By Benjamin Brits
The process involved in ensuring all food products are safe for consumption is a complex one and relies on a lot more than what meets the eye, with multiple layers of considerations and regulations.
Food safety in principle is nothing new as various documents dating back to a few hundred years BC illustrate that food-borne illnesses were already common in that time. More recently, between the early 1200s and late 1700s, many proclamations, regulations, laws, and guidelines were established throughout the world as authorities came to realise the importance of ensuring safe consumption in both foods and beverages.
Today, food safety has reached exceptional levels as equipment, processing, handling, and managing associated food safety hazards have become quite a science through the implementation of global consumer safety standards and systems. Here hazard analysis and critical control points or HACCP, has been established as the foundation for a system of a preventive approach, and takes under consideration many factors that can cause consumer safety concerns.
The HACCP system was first developed in the US in 1960s to reduce or eliminate quality and pathogenic challenges to prolong shelf-life for speciality foods such as those used for space travel and military operations. In the early 1990s Codex issued the first HACCP guidelines, the mid 1990s saw the formation of the international HACCP alliance and then in 2005 the ISO 22000 standard was formed and later adapted into FSSC 22000 – a private food safety certification scheme. It is safe to state that HACCP today is part of every food related operation coupled with particular additional standards – dependent on each food product or position in the food value chain. There are standards for farming, transport, and distribution, and hopefully soon, retail. This is in addition to manufacturing, or the manufacturing for example of food packaging materials.
What food safety entails
Answering this question, one would have to take a step back and understand the dynamics of increasing volumes of all food categories being consumed in the form of anything from vegetables to seafood across the globe. With this factor in mind, more food-borne incidents occur, and are likely to occur in future as the globalisation phenomenon expands with both import and export volumes that baffle the mind. Much research has been made available as to the impacts supply chains have on the growing consciousness around health and the associated benefits that fresh produce holds, and therefore emphasis on food safety. It is not uncommon for fresh produce to travel far distances and be handled multiple times.
Food safety, however, is not only about maintaining the cold chain; it starts from the producer level – be that the farmer or processing facility, where several risks can be identified that require management or elimination. This could be as early in the process as chemicals affecting soils, keeping fresh fruit in storage alongside contaminated produce, failure in a production facility where an undesired substance enters the line that would ruin the batch, or even the antibiotics given to livestock.
What matters most at the end of the day is ensuring that any product destined for consumption will not cause illness, or in some cases fatality, which is unfortunately a real outcome – while either result may have dire legal consequences too.
“When one talks about food safety, the first thing that comes to mind is product protection and consumer confidence. Food safety is a discipline that describes (on a high level) the way in which we handle, and store products intended for consumption – which is the protection aspect. Consumers are generally unaware of the process involved in ensuring that their purchased products are safe to eat. It is just assumed that frozen food purchased is safe. There is no consideration to any cold chain, how many times the item has changed hands, if it has been thawed out anywhere in the process, or if it may have been exposed to contaminants. For this reason, each role player in the supply chain must do their bit to ensure that product is produced, handled, and stored in a safe manner to maintain this confidence. This is our responsibility,” says Larna Jodamus, Compliance Manager at CCS Logistics and Chairperson of the GCCA-SA Food Safety & Compliance Committee.
In many cases though it must be noted that consumers also contribute to the risk in food safety when they may go shopping and leave their goods in the car after purchase which can dramatically affect product quality and expected shelf life, possibly resulting in unsafe goods.
“From a legal standpoint, and in very simple terms, producers, manufacturers, and processors are not allowed to sell anything that can cause harm to the consumer, whether it’s a motor vehicle, a jumping castle, or a lollipop. If a case does arise from any claim, the producer or source will have to provide evidence that they did everything to ensure the product was safe for consumption in accordance with the intended use. Here the HACCP system would be the reference point. Conversely, the consumer must use the product as intended when produced. A simple example would be a packet of soup thickening powder– if that packet of soup is incorporated into a dish as a thickening agent this is the intended use, however once the consumer uses this packet of soup thickening powder to flavour a ‘chip-dip’, which it was not intended to, it is used incorrectly and therefore the consumer may be open to a food safety risk. So, when a product is used differently on the consumer level, a whole different legal aspect would be created,” advises Anya Knoetze, food safety specialist.
