Agenda Item 4 b) CX/FH 03/4-Add. 1 December 2003

Transcription

1 Agenda Item 4 b) CX/FH 03/4-Add. 1 December 2003 JOINT FAO/WHO FOOD STANDARDS PROGRAMME CODEX COMMITTEE ON FOOD HYGIENE THIRTY-FIFTH SESSION 1TNCPFQГ (NQTKFCГ 75#Г,CPWCT[ (GDTWCT[ Г CONSIDERATION OF THE OBSTACLES TO THE APPLICATION OF HACCP, PARTICULARLY IN SMALL AND LESS DEVELOPED BUSINESSES AND APPROACHES TO OVERCOME THEM Prepared by The Netherlands BACKGROUND The HACCP system has been detailed in the basic texts f the Cdex Alimentarius Cmmissin in the HACCP Annex f the Annex f the Recmmended Internatinal Cde f Practice General Principles f Fd Hygiene (CAC/RCP , Revisin-3, 1997) (CAC/RCP , Revisin-3, 1997). Frm 1997 n the cmmittee has been discussing bstacles t the applicatin f HACCP, particularly in Small and Less Develped Businesses (SLDBs) and appraches t vercme them. The prpsals presented t amend the Guidelines fr applicatin f the HACCP system t make the Guidelines mre suitable fr applicatin in SLDBs, were seen as a way t vercme these bstacles. In its deliberatins the Cmmittee had cncluded that, due t several barriers and limitatins inherent in SLDBs, the HACCP principles are difficult t be implemented by them. SLDBs were als cming under increasing pressure t apply HACCP t their peratins as a result f such external factrs as legal requirements, market frces and expectatins fr in-huse management cntrls. The barriers t implementing HACCP in SLDBs have been discussed extensively at several Sessins f the CCFH ( ). The same issues were raised by a WHO expert cnsultatin (Strategies fr Implementing HACCP in SLDBs, June 1999), the reprt f this expert cnsultatin was input fr dcument CX/FH 99/9 Discussin Paper n the Implementatin f HACCP in Small and/r Less Develped Businesses, which was cnsidered by the Cmmittee at its 32 nd Sessin. The current Cdex Guidelines n the applicatin f HACCP was ne factr/barrier, which the WHO Expert Cnsultatin in June 1999, cnsidered t inhibit the mre widespread utilisatin f HACCP by SLDBs. The present applicatin guidelines acknwledge that HACCP can be applied flexibly in all fd businesses, irrespective f their size r nature. Hwever, as they are directed twards the apprach that can be taken in larger fd peratins, the present versin prvides nly limited guidance n hw the seven HACCP principles can be applied in practice in SLDBs. The Cdex Cmmittee n Fd Hygiene has acknwledged

2 Page2 this and als that the current Cdex Guidelines n the Applicatin f the HACCP principles are nt well suited t use by SLDBs. HISTORY At its 32 nd Sessin, the Cmmittee cnsidered a Discussin Paper incrprating infrmatin frm the WHO Expert Cnsultatin. The Paper prvided guidance t gvernments and rganizatins n assisting small and less develped businesses in the implementatin f HACCP. The Cmmittee generally agreed with the Paper but believed that it wuld be helpful t prvide mre explicit practical guidance n the implementatin f HACCP by SLDBs and therefre requested the Netherlands, with the assistance f its drafting partners, t revise the Discussin Paper. The 33 rd Sessin f the Cmmittee cnsidered a substantially revised Discussin Paper, CX/FH 00/10, that prpsed enhancing the existing text f the HACCP Annex t the Internatinal Recmmended Cde f Practice: General Principles f Fd Hygiene (CAC/RCP , Rev. 3, 1997). The revised Paper incrprated int the HACCP Annex additinal guidance that reflected the circumstances f SLDBs. The revised dcument tk as its basis fr the enhanced text the results f the WHO Jint Expert Cnsultatin n Strategies fr Implementing HACCP in Small and/r Less Develped Businesses (SLDBs). The prpsed enhancements t the HACCP Annex did nt