Food Control 36 (2014) 132e137

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Food Control
journal homepage: www.elsevier.com/locate/foodcont

HACCP in small food businesses e The Polish experience

W. Dzwolak*
Chair of Dairy Technology and Quality Management, Faculty of Food Science, University of Warmia and Mazury, ul. Oczapowskiego 7, 10-957 Olsztyn, Poland

a r t i c l e i n f o
Article history: Received 23 November 2011 Received in revised form 19 July 2013 Accepted 27 July 2013 Keywords: Food safety management Small businesses HACCP principles HACCP documentation

a b s t r a c t
The specicity of small organizations (i.e. limited human, nancial and technical resources) within the food sector results in problems with adopting the Codex HACCP model used in medium and large-sized businesses. In Poland, it is additionally hindered by the use of a model system mostly based on rigid adherence to quality management protocols based on the ISO 9001 standard. This paper presents how some of the Polish small and/or less-developed food businesses have implemented some elements of the HACCP system. Several practical solutions focusing on the simplication of some system areas such as ow diagrams, hazard analysis, documented procedures and records are described. Moreover, the possibility of applying the GMP/GHP Manual instead of the typical procedures/instructions is presented. 2013 Elsevier Ltd. All rights reserved.

1. Introduction Limitations relating to the nances and technical, information and human resources existing in small organizations of the food sector are a serious hindrance to the implementation of the Codex HACCP principles in this group of food businesses (FAO/WHO, 2006). The main barriers hindering the implementation of the HACCP system in small businesses involves a lack of understanding of the need for system documentation (Holt & Henson, 2000), a lack of qualied staff for the system implementation, insufcient skills for the assessment of the qualications of an external consultant who is employed for the HACCP implementation (Karipidis, Athanassiadis, Aggelopoulos, & Giompliakis, 2009), limitations relating to qualied and experienced staff (Taylor, 2001) as well as a low level of knowledge of food safety relating to the control of microbiological hazards (Walker, Pritchard, & Forsythe, 2003). Most of these and other problems identied in small and other businesses in recent years (Celaya et al., 2007; Fielding, Ellis, Clayton, & Peters, 2011; Garayoa, Vitas, Dez-Leturia, & Garca-Jaln, 2011; Holt & Henson, 2000; Lowe & Taylor, 2013; J.Z. Taylor, 2008; Violaris, Bridges, & Bridges, 2008; Wallace, Powell, Holyoak, & Dykes, 2012; Yapp & Fairman, 2005, 2006) conrm the difculties anticipated by WHO in the late 1990s (WHO, 1999). Flexibility in the HACCP approach to certain small food businesses is recommended in point 15 of the regulation (EC) No 852/ 2004 on the hygiene of foodstuffs (EU, 2004). Such exibility is much more developed in the guidance document of the EC Health &
* Tel./fax: 48 89 523 44 72. E-mail address: waldekdz@uwm.edu.pl. 0956-7135/$ e see front matter 2013 Elsevier Ltd. All rights reserved. http://dx.doi.org/10.1016/j.foodcont.2013.07.043

Consumer Protection Directorate-General (EU, 2005) and also in the FAO/WHO guidance to governments on the application of HACCP in small and/or less-developed food businesses (FAO/WHO 2006). More specic and more useful guidelines on the implementation of Codex HACCP principles in small businesses were formulated by Taylor and Kane (2005) and extended in the Salford Model developed by FSA and successfully used in numerous British food businesses (FSA, 2006a, 2006b; E. Taylor, 2008). Although the HACCP principles have been compulsory in the Polish food sector since 2001 (RP, 2001), small food businesses have been obliged to use HACCP since 2004 (RP, 2003), which was determined by Polands accession to EU. However, before and after the accession, the implementation of HACCP in small food businesses was insufcient (Konecka-Matyjek, Turlejska, Pelzner, & Szponar, 2005; _ Traa1ek & Ko1ozyn-Krajewska, 2011). In the beginning of compulsory HACCP implementation in Poland within the small businesses sector, the most common practice was to adopt the HACCP models developed earlier in large- and medium-size businesses based on the 12-step method (CAC, 2003). At the end of 1990s, in many large and medium-sized Polish businesses the Quality Management System (QMS) according to ISO 9001 standard (ISO, 2008) and HACCP rules were simultaneously implemented. The models of HACCP in these plants were based on the documenting procedures adapted from ISO 9001 which also included HACCP elements. Although many of the HACCP guidelines were developed within the framework of PHARE1
1 Poland and Hungary Assistance for Restructuring their Economies projects operated from 1989 till 2007 and was a pre-accession instrument for the European Communitys nancial and technical cooperation with the countries of Central and Eastern Europe.