HACCP and safety standards in SA
HACCP is a framework used to identify, prioritise, and manage food safety risks. In essence, it is a form of risk (food safety hazard) assessment that considers the severity and likelihood of occurrence of any identified risks, but also factors within current control measures and the effectiveness of those controls. The system is applied to reduce to an acceptable level (or eliminate) any food safety hazards that may already be present in the product itself, or that can be introduced during manufacturing, processing, or handling.
“The HACCP methodology is based on seven principles that guide teams through the process to set up and manage their systems. More so than just a system that is suitable to the particular process, it aims to proactively address root causes of risks rather than reactive measures which typically involve situations where contamination or loss has already happened,” Jodamus adds.
System development is also application specific. If you look at a facility that making glucose versus a facility that’s making pizza bases, the technology in the facilities is different, the science and engineering involved is different, the machinery is different, the sophistication related to the employees may be different. With a vast set of outcomes related to food safety, it would not be uncommon to have anything from 200 to 2000 documented procedures in any given facility.
The seven principles in HACCP follow, and are applied in conjunction with any other relevant food safety standards applicable to the product being worked with:
- Conduct a hazard analysis
- Determine the critical control points (CCPs)
- Establish critical limits
- Establish monitoring procedures
- Establish corrective actions
- Establish verification and validation procedures
- Establish record-keeping and documentation procedures
“HACCP is one of a couple of systems available globally and is one of the most affordable standards to implement, maintain and be audited against. Because some standards are voluntary, companies can choose which certification system to implement. Others include the ISO certification system and the FSSC 22000 scheme. Each of these systems progresses in complexity and electing either could be of the organisation itself or driven by the customer. The requirement of the specific food safety management system, be it HACCP, ISO 22000 or FSSC, is applied in best practice to the organisation to ensure their maximum operational output and increased control over any risks and hazards,” says Verona Ramsook, Group Food Safety Manager at Etlin International (Pty) Ltd.
The establishment of the relevant HACCP system is further not a single point or person responsibility but includes all departments that are involved in the handling of any product throughout the process. Each department needs to know their exact roles and responsibilities but for the purpose of structure, ultimate responsibility lies with the most senior manager who takes responsibility for any site. Given this, it is logical to understand that it would be impossible for one person to ensure compliance and thus food safety is considered an organisation-wide duty driven by a responsible culture.
“The biggest part of this process is to ultimately ensure consumer safety. Naturally, there are several things that could go wrong in any sort of production or manufacturing environment, and similarly, in every element of the cold chain lies responsibility towards the given product or produce. It is therefore critical for every stage in the supply chain to follow the HACCP system as we say, from farm to fork. This further should include every person that comes into contact with the goods throughout the process and not only a high-level view, so essentially everyone from the pickers onwards,” adds Ramsook.
In the South African context, we have regulations and standards for both local and international consumption intent. Exports need to meet varying higher-level conditions, so for example, the requirements for products going to the UK are different to products going to the US or for consumption in Asian markets, however, as a base point, all food safety protocols essentially start with the HACCP principles.
The reason for differing food safety protocols to be met in the international setting is primarily due to the fact they these countries may have specific established national standards where for example particle counts are below what is classed as acceptable and safe in South Africa, not that South African standards are by any means unsafe. This result could be the difference of a few particles per million such as seen in the grades of water per region.
Primary regulations and standards related to food safety locally include the following examples:
- SANS 10330: Food safety management requirements for a food safety system based on prerequisite programmes and hazard analysis and critical control point (HACCP) principles
- Regulation 638: General hygiene requirements for food premises, the transport of food and related matters – regulated by the Department of Health
- VC 8017: Compulsory specification for frozen fish, frozen marine. molluscs and frozen products derived there from – regulated by the National Regulator for Compulsory Specifications (NRCS)
- R146: Regulations relating to labelling and advertising of foodstuffs
- Meat Safety Act regulated by Department of Agriculture, Land Reform and Rural Development (DALRRD)
- PPECB Act regulated by the Perishable Products Export Control Board
- VPN38: Standards for the registration of a veterinary approved cold storage facilities for imports and/or exports regulated by Department of Agriculture, Land Reform and Rural Development (DALRRD)
- Foodstuffs, Cosmetics and Disinfectant Act administered by the National Department of Health
- The Consumer Protection Act administered by National Government
- SANS 10156: The handling of chilled and frozen foods
“Both SANS 10330 and ISO 22000 are Codex aligned and in fact SANS 10330 is suitable to be used as an export standard, while what we find in South Africa with companies participating in export is that because this is not a well-known standard globally, international customers request the use of the internationally recognised standards such as ISO or the FSSC system as Verona suggested,” Knoetze adds.
