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FAQ about Food Safety Programmes

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Food Safety Programme Resource Folder	06/03

Here are some frequently asked questions relating to the implementation and approval of Food Safety Programmes (FSP's). For information on HACCP and Food Safety Programmes, please read the publications "An introduction to HACCP" and "What does a Food Safety Programme Look Like?" These publications are available from your local Public Health Unit or the New Zealand Food Safety Authority.

This information has been compiled by the Processed Foods and Retail Sale Group, New Zealand Food Safety Authority.

How do I deal with hazards that re-occur throughout the process?

It is up to the individual premises to determine the best way to do this for their process. There are two possible options, a) state the hazard at each step it occurs or b) state the hazard and that it reoccurs through out the whole process e.g. potential for microbiological contamination from pests. The second option may help prevent duplicate work and ending up with an unnecessarily large document.

An issue noted in some FSP applications is that hazard identification has not been documented for controls that occur process wide (for example pest control, personal hygiene, maintenance and cleaning). Only the controls are given in a procedural format. To ensure that the controls are adequate it is important that all hazards reasonably likely to occur (even with reoccurring hazards) are documented.

I am having problems determining CCP's. Can you give me some guidance?

The CCP decision tree detailed in the codex document is somewhat confusing and can lead to numerous CCP's being determined. Therefore we suggest that the decision tree is not used for less complex food production systems and the following guidelines are used to determine CCP's.

A CCP should have the following characteristics:

• A control measure can be applied
• It is somehow essential or critical to achieving a safe food outcome
• It is specifically designed to eliminate or reduce contaminate levels
• There is no subsequent step at which control can be successfully applied to eliminate or reduce the likely occurrence of a hazard to an acceptable level

Some useful tips for selecting CCPs:

• Ensure that the CCP relates to food safety. Do not use the CCP approach for other quality characteristics.
• Ensure that the hazard can actually be controlled (eliminated or reduced) by the measures applied at the CCP.
• Preferred CCPs tend to be those for which the critical limits are numeric and objective.
• CCPs should not be used for measures such as personal hygiene, environmental control or correct technique (can be exceptions to this)
• Consider the cumulative nature of control measures to prevent or minimise hazards.
• If the operational characteristics of a reliable process well exceed what would be required in a critical limit then it should not be a CCP. For example, if frying bacon until crisp.

It should be noted that whenever a control measure is treated as a CCP, there is a real obligation to document the monitoring against the critical limits. So you need to be prepared to do them.

We also suggest things such as;

• Cleaning
• Maintenance
• Insect and rodent control
• Operating methods

are not treated as CCP's. Although they may be essential to control, we find they are best handled by basic procedures, supported by training and good supervision.

We suggest things such as:

• Refrigeration
• Cooking
• Acidity and water activity levels
• Visual checks of incoming materials

are treated as CCP's and critical limits, monitoring, and corrective actions are established accordingly.

We find if these "guidelines" are followed, programmes tend to be more practical and free from undue paperwork.

Why do I need to get my Programme audited within 28 days of getting it approved?

If a Food Safety Programme is approved (and given an exemption from the Food Hygiene Regulations) by the NZFSA, then it must be audited within 28 days. This is important because although the NZFSA's staff will consider the suitability of the Programme, generally their scrutiny will be limited to a review of the written systems, and not take into account whether the Programme works in practice. That is the job of the Auditor.

It is important that this audit occurs without too much delay. The NZFSA have established a 28 day rule and request that businesses arrange for the audit to take place as soon as possible after receiving notice of exemption.

Should I get the Audit done prior to applying for approval from the Ministry?

There is good sense in getting the food safety audit done first. It may avoid some costs from the Public Health Unit as well as avoid problems with the 28 day issue.

Any audit must be performed by a person who is registered for that purpose and the Public Health Unit has a list of those that are available.

How often do I need to have an external audit?

The frequency is usually once per year. But this can vary depending on the process; you will be informed on your frequency when you receive your exemption.

What happens if I change my process after my exemption is granted?

If you plan change your process or introduce a new process you need to inform your local Health Protection Officer. If it is decided that the change may impact on food safety they will request further from you (ie HACCP worksheets for the new food product) and assess that information. An external audit may also be required.

Where can I get further help?

Your local Health Protection Officer can answer general questions, let you know if your FSP is on the right track and supply NZFSA publications and updates.

Contact your local Health Protection Officer at your nearest Public Health Unit:

http://www.nzfsa.govt.nz/processed-food-retail-sale/food-complaints/public-health-units.htm

Your local Health Protection Officer can also supply you with a list of food safety consultants who can aid with the development of your FSP. You may also wish to contact your industry association; they may be developing a code of practice to help their members develop own their FSP.

Will Food Safety Programmes be made mandatory in New Zealand?

The development and implementation of FSP's in New Zealand food premises is optional at present. The NZFSA are working towards setting the framework around making FSPs mandatory. This framework will include a lead in period, and time frames varying depending on the risk of the product.