Module 6 Special aspects of European Ordinances regarding Cleaning and Disinfection in Food Premises This project has been funded with support from the European Commission. This publication [communication] reflects the views only of the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein. 1
Contents HACCP history EU food legislation Hygiene of foodstuffs Cleaning and maintenance Guides and processing Development of community guides HACCP as a requirements means... HACCP and QM Risk priority number Elements of a HACCP system Application of HACCP means How to employ the 7 principles in a cleaning company Microbial sampling 2
HACCP history International food standard HACCP is an internationally accepted food standard, laid down in the annex of the Recommended International Code of Practice General Principles of Food Hygiene HACCP was developed by the WHO/FAO Codex Alimentarius Commission for the safety of astronaut s foodstuff. The EU joined the commission in 2003. First version published in 1960, current version is from 2003 HACCP was initially integrated into European legislation in 1993, by Council Directive 93/43/EEC. All EU Member States are Members of the Codex Alimentarius. 3
EU food legislation The new EU food legislation has added HACCP to its requirements to ensure hygiene and safety of foodstuffs consisting of a number of regulations, in particular of Regulation (EC) 852/2004: Common rules of hygiene in the food industry Regulation (EC) 853/2004: Hygiene of foodstuffs of animal origin Regulation (EC) 854/2004: Official controls and animal health rules Regulation (EC) 2073/2005, and 1441/2007 on the microbial criteria for foodstuffs 4
Hygiene of foodstuffs The requirements laid down in the EU regulations are to ensure compliance with The microbiological criteria of foodstuffs Temperature control requirements Maintenance of the cold chain Cleaning and maintenance Sampling, analysis, reporting 5
Hygiene of foodstuffs Regulation (EC) 852/2004 stipulates general requirements on the hygiene of foodstuffs, defining hygiene as: the measures and conditions necessary to control hazards and to ensure fitness for human consumption of a foodstuff taking into account its intended use Scope Layout and design of food premises Design of food processing Waste disposal Water supply Personal hygiene facilities Personal hygiene and health status of personnel Appropriate cleaning and maintenance 6
Cleaning and maintenance Annex 2 of this Regulation states in that food premises Must be clean and kept in good maintenance condition Must be designed for appropriate cleaning and disinfection and provide adequate working space Where accumulation of dirt may occur, foodstuffs must be protected against it No toxic material is allowed to contact with the foodstuffs (including cleaning and disinfection agents) 7
Guides and processing No recommendations on cleaning and disinfection processes were given. Instead, the legislation refers to national and international hygiene and HACCP guides such as Guides to Good Practice for Hygiene, e.g. DIN 10516 Food Hygiene - Cleaning and Disinfection, Codex Alimentarius guides Sector Guides for the application of HACCP Community guides referring to both, Good Hygiene Practice and HACCP, e.g. The International Food Standard (IFS) 8
EU is open for community guides Regulation (EC) No 852/2004 allows the development of new national and international guides. Look out for new guides! FAO/WHO level International Code of Practice CAC/RCP 1-1969 HACCP for small and less developed businesses EU level Regulation (EC) No 852/2004 Member State level National authority draft Industry Consumer groups Community guides on hygiene and Code of good hygiene practice HACCP guides HACCP 9
Current community guides A current list of community guides can be obtained from the HygTrain homepage or from our partners web pages Germany: Bund für Lebensmittelrecht und Lebensmittelkunde e.v, and Bundesverband des Gebäudereiniger Handwerks (DE) Czech Republic: Czech Association of Cleaning (CAC) Slovenia: Chamber of Craft and Small Business of Slovenia Romania: Euroactiv Netherlands: CINET 10
HACCP Risk analysis means Hazard Analysis and Critical Control Points Process control system designed to identify and prevent microbial and other hazards in food production Requires the analysis of hazards, both chemical and biological hazards Followed by the introduction of critical control points (CCP) Introduction of such a HACCP system is guided by the 7 HACCP principles Is similar to other hygiene management systems like RABC 11
How are HAACP and QM/QA linked together? HACCP introduces a monitoring system with Critical Control Points (CCP) to a QM system Procedures based on the HACCP principles HACCP amends a food safety program with critical control points Guides to Good Hygiene Practice help to implement HACCP Established and validated processes should be used HACCP based food safety programs can be certified Design of facilities HACCP Good Hygiene Practice CCP Food safety program me 12
Risk priority number (RPN) The risk with a product or a process can be denoted using the risk priority number (RPN), which is defined by the factors Severity of a potential failure Occurrence, i.e. likelihood of a failure Detection, i.e. the likelihood to be detected before it reaches the end-user/consumer RPN = Severity x Occurrence x Detection Rating scales range from 1-5 or from 1-10. The higher the number, the higher the potential risk 13
Elements of a HACCP system I A HACCP system will contain elements such as A HACCP plan: Flow diagram, result of hazard analysis, description of critical control points, and the monitoring system. Critical limits and corrective actions to take place, modification of the HACCP plan after establishment. Working instructions and procedures. Documentation of CCP monitoring activities, checklists, deviation occasions, corrective actions taken. Regular review of deviations / trend analysis Documents on the regular review of the whole HACCP system. Description of procedures, tests, auditing method 14
Elements of a HACCP system II Additional elements are A personnel hygiene plan Documentation on training activities, e.g. Contents of personnel training: HACCP principles and applications on working instructions and work documentation Documentation of initial training and occasions of refreshing Cleaning personnel is regarded as a food handler according to the HACCP standard, because they directly are in contact with food equipment and utensils, or food contact surfaces Food hygiene training must be given to each person that directly or indirectly comes into contact with foodstuffs! 15