“Depending on the commodities stored and customer requirements, there may be several inspections carried out annually to ensure that companies are taking the necessary measures to protect the consumer. The unfortunate reality is that strict enforcement or strict monitoring of any of these regulations is often limited due to resources and capacity, and so there is a large reliance on the organisation’s business leaders to act ethically,” Jodamus says.
Ramsook adds, “To give an idea as Larna has alluded to, up to 12 inspections or audits could be carried out a year dependent on the handling of various products at any given facility.”
Some of the underhanded elements that have been highlighted for authorities include dummy systems and paperwork, altered data, backdated records, and closure of non conformances that have been open since the last audit. This involvement with non-conformance indicates the levels at which these issues may occur. The reasons for this behaviour may be for several reasons, however without a clean audit and re-certification, the impact on facilities may be harsh. Although cold stores for example simply may not receive input products until all non-conformance is remedied, a processing facility on the other hand may have a ten-fold impact, as no production means massive financial losses.
For most facilities, the process of inspection and re-certification is initiated long before expiry to ensure a smooth transition between periods, and most often notice is issued in terms of audits, however depending on some certifications, inspections and audits will be un-announced, and therefore ensuring compliance to all regulations and standards at all times forms part of best practices in food safety and process systems.
“It is important to know up front that any food organisation cannot operate if they don’t have their certificate of acceptability from the Department of Health. This is the mandatory minimum requirement and even if you complete a HACCP process, or meet an ISO certification audit, if you do not have your R638 certification, you are automatically non-compliant. You could be doing everything right, but by not complying with the minimum regulation it would not matter how good your facility is. Further it is critical to identify the difference between regulations, legislations acts, and standards involved in food safety as each technically would refer to something mandatory or voluntary,” says Ramsook.
In the HACCP process it is also important to understand each product that is being handled as all fresh produce will have organisms that are inherent. It must be stressed that with all food produce a certain level of these organisms is considered acceptable because no product is sterile. These include examples such as Salmonella, E. coli and Listeria which have made headlines in recent years. The problem in food safety comes about when levels exceed what are classified as acceptable. Measurement is taken in biological terms of ‘colony forming units per gram’. As part of several product’s cycles that contains any such organisms, there is a reasonable assumption that a kill-state would be achieved through cooking at a particular temperature for a particular time. However, not all products are cooked, so there isn’t always a kill-state involved. It is for this reason that ready to eat products have more stringent microbiological specification versus product that requires further processing or cooking.
Looking further at the HACCP system, food safety hazards are divided into four categories, namely:
- Physical: Wood, glass fragments, bone or claws, plastics
- Biological: Micro organisms, spores, insect eggs, larvae
- Chemicals: Pesticides, cleaning, sterilisation, mechanical oils, or grease
- Allergens: Soy, gluten, milk, peanuts and tree nuts, eggs, fish
“As part of risk analysis other examples could also include rodent control, premises security, security of supply chains, cyber security which is a big factor in a number of industries today, and even fraud. Preventative measures against these sorts of incidents should also be included in any evaluations,” Ramsook continues.
Because HACCP is based on a preventative concept, you have to identify and manage problems in the environment rather than cure as we have identified. When testing is done during operations, it would therefore be product testing, environmental testing, equipment, and machinery swabs, etc to verify that the processes in place are working and for example, the bacteria counts are in line to the limit that are specified, or that are allowed by law or the customer.
“In terms of overall food safety, a lot of people in this country continue to think and believe that testing is the answer in any manufacturing or processing operation, but it’s not. If you don’t do proportionate sampling, there’s no ways you can actually rely on testing to ensure that your product is safe. A good example is taking one hamburger patty out of a tonne of product, testing 25 grams, and being satisfied with the result. This needs to change,” Knoetze remarks.
Procedure for incidents
When you think about food safety you may be swayed, I as I was, to assume every incident would require ‘crisis management’ because contamination has made its way into a facility, but as I’m sure you will find amusing in hindsight as I did, this is not the case at all and in fact, “crisis scenarios that reach public level” are extremely rare. In most cases any incidents are handled between supplier and customer.
