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The purpose of a safety management system


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Any opinions, findings, conclusions or recommendations expressed in this material are those of the authors and do not necessarily reflect the views of UK Essays.

A safety and management system is a proactive system that controls all aspect of a product's quality and safety; it acts as a framework within which the HACCP process can be managed as legal requirement. The system is expansive across the company; everyone is involved and will have received the appropriate training. In addition, the system is documented so that it can be audited both internally and externally by third party auditors, for certification purposes.

The use of a safety and QMS ensures that all aspects of a business are working cost effectively. It provides a competitive advantage (Nicolaides, 2004), which can increase marketing and sales opportunities; this helps the company gain new customers in addition to retaining existing business.

By working within a Safety and QMS, the whole workforce will be involved, subsequently improving communication, morale and job satisfaction. Though the QMS is not a pre-requisite programme for hygiene practices (Mortimore and Wallace, 2001), it is often implemented to manage the pre-requisite programme and HACCP systems so that any element of the operation can be effectively controlled. One of the elements of operation can be CCPs which, being the points where control is effected, are essential for product safety.

HACCP by itself will not guarantee safe food. Rather, in order to be effective, HACCP needs the support provided by other management systems operating within the business of which pre-requisite programme is one of them.

Pre-requisite programmes are, therefore, the good manufacturing practices (GMPs) or good hygiene practices (GHPs) that any reputable food business operator would be adhering to in order to ensure that safe, wholesome food is provided to the consumer (Mortimore and Wallace, 2001).

As a result, Quality Management Systems act as a framework within which the activity of the pre-requisite programme and HACCP can be managed as explained above.

Figure 1 illustrates the programme of the QMS:

Quality Management System

Total Food Safety

Pre-requisite Programmes


HACCP Study Personal hygiene training

HACCP Plan Building and equipment design

HACCP team Sanitation and maintenance

Training and awareness Pest control systems

Commitment Raw material control

Waste and drainage controls

Operational controls

Traceability and recall procedures

Good Hygiene practices

Supplier quality assurance

Glass/ metal Management

Figure. 1 Quality Management Systems

Source: Mortimore (2001)

1.2. The project rationale, aims and objectives

The primary aim of a Safety and QMS is to ensure that customer requirements are met consistently. Both HACCP and such a Safety and QMS aim at preventing non-conformity (Mortimore, 2001), placing emphasis on effective corrective action and getting it right first time.

Ocean Food is an SME producing ready chilled foods without any documented procedures and relying only on work instructions. It employs about 15-20 people with the owner acting as the Managing Director, Production and Sales Co-ordinator. The size of this production business and its limited resources has, however, limited the engagement of competent technical personnel and the implementation of a fully-fledged technical department. These reasons have made Safety Management Systems and documentation procedures virtually non-existent in the company. As a food producing company Ocean Foods operation must comply in all respects with the provisions of the Food Safety Act 1990 (Amendment) Regulations 2004 and the General Food Regulations 2004, in addition to all relevant UK legislation and EU Regulations and all other applicable codes of practice. An example of this is the Regulation 852/2004, concerning the hygiene of food stuffs across all food sectors.

The Directive is a horizontal Directive, and thus applies across the whole of the food industry (Forsythe, 2002), covering producers, manufacturers, distributors, wholesalers, retailers and caterers. In essence, this Directive combines the proactive approach of food safety by HACCP implementation and codes of Good Hygienic Practice into food law.

As aforementioned, times have changed, and the company can not longer be complacent about food safety. Customers have become more aware of and concerned about the potential dangers of unsafe food and foodborne illness (Loken, 1995). Hence, it is important to design a system, which will prevent or reduce food hazards to a minimum.

It is for these reasons that the research project is undertaken to investigate the issues that are caused when a Safety and Quality Management System is introduced into a SME such as Ocean Foods. It will also investigate the difficultites that have been found as a result of the new operational systems, in addition to analysing the solutions developed to overcome the identified difficulties, and the opportunities offered to strengthen the system.

Finally, the new systems will articulate the procedure which must be followed to ensure that all Ocean Food products are completely traceable from raw material to finished product and that records are kept (General Product Safety Directive 2001/95/EC), hence ensuring that the company will comply with the relevant legislation in the UK and EU in the interests of public safety.

Therefore, the aim of this project shall be:

To investigate, identify issues and related solutions for SME for developing, implementing and maintaining a Safety and QMS.