alter the existing HACCP Principles, recgnizing that there shuld be n difference in the principles f HACCP, whether applied in small, medium r large premises. The prpsed enhancements did prvide further guidance n the applicatin f HACCP by SLDBs. At this sessin the Cmmittee cncluded that dcument CX/FH 00/10 was useful, and there was general supprt t further elabrate it. Therefre the cmmittee agreed t an amendment t the existing HACCP guidelines t enhance the Annex s use by SLDBs and agreed t circulate the dcument at step 3. The Cmmissin cnsidered the cmmittee s recmmendatin as New Wrk, ALINORM 01/21-Suppl.1. The Cmmittee decided t ask fr cmments, especially frm develping cuntries, n hw t develp the Guidelines. It requested the delegatin f the Netherlands, tgether with its drafting partners t revise the dcument that shuld be circulated at step 3 fr cnsideratin by the Cmmittee at its 34 th Sessin. Cmments were received frm India, New Zealand and the USA. At its 34 th Sessin, the Cmmittee cnsidered Draft Revised Guidelines fr the Applicatin f the HACCP system in SLDBs (CX/FH 01/10). In rder t aid gvernments and businesses, particularly in SLDBs, t vercme the identified burdens and t prvide additinal guidance, the revised dcument cntained tw Annexes t help facilitate HACCP implementatin by SLDBs. Annex I prpses changes t the existing HACCP Guidelines currently prviding guidance n hw t apply the seven principles f HACCP in any size f business including SLDBs. Annex II discusses the bstacles t implementing HACCP by industry, particularly by SLDBs. It prvided additinal recmmendatins t help t ver cme thse bstacles. It was als indicated that the develpment and use f sectr specific cdes by gvernments and industry culd be f great imprtance. The Cmmittee discussed the prpsed draft Guidelines sectin by sectin and agreed t a limited number f changes. Sme delegatins were f the pinin that the amended Annex I prvided flexible guidance in implementing HACCP in SLDBs, while a number f ther delegatins, especially frm sme develping cuntries, were f the view that still mre flexibility was needed and that clarificatin f the term SLDBs as well as mre detailed classificatin f the SLDBs was necessary. The Drafting Grup cnfirmed that Annex II was intended as a pssible basis fr the develpment f mre detailed guidance by bdies utside f the Cdex framewrk, which was clear frm the secnd recmmendatin t the Cmmittee cntained in dcument CX/FH 01/10: The Cmmittee is invited t cnsider the appraches t vercme bstacles t the applicatin f HACCP described in this paper and t recmmend that FAO and WHO develp guidance materials fr Gvernments and Industry t prvide aid in the implementatin f HACCP by SLDBs, that wuld take int accunt the bstacles described in the paper, infrmatin frm past Cmmittee deliberatins, and reprts frm previusly held expert cnsultatins. The Cmmittee had an extensive debate regarding future wrk and the use f Annex II. The Cmmittee agreed that Annex II cntained imprtant data n bstacles and culd be very valuable, hwever there were cntrary pinins expressed regarding its intended use. While sme delegatins were f the view that Annex