When you consider incidents in the food safety process, there are so many possible situations that may be the cause, and may, or may not be part of the determined hazard analysis.
“All recalls are deemed incidents but not all incidents would warrant a withdrawal (crisis management). Examples of food safety incidents that does not necessarily warrant a withdrawal: verification testing of a temperature monitoring device exceeding the permissible tolerance, above specification indicator organisms detected (for example, total microbial count) on a surface, incorrect cleaning chemicals used etc. However, it must be noted that with each food safety incident, you are advised to undertake a root cause analysis and risk assessment to determine the consequences of the said incident. The outcome of this exercise will provide the information needed to make an informed decision on whether a withdrawal is required,” Jodamus advises.
A crisis on the other hand would involve a major food safety risk where the only choice is to stop the product distribution totally. This would require the involvement of the relevant authorities such as the Department of Health, track, and trace protocols to pinpoint where any produce may have already landed at a consumer, or in a further processing facility that has converted the product into another couple of tonnes of food. The situation may be compounded when exporting is involved while the last resort in the most serious conditions is to turn to the mainstream media to announce the risk and request all products are returned. Logistically this is an extremely difficult operation to manage and a key reminder of why risk assessment is needed as a precaution and not a reaction, but further extremely damaging to a brands reputation.
It would be foolish to think that any facilities have zero incidents and collective opinions from food safety managers are that incidents are not something to be ashamed of or try to hide away. The speed of resolution and identifying what went wrong to add this to the food safety system is important, while ensuring bad goods don’t reach the consumer would be the priority.
Key elements linked to the cold chain
“When we talk about products that needs to stay cold, the cold chain is actually the most important in moving products from the farm to the manufacturer, from the manufacturer to the distribution centre, from the distribution centre, to the to the retailer or to the restaurant or to your favourite pizza takeaway. Simply keeping food product cold, directly equals prevention of bacteria growth. Unfortunately, this is also the area we see the most inconsistency,” Knoetze says.
Maintaining the cold chain by ensuring that product is received at the required temperature, staging times are kept to a minimal and products being stored at the correct temperature are some of the highlights for storage facilities. Additionally, regulations specify the temperature ranges required to be maintained for the various fresh produce and processed foods. Seafood as an example is required to be stored at minus 18°C or below as per Regulation 638, while other frozen goods require temperatures of minus 12°C and chilled produce may require a couple of degrees above 0°C.
“Breaks in the cold chain, also known as temperature abuse, have been proven to result in quality issues such as formation of ice crystals and discolouration of products, but the more serious threat here is food safety risks related to organisms as Anya has stated, that may compound exponentially given the product reaches conditions outside of the required parameters. For example, if frozen food thaws, water activity increases which stimulates the growth of microbiological organisms. Safeguarding a product holistically by making sure that we provide a compliant facility involves a broad range of elements that spans across construction and layout of facility, preventative maintenance programmes, facility management, environmental monitoring programmes, and so on, and is not just a matter of storage. What is involved, through various toolsets, is temperature testing, visual inspections of incoming products and vehicles, testing of food contact surfaces and equipment to verify the effectiveness of cleaning protocols, water quality testing and ongoing calibrations as a few examples,” Jodamus points out.
When any product falls outside of the particular temperature range as it moves along the cold chain, establishing or having access to an accurate timeline is highly important because this ultimately will determine the outcome of the goods. For example, if a breakdown occurs in logistics and the product core temperature can be maintained this will have a far less troublesome outcome that a breakdown with a poorly insulated truck body for an extended period that in turn results in even partial thawing.
Each scenario is based on the particular event while the cold chain is merely an element in the process of getting the product (that is owned by the producer) to the consumer in the safest environment possible. This essentially means that the owner of the product has the ultimate responsibility to decide what happens to their goods. That being established, it is also important to note that each role player in the cold chain may have and uphold their own specification ranges to ensure safety of food, but in some instances the law will prohibit goods progressing any further.
Food safety related to the cold chain is additionally burdened because of the often and unavoidable “many hand changes” essentially meaning that there are several areas in logistics that can fall short. Logically speaking, it is never a case of a single path from the farm or processor to the consumer and several stops exist in the cycle. Perhaps an initial cold store or cool-down facility is used, transportation to a local hub, staging time, storage, transportation to a distribution centre – again with staging time, then distribution to retail outlets before it reaches the consumer. The product in that time and in this example has already been through seven stages and varying conditions which increases the risk.