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projects and published by the Foundation of Assistance Programmes for Agriculture (FAPA),2 most of the guidelines available in Poland were published both by the trade and/or commercial organizations. In spite of the fact that most of the guidelines were evaluated by the Chief Sanitary Inspectorate (CSI),3 the practical usefulness of the plans in small food businesses was very limited. CSI did not evaluate the factual content of these texts, but only the conformance with the hygiene standards detailed by the Polish food regulations. Therefore, the guidelines in these publications were sometimes insufcient for development and implementation of the HACCP system, especially by the small food businesses. Nevertheless, relying on the experience of food businesses as well as on a exible approach to HACCP and system documentation, in some Polish small food businesses some reasonable solutions have been elaborated to account for the specicity of small organizations. The aim of this paper was to present how HACCP was interpreted in Poland in the past and how, at present, the main solutions enable implementation of the HACCP principles in some small Polish food businesses. 2. Practical approach HACCP documentation is an element which greatly determines the effective implementation of the system (Mortimore, 2001) and has long been perceived as the main cause of system failure (Mitchell, 1998). There are many books, articles and guidelines that help food businesses understand the HACCP principles and documentation requirements. In many Polish food businesses that have been simultaneously implementing the ISO 9001 standard and HACCP for years, the main source of general information on system documentation has been the technical report ISO/TR 10013 (ISO, 2001) which presents some of general rules on developing the Quality Manual and procedures/instructions in the QMS. As could be expected, this practice was a hindrance for further HACCP implementation in Poland since these models were later adopted also by small businesses that did not implement ISO 9001 (Dzwolak, 2012). The product description, ow diagrams, a hazard analysis sheet, documented procedures/instructions and records are identied in the Polish food sector as the most extended parts of the HACCP documentation hindering the implementation of this system (Dzwolak, 2012). For this reason, small Polish food businesses have attempted to modify and/or simplify these elements so the modications will not impair food safety and will remain in accordance with Codex HACCP principles and support and improve the food safety system. 2.1. HACCP manual In the case of HACCP documentation, Polish businesses most commonly implement a model which consists of the HACCP Manual as the core document; its content and structure resembles the Quality Manual in QMS based on ISO 9001. This model is applied especially with the implementation of food safety management systems according to such standards as BRC (BRC, 2012), IFS (IFS, 2012) and ISO 22000 (ISO, 2005). In relation to the content of the document presenting the application of HACCP principles in the Polish food businesses there were three main options developed as presented in Table 1. Options

