is temperature control on arrival and during storage.
These seven basic principles were subsequently enshrined in European regulations: Regulation 852/2004 on the hygiene of foodstuffs and Regulation 183/2005 laying down requirements for feed hygiene (collectively: the European Hygiene Regulations).
Point 2: Be aware of applicable regulations
Regulation 178/2002 (the General Food Law Regulation or GFL) sets out general principles and requirements relating to food. One of those requirements is that food and feed business operators must ensure that the products under their control comply with the applicable requirements during all stages of production, processing and distribution. They must furthermore verify actual compliance with those requirements.
Every business that produces, processes or distributes food is required to identify hazards and describe how they will be managed. This is set out in Article 5 of Regulation 852/2004. The same requirement is specifically set out for feed business operators in Articles 6 and 7 of Regulation 183/2005.
A business may also use a hygiene code drawn up and officially approved by a trade association. This is set out in Article 8 of Regulation 852/2004. A hygiene code is a kind of guide for food business operators, drawn up by the industry. It contains rules for monitoring food safety and hygiene within a business. The Warenwetbesluit hygiene van levensmiddelen (Hygiene of Foodstuffs Commodities Act Decree) sets out the rules for drawing up and approving hygiene codes. Compliance by a business operator with an industry hygiene code implies that the HACCP guidelines have also been met.
Point 3: Pay attention to hygiene codes in your sector
A business operator may opt to draw up its own HACCP food safety plan. Such a HACCP plan of its own must comply with the requirements of the European hygiene regulations, including scientific substantiation of all the processes involved.
As stated above, a business operator may also use an approved industry hygiene code. The NVWA has published a list of approved hygiene codes for each industry on its website. Copies of these hygiene codes can often be provided by the relevant trade association.
Point 4: Be prepared for an NVWA inspection
The NVWA checks whether food businesses comply with the HACCP rules. NVWA inspectors may visit food businesses to check whether they have a food safety plan in place based on the HACCP. An audit of the HACCP system based on inspection lists may be conducted during such an inspection. System inspections may also focus on specific parts of the HACCP plan or basic conditions. The NVWA announces such an audit in advance. System inspections, however, are never announced beforehand and may be conducted at any time.
Businesses must cooperate with an investigation. However, this does not mean that the NVWA’s powers are unlimited. It is therefore advisable to be well prepared for such an inspection. For more information on an NVWA inspection see this video with practical tips or see invalnvwa.nl.
Point 5: Be aware of the consequences of breach of the rules
The NVWA has published intervention policies for various sectors. An intervention policy is an NVWA policy rule in which it explains in more detail which intervention (warning, fine or even suspension or withdrawal of a licence or approval) the NVWA applies in a specific case. The NVWA has, for instance, a general intervention policy as well as specific intervention policies per sector: animal feed, hospitality, artisanal production, retail and institutions, industrial production, fish, dairy and eggs, and meat.
In this intervention policy, offences are categorised as light, medium and serious. The category is determined based on the risk to food safety, the offender’s behaviour, and the facts and circumstances involved, among other factors. The NVWA may impose an administrative fine of up to €5,000 for a breach of hygiene regulations. In the case of a repeated offence, i.e. the same offence within five years, this amount may be doubled each time. If the risks or consequences of a breach for public health, animal health, animal welfare or the environment are serious, the amount may also be doubled. The NVWA may furthermore intervene in a business’s production process by way of a corrective intervention (e.g. by suspending production).
It is therefore essential to keep up to date with European laws and regulations in order to comply with the NVWA’s requirements and to avoid the risk of fines.
More blogs on food safety can be found at invalnvwa.nl
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