“Because of the number of changeovers as illustrated, the biggest risk, in my opinion for the cold chain is temperature control. When poor temperature control is a factor, you’re going to have spoilage and you’re going to have microbial activity as we have discussed which produce obvious risks. Temperature control and correct ranges at that are vital. This includes the timeous corrective actions if a deviation occurs. If the product needs to be stored at minus 18 degrees and your freezers malfunction, companies need to action corrective measures or ensure contingencies are in place. Notifications may also need to be issued. This is of particular importance with both import and exports as a single container could hold as much as 27 tonnes of product that if spoilt, can be extremely costly to just discard or have destroyed,” Ramsook adds.
Training and areas of improvement
“Foremost I think the complexity of the science that is rooted in HACCP is not understood properly. The foundation of food safety is essentially in microbiology – which is science. When one lacks knowledge in things like micro-organisms for example, and must consider where they come from, what they eat, how they survive, what they excrete, and so on you start to get an understanding of why the science portion is critical. How can you manage something you don’t fully understand? Science also includes validations to make sure we are cooking food at the right temperature, or is sufficient salt or sugars being added during processing. Most people’s re-collection of anything biological is from their school years and haven’t touched the subject again. Nor have they pursued any career with a scientific background. Further, we find people involved in a food safety system that have no insight whatsoever into what the product is about because they are “just moving the package from one area to the other”. When this happens, it is clear that there can be no real perception of what the risks are or could be regarding any food product safety,” Knoetze says.
Improvements in food safety are organisation specific because one would find some organisations where management doesn’t commit to food safety, or they don’t provide the necessary support for it, while other companies are fully behind all initiatives and lead the industry in terms of best practices and quality implementation.
“It is further important to note that food safety culture plays a major role in the execution and effectiveness of food safety management systems. There’s this saying ‘culture eats HACCP for breakfast’. Food safety culture is the foundation that is often overlooked by organisations and their food safety teams. In short, culture can be described as ‘the way things are done around here’ or even ‘what we do when no one is watching’. Do we have a culture of accountability, one where employees feel safe to report non-conformances and have confidence that these non-conformances will be actioned by their team leaders? In an organisation where the food safety culture does not exist or is weak, you will often find that food safety is the responsibility of the compliance team/food safety team alone, and food safety matters are only given priority in preparation for an audit. The required attention towards food safety culture is something definitely lacking in South Africa. This is of greater importance now as the country is quickly progressing towards global participation in food supply chains. We need to keep up with the international standards to continue to service other regions and this stems from successful planning and delivery of an effective food safety management system and culture,” Jodamus stresses.
Another significant aspect of food safety is essentially a full understanding of what is involved. If people don’t understand a process or objective, they will never buy into it.
This is demonstrated perfectly when business owners or senior management sit in an audit and can’t relate to or have an opinion of future strategies, or the simplest compliance aspects. This too indicates lack of commitment. However, if you look at the way food safety is moving these days as Larna has mentioned, creating a supported culture in food safety is a two-way street where the applied importance of food safety for all staff will produce results that management is seeking. It is unfortunate that food safety had to be highlighted with the Listeria outbreak in 2018 because before that, generally people didn’t even know what food safety systems were. It was a ‘company’s responsibility’ but now everyone is taking a little more interest including the consumers who today more than ever drive change. Training is a further highlight here. Somebody who understands the principles and concepts who is correctly trained, will apply systems that benefit the organisation,” notes Ramsook.
“We can of course teach people all the ins and outs around HACCP through various training programmes but just as a simple example, if you take the ISO 22000 standard, there are approximately 475 requirements. If you spend 30 seconds on each item, it’s going to take you longer than two days to read and understand the requirements as intended by the standard. People go on training courses as a tick box exercise, the certification body comes in, they see the box ticked but when you really sit down and look at system design and implementation and how systems are managed, one can immediately see that a crash course is just not suitable. Training should depend on the level of each person’s background in the team. A new person to the HACCP system may require months to years of training while someone with a BSc degree may adequately be prepared with a five-day exercise. Although standards don’t change often, biology changes, food science changes, food technology changes, bacteria mutates, and allergens come and go. As someone in food safety, staying on top of things remains critical through continual learning and training is key in this sector,” Knoetze concludes.