A. Mancuso - HACCP and small food producing establishments – experience from Italy 1 HACCP AND...

A. Mancuso - HACCP and small food producing establishments – experience from Italy 1

HACCP AND SMALL FOOD

PRODUCING ESTABLISHMENTS –

EXPERIENCE FROM ITALY

HACCP AND SMALL FOOD

PRODUCING ESTABLISHMENTS –

EXPERIENCE FROM ITALY

Alberto Mancuso

Zagreb, 20 April 2009


HACCP implementation: in Italy, compulsory from 1997 (implementation of Directive 93/43)

The initial situation

• Large companies: apparently no need for support (adoption of Quality Systems)

• Small companies: almost nothing in place (despite several postponements…)

• But…Small establishments were (and are) the “excellence” of Italian food production

• Implementation of HACCP principles concomitant with the upgrading process

STARTING POINTSTARTING POINT


1. Guidelines for own-check implementation: stressed the importance of prerequisite

2. Training on own-check and HACCP principles

3. Guidelines on own check and HACCP assessment

4. Documentation: Check lists and templates

WHAT HAS BEEN DONE…WHAT HAS BEEN DONE…Starting

from 1997


Before to implement Haccp it’s required to have in place adequate prerequisite programs, which provide the basic

environmental and operating conditions that are necessary for the production of safe, wholesome food

GUIDELINES FOR OWN-CHECK IMPLEMENTATION

GUIDELINES FOR OWN-CHECK IMPLEMENTATION

• Cleaning and disinfections

• Grounds and Pest Control

• Construction (buildings, etc.)

• Water Supply

• Equipment – utensils

• Employee Hygiene

• Training

•Supplier Control

11


TRAINING ON HACCPTRAINING ON HACCP

• Translation of WHO manual on Haccp implementation

• Provided several training courses

• Practical training on Haccp assessment (“on the field”)

• Training at national level to obtain uniformity

• Adopted train the trainers system

Officials with responsibility for enforcement

Establishments with responsibility for implementation• Several meeting with stakeholders

• Developed training material

22


GUIDELINES ON HACCP ASSESSMENT, CHECK LISTS

GUIDELINES ON HACCP ASSESSMENT, CHECK LISTS

3-43-4

• Developed in parallel with Guidelines on HACCP implementation

• Addressed to Competent Authority

ESSENTIAL STEP IN ORDER TO OBTAIN THE SAME APPROACH AND TO CREATE A COMMON LANGUAGE FOR FBOs AND

COMPETENT AUTHORITY


SOME PROBLEMS…SOME PROBLEMS…

• Several Regional Departments, differences in implementation

• Old control system versus new: necessity to train inspectors

• Resistance: small business, typical production, inspectors…

• Lack of official guidelines at national level

• Inadequate dissemination of Guide to Good Hygienic Practice

• Guides dissemination not adequately supported by explanation of contents

Difficulties in small business and retail

Difficulties in small business and retail


FACTS AND FIGURESFACTS AND FIGURES

4.231.000 inhabitants

222

1 INSPECTOR FOR 19.000 INHABITANTS

2003

Number of inspectors

Non animal origin food sector

Number of official

veterinarians:

•Animal health: 254

•Food safety (food of animal origin): 174

•Residues control: 80


Large Small

Slaughterhouse 11 207

Slaughterhouse and cutting 45 95

Cutting 43 68

Storage (fresh meat) 21 116

Meat products 63 226

total 183 712

FACTS AND FIGURESFACTS AND FIGURES 2007

UNIT TO CONTROL: food of animal origin

UNIT TO CONTROL: food of animal origin

Around 4000 retailers (meat)


FACTS AND FIGURESFACTS AND FIGURES 2003

catering•Restaurants 25911

•Schools, Hospitals: 4513

distribution•retail: 16894

•wholesale: 2747

production•retail: 9092

•wholesale: 2004

61161TOTAL

UNIT TO CONTROL: food of non

animal origin

UNIT TO CONTROL: food of non

animal origin


2003Official control: resultsOfficial control: results

Unit

Controlled

n. Inspections

Units not in compliance

Non compliance

Fines

Court

63084

15923

20153

1660

1867 (9,3% of inspections)




Haccp principles implementationHaccp principles implementation

N. Controlled units

N. Non compliance

Warnings

Fines

14970

3544

3412

132

2003FACTS AND FIGURESFACTS AND FIGURES

23% non compliance


2003: ESTABLISHMENTS WHO HAVE INTRODUCED HACCP

2003: ESTABLISHMENTS WHO HAVE INTRODUCED HACCP

Successfully?Successfully?