3 Page3 II shuld be used, especially by FAO and WHO fr training purpses as an infrmatin paper in develping guidance materials fr gvernments and industry in rder t prvide additinal assistance in the implementatin f HACCP by SLDBs, sme ther delegatins favred incrprating Annex II int the main bdy f Annex I. Sme delegatins indicated that the implementatin f the cntent f Annex II be left t natinal gvernments fr the decisin n its intended use. The Cmmittee agreed t request cmments n Annex II. Since sme delegatins expressed the need fr cnsideratin f the paper in its ttality, the Cmmittee als agreed that written cmments and the abve discussin in relatin t Annex II (Obstacles t the Applicatin f HACCP, Particu1arly in SLDBs and Appraches t Overcme Them) shu1d be frwarded t the Netherlands fr preparatin f an up-dated versin f the Annex II fr cnsideratin at the next Sessin f the Cmmittee. Cnsequently the Cmmittee was invited t cnsider the appraches t vercme bstacles t the applicatin f HACCP described in Annex II and the recmmendatin that FAO and WHO develp guidance materials fr Gvernments and industry t prvide aid in the implementatin f HACCP in SLDBs, that wuld take int accunt the bstacles described in Annex II, infrmatin frm past Cmmittee deliberatins, and previusly held expert cnsultatins. In respnse t CL 2001/32-FH, item C3 Obstacles t the applicatin f HACCP, particularly in Small and Less Develped Businesses and appraches t vercme them cmments frm the USA and New Zealand, were received. The cmments suggest that the infrmatin in annex II f the dcument CX/FH 01/9, seen as additinal t the infrmatin t the reprt f the WHO expert cnsultatin n Strategies fr Implementing HACCP in SLDBs (June 1999), are valuable and shuld be used t assist SLDBs. It is suggested that this assistance shuld be develped by FAO and/r WHO, fr example in the frm f a Guidance dcument. In respnse t CL 2002/36-FH Request fr cmments at Step 6 n the Draft Revised Guidelines fr the Applicatin f the HACCP System sme cuntries cmmented n the issues that are subject f this Paper Cnsideratin f the Obstacles t the applicatin f HACCP, particularly in Small and Less Develped Businesses and appraches t vercme them. It was advised t give reference t it in the main HACCP dcument and be appended tt it. Sme prpsals were made t recgnize the difficulties f SLDBs in implementing all seven principles f the HACCP system. All cmments made are related t the future psitin and use f the text earlier presented as annex II t CX/FH 01/10, n prpsals t change r amend the cntent were made. Fr that reasn the text in the last part f this dcument (title: OBSTACLES TO THE APPLICATION OF HACCP, PARTICULARLY IN SLDBS AND APPROACHES TO OVERCOME THEM) remains unchanged. CONCLUSIONS AND RECOMMENDATIONS It has been indicated that many cuntries r regins, and sme industry sectrs within cuntries r regins, need additinal guidance and supprt t help SLDBs with HACCP implementatin and with the applicatin f the system, apart frm the prpsed amended versin f the Draft Guidelines fr the HACCP System at Step 7. The type f infrmatin presented in this dcument (CX/FH 03/4-Add. 1) is mstly nt cmpatible with guidance dcuments in Cdex frmat, such as the Guidelines fr the Applicatin f the HACCP System, in the Annex t CAC/RCP , Rev. 3, (1997). Fr this reasn it was already recmmended in the previus dcument (CX/FH 01/10), t ask FAO and WHO t prvide training r supprt material fr the purpse f this additinal guidance. Cdex shuld urge this internatinal rganizatins t priritize this task and prvide adequate expertise t facilitate the task. Psitive experience has been acquired in sme cuntries with implementing the HACCP system in SLDBs n the bases f industry sectr specific guidance, smetimes referred t as sectr specific hygiene cdes based n HACCP. Als assistance in the develpment f this type f guidance, nrmally based n bth the Recmmended Internatinal Cde f Practice General Principles f Fd Hygiene and the Guidelines fr the Applicatin f HACCP, culd prve wrthwhile. The abve mentined additinal guidance and supprt material culd, as sn as it is made available, be referenced in the relevant Cdex Fd Hygiene Basic Texts.

