HACCP in the meat and poultry industry

R.B. Tompkin

An international consensus now existsfor the principles of HACCP and how they should be implemented. The relative roles of industry and regulatory agencies has been described. A generic flow diagram is outlined and briefly discussed. A questionnaire for use in HACCP verification is provided. A rationale is suggested for determining when HACCP should be mandatory. The transitionfrom theory to practice and regulatory involvement raises a varietyof issues, some of which are discussed.

Keywords: HACCP; poultry industry

INTRODUCTION HACCP combines prevention with detection at the steps in the food chain where problems are An international consensus has been reached on the most likely to occur. In the event that cohtrol is lost at a basic principles of HACCP and how they should be critical control point (CCP) it will be detected so that implemented. A consensus has also been reached on approriate corrective actions can be taken to prevent the definition of hazard. This is important because the unsafe food from reaching consumers (Tompkin, term ‘hazard’ defines the scope of HACCP. The 1992). Widespread adoption of HACCP by the meat current Codex definition of hazard is ‘the potential to and poultry industry should enhance consumer confi- cause harm. Hazards can be biological, chemical or dence in its products and reduce barriers to inter- physical’ (Codex, 1993~). This definition clearly places national trade. the focus of HACCP on food safety. The meat and poultry industry can, derive several Universal acceptance of HACCP is very important to benefits through the application of HACCP. Foremost the meat and poultry industry because an enormous among these is that HACCP is the mo$t cost-effective quantity of these products move in international com- management tool for producing th& safest foods merce. Reliance upon microbiological criteria at the possible with existing technology. A complete, port of entry cannot assure that foods are safe. properly developed HACCP plan can minimize or Realization of this fact led the International Commis- prevent the occurrence of food safety problems; sion on the Microbiological Safety of Foods (ICMSF) thereby maintaining consumer confidence and protect- to further develop and promote the use of HACCP ing the business. (ICMSF, 1988). After much debate and evaluation, The process of developing and maintaining a HACCP has now matured to the point where it can be HACCP plan is also educational. Appropriate plant promoted by industry and regulatory agencies alike. personnel must participate in the delvelopment and Both groups are becoming convinced that this approach maintenance of the HACCP plan becguse they know is more effective for assuring the safety of domestic and the limitations of the facility, equipmqnt, people and imported foods than relying upon traditional end- other factors. In the process, they should become more product testing to detect unsafe food. knowledgeable as they develop the plan with appro- The reason that HACCP is more effective is that the priate experts. Through detailed anal&s, steps in the emphasis of HACCP is upon prevention. In addition, process are identified which can impact upon product Armour Swift-Eekrich, 3131 Woodcreek Drive, Downers safety. Through this analysis, plant petsonnel become Grove, IL 60515, USA familiar with the real food safety issues and learn to

09!56-7135/94/03/0153-09 @ 1994 Butterworth-HeinemannLtd Food Control 1994 Volume 5 Number 3 153 HACCP in the meat and poultry industry: R.B. Tompkin