To research how a user friendly Safety and Quality System Manual can be developed to encourage employee training by SMEs.

To outline, with the Manual, the guidelines for Good Manufacturing Practice (GMP) in the company, thereby helping to understand legislation and how it needs to be complied with.

The above aims will help to understand constraints of introducing food safety and quality management systems into SMEs such as Ocean Foods.



This chapter briefly describes an SME and outlines the requirement for a Safety and Quality Management System (SQMS) and the role and responsibility of the Management in ensuring safety requirements are met. It also emphasises the importance of training employees, the role of audit in verifying the efficacy of the QMS, and issues that can affect small scale businesses when implementing a SQMS. Furthermore, it discusses the importance of HACCP as an effective way of managing food safety.

The chapter discusses studies in the literature that have assessed the SQMS, with particular reference to Small and Medium Establishments (SMEs). Particularly, it examines the impact of legislative requirements on SMEs, the unique problems encountered by SMEs in establishing SQMS and implementing an HACCP system, as well as possible solutions.

2.1. What is an SME?

SME is a commonly used acronym for ''Small and Medium-Sized Enterprise'' and has become something of a 'catch all term' (Hillary, 2000), used whenever anything other than big business is being discussed. It is currently used extensively among policy makers, support organisations, the government and researchers, but significantly, not by SMEs themselves. As far as they are concerned they are just business, and can't see why they should be defined by such narrow variables such as size, turnover and ownership (Hillary, 1995).

In 1996, the EU attempted to define this extremely diverse sector by differentiating between an SME and a small enterprise, based on employee numbers, turnover or balance sheet total, and ownership (CEC, 1996). According to these definitions, an SME has fewer than 250 employees and either an annual turnover not exceeding 40 Million Euros or an annual balance sheet total not exceeding 27 Million Euros, and is an independent enterprise, i.e. 25% or more of the capital or voting rights cannot be owned by (a) larger enterprise(s), as illustrated in Figure 2. As also been seen, a further distinction is made between micro, small and medium firms.

An SMEcan be define as an Organisation which

Has no more than 50 employees.

Has either an annual turnover of less than Euro 40 million, or an annual

balance sheet total less than Euro 27 million.

Is less than 25% owned by one, or several, enterprise(s) not satisfying the same criteria.

Small firm

0-49 employees

(includes micro)

Micro firm

0- 9 employees

Medium firm

50-249 employees

Figure 2. Illustrates Small and medium sized enterprises and definition and categorisation

Source: Small Business Services (2003)

By contrast, a small enterprise has fewer than 50 employees (CEC, 1996), and either an annual turnover not exceeding 7 Million Euro, or an annual balance sheet total not exceeding 5 Million Euro, and is an independent enterprise, i.e. 35% or more of the capital or voting rights cannot be owned by (a) larger enterprise(s).

2.2. Why is a Safety and Quality Management System is needed by SMEs?

Regardless of the size or type of organisation, quality Management prides itself on the reduction of errors... Subsequently, the adoption of a Safety and QMS may help in implementing the following (Waller et al., 1993) by SMEs.

Creating an appropriate management structure that will ensure that the processes needed for the quality management system are established, implemented and maintained.

Defining requirements for the ISO 9001-2008 Quality Management System.

Agreeing and formalising documented procedures required by the ISO 9001-2008 standard.

Taking corrective action to eliminate the cause of non-conformity, with aim to prevent recurrence.

Carrying out internal audits at planned intervals in order to determine whether the QMS conforms to the planned arrangement of the requirements of ISO 9001-2008.

Improving efficiencies of those involved by offering information and training orientated awareness of the relevancy and importance of their activities.

Increasing customer satisfaction to ensure that customer requirements are determined and met.

What are the driving forces for adopting safety and QMS by SMEs

There are a number of driving forces for SMEs to procure Safety and QMS. Perhaps most significant are the issues of legislation and customer requirements. Today's consumers are preoccupied with knowing that the food they purchase and consume is safe, regardless of where it has been grown or processed. Furthermore, retailers require suppliers to demonstrate that they are providing safe, quality food that meets the expectations of the consumer. (www.sqfi.com). subsequently, retailers have identified the need for consistent, internationally accepted food safety and quality management systems.

