FSAI-HSE National HACCP Strategy 2007 to 2010
A Strategy to Facilitate an Increase in the Development, Implementation and Maintenance of Food Safety Management Systems within the Irish Food Industry
Background
The National HACCP Strategy was put in place in 2002, to tackle the low level of compliance with the HACCP requirement of Council Directive 93/43/EEC on the hygiene of foodstuffs. Its implementation was achieved through a HACCP Steering Committee consisting of environmental health officers (EHOs) from each of the 10 former health boards (now known as the Health Service Executive (HSE)) and chaired by the Food Safety Authority of Ireland (FSAI). Over a four year period the strategy achieved considerable success among the specific groups that were targeted:
- Hotels with function catering
- Hospitals
- Nursing Homes
- Butchers selling ready-to-eat food
On 1 st January 2006 Directive 93/43/EEC was replaced by Regulation (EC) No 852/2004 and brought into effect in Ireland by European Communities (Hygiene of Foodstuffs) Regulations 2006 (S.I. No. 369 of 2006) . The Regulation retains the HACCP requirement (Article 5) but introduces a degree of flexibility. It obliges food business operators to:
‘…put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles’.
The Regulation recognises that in businesses undertaking low risk activities, the prerequisite hygiene requirements (i.e. the general and specific hygiene requirements outlined in Article 4 and Annex II) are sufficient to control food safety, without the need to develop a HACCP based system. Additionally, it allows for businesses to follow guides to good practice where typical hazards and controls have been identified. The European Commission issued detailed guidance (Guidance document on the implementation of procedures based on the HACCP principles, and on the facilitation of the implementation of the HACCP principles in certain food businesses. http://ec.europa.eu/food/food/biosafety/hygienelegislation/guidance_doc_haccp_en.pdf) on its interpretation of HACCP flexibility, which has formed the basis for the revision of the FSAI Guidance Note No 11 on Assessment of HACCP Compliance
To build on the success of the previous strategy and to ensure consistency of enforcement against a background of flexibility this revised strategy has been issued for a further 3 year period.
Note: In this document the term ‘food safety management system’ is used to describe ‘procedures based on the HACCP principles’.
Strategic Goal
"Bring about a significant increase in the number of food businesses that implement a food safety management system by the end of 2010."
Scope
This strategy applies to businesses covered by the European Communities (Hygiene of Foodstuffs) Regulations 2006 (S.I. No. 369 of 2006). In practice, this means businesses inspected by the Environmental Health Service of the Health Service Executive (HSE).
Constraints on resources at HSE level necessitate the adoption of a targeted approach to implementation of this strategy. It has been agreed that the Environmental Health Service will undertake its role in the strategy by targeting high-risk businesses groups as defined by FSAI Code of Practice No. 1. Medium-risk businesses will be targeted only after sufficient compliance has been achieved in high-risk businesses.
Strategic Objectives
1. To promote the requirement for a food safety management system.
2. To clarify and promote understanding of the food safety management system requirement.
3. To employ a targeted approach to ensuring full compliance with the law.
4. To facilitate the development of an enhanced role for industry in its own development of food safety management systems.
5. To develop a consistent approach to enforcement.
6. To measure the success of the strategy.
Strategic Roles
The Role of the Food Safety Authority of Ireland (FSAI)
- Co-ordinate the implementation of the strategy via the HACCP Steering Committee.
- Promote the concept of food safety management systems nationally.
- Develop an agreed consistent approach to enforcement.
- Work with the food industry to increase their involvement in their own adoption of food safety management systems.
- Develop novel approaches to the design of Food Safety Management Systems for small and less developed food businesses
- Evaluate the success of the strategy.
The Role of the Health Service Executive (HSE)
- Participate in the HACCP Steering Committee.
- Promote the concept of a food safety management system.
- Promote food safety training.
- Act in an advisory capacity to guide local businesses towards achieving compliance (this does not extend to designing a system for food businesses).
- Follow FSAI Guidance Note No 11 to ensure consistent assessment of compliance.
- Conduct the necessary activities involved in measuring the success of the strategy.
Strategic Activities
The objectives of the strategy will be carried out through a series of co-ordinated activities which will be overseen by the HACCP Steering Committee. These activities will be fully developed during the lifetime of the strategy. However, some key activities are identified below.
1) To promote the requirement for a food safety management system
FSAI
- Develop and instigate national promotion campaigns as appropriate.
- Encourage trade associations to promote the benefits of and legal requirement for a food safety management system.
HSE
- Develop and co-ordinate appropriate promotional activities around national campaigns where possible.
- Reinforce the requirement for a food safety management system and food safety training during routine inspections.
- Reinforce the need for all food workers to be aware of their responsibilities in implementation and maintenance of the food safety management system.
2) To clarify and promote understanding of the food safety management system requirement
FSAI
- Develop training material to support food businesses in the use of the Safe Catering pack.
- Develop, as necessary, other novel approaches to the development of a food safety management system.
- Involve industry in the development of future guides.
- Engage in seminars aimed at promoting an understanding of the food safety management system requirement.
- Promote FSAI Guide to Food Safety Training Level 3 - Food Safety Skills for Managers.
- Assist EHOs in the assessment of critical limits which differ from the national guides to good practice and disseminate conclusions via the Enforcement Consistency Group.
HSE
- Participate in groups formed by the FSAI to draft key documents and information leaflets.
- Use educational opportunities, where appropriate, to promote understanding of the food safety management system requirement.
3) To develop a targeted approach to ensuring full compliance with the law
FSAI
- Agree target groups and a timetable for each target period.
- Undertake any planned promotional activities
HSE
- Agree target groups and a timetable for each target period.
- Plan the activities necessary to implement the targeted approach
4) To facilitate the development of an enhanced role for industry in its development of food safety management systems
FSAI
- Liaise with key food industry representative organisations based on the agreed target group.
- Investigate alternative means of engaging food businesses not represented by trade organisations.
- Encourage provision of alternative sources of financial support for food businesses implementing food safety management systems.
- Foster collaboration between the FSAI, the HSE and the food industry to promote and discuss issues relating to food safety management systems.
HSE
- Participate in any forums formed between the FSAI, the HSE and the food industry to promote and discuss issues relating to food safety management systems.
5) To develop a consistent approach to enforcement
FSAI
- Promote use of the FSAI Guidance Note No 11 on Assessment of HACCP Compliance.
- Revise Guidance Note No.11 as necessary to reflect any future changes in the legislation.
HSE
- Utilise Guidance Note No. 11 when assessing compliance with the food safety management requirement.
- Participate in revision of Guidance Note No. 11 as necessary.
6) To develop and implement an accurate measure of the success of the
strategy
FSAI
- Develop a workable matrix for assessment of compliance, based on Guidance Note No. 11, to be used in baseline and final assessments of target groups.
- Agree timeframes for baseline and final assessments of target groups.
- Analyse and report the results of all monitoring activities.
HSE
- Participate in the development of a workable matrix for assessment of compliance, based on Guidance Note No. 11, to be used in baseline and final assessments of target groups.
- Conduct baseline and final assessments of target groups in line with the agreed timeframes.
Last reviewed: 12/5/2011