SQMI Information Sheet 2 - Food Safety Programmes

The area of Food Safety Programs (Chapter 3.2.1) is one that will continue to require further clarification. Under Chapter 3 of the Food Standards Code, a food safety programme at some level will be a requirement for any business at which “substantial transformation “of the product occurs. This definition of “food business” will therefore include transporters, processors, wholesalers, retailers and restaurants.

Under Chapter 4 of the Food Standards Code, primary producers who produce a low risk product and do not significantly alter their products will not have to implement a food safety program. Their requirements will be summarised in the Primary Production and Processing Standard for Seafood, which will be gazetted in 2005.

In reality, it is more likely that commercial considerations could come into play, bearing in mind that Hazard Analysis Critical Control Point (HACCP) and food safety are often used as commercial tools. If a primary producer wants to supply some of the larger retail outlets or wants to have product sent to a number of the Eastern States (who look likely to adopt the original model, whereby everybody needed to have a food safety plan), the buyers may demand evidence that the primary producer is an “approved supplier”.

Background:

As we are all aware, the food industry is currently going through a period of rapid change - changing requirements to supply large retail food outlets, changing food regulations, the question of Quality Assurance, as well as a stronger media and consumer focus on food safety. To enable effective decision-making on these issues, the food industry, and seafood industry in particular needs to understand why these changes are occurring and what will be their impact.

New Approach:

Recent high profile incidents involving food safety have focussed consumers' attention firmly on this issue. It is no longer appropriate to assume that everything is alright with the product you are producing. We live in changing times and one of those changes is that we need to adopt preventative risk management practices for our food products.

Traditionally, food safety has been determined through end product testing. This form of reactive control has proved costly and ineffective. To reverse the increasing incidences of food-borne illness, the new approach to managing food safety must be proactive and based on prevention, not relying on end product testing.

New Food Regulations:

The proposed national food hygiene regulations will take a common sense approach by requiring food businesses to demonstrate that they are handling food safely. This will protect both businesses and consumers.

Under the proposed legislation, food businesses must have documented evidence to demonstrate in a court of law that they have taken care to produce safe food. Consumers will be protected from food poisoning as food will only be produced by businesses that have a system in place to handle food safely.

The proposed national food hygiene regulations consists of the following Food Safety Standards:

Standard 3.1.1 Interpretation and Application

Standard 3.2.1 Food Safety Programs

Standard 3.2.2 Food Safety Practices & General Requirements

Standard 3.2.3 Food Premises & Equipment

Standard 3.2.1 Food Safety Programs

The food safety program must:

• Systematically identify the potential hazards that may be reasonably expected to occur in all food handling operations of the food business;
• Identify where, in a food handling operation, each hazard identified can be controlled and the means of control;
• Provide for systematic monitoring of those controls;
• Provide for appropriate corrective action when a hazard is found not to be under control;
• Provide for the regular review of the program by the food business to ensure its adequacy; and
• Provide appropriate records to be made and kept by the food business.

The food safety program is to be

• Described fully in a written document
• Maintained on site
• Reviewed annually to ensure its adequacy, and
• Audits of the program are to be completed by a Food Safety Auditor

"What does this mean to my business?"

To be able to answer this question, you must first understand what constitutes a food safety program. A food safety program is a documented system that details how a food business is going to maintain premises and staff hygiene, and manage food safety during ingredient receipt, food preparation, storage and delivery. For the majority of the industry, a food safety program may comprise of:

• Documented food hygiene training requirements (commensurate with work activities);
• Written documents demonstrating compliance to food safety practices, premises and equipment requirements (i.e. maintaining hygiene);
• A risk management approach to food safety (a HACCP plan) (see SQMI Information Sheet 3);
• A food recall procedure including evidence of traceability documentation; and
• A system for maintaining records, reviewing the program, amending documents.

The level of documentation required for each food safety program will vary between different food businesses - and the detail and complexity may change with the size of the business. SQMI has produced a guidebook summarising all the food safety/quality assurance systems available to the seafood industry, with comments on cost applicability, etc and this book is available from the SQMI Manager.

SQMI has also completed two pilot projects looking at implementation of the quality assurance system SQF 2000 in several large seafood processing establishments and implementing the smaller FoodSafe Plus HACCP system into smaller seafood businesses including processors, restaurants and aquaculture facilities.

Cost benefit analyses were completed to assess the benefits of food safety programme implementation. Details of these projects are available from the SQMI Manager.

The regulatory approach of requiring a food premise to implement a documented system to manage food safety will move the regulatory focus from inspection of food premises, to performing audits on documented food safety programs used by food businesses.

More information

For further information please contact:

SQMI Project Manager, WA Seafood Quality Management Initiative at the Department of Fisheries.