2.3.1. Food hygiene legislation

The primary objective of new EU food hygiene legislation is to optimise public health protection by building on, improving and modernising the existing EU legislation (www.food.gov.uk). The new legislation articulates that the duty of Food Business Operators is to produce safe food. This is a requirement that is contained in current legislation and is underpinned by general food law.

Much of the detailed legislation on food standards originates in the European Union. There are details on proposals to consolidate and simplify food hygiene legislation as well as details of other European legislation. On 29 April 2004 new EU food hygiene legislation was adopted and came into force from 1 January 2006.

The EU legislation, for example, includes a farm in the fork approach to food safety, hence including primary production (i.e. farmers and growers) in food hygiene legislation for the first time in the majority of cases.

The following are included in the new package of legislation:

Regulation 852/2004: Regarding the hygiene of foodstuffs:

The above regulation offers a "horizontal" rule which applies to the production of all foodstuffs and all stages of production, processing and distribution of food (including primary production). It introduces for all food sectors (with the exception of primary production), a requirement for food safety management procedures based on HACCP principles. The regulation also establishes the voluntary use of either national or Community good practice guides. Such guides are to be developed by the food business sectors concerned and are intended to assist food business operators in complying with the general high-level requirements and objectives of the regulation. (www.opsi.gov.uk)

Regulation 852/2004 further notes the need for food businesses to be registered with a competent authority. This is to ensure that enforcers know where food businesses are and can factor them into official control programmes. This Regulation also lays down basic hygiene requirements for premises, staff, packaging, storage, transport, and handling of foodstuffs

Regulation 853/2004: On laying down specific hygiene rules for food of animal origin:

This Regulation reflects the fact that products of animal origin tend to represent the

highest risk, supplementing Regulation 852/2004 by laying down specific requirements for food businesses dealing with foods of animal origin.

The Regulation requires the approval by enforcement authorities of premises handling products of animal origin (POAO). POAO will have to bear an identification mark displaying information about where the product was produced or handled. Fresh red meat and game meat will have to bear a health mark, applied under the supervision of the Official Veterinarian (OV).

Regulation 854/2004: On laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption:

The bulk of this Regulation concerns detailed rules for the conduct of meat hygiene controls, though rules are also noted regarding controls on live bivalve mollusks (and the areas from which they may be gathered), fishery products and raw milk and dairy products.

The changes to controls on meat hygiene are intended to take account of the introduction of HACCP-based procedures in slaughterhouses. These changes are also intended to take account of the fact that the traditional meat organoleptic-based inspection regime is not equipped to cope with the presence of pathogenic micro-organisms which now account for most meat- related food borne disease incidents. (www.opsi.gov.uk)

Directive 2002/99 further lays down the animal health rules governing the production, processing, distribution and introduction of products of animal origin for human consumption.

Directive 2004/41 repeats certain directives concerning food hygiene and health conditions for the production and placing on the market of certain products of animal origin intended for human consumption.

While the primary objective of the package of EU food hygiene proposals is to optimize public health protection by improving and modernising the existing EU legislation, such optimization will be achievable by SMEs and would be facilitated by the introduction of food safety management procedures based on the application of Hazard Analysis and Critical Control Points (HACCP) principles.

To summarise, some issues in the current legislation are as follows:

The current legislation exhibits inconsistencies in approach and a degree of

duplication that makes it difficult to interpret and to enforce.

It has not kept up with change and improvements in food technology.

Many of the businesses, particularly in the catering sector, have little knowledge of the hazards inherent in the operations they undertake (www.food.gov.uk) or how to control them.

Such issues are addressed in the new legislation, which acts to condense the requirements into three regulations rather than sixteen directives and updates much of the information contained in the older directives. The new legislation also acts to ensure that businesses identify hazards and control them in an appropriate manner (www.food.gov.uk).

2.4 What is BS EN ISO 9001-2008?

The BS EN ISO 9001-2008 is a series of documents that define requirements for the Quality Management System Standard. ISO 9001 is one of the documents in this set, and it contains the actual requirements to which an organisation must conform in order to become ISO 9001 registered (www.the9000store.com)

This BS EN ISO 9001-2008 standard is based on eight quality management principles, which are used by management in a variety of industries to improve the performance of a company and the quality of its products (www.nsf.org). These eight principles are:

Customer focus


Involvement of people

Process approach

System approach to management

Continual improvement

Factual approach to decision making

Mutually beneficial supplier relationships

2.5 International Standard requirement for Quality Management System (ISO 9001- 2008)

The requirement for a Quality Management System (QMS) should be the basis for all operations undertaken by SMEs . Food companies should establish, document, implement and maintain a QMS and continually improve its effectiveness. The QMS should be in accordance with the requirements of the international standard ISO 9001-2008 (ISO Standard), and thus SMEs should:

Identify gaps in the Safety quality management system that is in place.