4 Page4 OBSTACLES TO THE APPLICATION OF HACCP, PARTICULARLY IN SLDBS AND APPROACHES TO OVERCOME THEM The HACCP system has been detailed in the Basic Texts f the Cdex Alimentarius Cmmissin: Recmmended Internatinal Cde f Practice General Principles f Fd Hygiene (CAC/RCP , Revisin-3, 1997). Hwever, due t several barriers and limitatins inherent in SLDBs, these principles are difficult t be implemented by them. Therefre, the bjective f the fllwing infrmatin is t prvide guidance and advice, which can help SLDBs in implementatin f HACCP principles in light f thse bstacles. T avid cnfusin, it is necessary that the term SLDBs is mre precisely explained. The reprt f WHO Cnsultatin n Strategies fr Implementing HACCP in Small and/r Less Develped Business (WHO/SDE/PHE/FOS/99.7) has explained the term SLDBs as fllws: The term small and/r less develped businesses (SLDBs) shall mean businesses that because f their size, lack f technical expertise, ecnmic resurces, r the nature f their wrk, encunter difficulties in implementing HACCP in their Fd business. The term less develped business refers t the status f the Fd safety management system and nt t the number f staff r vlume f prductin. It is imprtant t cnsider each f the bstacles, in the light f the terms f reference f Cdex, and cnclude if the prpsed text amendment f the present Guidelines in Annex I can assist in vercming them, r alternatively, if ther activities within the terms f reference f Cdex can be f any help. Other recmmendatins are given t assist SLDBs, such as t prmte relevant actin f natinal gvernments and industry and trade rganizatins. The rles f WHO and FAO r maybe ther internatinal bdies, culd be instrumental, in achieving imprvement in the area f HACCP applicatin in SLDBs. Each f the fllwing bstacles is seen as having a negative impact n the implementatin and/r use f the HACCP system, especially in SLDBs. Appraches are suggested t vercme these bstacles. OVERVIEW OF OBSTACLES FOR SLDBS TO APPLY THE HACCP SYSTEM Obstacles with a direct impact n SLDBs, internal bstacles 1. Inadequate basic hygiene 2. Lack f expertise and infrmatin 3. Human resurce cnstraints (inadequate training, limited number f staff) 4. Perceived and real financial cnstraints Obstacles utside the cntrl f SLDBs, external bstacles 5. Insufficient gvernment infrastructure and cmmitment 6. Absence f legal requirements (prerequisites and HACCP) 7. Lack f business awareness and psitive attitude f industry and trade assciatins 8. Lack f custmer awareness, including cnsumer awareness 9. Lack f effective educatin and training prgrams 10. N expertise, infrmatin and technical supprt made available t SLDBs 11. Inadequate infrastructure and facilities 12. Inadequate cmmunicatins (see awareness)

5 Page5 DISCUSSION OF OBSTACLES AND RECOMMENDATIONS TO OVERCOME THEM 1. Inadequate basic hygiene When basic hygiene is nt prperly applied in fd businesses, applicatin f the HACCP system is becming pintless. In rder t successfully implement HACCP, fd businesses shuld, as part f prerequisite prgrammes (PRPs), already be perating accrding t the Cdex General Principles f Fd Hygiene, the applicable Cdex Recmmended Cdes f Practice, and accrding t the fd safety legislatin. If needed existing fd safety legislatin shuld be imprved. Recmmendatins t vercme bstacle: Mdify the text f the HACCP guidelines t stress the imprtance f adequate basic hygiene as prpsed in Annex I. Prmte the use f Cdex General Principles f Fd Hygiene and the cncept f prerequisite prgrams. Adequate fd safety legislatin shuld be in place and enfrced by gvernments. Prmte (financial) supprt fr training f stake hlders t emphasize the essential rle f basic fd hygiene. Prmtin f the essential rle f basic fd hygiene by gvernments, internatinal rganizatins, industry assciatins, and prfessinal rganizatins. 2. Lack f expertise and infrmatin SLDBs ften lack the technical expertise required t implement HACCP alne and may therefre need external supprt. There shuld be access t infrmatin that is crucial t prperly apply HACCP, such as in perfrming a prper Hazard Analysis. The capacity f gvernments and especially industry/trade assciatins t prvide adequate technical supprt is a critical factr in the successful implementatin f HACCP by SLDBs. Recmmendatins t vercme bstacle: The external technical supprt that culd be prvided by gvernments r industry/trade assciatins may include: Prviding relevant technical training with cnsideratin given t the level f educatin, culture and language f the SLDB managers and staff Facilitating the availability f apprpriate, current scientific supprt. Prviding accessible, sectr-specific generic guidance t businesses, such as industry guides, templates 1, and generic HACCP plans; these dcuments can als serve as training aids. Establishing and maintaining fd brne disease surveillance prgram and facilitating access t cllected epidemilgical data. Availability f databases with specific infrmatin n prducts and prcesses and their attached hazards. Facilitating access t lw cst analytical services. 1 A dcument prviding general advice n the develpment f a Guide, which may include advice n cntent, structure, issues t be cvered and the develpment prcess.

