All food business must have in place prerequisite programmes (PRPs). These are good hygiene practices that are the basic conditions and activities necessary to maintain a hygienic environment. PRPs with examples are listed below. You must also consider maintenance of the cold chain and allergen control when putting PRPs in place.
Controlling hazards with PRPs alone
Depending on the complexity of your food business operation, PRPs may be all that you need to comply with the HACCP requirement. For example, if your food business carries out low-risk activities, all the hazards may be controlled by the PRPs, with no need for the application of a full food safety management system based on the principles of HACCP.
PRPs as the basis of your food safety management system
For more complex food businesses that involve the preparation, manufacturing or processing of food, you will need to implement a food safety management system based on the seven principles of HACCP. You can do this by:
a) following a recognised guide to good practice appropriate to your food business (see section on Guidance below), or
b) developing procedures based on the principles of HACCP if required.
The majority of hazards can be controlled by PRPs, so they will be the foundation for the HACCP-based procedures that you implement. Once you have your PRPs in place, your HACCP-based procedures will focus on controlling the steps in your business which are critical to ensure the preparation of safe food.
For more information on the various options for complying with the HACCP requirement, see Guidance Note 11 Assessment of HACCP Compliance (Revision 2).
- Premises and Structure, e.g., design and lay-out of workspace allowing for one-direction production flow; sufficient lighting especially in food preparation and inspection areas; suitable employee facilities; hand-washing facilities; external and interior construction of walls, floors, doors
- Plant and Equipment, e.g., refrigeration services/systems; equipment fit for purpose, operated in accordance with its instructions and accessible for cleaning
- Technical maintenance and calibration
- Cleaning and sanitation
- Zoning, e.g., physical separation of activities to prevent cross contamination with allergens or biological hazards such as harmful microorganisms from raw to cooked food
- Procedures to control and prevent physical and chemical contamination from the production environment, e.g., what to do in the case of breakage of glass, hard plastic, etc.
- Supplier control, e.g., supplier selection and agreement on specifications for raw materials, additives, processing aids, packaging material, food contact material
- Services, e.g., water, ventilation, electricity, gas, etc.
- Storage, Distribution and Transport (including temperature control)
- Waste management
- Pest control (i.e., prevent entry of pests and implement suitable pest control program)
- Personnel hygiene and fitness to work, e.g., procedures for personnel suffering with gastro-intestinal infections, hepatitis, wounds or other relevant health problems
- Training and supervision
- Working instructions (i.e., provision of clear and simple work instructions which are visible or easily accessible)
Maintenance of the cold chain means making sure foods that require refrigeration or frozen storage are kept at the appropriate temperature. This is a legal requirement (Article 4(3) (d) of Regulation (EC) No 852/2004) and important to consider when implementing a number of PRPs, for example:
- operation and maintenance of refrigeration systems
- temperature control of raw materials supplied to your business
- storage, distribution, and transport of your product
The legislation does not stipulate storage temperatures for chilled and frozen food. In Ireland, recommended storage temperatures are given in national guides to good practice (see section on Guidance below). However, for certain foods of animal origin there are specific temperature requirements set out under Regulation (EC) No 853/2004.
There are 14 EU recognised allergens and controls must be put in place to prevent their unintentional presence in foods from cross-contamination. PRPs can be used to control allergens based on two approaches:
- by keeping allergens out of the premises through good supplier control, or
- by implementing strict measures to minimise the potential for cross-contamination.
Allergens may need to be considered as part of your food safety management system depending on the nature of your food business operation. If necessary, you should incorporate good practices and staff training to minimise or eliminate the potential for cross-contamination.
The National Standards Authority of Ireland (NSAI) has produced sector specific Irish Standards (I.S.) which provide guidance on complying with the food hygiene legislation, including PRPs and HACCP-based procedures, as well as giving advice on best practice. All food businesses are advised to use the appropriate standard for their sector (available at www.nsai.ie):
- I.S. 340:2007 - Hygiene in the Catering Sector
- I.S. 341:2007 - Hygiene in Food Retailing and Wholesaling
- I.S. 432:2010 - Packaged Groundwater
For processors, the following general standards may be helpful:
- I.S. EN ISO 22000:2018 - Food safety management systems
- ISO/TS 22002-1:2009 - Prerequisite programmes on food safety (available on ISO website)
The FSAI’s Safe Catering Pack is a tool to help caterers develop a system to manage food safety and comply with the food hygiene regulations.
The European Commission has published guidance on the implementation of food safety management systems covering prerequisite programs (PRPs) and procedures based on the HACCP principles, including the facilitation/flexibility of the implementation in certain food businesses. For further guidance, see Commission Notice on the implementation of food safety management systems covering Good Hygiene Practices and procedures based on the HACCP principles, including the facilitation/flexibility of the implementation in certain food businesses (2022/C 355/01; published on 16.9.2022).
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