Determine the sequence and interaction of safety and quality control processes.

Determine criteria and methods needed to ensure that both the operation and control of these processes are effective.

Ensure the availability of resources and information necessary to support the operation and monitoring of these processes.

Monitor measures in place and analyse the above processes.

Implement the actions necessary to achieve and improve on their planned results.

Identify and difficulties in implementation and generate solutions.

Ocean Foods encountered some difficulties in addressing the above issues, which must be dealt with for a successful QMS. These were:

They lacked a comprehensive QMS that would meet the requirements of the ISO 9001-2008 standard initially, because Ocean Foods only used work instructions and had inadequate staff training.

What Ocean Foods already had documented was either out of date because it had not been updated to reflect changes in the relevant regulations, or simply did not comply, thereby preventing the system from working at the early stage of the implementation. This was dealt with by gradually introduction new procedures in accordance with current regulation.

Due to lack of previous proper training, the workers did not understand much of the quality-related jargon mentioned when trying to introduce new quality procedures, because they had not been exposed to it before.

Workers had very little knowledge about quality policy, if any, and most found it difficult to understand, because management had not previously committed to staff training on the subject.

2.5.1 Quality manual requirement

Companies in the food industry are required to establish and maintain a quality manual that includes:

The scope of the quality management system, including detail of any justification for any exclusion. Such exclusions must not affect the companies' ability or responsibility to provide products that meet customer needs and applicable regulatory requirements.

The documented procedures established for the QMS to define the control needed are:

To approve documents in terms of their adequacy prior to issue

To ensure that changes and the current revision status of documents are identified

To ensure that relevant versions of applicable documents are available at the point of use.

To review and update as necessary and re-approve documents.

To ensure that documents remain legible and readily identifiable.

To prevent the unintended use of obsolete documents, and to apply suitable identification of them if they are retained for any purpose.

A description of the interaction between the processes of the QMS (ISO 9001-2008).

The difficulties identified according to Waller et al. (1993) in addressing the manual requirements include the lack of adequate standard work place references needed to carry out particular procedures. This is a particular problem for SMEs, of which Ocean Foods Limited in an example.

2.5.2 Record control requirements

A record needs to be established and maintained to provide evidence of conformity to requirements and of the effective operation of the Quality Management System. As previously mentioned, it must remain legible, readily identifiable, and retrievable. In addition, records must provide evidence that quality-ensuring processes are under control and ensure safe food (Mortimore, 2001). In essence, these records will normally involve the HACCP plan, and monitoring activities which serve to verify that the company has an on-going system in place. Records should be as simple as possible in order that members of staff have the time to keep them, and are thus more likely to do so.

The Documented Quality System (DQS), a structure for documentation, requires that all activities which directly or indirectly affect quality be documented. ISO 9001:2008 provides guidelines on how to document a quality system. Records must be kept for a length of time that is defined by legislation, customers, and the shelf life of the product(s) in question. Records can be used to support due diligence (as required by UK legislation) or any other litigation proceedings (Mortimore, 2001). For one thing, records are needed so that the results of monitoring activities can be recorded. A documented quality system was set up in Ocean Foods and procedures for the collection, filling, retrieval and disposition of records developed by the writer.

Record-keeping and documentation is one of the HACCP principles, so when introducing an HACCP System the requirement for proper regulation of records is introduced as part of it, along with the difficulties that that entails. The concept of formalised pre-requisite programmes places in context various good practices (GMP, GHP, etc) providing a basic foundation upon which the HACCP plan is built (Wallace and Williams, 2001).

2.5.3 Management responsibility

Since management commitment is an element of the ISO 9001-2008 standard, there is a requirement for top management to show commitment to the development and improvement of the QMS through leadership and active participation (www.iqa.org). Top management must ensure that it understands and meets the regulatory and legal requirements with respect to the products and services it supplies.

Thus, management should provide evidence of its commitment to the development and implementation of the quality management system (Nicolaides, 2004) and continually improve its effectiveness by:

Communicating to the organisation the importance of meeting customer, as well as statutory and regulatory, requirements.