focus their efforts to minimize or prevent their occurr- wholesome’ to mean that the meat has passed inspec- ence. There are numerous demands for the time and tion and: attention of plant management and employees (e.g. profit, filling orders, product quality, increasing the (a) will not cause foodborne infection or intoxication rate of production). HACCP places into proper pers- when properly handled and prepared with respect pective the factors that are of the highest priority and to the intended use; that must be controlled. As active participants, plant (b) does not contain residues in excess of established personnel are more likely to assume ownership of the Codex limits; plan and see that it is correctly implemented. (c) is free of obvious contamination; When developing a HACCP plan, a generic HACCP (d) is free of defects that are generally recognized as plan can be used for guidance. The plant must objectionable to consumers; customize the plan to its own specific conditions, (e) has been produced under adequate hygiene however, because each HACCP plan must address the control; unique features of the plant’s process, equipment, (f) has not been treated with illegal substances as layout, people and other factors. specified in relevant national legislation. The use of HACCP for the meat and poultry industry must begin at the farm because certain safety concerns This definition is somewhat broader than the Codex cannot be eliminated during the slaughtering process. definition of hazard. It is clear, however, that the For example, chemical residues and certain microbial objective of HACCP and the Codex codes of practice pathogens (e.g. salmonellae, Cumpylobacter jejuni, for fresh meat and poultry do share a common goal, Escherichia coli 0157:H7) cannot be controlled without, safe foods for consumers. enlisting the help of producers. Eliminating these The application of HACCP in the meat and poultry human pathogens from farm animals is a long-term industry will be described in a very limited, generic objective. In the short term, companies with integrated sense. Figure I outlines a generic HACCP plan which operations may have more opportunity for controlling begins at the farm and ends with the shipping of a certain hazards than those who purchase livestock on vacuum-packaged cured sliced meat or poultry product the open market for slaughtering. from the plant. The flow diagram is adapted from Simonsen et al. (1987) and 1CMSF (1988). Although spore-forming pathogens (Clostridium botulinurn, APPLICATION OF THE PRINCIPLES OF C. perfringens, Bacillus cereus) and certain parasites HACCP must be controlled, the hazards of primary concern to humans in fresh meat have been microbial infectious The principles of HACCP have been described by agents. Information on the effect which the steps from Codex (1993c) and in this issue of Food Control by the farm through slaughtering have on salmonellae, E. Kaferstein (1994). Additional information is available coli 0157:H7, Campylobacter jejuni and Yersinia entero- from ICMSF (1988), NACMCF (1992), ILSI Europe colitica in meat and poultry has been described (1993) and others. ICMSF(1988) provides information (Simonsen et al., 1987; Kapperud, 1991; NACMCF, on the importance of plant layout, equipment design, 1994a, 1994b). Salmonellae, Y, enterocoliticu and cleaning and disinfecting, and employee health that is Trichinella spiralis; salmonellae and C. jejuni; and not available in the other documents. Codes of hygienic salmonellae and E. coli 0157:H7 are the pathogens of practice have been developed for the production of greatest importance to human health in raw pork, fresh meat and poultry (Codex, 1976, 1993a, 1993b) poultry and beef, respectively. and for processed meat and poultry products (Codex, As the association of Y. enterocolifica with raw pork 1986). An assessment of the microbiological hazards became recognized, particularly in Scandinavia, atten- associated with beef slaughtering and a generic tion has been given to reducing the risk of contamina- HACCP plan were recently developed by the US tion. Figure 2 is a flow diagram which shows the major National Advisory Committee on Microbiological sites of contamination of pork from production through Criteria for Foods (NACMCF, 1993). processing (Kapperud, 1991). Investigations are lead- Codex (1993a) has described HACCP as a scientific ing to recommendations to modify certain slaughtering approach to food safety and wholesomeness through- and inspection procedures (Kapperud, 1991). Some of out the production, processing and distribution of fresh these modifications also may reduce contamination of meat. Codex has endorsed the inclusion of HACCP pork with salmonellae. into the codes of practice and, also, the development of The hazards associated with meat and poultry specific HACCP systems tailored to the individual products may differ in various regions of the world. product, processing and distribution conditions of each These differences should result in HACCP plans which abattoir or establishment. The purpose of the Codex reflect the existing hazards. For example, the existence codes of practice has been to specify the conditions of pathogenic bioserotypes of Y. enterocolitica in raw required at each step in the process from production pork is of greater concern in cooler climates (e.g. through distribution that will assure that meat will be Scandinavia) than in countries where these specific safe and wholesome. Codex has defined ‘safe and bioserotypes are of lower risk. In another example, the

154 Food Control 1994 Volume 5 Number 3 HACCP in the meat and poultry industry: R.B. Tompkin

Contaubiated mtreame ??- CCP2 Pigs Purchaeed ?? and pasturer I from other farms v v v

Animal feed9 0

Transporting o to slaughter I Holding o I Stunning

Skinning ?? 4-CCP2 Scalding 44CP2 Scalding o ?-CCPZ? I I

Dehairing ?? Defeathering ?? I Singeing 4--CCP2 I Wamhfng 4--cCP2 Polimhing ?? I -w Evimcerating 0 4--CCP2 4 I Chilling 4-----cCPl I , , I Solocting Fremh Meat o 4--CCPl And Other Ingredientm I Injecting, Tumbling, Filling I Cooking +-CCPl

Chilling 0 4--CCPl I I Slicing, Packaging 0 14-CCP2

Storing, Dimtributing 4--ccP2

Fire 1 Flow diagram from farming to shipping sliced lunchmeat from a plant. Sites of contamination and control of human pathogens. ??, Major contamination; o, possible contamination; CCPl, effective CCP; CCP2, not absolute

rood Control 1994 Volume 51Number 3 155 HACCP in the meat and poultry industry: R.B. Tompkin

Brtifng C Rouing ] .-_1]

Tranxporting G holding

Stunning C Killing

Scalding C dohairing

I Singoing C polfxhing

’- ?? Ramovxl of intwtfnw ??