DISTRIBUTION•Retail: 70%•Large supermarket: 100%

PRODUCTION•Small/medium: 80%•Large: 100%

CATERING•Schools, hospitals etc.: 100%•Restaurants, cafeteria etc: 70%


• HACCP implementation is not sided by application of new technologies in the plants

• Food business operators perceive HACCP implementation as useless and expensive

• Sanitarians consider HACCP as a useful tool for food safety, but are doubtful on practical implementation

REGIONAL SURVEY CARRIED OUT IN 2004REGIONAL SURVEY CARRIED OUT IN 2004

Poor knowledge of HACCP principles, lack of resources (particularly in small plants) and no

availability of national guidelines, affect negatively HACCP implementation

Poor knowledge of HACCP principles, lack of resources (particularly in small plants) and no

availability of national guidelines, affect negatively HACCP implementation


LA SITUAZIONE IN ITALIALA SITUAZIONE IN ITALIA

Recent development

GUIDES TO GOOD HYGIENE PRACTICE GUIDES TO GOOD HYGIENE PRACTICE

• Guides developed by food business associations supported by Official authority

• Official guideline on prerequisites and Haccp, on the basis of which to draft sector Guidelines

• Guides dissemination adequately supported by explanation of contents


MAIN PROBLEMSMAIN PROBLEMS

• HACCP implementation in small businesses

• FBO’s responsibility

OLD AND NEW MEMBER STATES, CANDIDATE COUNTRIES


HACCP AND SMALL BUSINESSES: NEXT STEPS IN THE EU??


reducing administrative burdens

Proposal for a Regulation 2007/0037 (6.3.2007)

Basis

Goal:

In certain food businesses food hygiene can be ensured by the correct implementation of the

food hygiene requirements without having recourse to the HACCP system




PROPOSAL

to exempt small food businesses able to control

food hygiene by implementing the other

requirements of Reg. 852/2004 from the

requirement to implementing and maintaining a

procedures based on the HACCP principles


• Adopt an appropriate approach on the basis of the visited establishment

• Consider HACCP principles bearing in mind the final objective: the production of safe food

• Essential is training of Inspectors and preparation of Guidelines

CONCLUSIONSCONCLUSIONS

Small businesses are different from large ones


Facilitation for small

businesses shall be included

in the Croatian legal

framework




•Manuals play an essential role

•Different Manuals should be prepared and adopted for large and small companies

If Manuals are lacking, HACCP implementation is nearly impossible in small establishments


What is a small business?

Fewer than 10 persons employed and no more than € 2M turnover? (Commission

Recommendation of 06/05/2003, micro-enterprises)

BUT…AN ESSENTIAL DEFINITION IS MISSING…

BUT…AN ESSENTIAL DEFINITION IS MISSING…


Slaughterhouse: red meat Slaughtering activity: less than 1000 adult cattle/year, or 20 adult cattle/week

Slaughterthouse:poultry Less than 150000 head per year

Cutting meat Fresh meat introduced in the establishment: less than 5 ton/week or 250 ton/year

Minced meat and meat preparation

Fresh meat introduced in the establishment: less than 5 ton/week or 250 ton/year

Meat products production Meat products: less than 7,5 ton/week

Milk products production Milk introduced: less than 500.000 litres/year

SMALL BUSINESSES: A PROPOSALSMALL BUSINESSES: A PROPOSAL

The definition must be included in the National legislation


• Community legislation does not contain a

requirement for HACCP procedures to be

certified e.g. under quality assurance schemes

• Assessment of HACCP carried out by

Competent Authority doesn’t mean approval of

procedure: validation is a task of the Company

KEEPING IN MIND THAT…KEEPING IN MIND THAT…


[email protected]

Thank you!

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