ISO 22000: a blessing or a curse?
What are the benefits and disadvantages of having a standard specifically designed for the food industry? Mary Duggan discusses the practicalities
The Registered Board of Assessors of Ireland (RBAI) was set up in 1998 to run ISO audits across different industries, focusing mainly on the food sector.
It recognized that there was a need for specialist audits for the food industry. The company now trains auditors and carries out external audits and third-party audits in Ireland.
Auditing food safety management systems
Much of RBAI’s work involves food safety management system (FSMS) audits. These audits are based on the hazard analysis critical control point (HACCP) system. RBAI Ltd audit to standards based on the codex 7 principles of HACCP.
The food company must have the HACCP PreRequisites Program (PRP) in place before setting up the HACCP system.
The PRP is an essential part of the FSMS being audited. The company must demonstrate its commitment to food safety and meeting legal requirements.
It is very important that food companies have the PRP. It must be in place (covering company policy and procedure, premises, cleaning, pest control, hygiene training and on the job training, traceability) to make a HACCP system effective.
In the working document ISO 22000 these areas are part of a food company's risk assessment.
A company’s FSMS is based on HACCP, so the auditor’s first job is to go through the company records and flow charts, and tour the plant. This helps the auditor find out basic information about food standards at the company. It establishes what processes are in place and how their documentation is organized.
Next the auditor can examine food hazard analysis and assess how the company chose its critical control points (CCP). The decision-making in the hazard analysis is vital for food safety, the HACCP team decides what steps or processes are critical in their company. The decision- making process should be documented and auditable.
It is important that food companies identify and control all hazards
within the company and that the member of the management team implementing
the FSMS must be given the authority and responsibility to enforce
this.
Some food companies identify a lot of critical control points which are technically quality control points. This happens when organizations are influenced by their customers or third party auditors.
Trouble shooting
If a complaint has been made and the root cause cannot be found, the answer could lie in how the problem was investigated. The company may not have analyzed each step for the three main classes of hazard, which are:
- physical hazards
- chemical hazards
- microbiological hazards
If the examiners only looked at the main hazard, which was identified straight away, other problems can be overlooked.
If the HACCP plan is part of a FSMS then all aspects of customer and legislative requirements must connect to the system.
If an employee has checked for a substance, the check must be documented in their hazard system.
Companies do keep records to show that products are analyzed for antibiotics; however, if these records do not connect into their hazard system, it will look like they have not performed the correct FSMS.
Ignorance about FSMSs can lead to serious problems. One example is an organization that was analyzing products for specific levels of a food additive. There are many additives used in food and consumers are unaware of the effects additives can have.
The food industry is responsible for ensuring that the food is safe. Thorough investigation into the effects of a chemical hazard added into a product and the maximum levels permitted in food is relevant in a FSMS.
A company may not know the maximum level of additives that are allowed in the food and rely on the laboratories that samples are sent to to inform them if additive levels are too high. This is not satisfactory.
High levels of additives will have different affects on health, which is why guidelines are set. However, the responsibility to keep to these guidelines belongs to the organization producing the product. The laboratories testing for the substance have no accountability.
Be prepared
Some companies are unprepared for their audits. One company visited would not let the auditor into the premises to inspect them. The auditor persisted and was eventually allowed in, although she had to wait for 45 minutes.
The same company had performed a hazard analysis and decided that there were no CCPs, so nothing was documented. In this situation auditing could not take place.
Making sure that all processes are documented within an organization ensures that a thorough audit can be done. Relying on an outside organisation for important information leads to a lack of central knowledge and then a full audit would have to incorporate outside organizations in a wider audit. This is not practical.
Recent improvements
Over the last decade the food industry’s confidence in hazard control has improved. Often at the beginning of their career, a person may think: ‘I hope I never have anything to do with HACCP’. Students on training courses seem to substantiate this view further, often finding HACCP very difficult to understand initially, until they sit down with a team and set up and implement the HACCP plan.
A FSMS is logical and simple to use. Most people already know a lot of food safety procedures and students at the beginning of a training course often have the right idea before they start. This is part of the reason why food businesses have been able to operate safely in the past.
When will the benefits show?
From starting the HACCP system, it takes six months for any company to really implement it and to follow on after that, but if you go back after three months it’s never fully implemented. However, an audit at this stage can provide the incentive to implement fully.
The HACCP plan must be kept up-to-date and reviewed at least annually.
The future of ISO 22000
The introduction of a standard specific to food safety is extremely beneficial. Risk analysis should be at the heart of food production companies. Companies should ask themselves the following questions:
- what can happen?
- how do I prevent it happening?
- if that goes wrong what can I do to put it right and stop it recurring?
The standard is now specific to the food industry but previously it was not. With existing standards such as ISO 15161 and ISO 9001, the HACCP plan was not the foundation of the system and was not easy for a food company to pick out.
In ISO 22000, the hazard analysis, risk assessment, flow diagrams and preventative measures are aimed directly at the food industry.
The future is simple
Many standards are not used because some companies think that they are too bureaucratic. ISO 22000 can be used to improve an organization.
The importance for the food industry is that all standards are HACCP based, otherwise they are not applicable.
Companies with ISO 9001 never had an advantage in the food industry.
Now, having ISO 22000, which is a risk-assessment based system like HACCP, means that a food company will have international recognition, and many companies will say: ‘I don’t need to do a supplier audit because they are achieving ISO 22000 standards’. It is a turning point in standard terms.
About the author
Mary Duggan is the training manager at
the Registered Board of Assessors of Ireland.
 |
|
 |
|
 |
 |
 |
|
 |
|
 |
|