0 Excision of tongue -b C tonxilx

bpEEzy

cutting/Daboaing mvxl of head moat ??

1 ChillLag I I v

mod procommiag/preparation ??

Figure2 Flow diagram for production and processing of pork products. ?,? Sites where major contamination with Y. enferocoliticu 0:3 is expected to occur. Lnn. mandibulares, mandibular lymph nodes restrictions applied to control T.spiralis in pork correctly, providing a plant layout that favours micro- products in Europe and North America do not apply in bial control, and selecting equipment which is readily Australia where T.spiralis does not exist. cleanable and which minimizes contamination. The primary goal of farmers is to achieve efficient Research may be necessary to reduce contamination feed conversion and sufficient disease control to below current levels. For example, more improved, maintain a favourable health status and maximize the cost-effective technology is needed to hygienically growth rate of the animals. Human pathogens (e.g. remove feathers from poultry and hair from hogs. The salmonellae, C. jejuni) can be introduced into the second concept has been gaining increasing acceptance animal population from a variety of sources. The in recent years by industry and regulatory officials. potential for higher carrier rates of these pathogens can That is to include procedures (e.g. spraying with increase due to stress and crowding as the animals are organic acids) which can remove and/or destroy patho- collected in pens and transported to the slaughtering gens which inadvertently contaminate the carcass plant. Other factors (e.g. age of animals) also can during slaughtering (Dickson and Anderson, 1992). affect the carrier rates of human enteric pathogens. When properly designed and implemented these de- Chemicals (e.g. pesticides, antibiotics) used by farmers contamination procedures can enhance the safety of must be properly applied to avoid unacceptable residue fresh meat beyond that which can be accomplished levels in meat. The risk of chemical residues is best by relying solely upon preventing contamination. Addi- controlled through continuing education of farmers and tional research to develop more effective methods for an appropriate level of testing to verify compliance. decontamination should be encouraged by Codex and Two fundamental concepts must be considered national regulatory agencies. during the slaughtering process. First and foremost is After eviscerating and chilling, the carcasses often the use of procedures which will minimize the degree of are cut into various sections of meat. In the example of contamination on carcasses during the slaughtering Figure I, deboned meat is selected for processing into a process. This may involve training workers in cooked meat or poultry product. The species of meat the proper use of knives and equipment, providing (i.e. beef, pork, chicken) must agree with the ingre- adequate work space and time to perform each function dient statement on the package because some indi-