6 Page6 3. Human resurce cnstraints (inadequate training, limited number f staff) Majr bstacles in the implementatin f HACCP by the SLDBs include lack f manpwer, a lack f expertise due t inadequate training f emplyees, and the lack f management cmmitment and understanding f HACCP. In this respect there is ften a need t change attitude and rganizatinal culture twards new management appraches. Additinally, time cnstraints, rapid turnver f staff, and a lw perceptin f risks are fundamental prblems and barriers encuntered when implementing HACCP. Recmmendatins t vercme bstacle: S Adequate training is imprtant fr vercming barriers related t human resurces. Fr guidance n HACCP training, SLDBs may refer t WHO dcument entitled Training Aspects f the Hazard Analysis Critical Cntrl Pint System and the ther manuals prepared by FAO and WHO. S S Cntinuus training and updating f knwledge. Training guidelines need t be adapted t the lcal requirements taking int accunt cultural and linguistic differences. It shuld be targeted t the needs f the SLDBs. A flexible apprach f training shuld be cnsidered. Examples include: distance learning, n-the-jb training and recgnitin f prir experience. 4. Perceived and real financial cnstraints Ecnmic cnstraints are a practical barrier t implementing HACCP by gvernments and industry; particularly SLDBs. These cnstraints culd mean that the prvisin f assistance by gvernment, assistance by industry/trade assciatins, r the capacity f the business itself t implement HACCP is cnsiderably reduced. Hwever, in cnsidering the csts f implementing HACCP systems, it is imprtant t take int accunt the lng-term savings that culd accrue t gvernment (in particular public health) and industry budget Recmmendatins t vercme bstacle: T bviate ecnmic cnstraints, the fllwing measures can be taken: Develping sectr specific guides and generic mdels f HACCP implementatin cmmn t all businesses in a sectr. (Cdex may request internatinal rganizatins such as FAO, WHO t set up a central data base f existing guides including infrmatin n their scpe, intended use, etc. and t make it accessible thrugh a website. Cdex may request FAO/WHO t explre ways and means t prvide supprt t gvernments, internatinal rganizatins, industry assciatins, and prfessinal rganizatins n an nging basis. Apply a realistic time schedule (including cncurrent) implementatin as an apprach t be taken by gvernments and businesses as manageable incremental steps. Fr example, first intrduce gd hygienic practices (GHP) and then gradually implement the HACCP system. Fcusing implementatin n a sectr-by-sectr basis Supprt prduct research (financial); SLDBs can use prduct research material f gvernment and use such databases. Shared verificatin prgrams.

