HACCP principles and implementation by Ron Dwinger VWA

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 Zagreb workshop, 20 April 2

Regulation (EC) No 852/2004 Article 4 Annex II Article 5 Zagreb workshop, 20 April 3

Article 4 general hygiene requirements microbiological criteria temperature control requirements cold chain sampling and analysis Zagreb workshop, 20 April 4

M. C. Escher Zagreb workshop, 20 April 5

guides to good practice national guides (Article 8) • developed by the sectors • validated by the competent authority Zagreb workshop, 20 April 6

Guide to Good Hygiene Practice Issued by the National Standards Authority of Ireland Zagreb workshop, 20 April 7

Issued by the Food Standards Agency (UK) Zagreb workshop, 20 April 8

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!) Zagreb workshop, 20 April 9

Annex I: guides to good practice 1. 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. Zagreb workshop, 20 April 10

record keeping for farmers (Annex I) • • • feed veterinary medicinal products diseases analyses plant protection products plant diseases Zagreb workshop, 20 April 11

Cross compliance Farmers are paid with EU funds provided they comply with: • veterinary rules • animal welfare rules • hygiene rules • environmental rules Zagreb workshop, 20 April 12

Annex II: general hygiene requirements infrastructure, layout and equipment raw materials (pre-) operational hygiene personal hygiene water quality pest control Zagreb workshop, 20 April 13

guides to good practice Community guides (Article 9) • procedure • food sector: wholesale cold stores egg products hunters catering Zagreb workshop, 20 April 14

HACCP • • • 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) Zagreb workshop, 20 April 15

The 7 HACCP principles identify hazards identify CCP’s establish critical limits establish monitoring procedures establish corrective actions establish verification procedures documentation and records Zagreb workshop, 20 April 16

Zagreb workshop, 20 April 17

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 Zagreb workshop, 20 April 18

regulatory HACCP assessment officials must verify HACCP-system being: ücorrectly established ücorrectly implemented üeffectively and consistently applied Zagreb workshop, 20 April 19

Zagreb workshop, 20 April 20

How to implement HACCP? • • pre-requisite hygiene programmes generic guides for HACCP guides to good practice develop your own plan or adapt the generic one Zagreb workshop, 20 April 21

Zagreb workshop, 20 April 22

HACCP for small businesses flexibility define small business - size - output - type of product Zagreb workshop, 20 April 23

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 Zagreb workshop, 20 April 24

HACCP for small businesses flexibility hazard analysis critical limits proportionate monitoring simplified recording (diary, checklist) verification, validation, certification Zagreb workshop, 20 April 25

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 Zagreb workshop, 20 April 26

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) Zagreb workshop, 20 April 27

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 Zagreb workshop, 20 April 28

Zagreb workshop, 20 April 29

Implementation in BE Business to business: > 2 personnel HACCP < 2 personnel no transformation GHP transformation HACCP light Business to consumer: surface area max 400 m 2 or max 5 fte Zagreb workshop, 20 April Same as above 30

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/ Zagreb workshop, 20 April 31

Questions • • • How is HACCP implemented in Croatia? What were the problems facing implementation? What is the CA currently focusing on? Zagreb workshop, 20 April 32

contact e-mail: ron. dwinger@vwa. nl telephone: +31 -70 -448 41 46 additional info: http: //ec. europa. eu/food/biosafety/hygienelegislation/index_en. htm http: //europa. eu. int/eur-lex/ http: //www. food. gov. uk/foodindustry/regulation/hyglegresources/sfbbretail/ www. vetimpleg. eu

Summary • flexibility • implementation in MS • guidance documents Zagreb workshop, 20 April 34

Flexibility derogations to facilitate SME’s national measures adapting the requirements for: ü continued use of traditional methods ü special geographic constraints ü establishments with low throughput ü construction, layout, equipment Zagreb workshop, 20 April 35

Zagreb workshop, 20 April 36

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 Zagreb workshop, 20 April 37

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) Zagreb workshop, 20 April 38

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 Zagreb workshop, 20 April 39

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) Zagreb workshop, 20 April 40

National measures for foods with traditional characteristics 1 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 Zagreb workshop, 20 April 41

Zagreb workshop, 20 April 42

action points: national legislation - 1 • • 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) Zagreb workshop, 20 April 43

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) Zagreb workshop, 20 April 44

Regulation (EC) 853/2004 Article 1, 5, b, ii derogations to facilitate SME’s ü 853 does not apply to storage, transport (temp) ü 853 does not apply to retail ü except for the large retailers (supply of food from retail to another retail establishment) ü unless supply is marginal, localised and restricted Zagreb workshop, 20 April 45

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% Zagreb workshop, 20 April 46

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 Zagreb workshop, 20 April 47

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* Zagreb workshop, 20 April 48

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) Zagreb workshop, 20 April 49

Training - 2 in 2009: • • 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 Zagreb workshop, 20 April 50