156 Food Control 1994 Volume 5 Number 3 HACCP in the meat and poultry industry: R.B. Tompkin viduals are sensitive to certain types of meat. For this (Codex, 1993~) should be modified to incorporate an reason species control is a CCP. A curing solution is important aspect of HACCP. As currently stated, the prepared and injected into the meat to achieve the emphasis of Principle 4 is on monitoring (i.e. checking) desired level of ingredients. The quantity of nitrite whether CCPs are under control. Instead, the results of added is a CCP because excessive quantities can be monitoring should be used to make adjustments in toxic to consumers. The level of nitrite can be con- processes to ‘prevent loss of control’, not ‘regain trolled through the use of a preblended nitrite-curing control’. If control has been lost, then a deviation will salt. Other measures also can be effective. Both the have occurred and specific corrective ‘action will be type of meat and the nitrite content can be effectively necessary (Principle 5). It is in Principle 4 that controlled (CCPl). detection and prevention are combined ‘to prevent loss In this example, the meat is tumbled under vacuum of control and deviations from occurring. in a chamber and then filled into a can, casing, mould It is necessary that educational materials begin to be or other container for cooking. The meat is heated based upon one common understanding #ofthe HACCP sufficiently to destroy non-spore-forming pathogens principles and definitions; otherwise, continued confu- and then chilled at a rate that will prevent the sion will be detrimental to the acceptance of HACCP. outgrowth of surviving spores. After chilling, the With recent agreement on the principles of HACCP product is removed from the container, sliced, vacuum- standardized teaching materials, such~ as the WHO packaged and placed into shipping cartons for storing document on training (WHO, 1993), can provide a and distributing. The packages and cartons are labelled uniform basis for educational programs on an inter- with appropriate statements (e.g. ‘keep refrigerated’) national level. to inform distributors, retailers and food handlers of The question of education raises the issue of certifi- the necessity for keeping the product cold. The condi- cation. Is it necessary or desirable to certify individuals tions of holding, slicing and packaging the ham after or processing facilities for having met certain basic cooking is critical to minimize the risk of contamination requirements? Should educational courses on HACCP with pathogens such as salmonellae and mono- be certified if they meet certain standards? Should the cytogenes. Experience indicates that post-process con- graduates of such courses be certified? Should food tamination with salmonellae can be prevented (CCPl) establishments be required to employ or have available (Tompkin and Borchert, 1992) whereas contamination for consultation a person who is certified in HACCP? with Listeria monocyfogenes can be minimized (CCP2) These issues must be resolved at a national rather than (Tompkin et al. 1992). The latter psychrotrophic an international level. pathogen is more difficult to control in the cooked Verification (Principle 6) is an important aspect of product environment. HACCP has been recommended HACCP. In fact, the major role of regulatory agencies to control L. monocytogenes and assure the safety of in facilities with HACCP plans should be to verify processed meat and poultry products (WHO, 1988; whether HACCP plans are complete, accurate and NACMCF, 1991; ICMSF, 1994). being correctly followed (NACMCF, 1994a, 1994b). Figure I contains four CCPs which can provide Periodic verification also is a responsibility of the effective control (CCPl). One involves formulating the HACCP team. Some companies have representatives product correctly to control the species of meat and the who visit facilities for periodic reviews. With so many quantity of nitrite. Another is for cooking because it groups involved in verification activities a standardized effectively destroys non-spore-forming pathogens. The checklist could be helpful. 7’uble I contains a general remaining two are for chilling. When properly con- questionaire which can be used to facilitate these trolled the chilling of carcasses is effective for prevent- reviews. The questionaire also can be helpful to the ing the multiplication of pathogens. The other involves HACCP team as it develops its HACCP plan(s) or chilling the cooked meat or poultry product. In this as it prepared for verification activities by outside case, the rate of chilling can be controlled to prevent inspectors. the outgrowth and multiplication of spore-forming pathogens which survive cooking. Physical hazards (e.g. metal, bone, plastic, wood, POTENTIAL PROBLEMS IN THE USE OF glass) must be controlled by applying preventive HACCP measures which minimize their introduction into the product via the raw materials and during the processing A number of issues must be resolved during the steps prior to cooking. Possible product contamination transition from traditional inspection ~to inspection of with metal can be monitored by passing the packaged meat and poultry facilities which have HACCP plans product through a metal detector. (Tompkin, 1990). One significant factor affecting the acceptance of HACCP by industry and government AREAS WHERE FURTHER INFORMATION inspectors is job security. As HACCP plans become OR STANDARDIZATION MAY BE implemented there is less emphasis on end-product’ HELPFUL inspection and testing. The responsibility for assuring product safety, and other product attributes, should Principle 4 of the current Codex document on HACCP shift to production personnel who actually monitor and

