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Is there any 'HARM' in 'HACCP'?
A number of companies in the packaging industry have been asked to send a member of the
management team on a HACCP course. It is now around 25 years since the relevance
of HACCP outside of food manufacture was challenged. The clue to the outcome
of that debate is the use of the term HARM (Hazard and Risk Management) in BRC Standards, other than the
there a significant difference between HARM and HACCP? When, in 2012, I authored the chapter
dealing with hazard and risk management in “Packaging technology – Fundamentals, materials and processes”
(Woodhead Publishing, 2012, ISBN978-1-84569-665-8) HACCP was seldom cited. Whilst the methodologies employed
in HARM and HACCP are similar in many respects, the differences may outweigh the similarities.
Potential hazards to consumer health
and wellbeing associated with food and drink are well recognised and the importance of acknowledging these and striving to
minimise the likelihood of occurrence is beyond challenge. It is scarcely a breakthrough in thinking to
state that, generally speaking, hazards and risks of that magnitude are not associated with food packaging. ‘Risk
Management’ in the broader commercial context covers a wide range of issues and concerns. These include,
among other things, preserving brand reputation, minimising financial exposure and avoidance of incidents/events likely to
compromise production or distribution. Each of these apply equally to all industry sectors, including those
deemed to be hygiene sensitive. HARM has the potential to be all-encompassing whereas HACCP is, quite correctly,
narrowly focused. Moreover, the application of HACCP has always been problematic in the matter of criticality;
that is, in identifying the threshold where a hazard/risk conundrum becomes critical. This can be especially
perplexing when the subject of decision-making is not food.
Thus, it might be argued, outside of food processing and manufacture, HARM is the
logical approach, especially if it is specified in the management standard to which a company is certificated or wishes to
aspire. However, if you try to find a training course in HARM your search will
find a plethora of training related to Health and Safety, but few directed at HARM in the context
of this text. I have delivered more HACCP courses than I can (or care to) remember,
mainly to packaging, laundry and medical device manufacture. Perhaps it is time
to reassess this and seek to develop HARM courses, with a broader curriculum, that could more appropriate to companies
outside of food manufacture, and more valuable to their trainees.
To answer the question in the title of this piece,
there may not be enough HARM in HACCP.
TACCP - Threat Analysis Critical
Some thoughts from Matt Ewart
What, you might be asking, is TACCP?
Threat Analysis Critical Control Point has been around since 2008 when the first Publicly Available Specification (PAS)
was first developed by the Centre for the Protection of National Infrastructure (CPNI) and The British Standards Institution
(BSI). The current PAS dealing with TACCP is known as PAS 96, published in 2010. It
is available free of charge from the BSI web site. Note that this document does not constitute a British
If you are reading this, it is likely that your primary interest is in
packaging manufacture. Thus the second question might be “Is this relevant to my industry?”
It is difficult to escape the conclusion that technical requirements starting in the food industry have a tendency
to migrate to packaging. There is, therefore, merit in at least being aware of what TACCP is, and having
an overview of it.
The first and obvious aspect is the hint that it might be rather akin to HACCP, given the similarities of the acronyms.
Indeed, the next reasonable question might be “How does TACCP relate to HACCP?” It is
apparent from various blogs and comments that opinion is divided. The application of HACCP as part of any
management system requires procedures for crisis management. The debate is made more intriguing by the
assertion on one side that TACCP is intended to be anticipatory and preventative/deterrent. Crisis management
systems tend to be mainly responsive.
Further complexity might be
seen in the term ‘Critical Control Point’. When HACCP was first applied, at a time when interpretation
of what was entailed and required was less that clear, over-complex systems were almost the norm. In time
greater clarity emerged, not least because of the separation of ‘hygiene’ from ‘HACCP’, brought about
by the concept of prerequisites. Another factor was the recognition that unless control of a parameter
was possible, describing that control as critical was palpable nonsense.
External threats, be they
for financial gain (such as blackmail which has been experienced from time-to-time by retailers) or terrorism directed toward
causing harm to a manufacturer and/or their consumers are difficult to anticipate, far less, control. Thus
the concept of criticality must to some extent be questioned. That’s not to say TACCP should
be dismissed or set-aside. In fact PAS 96 expects that most of the provisions of the document will be built-in
to existing protocols. This is common sense and should make the pill easier to swallow.
Another aspect noted in PAS 96 is that malicious threats are a developing problem.
Thus it can be said that review and revision of Crisis and Threat Management (CTM – is this another new acronym?)
documentation and supporting infrastructure (physical and electronic security) may need to be more frequent than is currently
common for other safety-related parts of a management system.
TACCP is something we cannot ignore. Some packaging companies may already be experiencing audits
where the topic is raised. It is apparent that it will be included in the next edition of the BRC food
standard. The packaging standard might well follow.
Has The Packaging Industry Gone To Far With Hygiene?
The packaging industry was first obliged to take account of food safety, and the
implications that arose from this, back in 1990. This was a requirement for which packaging manufacturers were ill prepared.
In addition, and this has been said many times, the pressure from the food industry came with the inevitable baggage of high-risk
manufacture. It has always been clear that the risks to food safety likely to arise from packaging and packaging materials
are extremely low. To express this differently, the cynicism with which we often regard the zeal displayed by health and safety
specialists might equally be directed at the emphasis placed on hygiene in packaging manufacture.
This is not to say that proper hygiene
management does not have a place in the packaging industry. Apart from the direct reasons for implementing management
systems, the collateral effect of improved working conditions and staff attitudes has had considerable benefits.
Rather, it might be that in being guided in compliance with technical standards (such as ISO22000 or the BRC Packaging Standard)
companies have tended to adopt a distinctly precautionary approach.
Some relaxation may be in order, at least in some cases. Personnel
rules, for example, can lead to the very cynicism mentioned above. Are gloves, or hats, or other protective garments
really necessary in the majority of circumstances? I am not aware of any instances of food safety breaches in the era
before today’s high level of control was present in the industry. Can pest prevention and control not simply be
left to a competent contractor? Are highly detailed cleaning records really useful, or would credible schedules and
a simple, regular, inspection suffice?
More questions could doubtless be added to the above list.
Similarly, training courses in hygiene
management for packaging manufacture may have played a part by lifting the topic beyond what the risks involved really justify.
More than half a training day spent on the subject of food poisoning bacteria does seem excessive. The niceties of pest
prevention and control are fascinating but in practice companies use competent contractors. Indeed, the technical standards
require them to do so. Protracted training sessions dealing with the topic may not be easy to justify.
is probably no reason why training in hygiene for managers in the packaging industry should take more than one day, especially
if it is supported by simple documented guidance that can be referred to when required.
I would welcome thoughts or comments on any of the above texts.
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