A and B represent an approach to the HACCP adopted from the large businesses implementing QMS according to the ISO 9001 standard. The third option (C) is applicable to small food businesses and it is an example of a exible approach not related to ISO 9001 in which the contents are limited to the key elements of the HACCP plan according to the best international practices. 2.2. Catering service description The product description as a part of the HACCP plan may be signicantly reduced if groups of products with similar characteristics are established and only food safety aspects are described (WHO, 1999). Moreover, in some Polish food businesses such as catering businesses, in the product description approach, the menu items may be used and/or any documented formulas/recipes may be applied as reference documents complementing product de_ scriptions (Dzwolak & Zuraw, 2003). In the past, as a result of a misunderstanding of CAC FAO/WHO HACCP guidelines (CAC, 2003), some Polish businesses developed the product description with duplication of information already existing in internal documentation such as recipes, specications, etc. This part of the system documentation was therefore needlessly extended. In recent years, in order to avoid these problems, instead of a product description some Polish caterers have introduced a Catering Service Description (CSD) which presents a list of prepared dishes and drinks (i.e. menu items), a short description of the catering process, identication of consumer groups, a description of the dish serving, etc. (Dzwolak, 2012). 2.3. Process packs The majority of the Polish food businesses prepare ow diagrams using the set of graphical symbols described in ISO 5807 standard (ISO, 1985). Although that option very much hinders the development of ow diagrams for those not familiar with the ISO symbols, it is still the most commonly used form in Poland. Nevertheless, many businesses did not apply this method of graphical presentation and they use simple ow diagrams without ISO symbols (Dzwolak, 2012; _ Dzwolak & Zuraw, 2003). Since the enlargement of the HACCP plan caused by numerous ow diagrams is cumbersome even after grouping the products together, some of the food businesses (catering, bakeries, meat products, etc.) developed an optional method of graphical presentation using the process concept adopted from QMS. The key element of this approach is the assumption that during the production of every foodstuff it is possible to dene a few generic Process Packs (PP) by grouping two or more technological operations and/or activities with proper interactions (Fig. 1). The obtained relationship diagram may be enriched with additional information on operations/activities within every element of the PP. Applying the PP caution needs to be applied during the hazard analysis to ensure that all hazards at all process steps are identied and evaluated, thus, sufcient detail within each Process Pack is essential. 2.4. Hazard analysis worksheet A typical HACCP worksheet in which every production step is analysed for food safety hazards (CAC, 2003), sometimes may overdocument this part of the system, even if products are assigned to product groups (Dzwolak, 2012). This element is especially enlarged when there are a wide range of products, many production steps included in ow diagrams and when food safety hazards re-occur. To assure elimination of such recurrences, the modied Hazard Analysis Worksheet (HAW) may be very useful. The modication consists of identication of the hazards or their groups and then assigning a proper process step to every food safety hazard or

2 FAPA was established in 1992 by the Minister of Agriculture and Food Industry acting within the framework of PHARE funds. The foundation supports the initiatives aimed at developing rural areas, agriculture, agricultural markets and agriculture-associated sectors. 3 The list of recommended guide books is available at CSI website: www.gis.gov.pl.

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Table 1 Possible contents of HACCP manual in small Polish food businesses. Option A              
a

B denitions, company presentation, HACCP/food safety Policy, scope, HACCP/food safety team description, authorities & responsibilities, product description, layout of food premises, ow diagrams, decision tree/description of quantication system, hazard analysis and CCP identication sheet, monitoring and corrective actions sheet, quality/food safety control loopsa (optional), a list of procedures/instructions (optional).            denitions, company presentation, HACCP/food safety Policy, scope, HACCP/food safety team description, product description, layout of food premises, ow diagrams, decision tree/description of quantication system, hazard analysis and CCP identication sheet, monitoring and corrective actions.

C      HACCP/food safety team description (optional), product description (optional), ow diagrams, hazard analysis and CCP identication sheet, monitoring and corrective actions sheet.

A ow diagram illustrating the monitoring, critical limits and corrective actions.

group (Table 2). However, such modication must be applied very carefully and only by an experienced HACCP team to assure identication all hazards that occur in the analysed process step. 2.5. Procedures and instructions In Polish small and medium food businesses, most of the operational documents are divided into two groups: general procedures _ and detailed instructions (Dzwolak & Zuraw, 2003). In the past, this model caused much confusion within small businesses and during the last decade some of the food businesses used only one of the two groups of documents. The classical procedure model used in Polish businesses is based on the structure and format based on ISO/TR 10013 (ISO, 2001), in spite of the fact that, according to international practice, the ISO Standards are not usually used to determine how HACCP documentation should be formulated. In the practice of many Polish food businesses, the classical ISO structure is complicated by adding several additional elements (Table 3), leading to an undesirable extension of the procedure (Dzwolak, _ 2012; Dzwolak & Zuraw, 2003). As was shown in earlier studies _ (Dzwolak & Zuraw, 2003), the majority of documentation users ignore most of the structural elements listed in Table 3, such as purpose, scope, authorities and responsibilities, etc. The users of procedures/instructions omit these points, since the information they contain very often results from the content of Description of activities. Thus, some of the Polish businesses use a simplied

