By Ron Wasik
Everyone in the agri-food supply chain must feel overwhelmed at times by the number of regulatory and public food safety initiatives affecting our industry. Here’s a brief overview of some of the major influences.
CODEX originated in 1962 and in1969 published the document General Principles of Food Hygiene (GPFH), which became the foundation of all food safety programs. However, today’s food landscape is different. GPFH proposed updates include new definitions for terms such as contaminant, hazard and prerequisite programs, to mention a few of the many suggested revisions. The proposals attempt to draw a clearer distinction between prerequisite programs (PRP), operational prerequisite programs (OPRP) and HACCP programs. Readers unfamiliar with these terms should consult the CODEX website.
At least three proposals may be of concern to food processors. One proposal is that food safety risks managed within the PRP and OPRP programs be regularly verified and results recorded. The second proposal is that some numerically quantifiable food safety management risks managed within an OPRP program be monitored as CCPs. The third proposal concerns the recommendation that Good Hygiene Practices (GHP), which are the essence of PRP and OPRP programs, be in place before a HACCP program is developed. Few would debate that it is essential to have GHPs in place to have an effective HACCP program, but most companies develop their GHP and HACCP programs simultaneously.
To me, these proposals echo to some degree the requirements in the U.S. Food Safety Modernization Act, parts of which come into effect this year. The CODEX proposals, if strictly applied, will add significantly to the amount of food safety oversight to be done and documentation to be collected. This is a bit of a departure from Canadian and, to a lesser extent, U.S. FDA regulators’ promises to be results focused vs prescriptive. If the proposed changes concern you, voice your concerns to your industry organization, Health Canada and your MP.
The International Organization for Standardization (ISO) is an independent non-government organization founded in 1947. The organization has published nearly 3,000 standards in over 300 fields, including food processing. Most food processors will have heard of the ISO 22000:2005 Food Safety Management System (ISO:FSMS) which is referred to in many Global Food Safety Initiative (GFSI) schemes. Many ISO food programs focus on the implementation and management of CODEX standards. The two organizations are closely allied and dependent on each other to implement effective programs.
It comes as no surprise that ISO is also revising the ISO 22000 FSMS to reflect many of the proposed CODEX changes mentioned above. However, there is one proposed procedural change that has me shaking my head in disbelief. Specifically, this proposal states: “PRPs should be established and designed before proceeding to the hazard analysis.” After reading that proposal I asked myself, “Aren’t PRPs developed to address risks?” and “How can you develop a PRP before you have done a risk analysis?” To see a proposal like this from ISO is concerning, especially given the reliance on ISO in many GFSI and national food safety programs. We can only hope that the proposal is not approved, or is revised to reflect a logical sequence.
Other food safety initiatives
In addition to CODEX and ISO, food processors and other segments of the agri-food chain will be influenced by one or more GFSI schemes, the U.S. FSMA, the Canadian Safe Food for Canadians Act, provincial regulations, municipal or city regulations, customer food safety programs and last but not least, consumers using social media. What interesting times we live in!
How we manage to provide plentiful, affordable, safe and nutritious food to Canadians and the rest of the world as well as a livelihood to millions of people is remarkable. Our industry is the second-largest contributor to Canada’s GDP. Our industry deserves a week of recognition! How about the week of Oct. 10 starting with Thanksgiving Day? Let me know what you think.
Dr. R.J. (Ron) Wasik, PhD, MBA, CFS, is president of RJW Consulting Canada Ltd. Contact him at [email protected]