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Table 1 General questionaire for use in HACCP verification failure to acknowledge the existence and distinction Name of plant: between CCPl and CCP2 (ICMSF, 1988). A CCPl is a Date of review: CCP that will assure control of a hazard. A CCP2 is a Who is on the HACCP team? CCP that will minimize but cannot assure the control of Who is the HACCP team leader? a hazard. Thus, certain hazards can be minimized but Is there a HACCP plan for each process? Is there a flow diagram for each process? not prevented. Is a simple plant layout available? The new draft revised code of hygienic practice for Review the layout. Does the flow of product and people minimize fresh meat (Codex, 1993a) clearly states throughout the the possibility of cross-contamination? Who was responsible for identifying hazards and critical control document that some level of contamination will occur points (CCPs)? during the slaughtering process but conditions should Does that person qualify as an expert in hazard analysis for the be such that the contamination is held to a minimum. type of foods and food processes in the facility? Have critical limits been established for each CCP in each Thus, the Codex document fully recognizes the exist- HACCP plan? ence of CCP2 at many steps in the process of converting Who established the limits? live animals into fresh meat. The adoption of HACCP What rationale was used for the critical limits? Who approves a change in a CCP? Is the change documented? will not eliminate all hazards because current tech- Select a HACCP plan and review the current process flow. Does nology is inadequate to reach this desirable goal. The it agree with the HACCP plan? absence of an effective kill step (e.g. pasteurization, Who monitors the CCPs? Do they understand their role in the HACCP plan? cooking) during slaughtering means that raw meat and Is the monitoring done according to the plan? poultry may harbour some level of pathogens. The Are the results recorded? adoption of HACCP can lead to a reduction, but not Who verifies that the CCPS are being monitored correctly? Do the operators know the critical limits and when a deviation the elimination of enteric pathogens (i.e. salmonellae, occurs? C. jejuni, Y. enterocolitica, E. coli 0157:H7), spore- Do the operators know how to adjust the process to prevent a forming pathogens (e.g. C. botulinum, C. perfringens, deviation or does this occur automatically? What happens when a deviation occurs? B. cereu.s) and certain parasites. Thus, proper handling Is a plan in place to address deviations at each CCP? and preparation of meat and poultry products by the How is management notified of a deviation? food preparer is essential for food safety. Are corrective actions for deviations recorded? Is a deviation log book or similar central record being main- Recognition that carcasses may harbour microbial tained? pathogens has led some to believe that rapid tests are Who is responsible for making decisions on corrective actions? needed to detect pathogens on carcasses. Such tests Where are the HACCP plan records maintained? Are the records available for verification (can they be seen and could qualify as monitoring procedures if the results reviewed)? become available before the carcasses are shipped from Are all records pertaining to CCPs available? the plant. This presumably would permit the processor Where and how long are they kept? Who is responsible for maintaining the records? to subject carcasses which test positive to some addi- Is the effectiveness of the HACCP plan verified by any physical, tional process to eliminate the pathogens or, perhaps, chemical or microbiological testing? divert the meat to a processor who would use the meat Who collects and interprets the data from tests which are performed for verification? in a cooked product. This approach, however, over- Who receives the test results? looks the weakness that no feasible sampling plan can Do the plant manager and his/her staff understand the HACCP guarantee the absence of a pathogen. Also, in the event concept and support the plant’s HACCP system? Are those who are directly involved with CCPs adequately that an enteric pathogen is found, then how many trained? carcasses must be diverted? Which carcasses are Who is responsible for training? unacceptable - those that were tested, all carcasses Does the plant have someone on staff who has attended a course in HACCP? from the same farm or all the carcasses processed that On the basis of your review is the HACCP plan complete, hour, shift or day? The long-term solution to enteric accurate and being correctly followed? pathogens lies not in testing carcasses but in controlling Do you have any recommendations for correction or improve- ment? the pathogens at the farm plus impoved technology during slaughtering. Other problems must be resolved as HACCP control the process. The role of traditional inspectors becomes more widely adopted. As HACCP becomes should shift toward verification activities. This can incorporated into the regulatory inspection process result in fewer inspectors being required in plants that there will be disagreements over whether certain have effective HACCP plans. This could result in hazards of potential significance are likely to occur in a significant changes in the meat and poultry industry process and whether certain steps in the process are which, in many countries, traditionally has received CCPs. These debates will be influenced by existing more intensive regulatory inspection than other food knowledge and the conservative nature of the parties industries. involved. A second significant issue in the meat and poultry Decisions over the risk of a hazard and whether a industry concerns expectations. As the potential value processing step is a CCP are best made by an ‘expert in of HACCP becomes more widely recognized, there is a hazard analysis’. These experts are individuals with the tendency to oversell the benefits of HACCP, particu- knowledge and experience to correctly: (a) identify larly to consumers and legislators. This stems from potential hazards; (b) assign levels of severity and risk;