procedure/instruction structure which is limited to the title, description of activities and attachments (Table 3), which results in the development of shorter and more user-friendly procedures/ instructions. 2.6. GMP/GHP manual GMP/GHP Manual is a system document which was developed in a majority of Polish food businesses in the 1990s when the HACCP and documented GMP/GHP were voluntary and there were only a few Polish ofcial food laws available specifying GMP/GHP requirements. Due to the limited number of legal acts detailing GMP/GHP requirements and the lack of documented operational procedures, Polish businesses started to develop documents titled GMP/GHP Manual or GMP/GHP Programme. Such kind of interactive document included a detailed description of the target and current GMP/GHP state strictly referring to the specic conditions _ of a given food business (Dzwolak & Zuraw, 2003). With the changing sanitary and/or technical level of the business, the GMP/ GHP Manual was continuously updated until the target GMP/GHP state was reached. Due to interactive function of this document, some of the Polish food businesses, especially the small ones, started to treat the GMP/GHP Manual as an alternative to GMP/ GHP procedures/instructions developed on the pattern of ISO 9001 _ documentation (Dzwolak & Zuraw, 2003). 2.7. Recording by exceptions In a food business, registering every acceptable and unacceptable state of a monitored parameter generates a signicant number of records. This is very burdensome, especially for small businesses where many records are made manually. A signicant facilitation in recording is possible by the application the concept of management by exceptions recommended by FAO/WHO experts (FAO/WHO, 2006). Although this concept has been wellknown for many years and is a part of the Safer Food Better Business packages (FSA, 2006a, 2006b), in Polish organizations within the food sector, this form of recording is very rarely practiced. However, in some of the small food businesses where recording by exceptions is applied, only non-conforming parameters initiating corrective actions and/or corrections are recorded (Dzwolak, 2012). Due to the limitations of the concept, consisting in the difculty to prove that monitoring has been carried out, recording by exceptions requires reliable supervision of employees by their superiors.

Fig. 1. An example of the Process Packs for baking products.

W. Dzwolak / Food Control 36 (2014) 132e137 Table 2 Example of a modied Hazard Analysis Worksheet for a restaurant (food preparation area). Food safety hazard and source Physical contamination (foreign materials e stones, pests etc.) e raw materials, pests Physical contamination (metal shavings from equipment) e kitchen equipment and machines Survival of vegetative microbial pathogens e meats, sh etc. Process step Receiving of raw materials and components Storage of raw materials and components Peeling Cutting Grinding, mincing, milling, grating Frying Baking, Grilling, Stewing All operations connected with the direct contact of the employees with food or food contact surfaces Control measure Visual inspection of receiving raw materials and other foods 1. Pest control procedure 2. Housekeeping procedure Visual inspection of work surfaces before and after using the equipment/tools Temperature control - use a probe thermometer to check core temp. (target level 75  C)

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CCP e e e

CCP

Physical contamination (personal items) e employees

Complying with a personal hygiene procedures (clothes, jewelry etc.)