Establishing the quality policy that will meet their business objectives and satisfy their customers.

Ensuring that the policy also creates a framework for the organisation's quality objectives, meaning that every goal they establish for the business must be measurable (www.bsiamericas.com), e.g. customer satisfaction, warranties, delivery time and meeting regulatory commitments.

Conducting management reviews at planned intervals to ensure the continuing suitability, adequacy and effectiveness of management.

Ensuring the availability of resources to implement and maintain the QMS and continually improving its effectiveness.

In the case of Ocean Foods, an identified issues concerning management was that there was a lack of commitment to the development of the QMS and the provision of resources, e.g. for the training of the staff.

2.5.4 QM manual review

The Quality Management Manual (QMM) is effectively a written summary of all the quality management activities in an organization. Its role is to represent quality management systems (Waller et al., 1993) as a practical reference book or guide to the QMS.

The core of a suitable manual should therefore include:

Results obtained from auditing.

Results obtained from customer feedback (customer questionnaire).

The conformity and performance of product process.

Status of preventative and corrective actions.

Any recommendations for further improvement.

The only significant problem identified in the manual review at Ocean Foods was the lack of appropriate quality procedures, which should form the fundamental part of an effective quality system.

2.5.6. Training of operatives

The training for quality should have, as its first objective, an appreciation of the personal responsibility for meeting 'customer' requirements (Oakland, 1995). This applies to every employee, from the most senior to the most junior.

The food industry QMM should provide some guidance with respect to training food industry operatives, including:

Determining the necessary competence of food handlers in performing work affecting product quality, evaluating present competence and determining action to be taken. Generally, the QMM should provide guidance on implementing initial plans, checking that the objectives have been achieved (Nicolaides, 2004) and taking corrective action if targets are not met.

Requiring that handlers be aware of the relevance and importance of their activities and how they contribute to the achievement of the quality objective.

Being used to maintain appropriate records of education, training, skill and experiences acquired.

An identified problem in training food industry workers, in SMEs such as Ocean Foods, is the lack of management commitment to the whole processes in releasing money for training of its food handlers and to maintain the standard. This leads to an inability to make reviewing of the effectiveness of quality training programmes a continuous process.

The training that food handlers receive must be related to need, expectation and process improvement. Documentation procedures for identifying and reviewing individual training needs, and the ability to carry out the training effectively, must be established and maintained. Furthermore, training should be flexible in physical design, so that it can be easily used in the work place (Oakland, 1995).

2.6. Aims of implementing ISO 9001:2008 Standard

Implementation of this standard will enable SMEs to demonstrate their ability to consistently provide products that meet customer needs and applicable regulatory requirements. Therefore the aims and goals are usually based on the individual SMEs need for the following (www.iqa.org):

Enhanced customer satisfaction through the effective application of the system, including processes for continual improvement of the system and the assurance of conformity to the customer and applicable regulatory requirements.

Performance improvement and an increase in bottom line profit

The effective management risk

Assurance of quality products or services for the customer

The basis for implementing a culture for opportunity

The acquisition of a symbol of international recognition (ISO 9001).

In order to achieve the above goals, the emphasis must be placed on:

Identifying the processes necessary for the effective implementation of the quality management system. These processes include the management, resource, product realisation and measurement processes that are relevant to the effective operation of QMS (www.ISO.org).

Understanding the interactions between these processes.

Documenting these processes to the extent necessary to ensure their effective operation and control. (If appropriate, processes can be documented using process maps, but this is not a requirement of ISO (9001-2008).

2.7 SMEs benefit of implemented ISO 9001:2008 (QMS)

Implementation of a safety and quality management system will vary depending on the type and size of the SME, and on its products. Each SME will have its own objectives, although the primary objective for most SMEs is to increase their profitability (www.ISO.org).

Because of the responsibilities set out in the ISO 9001:2008 Standard, SMEs often see an increased involvement of top management with regards to the Quality Management System. This involves setting of the Quality Policy and Quality Goals and Objectives. It continues with a Management Review looking at data from the QMS, and taking action to make sure that Quality Goals are met, new Goals are set, and continual improvement is achieved.

The QM system leads to a number of general benefits (Krause, 1996), including:

The company is focused towards the Quality Goals. Management is provided with data on a continual basis and able to see progress (or lack of progress) towards goals and to take appropriate action.

It provides a mechanism for reviewing goals and performance on a scheduled basis, and for taking action based on the evaluation.