158 Food Control 1994 Volume 5 Number 3 HACCP in the meat and poultry industry: R.B. Tompkin

(c) recommend controls, criteria and procedures for conclusion that under a zero tolerance for carcass monitoring and verification; (d) recommend appro- contamination none of the steps in the slaughtering priate corrective actions when a deviation occurs; process are CCPs. (e) recommend research related to the HACCP plan if The answer to question 2 of the decision tree also can important information is not known; and (f) predict the lead to another conclusion depending on one’s view of success of the HACCP plan (NACMCF, 1992). Unfor- ‘specifically designed’. Many of the steps in the tunately, at this time there is an insufficient number of slaughtering process can be controlled to minimize experts in hazard analysis available to assist in the contamination even though they may not be ‘specific- development and assessment of HACCP plans. ally designed’ to do so. Since these steps are not Wider use of HACCP will result from supplier- ‘specifically designed’ to eliminate or reduce contami- buyer relationships. Some buyers of meat and poultry nation with enteric pathogens, the answer to question 2 products now require the use of HACCP plans by is no (Q2 = no). The response to question 3 is yes suppliers; perhaps, even requesting that suppliers (Q3 = yes). The decision tree would suggest that the submit a copy of their HACCP plan. Such a request is contamination which may occur at these steps is of unacceptable for two reasons. First, HACCP plans are little, or no, concern because a subsequent step (i.e. unique to each operating facility and are of value only cooking) will eliminate the hazard of exaessive levels of when reviewed for accuracy and completeness during a enteric pathogens on carcass meat. Thus, the steps in visit to the plant. Second, HACCP plans contain slaughtering which are not ‘specifically designed’ to important proprietary information concerning the eliminate or reduce contamination with enteric patho- plant’s operating procedure. Careless or unethical gens are not CCPs. Perhaps this was the intended result sharing of the HACCP plan with other potential of those who designed the decision tree. On the other suppliers could occur. HACCP plans should be avail- hand, since these steps are not CCPs they may receive able for buyer review only at the plant. less attention and, thus, less effort to control the level The generic HACCP plan as described above and in of contamination. Figure I shows eviscerating as a CCP. In reality there Two variations of question 4 of the Codex decision are many steps involved between when the hide, hair or tree have been proposed which place even greater feathers are removed and when the carcass is chilled. emphasis on the role (i.e. responsibility) of the Thus, decisions should be made whether any of these consumer for eliminating the hazards associated with steps are CCPs. The Codex HACCP decision tree contamination that may occur during slaughtering. One which was developed to help decide whether the steps asks, ‘will subsequent processing inaluding correct in a process (e.g. slaughtering) are CCPs can lead to consumer use, guarantee removal of the hazard or debatable results. The first question the decision tree reduction to a level regarded as safe?‘, (Mayes, 1992). asks is whether preventative measures exist. The The other asks ‘will subsequent processing stages response should be, yes, measures do exist to minimize including expected consumer use, guaradtee removal of contamination (Ql=yes). The second question is the hazard or reduction to an acceptable level?’ (ILSI pivotal with the answer depending upon one’s view of Europe, 1993). This is unfortunate because control an ‘acceptable level’. It is possible to specifically design should be exercised wherever possible during various and control certain steps in the slaughtering process to steps in the slaughtering process to minimize contami- minimize carcass contamination with enteric patho- nation, even though cooking by the consumer will kill gens. The acceptable level should be the minimum level enteric pathogens. The potential for cross contamina- that can be consistently achieved for a facility when the tion from raw meat and poultry to ready to eat foods in process is under control. The acceptable level in one the kitchen must be considered. The higher the level of facility may differ from another facility. Failure to contamination during slaughtering, the #greater the risk control a specific step could result in a higher level of of subsequent cross contamination. Furthermore, the carcass contamination. In agreement with the Codex burden of food safety should not be shifted dispropor- code of hygienic practice for fresh meat (Codex 1993a) tionately from the producer and processor to the the conditions should be such that the level of contami- consumer. nation is held to a minimum. Thus, it must be It is evident that ‘acceptable level’ and ‘specifically concluded that certain steps in the slaughtering process designed’ in question 2 of the decision tree are key can be CCPs (Q2=yes). This conclusion should be the phrases influencing the decision whether a step in the one favoured by most proponents of HACCP, includ- slaughtering process is a CCP. It is the intention of ing those who are redrafting the code of hygienic HACCP to focus on the steps which are CCPs because practice for fresh meats. they are of greatest concern to food; safety. If it is If, on the other hand, an unrealistic position is taken concluded that certain steps in slaughtering are not that no contamination is acceptable, then the answer to CCPs, even though contamination can be minimized, question 2 becomes no (Q2 = no). Under a zero then HACCP will not achieve its potential of improved tolerance, any contamination at a step would be in food safety. The use of the Codex decision tree is excess of the acceptable level (Q3 = yes). Since a optional and is intended to facilitate the identification subsequent step (i.e. cooking) can eliminate the hazard of CCPs. If used, the decision tree shoqld be used with of enteric pathogens (Q4 = yes), this could lead to the caution and not taken literally as has been done in this

