Would the implementation of HACCP-based food safety control procedures become a blow to small food producers?
Today, this matter caused strong discussions among small food producers, owners and managers of food service establishments, experts and simply consumers.
Even though the acronym “НАССР” has recently become increasingly popular and is being mentioned in mass media more and more often, the meaning of this system is not always conveyed correctly. Therefore, it is important to explain what the НАССР system is and why businesses and consumers need it.
The system of hazard analysis and critical control points (НАССР) means correct organization of production and ancillary processes, continuous analysis of reasons for mistakes and determining methods of fixing them in order to avoid the repetition of these mistakes in the future.
Such an approach allows to single out among all processes the ones which are critical for safety, and focus on controlling them. It allows for efficient use and redistribution of resources without wasting efforts on processes of secondary importance.
The НАССР system helps identify hazardous foods early at the production stage, not when they are sold to consumers off food store shelves or at a restaurant table.
In other words, НАССР allows to avoid losses, damages and poisonings.
European producers and consumers have long understood that.
The requirement to implement the НАССР system means implementation of the world’s best practices applied in almost 80 countries of the world. In the EU, in particular, the implementation of the НАССР system is obligatory for all operators regardless of the type and size of production.
Moreover, this requirement also concerns the countries where the share of small producers is substantial (Austria, Italy, Spain), because НАССР is an efficient and extremely flexible system.
Historically, НАССР systems in Ukraine were implemented, for many years, only at large, export-oriented enterprises. This situation gave birth to a whole number of myths which scare small producers, creating in them strong distaste of that “bureaucratic and burdensome system which only wants money and serves as an instrument of pressuring them by controlling authorities or by customers”.
We shall try to dispel these myths and prove that the НАССР system is an efficient instrument in the enterprise’s daily operations aimed at improving its performance.
Myth 1: НАССР is a system designed for large enterprises only
The phrase “НАССР-based procedures” written in the Law of Ukraine No 771 on the Main Principles of and Requirements to Food Safety and Quality means that market operators are not obliged to implement this system in its entirety. They can implement only the procedures pertinent to their activity.
It means that small producers or producers with simple processes may only analyze the technology, optimize certain areas of their business, and most importantly, develop and keep only the truly important documents, and that should suffice.
In other words, a small confectionery café is not required to implement the same НАССР system as required for a confectionery factory. In the former case, everything is much simpler and the compliance with hygienic requirements only would be enough.
Myth 2: НАССР is suitable only for new enterprises with good infrastructure
This stereotype was born for two reasons.
Firstly, in the past, when НАССР wasn’t a legislative requirement, it was implemented mostly by exporters on demand of their customers, i.e., by enterprises with modern infrastructure.
Infrastructure is more important for a large enterprise with a lot of complex equipment and materials and a large number of personnel, whereas a small producer may correctly organize its production process even in existing conditions.
In EU states with their requirements of food legislation, for example, there are thousands of enterprises which have been successfully operating for several decades.
Secondly, it became a consequence of using certifications based on voluntary standards, such as BRC, IFS, FSSC 22000, which have stricter requirements to infrastructure.
As for legislative requirements, everything is simpler in this respect. One has to correctly organize business processes, keep facilities in the proper state, and ensure proper operation of equipment.
It can be achieved even if infrastructure is obsolete; the most important thing is to analyze mistakes. Again, the law does not require НАССР certification!
Myth 3: НАССР is a bureaucratic procedure and a burden for small producers
This stereotype was born mainly because of the efforts of some unscrupulous certification authorities and consultants, for whom it was important to issue more certificates rather than to implement procedures and make them effective.
Their efforts are aimed at developing documentation only. The absence of knowledge of НАССР principles leads to increasing requirements to documentation and its volume.
In fact, however, documentation serves only as a proof of the effectiveness of НАССР, but not the only proof. It is important for small producers to remember that the knowledge of processes and their correct implementation represents the main proof of the system’s effectiveness, and only nonconformities should be documented in order to analyze the reasons that caused them and find out how to solve the problem.
But how it works in reality?
When implementing legislative requirements concerning НАССР, a producer must ensure compliance with hygienic requirements and НАССР-based procedures.
Hygienic requirements concern infrastructure, planning and organization of production environment (the state of facilities, equipment, water discharge and sewage system, lighting, personal hygiene, etc.), which means that they could be potentially more costly. However, legislation has always required, and requires now, compliance with the rules of hygiene in food production.
НАССР-based procedures comprise a scheme for verification by the market operator of how effectively hygienic requirements and technological parameters of production are applied. This is an instrument of self-evaluation and a method of identifying critical (in terms of safety) stages of the production process. The implementation of these procedures requires knowledge and understanding, but almost no investments in infrastructure.
What does the implementation of НАССР give to small producers?
First of all, production of safe foods, avoidance of expenses related to utilization of non-conformant batches, optimization of processes and economic effect as a result, a system oriented toward particular enterprise, compliance with legislative requirements, consumer and customer trust, expansion of sales markets, export opportunities (even if in small volumes only).
The advantages for consumers from implementing НАССР are even more undisputable. First of all, this is food safety.
What would happen if НАССР procedures are not implemented?
Increasing risk of harming consumers (if we recall a number of food poisonings at food service establishments, not to mention schools and kindergartens where children eat…), deterioration of relationships with partners, no need to analyze mistakes, and as a result, absence of improvement, formalized approach to the compliance with requirements of law.
On top of that, noncompliance with the EU legislation with which Ukrainian food legislation must be harmonized according to the Association Agreement, would have negative consequences for the opening of the EU market to small and medium-sized producers.
Finally, small producers are accorded by law the longest transitional period to implement НАССР: 5 years.
The guidelines and recommendations for small businesses concerning implementation of НАССР-based procedures, describing the algorithm of implementing these simple yet efficient procedures, are planned for publication in the nearest future.
Therefore, while charging every operator of the food market with responsibility for food safety within the scope of that operator’s activity, the new food legislation provides them with an efficient controlling instrument: НАССР-based procedures.
Yurii Ohlashennyi, expert in food safety and development of the agro-industrial sector at the Project of Improving Legislation, Control and Awareness in the Fields of Food Safety, Health and Animal Wellbeing in Ukraine financed by the EU;
Kateryna Onul, a World Bank Group advisor on food legislation
Zhanna Pastovenska, expert in the EU legislation at the Project of Improving Legislation, Control and Awareness in the Fields of Food Safety, Health and Animal Wellbeing in Ukraine financed by the EU.
Source: European Pravda