HACCP Becomes Law in Europe

February 2, 2006 -- An effective hygiene management system based on the principles of Hazard Analysis and Critical Control Point (HACCP) is now a legal requirement in every industrial operation involving the manufacture, preparation, treatment, processing, transport and storage of food in the European Union.

Originally devised jointly by Pillsbury and NASA in the early 1960s, HACCP was a discipline developed to ensure the safety of the foods which astronauts were to take into space. In today's food processing plant it is a technique for scrutinising food preparation processes to find out just where something might go wrong (hazard analysis) and at what stage in the process that imminent fault can first be detected (a critical control point). A "hazard" may be anything from a failure to attain the temperature and time necessary for pasteurisation, or the deterioration of a surface through abrasion such that it is no longer cleanable under the CIP procedures in operation, or the failure of a sensor to provide accurate readings — any defect which can have a direct influence on the hygiene of the product.

In operation, HACCP is a sophisticated system developed to help food producers to anticipate problems. Only if potential hazards have been identified and monitoring procedures have been installed to detect the moment that they occur can prompt corrective action be taken, quarantining unsafe product, rectifying the cause of the problem and bringing the plant back up to standard — and speed — with the minimum of delay. Originally designed to target threats to hygiene there is no doubt that HACCP can additionally reap considerable financial benefits by minimising wastage and downtime.

Until 1 January 2006, however, HACCP was good practice but optional. Now it is to become a legal obligation for all food businesses within the European Union (except primary producers such as farms and abattoirs, certain smaller "undertakings" such as restaurants) to meet the requirements of Article 5 of EC Regulation 852/2004 on the hygiene of foodstuffs. This will require them to implement permanent food safety management procedures based on the HACCP principles (together with the application of good hygiene practices) including the identification of hazards and critical control points, the establishment of critical limits, appropriate monitoring procedures and corrective actions as well as check procedures to verify the effectiveness of the system. Furthermore, it is to become obligatory to establish documents and records commensurate with the nature and size of the food business to demonstrate the effective application of the system.

In addition, Article 10 of the parallel EC Regulation 882/2004 on the official control of Regulation 852/2004 requires competent authorities to carry out routine surveillance which shall, for the first time, include inspection of materials intended to come into contact with the food. They must be "smooth, washable, corrosion-resistant and non-toxic."

Stainless steel is an ideal, and reliable, material for food-preparation equipment. It is smooth, and so resists the adhesion of soils and biofilms. Its hardness preserves this smoothness, which not only maintains its cleanability but also reduces friction between itself and dry food products which, in turn, minimises local temperature rises which can initiate and sustain microbial growth. Its corrosion resistance enables it to withstand strong cleaning agents and to maintain the reliability of process sensors. All in all, stainless steel is a significant asset in any plant undergoing the rigorous scrutiny of HACCP.


Regulation (EC) No. 852/2004 of the European Parliament and the Council on the hygiene of 
    foodstuffs. Official Journal L 139; 30 April 2004.

Regulation (EC) No. 882/2004 of the European Parliament and the Council on official controls 
    performed to ensure the verificiation of compliance with feed and food law, animal health and 
    animal welfare rules. Official Journal L 165; 30 April 2004.

-- By Eric Partington, a U.K.-based Consultant to the Nickel Institute.