Transcript No Slide Title

OFFICIAL CONTROLS
- An FBO Perspective
Dr. Josephine Head
Independent Advisor
AMI 43rd National Seminar
9th September 2007
Harper Adams
PRESENTATION CONTENT

Food Safety Conundrum

QC- Traditional Meat Inspection

HACCP

Risk Based Meat Inspection

QA -Food Safety Management Programme
Meat inspectors fit
Flawed risk assessment
FSA New Hygiene Measures
Industry Assurance Schemes

(Dis)-incentives

The Way Forward

Challenges
LEGISLATIVE PROMISE
 A holistic‘farm to fork’ risk-based approach
 Adoption of Codex Principles for all foods
 Founded in sound science
 Responsibility for safe production of food by food
producers
Food Safety Conundrum
Meat Industry Guide & MOC
MOC still detailed & prescriptive
Not science based
HACCP & Traditional Meat Inspection – a dog’s
breakfast
Risk based inspection not acceptable within the EU
framework
QC- Traditional Meat
Inspection
 False assurance ?
100% inspection and attendance
Meat plants not re-approved!?
QC inspection cannot manage food safety
Workforce outside FBO responsibility
Hinderance to improvement
Meat Inspection- The Facts

Carcasse Contamination
The majority of contamination is not visible
There is no correlation between visible contamination and
carcase hygiene
Measures to minimise visual contamination often increase
the microbiological load
Control cannot be achieved by post-processing inspection
Meat Inspection- The Facts –Post-mortem

Post-mortem of apparently healthy animals detects only 20%
of macroscopic lesions present in 1% of animals

Pathogenic organisms will be carried without any visible signs
(ante- or) post-mortem

Physical meat inspection is hygienically counterproductive
Incision of lymph nodes & palpation spread pathogens
Tonsil inspection spreads pathogens
Extensive cross-contamination of pathogens
(Salmonella on the meat inspectors kettle!)

Modified approach required by meat inspectors within an
integrated food safety management programme
Meat Inspection- The Facts
From EFSA 2004. Possible Findings on Post-Mortem
Inspection of carcasses of lamb and goats
HACCP
It is not: A silver bullet
It cannot:Guide managerial decisions on hazard nature and public
health impact
It is :
Define acceptable process outcomes
A systematic and practical approach to hazard control
Providing assurance of the quality of compliance with
regulatory requirements i.e. Not necessarily related to food
safety
It needs:To evolve to include Quantitative Risk Assessment (QRA)
HACCP Implementation- Pitfalls
•Divorced from H1,2,3 implementation
•Traditional Meat Inspection & HACCP – a dog’s
breakfast!
•Superimposed over existing practices & procedures
•Questionable validation
•Lack of science
•Lack of science-based knowledge (FBO & Enforcement)
•No incentive
FSA website/ HACCP success!
•Provides a microbiological baseline
•Provides a yardstick to measure improvements in
process hygiene resulting from HACCP.
•Demonstrates significant improvement in
microbiological carcase hygiene between 2002 and
2006 (due to HACCP implementation)
Risk Based Inspection Scientific Evidence
•First Scientific Evidence from Australian Experience
(Sumner, 1997) of QA based inspection benefits
•Risk-based observational approach
•Allocation of limited resources to maximise meat hygiene
•Significant improvement in hygiene
•Industry Partnership with Enforcement Body
Percentage of Positive Regulatory Samples in Broilers for
Salmonella in HIMP vs. Non-HIMP Plants
Non-HIMP Plants
18%
16%
14%
12%
10%
8%
6%
4%
2%
0%
HIMP Plants
16.9%
13.0% 13.3% 13.3%
14.1%
11.7%
11.1% 10.9%
10.5%
8.9%
8.4%
7.0%
8.5%
5.4%
2001 2002 2003 2004 2005 2006 2007
Calendar Year
QA-
HACCP – Based Food Safety
Management Programme (FSMP)
SUPPORT
PROGRAMME
Process Control
HACCP
Significant Hazards
& preventative
measures
CCPs
Valid Critical Limits
Validation
Verification
Pre-Requisite
Programme
Good Manufacturing or Best
Practice
Standard Operating
Procedures
Incorporating Test and
Measure Methods
Meat Inspectors compliance to
a FBO FSMP!?
Unknown:
Personal Health Status
Personal Hygiene
Protective clothing
Design
Laundry
Allergens (c.f.latex)
Training
Hygiene
HACCP
Auditing
Meat Inspectors compliance
to a FBO FSMP!?
Compliance:
Jewellery policy
Clean/dirty separation
Equipment hygiene
Scabbards
Canteen
Attitude
Corrective Action:
Procedure
Without recrimination
FSA Plant Approval Risk
Assessment - Flaws
•Audit Category II is currently a ceiling for
slaughterhouses
•No incentive for improvement
•Blanket score by nature of the business
•No incentive for improvement
•Larger plants incur a higher risk score
•Science suggests no higher throughput =
lower risk ( e.g. skilled single task operators)
•Should be risk/ performance based
FSA Project New Hygiene
Measures for
Slaughterhouses
 Science-based best practice COP
 Linear Integrated Safety Assurance (LISA)
Performance/Risk –based auditing by FBO
Verification by enforcement
 Link to risk-based enforcement
Independent Assurance
Schemes
 Based around compliance to existing sector specific
standards
EN45011accredited
Recognition required by FSA
Farm Assurance as a precedent
Slaughter COP to be integrated into sector
specific standards
Robustness of Accreditation and Certification
bodies
Include within FBO performance/risk-assessment
algorithm for meat inspection
Industry (Dis)Incentives
Quality
Costs( %
added value)
30
Failure
25
Appraisal
20
Prevention
15
10
5
<40%
40-70%
Compliance rate %
( ISO 9000 )
>70%
Industry Incentives
• Performance/ risk-based meat
inspection
•Recognition of independent assurance
schemes
The Way Forward
• FBO Responsibility
– Food Safety Management Programmes
– Science based LISA
– Plant specific process (inc.operational) guidance and
criteria (not just micro.) for continuous improvement
• Process profile validation guidance
• Carcasse chilling guidance
– Outcome based/Objective measurement
• Official Verification
– Rewards for compliance
– Penalties for critical non-compliance and persistent
non-compliance
Conclusions
• We all want the same thing – safe food
• Risk based food safety management
programmes (FSMPs) are the way forward
• FBO responsibility requires science-based
FSMPs
• FBO / Enforcement partnership
• Proportionate performance/ risk-based
inspection for verification
• Recognition of independent assurance schemes
Challenges of Reform- QC to
QA
From
To
Regulatory Approach
Command-and-control
Performance standards
Identification of Corrective
Action
MHS
Industry
Documentation
Not too important
Critical
Supervision of employees
Directing
Directing, coaching, supporting,
delegating
Atmosphere of organization
Isolated and individual
Teamwork and trust
Empowerment and accountability
Chain-of-command
Lowest possible level
Identity of MHS employees
Plant
Agency
Performance of MHS employees
Performance tied to plant
compliance
Performance independent of plant
compliance
Challenges
• Can the MHS respond to the need for change?
• Will the financial cost to Industry allow
sustainability?
• Will the FSA be successful in lifting the EU
barriers to change/ facilitate to risk based
inspection?