7 Page7 5. Insufficient gvernment infrastructure and cmmitment Gvernment 2 cmmitment is ne f the mst imprtant factr in the develpment and implementatin f a successful HACCP initiative. In this respect, ne f the mst imprtant tasks f gvernments is t raise cnsistently the awareness f industry t the benefits f and the need fr intrducing HACCP t prduce safe fd. Recmmendatins t vercme bstacle: Gvernment awareness and cmmitment can be stimulated by: Epidemilgical data n fd brne diseases and fd cntaminatin; Cnsumer awareness and cncerns; The need fr fd safety and HACCP fr exprt f fds t ther cuntries; Advcacy by internatinal rganizatins, e.g., Cdex Alimentarius Cmmissin, WHO, FAO and the Wrld Trade Organizatin (WTO). T prmte HACCP and secure the cmmitment f enterprises, gvernments may need t draw the attentin f fd enterprises t the: Benefits achieved in ratinalizatin f fd safety management; Risks inherent in certain fdstuffs r prductin prcesses; Csts, including cmpensatin csts resulting frm prductin failure; Value f HACCP in safeguarding the enterprise s image frm any assciated utbreaks and/r prduct recalls. 6. Absence f legal requirements (prerequisites and HACCP) Legislatin and legal actins can be cunterprductive and may hinder the ability and willingness t implement HACCP. Hwever a legal requirement t apply the HACCP system, cmbined with prper enfrcement, can be a strng stimulus t prmte HACCP applicatin. Legal HACCP is nt a necessity, it is a matter f natinal plicy and will wrk in sme cuntries/cultures and may be nt at all in thers. In many cases, the mve t intrducing HACCP systems may be led by industry. The stimulus may cme frm within a cmpany itself where, fr enhancing fd safety and/r quality r fr market reasns, a decisin has been made t adpt HACCP. Fd industries experienced in fd safety management systems are mre likely t appreciate the need t mve t HACCP. Generally they recgnize the imprtance f HACCP in allwing them t gain access t dmestic and freign markets, t prtect the cmpany s reputatin and t satisfy the custmer s demand. Recmmendatins t vercme bstacle: Fr SLDBs it is mre prbable that active gvernment interventin will be required t prmte and facilitate this change. T this end, when apprpriate, gvernments may need t cnsider the necessity f mandatry measures 3, 4. The rle f stakehlders is t urge gvernments t implement and enfrce apprpriate fd safety legislatin. Whether HACCP is implemented under vluntary r mandatry schemes, gvernments culd: See: gvernment cmmitment 2 All gvernment agencies, including health, agriculture, trade, turism, industry, planning, etc. 3 HACCP: Intrducing the Hazard Analysis and Critical Cntrl Pint System. WHO dcument WHO/FSF/FOS/97.2. Wrld Health Organizatin, Geneva, Mtarjemi, Y and Käferstein, F. Fd Safety, Hazard Analysis and Critical Cntrl Pint and the Increase in Fdbrne Diseases: A paradx? Fd Cntrl, 1999, 10:

8 Page8 Cnsider establishing HACCP implementatin cmmittees r fra in cllabratin with all interested parties (including cnsumers, industry representative, trade assciatins, etc.); Train regulatry authrities in HACCP; Ensure, via regulatry authrities, and ther bdies that GHP is being practiced; Develp schemes that recgnize HACCP systems; When necessary, review fd laws t shift frm end-pint testing t a safety management system apprach. 7. Lack f business awareness and psitive attitude f industry and trade assciatins Fd industries experienced in fd safety management systems are mre likely t appreciate the need t mve t HACCP. Generally they recgnize the imprtance f HACCP in allwing them t gain access t dmestic and freign markets, t prtect the cmpany s reputatin and t satisfy the custmer s demand. Hwever in the area f small and/r less develped businesses, these incentives t apply HACCP are weak in many cuntries. Industry and trade assciatins have a particularly imprtant rle t play in prmting HACCP in SLDBs and in supprting them in the implementatin f the HACCP system. If assciatins are nt in existence, then cnsideratin shuld be given t their establishment. Recmmendatins t vercme bstacle: The rle f gvernment shuld be: Enfrcement activities t prmte HACCP in particular in SLDBs Prmte the establishment f fd and trade assciatins and their active rle in the prmtin f fd safety and HACCP applicatin, especially in SLDBs Prmte fd safety n a practive basis thrugh creating incentives; less gvernment versight; free training; fd safety awards; gvernment public relatins; Prmte industry awareness f the risks t cnsumers in the absence f HACCP prgram. The rle f industry and trade assciatins may include: Assistance in the prductin f industry guides; Cmmunicatin f infrmatin pertinent t implementatin f HACCP; Cllectin f data n prducts, hazards and risks; Develpment f prduct specificatins; Infrmatin n generic HACCP plans; Training, material, advice and central expertise; Negtiating cst-effective services and supprt fr SLDBs (e.g. bulk purchase r reduced prices fr trade members); and Wrking with and representing the sectr in the mass media and gvernments. Prmte awareness f the risk (lss f business/trade pprtunities) t industry in the absence f a HACCP prgram. 8. Lack f custmer awareness, including cnsumer awareness When custmers (and cnsumers) d nt perceive fd safety as an issue f fundamental imprtance, industry will be tempted t als neglect it, r at least will nt pay attentin as needed. This effect is mre strngly expected in the area f SLDBs.