Increased productivity results from the initial evaluation and improvement of processes that occurs during the implementation process.

Ability to remain/become competitive in the market.

Elimination of redundancy.

2.8. The impact of legislative requirements on SME's

The process of demonstrating compliance with the legislation may be a barrier greater than actually complying with the legislation itself. SMEs are less likely to have formal systems for measuring, recording and managing their impacts, and they may not have the capacity to deal with demanding paper trails. The cost of audits and certification can be prohibitive. This is often the same however large the SMEs is, so they will constitute a far lower percentage of a large SMEs budget and thus have a far lower detrimental financial impact on them. Standards therefore often have a significant scale effect, which works against SMEs. In many developing countries, the high cost of certification is also due, in part, to a lack of local certifiers (www.inni.pacinst.org)

2.9. HACCP

The use of a highly structured Hazard Analysis and Critical Control Point (HACCP) system in food-safety control is not new. Than et al. (2004) identified that HACCP is a scientific and systematic system for assuring food safety.

The first food-industry HACCP application was by the Pillsbury Company in the 1960s (Hulebak and Schlosser, 2002). They had been contracted by the National Aeronautics and Space Administration (NASA) in conjunction with the U.S. Army Natick Laboratories to design and produce foods for space flights. The cooperative HACCP program which evolved had the goal of nearly 100% assurance that space foods produced would be free of microbial or viral pathogens.

HACCP is a systematic, preventative approach which combines the principles of food microbiology, quality control, and risk assessment to give a high level of food safety assurance (Mortimore and Wallace, 1997; Bennet and Steed, 1999).

Various forms of HACCP have been applied in the food industry since the 1970s. The first regulatory application of HACCP was by the U.S. Food and Drug Administration (FDA) in the 1970s where the approach was used in a regulatory/industry cooperative programme for low-acid canned foods (FDA, 2001).

2.10. Problems associated with SMEs in the application of the HACCP system

A number of hindrances to the effective implementation of HACCP in SMEs have been identified, such as lack of expertise and perception of benefits, absence of legal requirements, various attitude barriers and financial constraints. The imposition of HACCP on SMEs that have no enthusiasm for it will also be counter-productive (archive.food.gov-uk).

Many will not have the technical expertise or support required to implement HACCP, and it may result, rather ironically, in concentration being deflected from actual food safety issues to dealing with the paperwork necessary to operate the system and keep the enforcing authority satisfied. The cost of implementing HACCP for food businesses can occasionally be huge both for those businesses and enforcement authorities and will not necessarily result in safer food.

One of the main reasons for this may be that the effective control of food safety hazards, such as through a HACCP system, requires a scientific-based design and in-depth understanding of the management system. HACCP is not a one-dimensional management system, but requires a process of analytical thinking to ensure that proper control is established (www.fao.org). Such a process needs to be reviewed either during the stages of HACCP development by processors or assessments by regulators. Some of the problems with SMEs in applying HACCP are discussed below section 5 will further give suggested solution to overcome the issues.

Technical difficulties

Since the introduction of the HACCP system, applying hazard analysis (HA) has proved to be a significant hurdle, even for larger companies. The process requires specific expertise and knowledge of chemical and microbiological hazards and their attached risks, which is often not available among companies' employees initially. For this reason, proper HA application is always an important focus in good quality training programmes (www.fao.org).

Critical limits are borderlines that define the acceptability (or unacceptability) of a product; these must be met at each critical control point (Hulebak and Schlosser, 2002). Unfortunately, not all borderlines are defined by discrete figures that are easy for industry to use. In this case, validation is vital. If the critical limits set for controlling hazards are not properly validated (for example, temperature and time used for pasteurisation or cooking of the product), the HACCP plan will not be able to ensure that safe food is produced. Such processes need to prove their sufficiency to reduce the targeted bacteria to an acceptable level (www.fao.org).

In some cases, scientific support for all critical limits selected is not available and the support, if any, is not relevant to the processing conditions present in the facility. Large factories usually have their own equipment and experienced personnel to establish the process. They can also hire external experts to perform the studies.

Another technical issue is the utilisation of data obtained from monitoring and HACCP-associated activities (www.fao.org). HACCP application generates important records which are useful as a substrate for trend analysis, which in turn contributes significantly to improving the HACCP system.