3. Discussion In Poland, an approach based on excessively detailed documentation of the HACCP system has three major causes. The rst results from following the method of recording typical of ISO 9001, which was a common practice in the 1990s. The second cause is related to a need for simultaneous documentation not only of HACCP principles, but also GMP/GHP which even at the beginning of 2000s had not been comprehensively documented. The third cause is the difculty in differentiating between food safety and food quality assurance/management encountered in the past in Poland (Konecka-Matyjek et al., 2005). Thus, the HACCP documentation, in which food safety is mixed with food quality, is far from user-friendly documentation, especially in the case of a broad assortment of manufactured products. By partial misunderstanding the product description concept, most of the Polish food businesses developed a very extensive technological description rather than a brief characteristic of food safety aspects. The product description constitutes the part of HACCP documentation which considerably increases due to the (often unjustied) joining of food safety with food quality. Exclusion of quality aspects from a product description is an obvious way of reducing at least part of a product description. If some of the product descriptions repeat information on a product already presented in recipes, specications or Standard Operating Procedures (SOPs) and even in legal regulations (Gamza-Micha1owska & Korczak, 2008; Gamza-Micha1owska, Nowak, & Korczak, 2011), these descriptions unnecessarily produce the large volume of HACCP system documentation. In this context, in the case of some links in the food chain, such as catering, it is reasonable to implement one Catering Service Description (CSD) instead of numerous product descriptions for individual or grouped menu items. The use of CSD is only possible when a business has internal documents

Table 3 The structure of procedures/instructions used in Polish food businesses. Old             title, purpose, scope/application, denitions & abbreviations, authorities & responsibilities, description of activities, records, related documents, references, attachments, distribution, amendments. New      title, denitions & abbreviations (optional), description of activities, records (optional), attachments.

that describe properties or manufacturing procedures of the products (i.e. specications, recipes, SOPs etc.) to which references can be made in CSD. If there is a lack of such documents, CSD does not ensure a correct hazard analysis and therefore a product description can be replaced with CSD only in some catering businesses. Until recently, the preparation of ow diagrams with product grouping was quite common in Poland and resulted from the fact that in Poland there were numerous manuals and books on HACCP published by commercial businesses which, in many cases, were not subject to factual verication and, therefore, contained some distortions and conceptual misunderstandings (Dzwolak, 2012). For many years, examples of ow diagram for food products have been available in many books, guidelines and research papers on the HACCP principles implementation (Gamza-Micha1owska & Korczak, 2008; Leaper, 1997; Mortimore & Wallace, 1998; WHO, 1997). Dillon and Grifth (2006) described a method developed by the American Society of Mechanical Engineers (ASME) where all production stages were graphically presented in a special table with seven dened criteria (i.e. time, temperature, action, transport, holding, inspection and storage). Despite the signicant informative value of this approach to describing production procedures, the ASME method is rarely used during HACCP implementation in Poland. In comparison with the modular ow diagrams widely used in HACCP documentation, the form of presenting food production by proposed Process Packs is easier to develop and update. Moreover, the application of the process approach in this part of the system documentation signicantly simplies the graphical presentation of the production process and is better perceived by documentation users (Dzwolak, 2012). Process packs enable the reduction of the ow diagram in some cases by more than half (Dzwolak, 2012). However, it should be emphasized that this method of visualization strongly depends on the experience of employees developing the HACCP plan and, if it is insufcient, there is a risk of an incomplete hazard analysis. In the area of the hazard analysis, there are available some examples of modication of this part of the HACCP system, including such proposals as a model for analysis of hygienic risks HYGRAM coupled with the program for HACCP documentation (Tuominen, Hielm, Aarnisalo, Raaska, & Maijala, 2003) and the quantity approach to HACCP based on the fault tree analysis (Bertolini, Rizzi, & Bevilacqua, 2007; Park & Lee, 2009). The described modication of the Hazard Analysis Worksheet (Table 2) by assigning process steps to identied food safety hazards and/or groups of hazards may signicantly reduce this part of the HACCP plan. As in the PP approach, this modication requires a high level of experience and if the HACCP team lacks sufcient experience, such simplication carries the risk of missing hazards. Therefore, both the PP approach

