Industry blog: by Dr. Andreas Klieber, FPSC Board Member and managing director Quality Associates

CODEX HACCP has been the backbone of food safety systems for the last 50 years. With the last revision in 2003, it was time for an updated CODEX HACCP in 2020. One of the key reasons for this is that the global food industry has moved ahead of the HACCP system as evidenced in the Global Food Safety Initiative (GFSI) and private standards.

So, what are the changes?
Some of the changes are cosmetic, for example CODEX HACCP now being its own chapter of the CODEX General Principles of Food Hygiene rather than an appendix.

Additionally, the guidance text has been expanded and strengthened in both chapters. As before, the first chapter on Good Hygiene Practices (GHP) and CODEX HACCP can be applied to micro-businesses and multinationals due to in-built adaptability of the system.

It is also essential that Chapter 1 on GHPs is read together with Chapter 2 on HACCP, as the GHPs are the foundation before HACCP can be applied. In effect the GHPs cover what we generally consider as prerequisite programs as well as facility and equipment requirements. If one is operating in an unsafe environment, one cannot expect that the HACCP processes yield safe food products.

More fundamental are significant new inclusion in the text. These are in the areas of:

Regarding Food Safety Culture, there is a clear requirement in Chapter 1 that Food Business Operators build and maintain a positive food safety culture. This must include the entire business from top to bottom. As in the GFSI schemes and private standards, this recognises the fact that positive behaviours are a major factor in preventing food safety issues.

Allergens have not been included as a specific food safety hazard; these are still described as biological, chemical and physical. However, allergens could be considered under chemical hazards and can be added to the risk assessment as are generally quality hazards in modern HACCP plans.
However, a whole new code of practice on allergen management has been issued by the CODEX Alimentarius Commission. This recognises the fact that allergen management is critical and that extensive pre-requisite programs are required to protect consumers from allergen hazards. This also highlights that there are few CCPs that truly reduce an allergen hazard, and that pre-requisite programs generally take centre stage for allergen management.

For Principle 1, there is a slight change in the text adding Conduct a hazard analysis “and identify control measures”. This is not truly new as this is what happens in practice; however, the guidance contains one crucial change. This is that all “known unintended” uses of a food must be considered, not just intended uses. The example given is that of a French Onion soup that could also be made into a French Onion dip without a home heating step.

Wording also has changed by changing Principle 3 to: Establish “validated” critical limits and Principle 5 to: Establish the corrective actions to be taken when monitoring “a deviation from a critical limit” at a CCP has occurred.

A significant change has occurred for Principle 6. In addition to the previous need to establish a verification system, now first the HACCP plan must be validated. Principle 6 now reads: “Validate the HACCP plan and then” establish procedures for the verification to confirm that the HACCP system is working “as intended”.

For new or updated HACCP plans (for example where new equipment is introduced) this means that not only the critical limit has to be validated, but it must be proven in practice that the whole HACCP plan will function effectively. This means, for example, that data has to be gathered on real world equipment in a real world factory that shows that processes can be operated reliably within defined limits.

What has not changed?
The CODEX HACCP system remains a system focussed on unintentional or incidental food safety hazards. It does not deal with intentional acts of food fraud or food defence attacks. This will need to be addressed through Threat Assessment and Critical Control Point (TACCP) and Vulnerability Assessment and Critical Control point (VACCP) systems, or in the US through Hazard Analysis and Risk-Based Preventative Controls (HARPC).

What do I do now?

Unlike GFSI schemes, there has not been any communication from the CODEX Alimentarius commission by when the new CODEX HACCP system must be implemented. Based on established due diligence principles, ie keeping up with industry best practice, this means that all HACCP systems should be updated right now to Revision 2020.