Inadequate basic hygiene

If basic hygiene practices are not properly applied in food businesses, application of the HACCP system becomes pointless. In order to successfully implement HACCP, food businesses should, as part of prerequisite programmes (PRPs), already be operating according to the Codex General Principles of Food Hygiene, the applicable Codex Recommended Codes of Practice, and according to the food safety legislation.

Insufficient government infrastructure and commitment

Government commitment is a vital driving force of the success of a HACCP programme. A clear policy on food safety should be elaborated and turned into strategic plans for actual practices (www.fao.org). In many instances, strong commitment from governments is still lacking, as reflected in the lack of real support at the operational level. Such support includes financial funding and manpower. Government commitment is also one of the most important factors in the development and implementation of a successful HACCP initiative. In this respect, one of the most important tasks of governments is to consistently raise the awareness of industry to the benefits of, and the need for, introducing HACCP in order to produce safe food (www.caa.gov.za).

Human resources

Limited qualified personnel are often a constraining factor on the success of HACCP. Lack of personnel or personnel with insufficient time available to perform monitoring tasks may result in inconsistent control of hazards. Large plants, where personnel management is well handled, can minimise the problem. However, small processing plants, where the turnover of key staff is often high, have more difficulties in developing and maintaining a HACCP system (www.fao.org).

Financial constraints

Financial concerns are a restriction particularly for SMEs, in which the majority of food is produced in many countries. As food hygiene standards are pre-requisites to HACCP, basic environmental processing conditions must be achieved (www.fao.org). For some food processors this may require a large amount of capital, as they have to make considerable efforts to upgrade their premises prior to implementing HACCP.

Besides these upgrade costs, HACCP also creates the additional costs inherent in recruiting new employees, increased paper work, consultant fees, training, etc. HACCP implementation is necessary for the long term viability of the food industry as a whole, but it poses a real threat to the viability of individual processing plants (Colatore and Caswell, 1998).

Legal requirements

In many countries, HACCP is widely applied only to exported products, while domestic products are not dealt with because there is no legal framework to enforce and assess HACCP systems involved in producing domestic products (this has recently changed in EU) (www.fao.org). Regulatory authorities face many time-consuming challenges in convincing processors to apply HACCP, especially SMEs who already experience difficulties in complying with GMP requirements. Legislation and legal actions can be counterproductive and may hinder the ability and willingness to implement HACCP (www.caa.gov.za). However a legal requirement to apply the HACCP system, combined with proper enforcement, can be a strong pull-factor in promoting HACCP application.

Lack of effective education and training programs

Many companies train their employees inadequately with respect to HACCP, largely because management lacks commitment to and understanding of HACCP themselves. There is low access to effective educational and training programmes that are designed with these barriers in mind. The lack of expertise is perpetuated by the absence of food safety in the curricula of professional schools (www.caa.gov.za). The cost of appropriate training is often prohibitive to SMEs, whether it could be achieved through the recruitment of more highly qualified staff (where none were previously available), the use of educated experienced consultants or the running of training courses (Mortimore and Wallace, 2001).

2.11. Supplier Quality Assurance

Regular auditing of suppliers or potential suppliers should be the starting point when implementing HACCP (Mortimore, 2000). Auditing is therefore a vital element of monitoring at the receiving stage, since this can form the basis of the decision to select new suppliers, suspend current ones and/or initiate the supplier development process, can be based (Sperber, 1998). The criteria for accepting foodstuffs and ingredients should therefore be identified, documented and strictly followed on a daily basis; they should also be issued to suppliers as the specifications that are required by Ocean Food as part of the supplier development process (Watts and Hahn, 1993).

Ideally, all of Ocean Food's suppliers would have been audited, but due to financial constraints and sensitivities of the findings, it was not possible to carry this out for more than one supplier. The investigation covered the supplier's sources of raw materials and the level of their hygiene standards. Raw material country of origin and certification was also required from them. There was some resistance in gaining access to the company in order to conduct the audit, but this was overcome through successful negotiation.

2.12. The role of UK government and industry in food safety assurance

The UK and members of the European research community emphasise that food quality control cannot be applied successfully in each country without the support of government and industry (Hanak et al., 2002). As noted by Ababouch (2000), the HACCP principles play a pivotal role in preventive approaches. Their application is the responsibility of the food industry, whereas the government control agencies are responsible for monitoring and assessing their proper implementation. Kvenberg et al. (2000) discuss the role of the UK government and the industry in ensuring food safety. The government's responsibility is (i) to mandate the regulatory requirements for HACCP implementation; (ii) to establish mandated critical limits when necessary; (iii) to establish criteria, methods and sampling plans when necessary and (iv) to verify that in individual facilities HACCP plans are adequate in order to assure food safety.