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and the modied HAW may be used only in Polish businesses that have several years of experience in the maintenance and/or improvement of the HACCP system or food safety management systems based on the Codex HACCP principles. GMP/GHP Manuals were used in medium and large-sized Polish food businesses until the mid-2000s, whereas in small food businesses this document has been used until present. This is particularly true for plants which gradually, yet systematically, have adjusted food premises to GMP/GHP requirements. The GMP/GHP Manual is constantly updated with introduced changes, modernization, repairs, etc. If an analysed element of the GMP/GHP is not met, the phrase should be is used, whereas after implementation of changes (repairs, etc.), when a GMP/GHP requirement is fullled, this phrase is replaced with is/are. In this way, the GMP/GHP Manual is simultaneously a specic map of all activities that adjust food premises to GMP/GHP requirements. Thanks to the simple form and limited volume of this document, it is much more userfriendly than ISO-structured procedures/instructions, which makes the GMP/GHP Manual more suitable for small businesses (Dzwolak, 2012). The records resulting from production processes, good practices and HACCP principles are identied by some authors as a factor hindering the effective implementation of the HACCP system (Shih & Wang, 2011; Taylor & Kane, 2005). The recording by exceptions described in this paper signicantly reduces the time of recording, which has been identied as an important factor hindering the implementation of HACCP (Walker et al., 2003). Furthermore, it reduces the number and quantity of all records and additionally facilitates analysis of the records and preparation of input data for management review during implementation of ISO 22000, BRC or IFS standards. However, a factor limiting such an approach to recording is the diligence of workers, since absolving the employees of responsibility for recording each state of monitored parameters may lead to a situation in which some of the workers would not follow the frequency of monitoring. Therefore, it is very important to frequently organize short training sessions to help the workers realize the important impact of accurate and reliable monitoring on the level of food safety. The initial observations have revealed that the proposed simplications of some parts of the HACCP system documentation have one signicant limitation, i.e. the technical knowledge and experience of the HACCP team, which was reported by other authors (Taylor, 2001; Walker et al., 2003; Wallace, Powell, & Holyoak, 2005; Wallace et al., 2012) as an important barrier to implementation of HACCP principles. With a low level of technical knowledge and experience (which is quite common in small businesses), there is a risk of incomplete identication of food safety hazards. However, with the minimum support of external experts and ofcial food control authorities, the presented modications would enable full control of all food safety hazards. This kind of cooperation with local food control authorities was identied by Conter et al. (2007) as a particularly important factor supporting small food businesses and in providing up-to-date information on food law. Hielm, Tuominem, Aarnisalo, Raaska, and Maijala (2006) emphasized the role of external experts and public food control ofcers in overcoming the conceptual barriers of HACCP implementation. These authors suggested that ensuring the same quality level of HACCP training modules in both groups was essential for the effectiveness of this support. The presented modications of some elements of the HACCP documentation have only been applied in some small Polish catering businesses, bakeries, fruit and vegetable processing plants, sugar producing plants and manufacturers of functional additives within the framework of the initial studies. In the businesses which introduced the above-mentioned simplications, all observed food

safety criteria for the analysed products stayed at the same level that was achieved before the modications to the HACCP documentation. However, the complete evaluation of the efcacy of presented solutions will be subject to further observation and analysis which, in the near future, will become a scope of studies covering a wider range of sectors of the Polish food industry. 4. Summary The presented descriptions of practical and exible approach to HACCP principles may be useful for, at least partially, overcoming the problem of over-documenting of the HACCP system, especially in small food businesses. At the present time, in Polish food businesses the Codex HACCP principles are implemented in accordance with the best international practices supervised by the ofcial food control authorities (i.e. the National Sanitary Inspection and Veterinary Inspection). The discussed simplications of the HACCP system documentation are not an alternative to Codex HACCP principles, but are another form of presentation of some areas of HACCP system documentation which may be applicable to small food businesses. The presented solutions may be applied both as a single solution or as a combination of two or more solutions depending on the specicity of the businesses, as long as food safety is not deteriorated. All decisions relating to the intended scope of the modications must be agreed with the food control authorities in order to avoid the risk of lowering the food safety level. However, since the presented proposals include specic conditions of small food businesses in Poland, they may not necessarily be suitable for implementation in other countries. Acknowledgments The author is grateful to all food safety managers for cooperation, an open-minded attitude and information relating to documentation solutions used in HACCP systems and food safety systems based on HACCP principles. References
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