From farm to fork, food security in Europe continues to falter at the very last mile. There is no shortage of rules; in fact, there are too many. Incomprehensible to almost all managers of retail and public establishments.
The European Commission tries to remedy this with Guidelines that are not quite within everyone’s reach, but useful in sharing an essential message. Simplifying HACCP does not mean ignoring hazards.
Self-control, theory
Self-control in the Covid-19 era seems a necessary virtue, the resilience needed to face the economic crisis of the century. Even at the dawn of the millennium, however, new rules to guard food safety in the EU introduced this concept as a cornerstone of the entire discipline. (1)
Good hygiene practices (GAP, GMP, GHP) must be applied by all operators in the food chain, from farm to fork. HACCP-a system unknown to most, although introduced in Codex Alimentarius as early as the last century- in turn applies to all with the sole exemption of primary agricultural production.
In theory, even the street vendor selling popsicles on the beach-or the operator of a vending machine selling cans of soft drinks and mineral water-should (in theory) know the CCPs(Critical Control Points) related to their specific activities. While the farmer who sprays carcinogenic and genotoxic herbicides (e.g., glyphosate, dicamba) can sleep soundly.
Self-control, practice
In practice, the only operators who really have any idea what good practices and HACCP are and how to apply them are those who apply food safety management systems subject to certification or audits. (2) Not By Received Grace but by a condition imposed by the large-scale retail trade (GDO) on all suppliers ofprivate label products. In addition to the more culturally evolved food processors, especially in the animal productions sector (where care is strictly prescribed and supervised under EC Regulation 853/04, so-called Hygiene 2).
The myriad micro-enterprises and SMEs that characterize the business fabric of the old continent, outside the categories listed above, are variously lacking the basic knowledge of how to prevent and control food safety hazards by applying the HACCP system. Especially in retail and public establishments, where people without specific professional experience often land.
The not a few incidents caused to people with food allergies-following the consumption of prewrapped foods as in restaurants-are therefore likely the tip of theiceberg of a multitude of foodborne toxins often not even recorded by public health.
Food safety management, European Commission guidelines
On 7/30/16, the European Commission had clarified that micro-enterprises can apply self-control in a simplified form. (3) Given the widespread difficulties in understanding the meaning of HACCP, it was decided to focus on primary hazards and the application of good hygiene practices. These have been redefined Pre-Requirements, following the vocabulary introduced by ISO 22000:2005(Food safety management systems, Requirements for any organization in the food chain).
On 12.6.20, the Commission returned to the subject with a communication that:
1) Provides guidance on Food Safety Management Systems(FSMS) for food retail activities, including food donations,
2) addresses a number of recommendations in the FVO (Food and Veterinary Office) report,
3) translates the scientific advice provided in two EFSA opinions on the issues mentioned in point 1 into guidelines aimed at different categories of practitioners and the professionals accompanying them (5,6).
The aim of the communication is to offer useful guidance on how to effectively ensure high levels of food safety, and related official public controls. This guidance also serves to clarify the concrete scope of flexibility measures granted to microenterprises in the application of the requirements set forth in Reg. EC 852/04. In Article 4 and Annex II (general hygiene requirements), as well as in Article 5 (procedures based on HACCP principles).
Food safety, the key points
The key-points of food safety are reiterated, based on the General Food Law (reg. EC 178/02) and Hygiene Regulation 1 (reg. EC 852/04, on food hygiene). Integrated supply chain responsibility, traceability, hygiene and self-control.
The reminder is also useful for retailers and public vendors who intend to give unsold food at the end of the day or nearing the end of its shelf life to charities (e.g., “I’m going to give the food to a charity”). Food Bank) or distribute them at the day’s sale prices through dedicated apps (e.g.
Too Good To Go
).