Additional government activities should be to use epidemiological and scientific data to identify hazards and conduct risk evaluations. The results of these risk evaluations can then provide information that can be utilized in improving HACCP plans (as was the case at Ocean Foods where the issues detailed in section 4.9 were high-lighted as requiring improvement), supporting research relating to CCPs, implementing critical limits and monitoring procedures and cooperating with interested groups in identifying new food safety hazards and identifying strategies for their control. They should also encourage and participate in educational programmes that promote the use of HACCP, and cooperate with industry in the development of generic HACCP plans that can be widely applied. In the researcher's experience, these generic HACCP plans are of value; where they were available, they were implemented at Ocean Foods with relative ease. Further effort now needs to be invested in the extending the range of these generic HACCP plans that are available.

In terms of industry responsibilities, the industry should be able to develop, implement and maintain a preventative QMS, and an HACCP system to identify any existing hazards, with each facility forming team that is responsible for the QMS and HACCP plans in that facility.

As an example of the implementation of a governmental role, Hanak et al. (2002) mentioned that the government in the UK appeared to play a crucial role in developing policy, promoting legislation, and implementing EU legislation. That role lay mainly in the Ministry of Agriculture, Fisheries and Food (MAFF), the Food Standards Agency (FSA) and the Department of Health (DoH), along with the Scottish, Welsh and Northern Ireland Offices. In recent years, EU bodies such as the European Food Safety Authority (EFSA) have had an increasing influence.

Some aspects that the UK and European government can support, according to Hanak et al. (2002) and Jill et al. (1999), are quality control programmes, training, research and the role of consultant, as well as logistical, supports. Billy (2002) also adds that industry and government have a very important role to play in the implementation of food standards, by setting standards for food safety and other consumer protection concerns.

According to Billy (2002) and Suwanrangsi (2000), although many food companies have excellent HACCP programmes, they need to improve their performance in conducting hazard analyses, reassessing their plans, and validating the measures they adopt in addressing those hazards because there are many gaps and deficiencies in HACCP implementation. This is something that Ocean Foods will need to bear in mind for the future; they cannot let themselves become complacent, even once they have well-executed HACCP programmes firmly in place. Therefore, is important to invest resources in identifying crucial areas where improvements may be needed, such as in risk management, infrastructure and resources, communication, training and education and workplace environment.

The responsibility of the government inspectors is to ensure that the HACCP programme used by the food processor is properly designed and properly implemented. In this respect, assessment of the HACCP programme can be done in the following two steps.

1. An assessment of the HACCP manual which is basically a document review.

2. An on-site verification to establish whether the approved HACCP manual is properly being implemented.

Regarding the industry role as previously mentioned, several countries are exploiting the possibility of privatisation of elements of hygiene inspection (especially in the meat, poultry and seafood sectors) and this requires different legislation and infrastructure as compared with traditional programmes.

Traditionally, the industry has had the primary responsibility for GMP-based process control, and now it has the primary responsibility for HACCP-based process control as noted by Lee & Hathaway (1999). Moreover, according to Motarjemi and Mortimore (2005), there are many measures that the food industry can use to manage food safety in a more efficient manner and reassure public confidence in the food supply. Such measures include regulations and policies, guidance on hazards, risk communication and education, incidents and crisis management.

Industry needs to revisit its approach to training and to recognise that there are companies and employees at various levels of maturity and experience with respect to the implementation of HACCP-based process control, who will require different levels of training, and that different types of company (e.g. SMEs) will face different problems. Industry/trade associations should provide relevant technical training with consideration given to the level of education, culture and language of the SME managers and staff, backed up with the availability of appropriate, current scientific support. It is also important that they provide accessible, sector-specific generic guidance, such as industry guides and generic HACCP plans. They also need to ensure that improvements are made at the start of the food chain, at primary production levels, as it may be that too little attention has been focused in this area. As Baines et al. (2004) observed, there are significant health risks centred around primary production, and even evidence of multiple food safety break downs, yet there is little evidence that HACCP is being adequately applied to it. The conclusion must be that although there has been considerable in the last few years, much remains to be done.

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