9 Page9 Fd safety shuld frm an imprtant part f business-t-business dealings thrughut the fd chain. As such, businesses shuld ensure that they purchase fd frm apprpriate suppliers, transprters and retailers wh, in turn, implement fd safety management systems. This shuld, in cnjunctin with better-infrmed cnsumers, create a demand fr imprvements in fd safety. Cnsumer demand can be an imprtant driving frce fr encuraging businesses t implement the HACCP system. Gvernment and internatinal rganizatins have an imprtant rle in educating cnsumers in this regard. The mass media can exert a pwerful influence in educating cnsumers, prmting the demand fr safe fd and apprpriate cntrl systems. Hwever, it may als have a negative effect, if nt handled and infrmed apprpriately. Recmmendatins t vercme bstacle: Infrmatin disseminatin by gvernment and industry abut all aspects f HACCP and fd safety in general, t custmers and cnsumers thrughut the fd chain. Prmtin by internatinal rganizatins. Labeling and certificatin f recgnitin f HACCP. 9. Lack f effective educatin and training prgrams As previusly stated, majr bstacles in the implementatin f HACCP by the SLDBs include lack f manpwer, a lack f expertise due t inadequate training f emplyees, and the lack f management cmmitment and understanding f HACCP. In this respect, there is lw access t effective educatinal and training prgrams that are designed with these barriers in mind. The lack f expertise is perpetuated by the absence f fd safety in the curricula f prfessinal schls. Recmmendatins t vercme bstacle: Prviding fr adequate training is imprtant fr vercming barriers related t human resurces. This is in particular f vital imprtance fr SLDBs. Fr guidance n HACCP training, SLDBs may refer t WHO dcument entitled Training Aspects f the Hazard Analysis Critical Cntrl Pint System and the ther manuals prepared by FAO and WHO. (A list f such easily available manuals/dcuments be prvided). Include HACCP appraches in prfessinal educatinal curriculum. Training prgrams may be rganized by gvernment spnsred rganizatins r thers fr SLDBs. The training prgram ideally includes bth emplyees within SLDBs and enfrcement fficials. Cntinuus training and updating f knwledge. Flexible apprach t use f human resurce, e.g., arrange access t prfessinal rganizatins. Training guidelines need t be adapted t the lcal requirements taking int accunt cultural and linguistic differences. It shuld be adapted t the needs f the SLDBs. Flexible apprach f training shuld be cnsidered. Such as distance learning, n-the-jb training and recgnitin f prir experience. Awareness educatinal/training prgrams identifying the ecnmics and scial benefits f implementing HACCP are essential fr regulatry fficials, managers f SLDBs and fd handlers. Gvernment r trade assciatins shuld help with the develpment and frmulatin f registers f HACCP qualified advisers r experts.