Food Control 1994 Volume 5 INumber 3 159 HACCP in the meat and poultry industry: R.B. Tompkin

paper. A thorough understanding of the goals and national authorities have responded by imposing principles of HACCP should be the overriding guide appropriate regulations. The regulations are usually when deciding whether a step in a process is a CCP. targeted for a specific step or steps (e.g. cooking, chilling, labelling, separating raw meat from cooked products) in the process where control must be applied ROLE OF GOVERNMENT AGENCIES to prevent . Thus, certain aspects of HACCP are already in place through national regula- The role of government agencies has been described by tions. Updating regulations in reponse to newly recog- the NACMCF (1994a). An early draft of this report nized problems will continue to be necessary to assure was provided to the WHO Consultation on HACCP food safety. Training (WHO, 1993). For a variety of reasons the The scope of HACCP and HACCP plans is limited to NACMCF did not fully address the specific issue of food safety. One of the most contentious issues of whether HACCP should be voluntary or mandatory. HACCP is the availability of records to regulatory This issue, however, could be approached through the agencies. Record-keeping is an essential aspect of same logic used by Codex, and others, for deciding HACCP. Industry is responsible for producing safe whether microbiological criteria should be established food products. Regulatory agencies are responsible for for a food. Codex states that, ‘the purpose of micro- verifying that industry is producing safe meat and biological criteria for foods is to protect the health of poultry products. To fulfil their responsibilities of the consumer by providing safe, sound and wholesome verification, regulatory agencies which are responsible products and to meet the requirements of fair practices for meat or poultry inspection must have access to in trade’ (Codex, 1989). Codex also states that, ‘a those records which pertain to the HACCP plan. This microbiological criterion should be established and would include, for example, the HACCP plan and applied only where there is a definite need for it and records which pertain to CCPs, deviations, corrective where it can be shown to be effective and practical’. actions, revalidations and the training and education of Furthermore, to fulfil the purpose of microbiological individuals who are involved in implementing the criteria, Codex recommended that consideration be HACCP plan. given to: Another significant issue is whether regulatory agen- cies should preapprove HACCP plans. In general, it is the evidence of hazard to health; unrealistic to expect regulatory agencies to preapprove the microbiology of the raw material; HACCP plans. Such a requirement would be adminis- the effect of processing on the microbiology of the tratively and economically burdensome. If preapproval food; is deemed necessary, this practice should be limited to the likelihood and consequences of microbial selected processes which involve hazards of high risk contamination and/or growth during subsequent and severity. A policy of regulatory preapproval handling and storage; ignores the fact that HACCP plans are documents the category of consumer at risk; which are unique to each specific plant and must be the cost/benefit ratio associated with the applica- verified on site for accuracy and completeness. Also, it tion of the criterion. is normal that changes (e.g. method of processing, location, equipment, establishment layout, reorganiza- The purpose of HACCP is to protect the health of the tion of management structure and responsibilities) will consumer by providing safe products. Similar to micro- occur. Thus, HACCP plans must be dynamic and biological criteria, HACCP should be mandatory only reflect the changes as they occur. where there is a definite need for it and where it can be shown to be effective and practical. HACCP is used to control chemical, physical and biological hazards in food. Thus, to fulfil the purpose of HACCP, considera- REFERENCES tion should be given to: Codex(1976) Recommended International Code of Hygienic Practice for Poultry Processing CACIRCP 14-1976, ?? the evidence of hazard to health; Commission, FAO, Rome ?? the expected hazards associated with the raw Codex (1986) Recommended International Code of Hygienic Practice materials; for Processed Meat and Poultry products CAC/RCP13-1976, Rev. ?? the effect of processing on expected hazards; 1 (1985) Codex Alimentarius Commission, Joint FAO/WHO Food Standards Programme, FAO, Rome ?? the likelihood and consequences of food safety Codex (1989) Principles for the establishment and application of hazards during subsequent handling and storage; microbiologicalcriteria for foods. CAC Procedural Manual 7th ?? the category of consumer at risk; Edn, Codex Alimentarius Commission, FAO, Rome ?? the cost/benefit ratio associated with the applica- Codex (1993a) Draft revised code of hygienic practice for fresh meat. tion of HACCP. In: Report of the 7th Session of the Codex Committee on Meat Hygiene Alinorm 93/16A, Codex Alimentarius Commission, FAO, Rome, pp. 32-57 In most instances if a specific process has been found to Codex (1993b) Draft revised code for ante-mortem and post-mortem be linked with repeated instances of foodborne illness, inspection of slaughter animals and for ante-mortem and post-

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