Food safety management systems. Risk analysis
Food safety management systems (FSMS ) are mentioned in the EC guidelines as the way forward, in a logic based on hazard analysis. (7) Hazard identification and analysis (principle 1) is actually the most difficult part for almost all operators to understand. (8) Therefore, the European Commission proposes a pragmatic approach:
– it is essential to be aware of the groups of hazards that can occur at each stage of individual processes. It refers to biological, chemical, and physical hazards as well as allergen contamination, which should be given special attention,
– Instead, in-depth knowledge of each of the specific hazards is not required. One must understand, for example, that handling raw meat carries biological hazards-and know how to mitigate them-without needing to remember whether it is
Salmonella
,
Campylobacter
or E. Coli STEC.
Pre-Requisites Programs (PRP)
Pre-Requisites Programs (Pre-PRPs), form the foundation of the FSMS. The PRPs are summarized in 13 points in an easy-to-read outline that indicates the criteria to be followed, the methods and frequency of surveillance, any need for recording, and appropriate corrective actions.
Additional PRPs are treated separately and concern:
– Checking shelf life (with attention to the expiration date),
– Management of food returned by the consumer before expiration,
– Preventive assessments and logistics in food donation,
– Freezing of food for donation.
Flow charts and approach to follow
Flow charts and hazard analysis diagrams are then devoted to butcher stores, grocery stores (fruits and vegetables), bakeries, fishmongers, ice cream parlors, distribution centers (including food banks), supermarkets and restaurants, mass catering services and pubs. Food donations are then the subject of a separate chapter.
The identification of hazards, grouped by macrocategories (physical, biological, chemical and allergens), remains the sine qua non of the EC guidelines. Without detracting from the scrupulous application of good hygiene practices, one must understand the risks in order to understand the essential value of individual operations.
Official public inspections
Official public controls must in turn follow a simple, hopefully effective, but not simplistic approach. Beyond the cyclostyles of sterile ‘HACCP manuals,’ the bartender and store clerk must also be able to answer some simple questions.
What should be done, how and why, when receiving goods, handling food, cleaning surfaces and utensils. And it is only when we understand the meaning of hygiene precautions that we can apply them appropriately, without losing sight of what really matters.
In short, we need to share the culture of food safety. Which is always and still useful for everyone, even for household consumption purposes. More training, less formality
For further study, see the free ebook Food Safety, Mandatory Rules and Voluntary Standards.
Dario Dongo, Sarah Lanzilli, Claudio Biglia
Notes
(1) Reg. EC 178/02(General Food Law), reg. EC 852/04 et seq. (Hygiene Package).
(2) Refers to international standards(ISO 22000 and later) and private food safety certification schemes (e.g., IFS, BRC, Global-GAP)
(3) Communication from the Commission on the implementation of food safety management systems concerning prerequisite programs (PRPs) and procedures based on HACCP principles, including facilitation/flexibility of implementation in certain food businesses (2016/C 278/01), http://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:52016XC0730(01)&from=EN
(4) Communication from the Commission providing guidance on food safety management systems for retail activities concerning food, including food donations (C/2020/2941), https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=uriserv:OJ.C_.2020.199.01.0001.01.ITA&toc=OJ:C:2020:199:TOC
(5) EFSA (2017). Hazard analysis approaches for certain small retail establishments in view of the application of their food safety management systems
(6) EFSA (2018). Hazard analysis approaches for certain small retail establishments and food donations: second scientific opinion
(7) See Donato Ferrucci’s ebook Quality and certification of agri-food products.
(8) The notions of risk and hazard are clarified in the new regulation on official public controls, reg. EU 2017/625.
(9) Keeping in mind that meat must be frozen ‘without undue delay after production,’ according to Hygiene Regulation 2 (EC Reg. 853/04)
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Veterinary surgeon, specializing in the inspection of food of animal origin. Since 1982 he has been a public veterinarian, since 1990 he has taught at the Universities of Turin and Teramo. He is the author of over seventy scientific publications and co-author of various texts on microbiology, radiocontamination of food, surveillance, health and food law, trade in public areas and communication in health emergencies.
Veterinary manager ASL Città di Torino, specialist in Inspection of food of animal origin, expert in food law, has published in international journals and deals, among other things, with food delivery and hygiene of collective catering.