Application of HACCP means... To follow the 7 HACCP principles 1. Conduct a hazard analysis 2. Determine critical control points (CCP) 3. Establish critical limits for each CCP 4. Establish procedures to monitor CCP 5. Establish corrective actions when the limits have not been met 6. Establish record keeping procedures 7. Establish procedures to verify that the HACCP system is working as intended 16
1. Hazard analysis The general procedure of hazard analysis is To list any hazards which are of such a nature that their elimination or reduction to acceptable levels is essential to the production of a safe food It is always an specific analysis looking at 1. Microorganisms ability to survive and to multiply 2. Production and persistence of their toxins 3. The occurrence of conditions that lead to 1. and 2. 4. Occurrence of other biological or chemical agent, foreign matter, or other substances multiplying bacterial cell 17
Example for hazard analysis Hazard analysis aims to avoid insufficient removal of chemicals and the survival of microorganisms. A hazard can be caused by Insufficient removal of organic matter. Organic residues hamper the efficiency of disinfectants Insufficient removal of detergents contaminates the foodstuffs Residues of detergents may react with disinfectants, thus reduce the efficiency of disinfectants Wrong combination of dilution, contact time and temperature Disinfectant is too old 18
2. Determine critical control points A CCP monitors conditions and measures important for the hygiene of foodstuffs Contamination with a known hazard will lead to an unacceptable level Subsequent steps will not be able to reduce the hazard to an acceptable level Decision tree that helps to decide whether a point is a critical control point 19
Example for critical control points Critical control points in cleaning companies may be Cleanliness after cleaning processes (remainders of foodstuffs, remainders of detergents) Expiring date, concentration, processing time, and temperature during application of disinfecting agents Quality of equipment (breaking, abrasion particles) Personnel hand hygiene Monitoring is done by documentation of services. It is mostly done by using documents like check lists and data from the stock database. Measuring (ph, Conductivity, change of colour) only occurs occasionally. 20
3. Critical limits for each CCP Critical limits must be specified and validated for each CCP Measurement of time, moisture level, ph, available chlorine Validation means to proof that values under a critical limit will minimize the hazard to an acceptable level Excess of a threshold means that certain action must take place. It is possible to have more than one threshold level per CCP. 21
Example for critical limits For the CCP Exposure time of disinfecting agent, this would mean Exposure time is tested and evaluated by the manufacturer of the disinfectant, e.g. 5 min Exposure time can be extended, but not be shortened Shorter incubation times will risk the microbial safeness of the product 22
4. Monitoring system for each CCP Monitoring is the scheduled measurement or observation of a CCP relative to its critical limits. Monitoring procedures must be able to detect loss of control of a CCP It should provide information on the violation of a critical limit in time If not continuous, the frequency must be sufficient to guarantee the CCP is in control Ideally, it should indicate a trend towards loss of control of a CCP before violation of a critical limit Information is used to adjust a process before deviation occurs Data derived must be evaluated by a designated person with knowledge and authority to carry out corrective actions 23
Example for a monitoring system A monitoring system in a cleaning company might imply Regular visual inspection of cleanliness Regular observation of exposure times Regular control of expiring dates Regular checks of personal hand hygiene by contact plates Regular checks of parameters to obtain the quality of rinsing water A foreman will probably have the authority to carry out corrective actions 24
5. Establish corrective actions Specific corrective actions must be developed for each CCP Actions must ensure that the CCP is brought under control Actions include proper disposition of the affected product Deviation and product disposition must be documented in the HACCP record keeping 25
Example for corrective actions Specific corrective actions are for instance Use of different cleaning technologies Repetition of a cleaning or disinfection step Discard products which have expired Higher frequency of hand disinfection procedures 26
6. Establish verification procedures Procedures, tests, including random sampling and analysis can be used to determine if the HACCP system is running correctly. A common procedure is auditing Verification should be carried out by someone other than the person responsible for monitoring and corrective actions Can be carried out in house by another person, but It is recommended to be carried out by external experts Validation in a cleaning company wants to confirm that the elements of a HACCP system work properly! 27
7. Documentation and record keeping Documentation and record keeping should be appropriate to the size and nature of a business. Should verify that HACCP controls are in place and maintained Sector specific HACCP guides may be used as part of the documentation Documentation examples are: Hazard analysis, CCP determination, Critical Limits determination Record examples are: CCP monitoring, deviations and associated corrective actions, verification of procedures 28
Example for record keeping Record keeping will be part of the cleaner s job at a work place with a HACCP system Record keeping is a responsible job which is important for the success of the company Must be integrated into existing cleaning and disinfection operations might include existing paperwork, e.g. invoices, checklists, for example exposure times A simple record keeping system can be effective and easily communicated to employees 29
Microbial sampling The Regulation (EC) 2073/2005 gives microbiological criteria for foodstuffs, particularly in Meat and products thereof Milk and dairy products Egg products Fishery products Vegetables, fruits, and products thereof It also summarises the rules for sampling, preparation of test samples, and contains requirements on sampling in slaughterhouses and production sites for minced meat and meat preparations 30
End of module The modules and additional information on this module can be obtained from www.hygiene-for-cleaners.eu www.europa.eu your local government s homepage Though I know a lot, I want to know everything." J. W. v. Goethe (1748 1832) Congratulations! You have finished the last module. 31