10 Page Lack f expertise, infrmatin and/r technical supprt SLDBs ften lack the technical expertise required t implement HACCP alne and may therefre need external supprt. The capacity f gvernments and industry/trade assciatins t prvide adequate technical supprt is a critical factr in the successful implementatin f HACCP by SLDBs. Recmmendatins t vercme bstacle: The type f technical supprt that culd be ffered by gvernments r industry/trade assciatins may include: Prviding relevant, technical training with cnsideratin given t the level f educatin, culture and language f the SLDB managers and staff; Facilitating the availability f apprpriate, current, scientific supprt; Facilitating access t lw cst analytical services; Prviding accessible, sectr-specific generic guidance t businesses, such as industry guides, templates 5, and generic HACCP mdels; Establishing and maintaining fd brne disease surveillance prgrams and facilitating access t cllected epidemilgical data in a frmat easily understd by industry, particularly SLDBs. Mentring by business assciates. 11. Inadequate infrastructure and facilities Pr infrastructures and a lack f adequate facilities can seriusly handicap HACCP applicatin, in particular fr SLDBs. Implementatin f HACCP may require imprvements in the infrastructure and facilities, bth within the cmmunity and the business itself. Recmmendatins t vercme bstacle: Businesses shuld ensure that: Premises, wrk surfaces and equipment are designed, cnstructed and maintained apprpriately t facilitate cleaning and t minimize any pssibility f crss-cntaminatin; Apprpriate facilities t encurage persnal hygiene are available t staff; Adequate, calibrated mnitring equipment is available and used crrectly; and in additin t visual assessment, where pssible, rapid tests are used t prvide real time results. Practical tailr made slutins, e.g., sectr shared verificatin prgrams. Gvernments have a rle and, in sme instances, an bligatin t ensure that the apprpriate infrastructure (electricity, rads, safe water supply, sewage facilities) is in place and that envirnmental pllutin is minimized. 12. Inadequate cmmunicatins Inadequate cmmunicatins between and thrughut internatinal rganizatins, gvernments and industry can impede the intrductin f HACCP. Cmmunicatin strategies, cvering the cntent f the cmmunicatin as well as the channels fr cmmunicatin, need t be part f any HACCP initiative. Recmmendatins t vercme bstacle: 5 A dcument prviding general advice n the develpment f a Guide, which may include advice n cntent, structure, issues t be cvered and the develpment prcess.

11 Page11 Cmmunicatin strategies shuld include: Infrmatin n the need fr change and the benefits f HACCP 6. Encuraging prductin f guides fr industry cntaining materials detailing the applicatin f HACCP t varius sectrs f industry. Prviding additinal and specific guidance fr SLDBs. Educatin f cnsumers regarding the imprtance f fd safety fr health thrugh varius channels, including the intrductin f fd hygiene teaching in schls. Trade assciatins and cnsumer grups culd als spnsr such measures thrugh prviding financial and/r teaching resurces. T ensure a cmmn understanding, it is imprtant t use a cnsistent and accurate terminlgy, such as that cntained in Cdex dcuments. The use f apprpriate and effective channels fr cmmunicatin is equally imprtant fr effective cmmunicatin. These may fr example include: Industry/trade assciatins Trade press and exhibitins Enfrcement authrities Mass media Prductin f leaflets, psters, vides, and ther aids Develping registers r lists f businesses, clleges, universities and educatinal bdies Prviding access t guidance, especially the use f mdern cmmunicatin technlgies, such as INTERNET (e.g. WWW), shuld be encuraged Activities by gvernments, internatinal rganizatins, industry assciatins, and prfessinal rganizatins that may cntribute t imprved fd safety management, especially by SLDBs: Translatin f relevant dcumentatin Simplificatin f guidance material Prviding access t databases with specific fd safety infrmatin 6 HACCP: Intrducing the Hazard Analysis and Critical Cntrl Pint System. WHO dcument WHO/FSF/FOS/97.2. Wrld Health Organizatin, Geneva, 1997.