This part is primarily in three sections (click to jump to topic); HACCP, microbiological criteria and microbiological risk assessment. But first I’ve written a prolog with links to reports covering the current and future issues in food safety control:

Guidelines for developing harmonised food control systems 
"Terrorist Threats to Food: Guidance for Establishing and Strengthening Prevention and Response Systems" from the WHO (pdf) 
FDA registration of food facilities; response to bioterrorism threat 
Risk Assessment for food terrorism and other food safety concerns 
FAO - Food quality & Safety 
IFT report - Food Safety issues for the 21st Century 
CAST recommendations 
CAST food safety 
American Academy of Microbiology - food safety, current and future needs 
Control of Listeria in small meat and poultry plants 
Guidelines for developing GMP, SOP, and environmental sampling plans for RTE products 
Listeria monitoring program 
Chlorination 

Something to consider concerning food safety implementation and practice

A food processing unit supplies an exhibition arena used for major events such a conferences and music concerts. Therefore it has multiple menus, large numbers of consumers who (presumably) consume the food within hours of purchase. The hygiene rules of the company are:

On ingredient receipt 
Reject if chilled products are >5oC 
Reject of frozen products >-18oC 
Reject any dented, blown or damaged tins 
Hygiene rules 
Keep cold food cold (<5oC) 
Keep hot hoot hot (>63oC) 
Keep prepared food out of the Temperature Danger Zone (5-63oC) 
If any refrigeration unit fails and the chilled food temperature is above 8oC then it must be used, reprocessed or discarded within 4 hours. 
Consider the following questions:

Are the rules achievable? 
What is the signifance of the set temperatures, ie -18, 5 and 63oC ? 
What organisms could grow to significant numbers at temperature above 8oC. 
If the legal limit for chilled foods is 8oC, then why is the comapny using 5oC? 
Despite these ’in-house’ temperature regulations, which organism(s) could neverthelss cause a major food poisoning outbreak from this establishment? (Hint see Section 5.3, p172.) 

HACCP
HACCP is the abbreviation for ’Hazard Analysis Critical Control Point’. It is the internationally accepted means of safe food production. The essential aspects are that hazard are identified and control measures implemented as opposed to the previous retrospect approach of reliance upon end-product testing. The latter being inadquate as a controlling method since the results (especially from microbiological analysis) would not be obtained until after the food had been packaged and distributed.

You can download a Powerpoint presentation I’ve written on HACCP, MRA and microbial criteria by clicking here.

It should be remembered that hazards in HACCP include physical and chemical hazards, not just microbiological. Also in the next edition I plan to expand on food additives and materials in contact with food since I am on the EU Food Safety Authority panel which considers these compunds. This includes the evaluation of semicarbazide in jar baby foods (chemical hazard: HACCP) which has caused concern in the Summer of 2003.

Before HACCP can be properly implemented there are a number of ’Prerequisite Programmes’ or ’PRP’ that are required. These have been defined by the WHO (1999) as ’Practices and conditions needed prior to and during the implementation of HACCP and which are essential for food safety, as described in Codex Alimentarius Commission’s General Principles of Food Hygiene and other Codes of Practice.’’. 

Prerequisite programmes include (but are not limited to): 
Building design and work flow pattern 
Equipment design 
Supplier control 
Receiving, storage and distribution 
Specifications 
Staff training and personal hygiene 
Cleaning and disinfection 
Pest control 
Chemical control 
Traceability and recall 
Waste management 
This list is largely taken from the NACMCF 1997 HACCP System, and many of these are covered in more detail in my book with Pat Hayes ’Food Hygiene, Microbiology and HACCP’ (originally published by Aspen, now Kluwer Academic) which was written for industry rather than undergraduates.

Seven Principles of HACCP 
Conduct a hazard analysis (HA) 
Determine the critical control points (CCPs) 
Establish critical limits 
Establish monitoring procedures 
Establish corrective actions 
Establish verification procedures 
Establish documentation and record-keeping procedures 
A ’hazard’ may be biological, chemical or physical. Although the book primarily deals with microbial hazards, there are many others such as glass, cleaning agents and pesticidies. At the moment a lot of attention is on acrylamide. Here are two web sites relevant to the FDA and EU (pdf file) stance on this compound. There has also been a well publicised ’food poisoning’ in Nanjing (China) that was due to food being contaminated with rat poison

The legal aspect of HACCP implementation is complicated and varies from country to country. Until June (2002) in the UK the first 5 principles were the only legal requirement. Large food companies would have Principles 6 (Verification) and 7 (Documentation and Record-keeping) in place. Smaller companies, although not obliged to have the latter principles, would be recommended to adopt them as a support for ’Due Diligence’ in a court of law. You may wish to consider how efficient a food company can control its hazards without documentation or verification - and I’d be interested if you could prove the saying "If it’s not written down, it doesn’t exist" wrong! This situation changed on 7th June (2002) with the Food Standards Agency (UK) announcement that meat and poultry plants required the full 7 stages. Additionally there are now draft proposals concerning consolidating and simplification of the EU food hygiene legislation. Essentially the proposals would require all non-primary food operators to implement a harmonised HACCP system, records to be kept of food safety checks carried out under HACCP, codes of good practice to be used as the food safety management on farms (instead of full HACCP implementation) and the compulsory registration of all food businesses. The two pdf files concerning these proposals can be downloaded here (1) and (2) . 

Another question you consider is "’How can small food companies identify the hazards appropriate to their food production? Where will their expertise come from?". The reason for the question is that there has been a problem in the past in that certain regulatory authorities have not assisted in HACCP-like implementation in case the system breaks down and they are blamed. Fortunately there are numerous independent experts available. But a key aspects is that HACCP implementation cannot be an off-the-shelf software package, it requires representatives from the factory floor to state what really happens during production as opposed to what management think happens. In 2002 HACCP implementation for companies handling meat was released by the HMSO for Northern Ireland and includes swabbing sites and microbiological levels.

It should be remembered that HACCP does not only refer to microbiological pathogens, but to physical and chemical hazards as well.

My first book ’Food hygiene, microbiology and HACCP’ published by Aspen (now Kluwer Academic) was focused on the complete industrial implimentation of HACCP. You can also visit various HACCP sites at:

NACMCF HACCP Principles 
Generic HACCP models from USDA/FSIS 
Generic HACCP models (USA) 
HACCP video 
HACCP resources (USDA) 
Generic HACCP models (Canada) 
Generic plan for beef jerky (Canada) 
template HACCP models for the meat industry (New Zealand) 
General HACCP models for various foods 
Generic seafood HACCP plans 
HACCP95 
HACCP and Total Quality Management 
International HACCP Alliance