Did HACCP regulations fail in the horsemeat scandal?

The fact that pig DNA as well as horsemeat contaminated with phenylbutazone (bute) was found in beef mince supports the argument for hazard control points, even if a meat product is not hazardous. Global Heat Transfer, a Midlands firm that supplies highly regulations-compliant food grade oils into the food chain asks whether the process has failed or whether it was flouted.

According the UK Food Standards Agency, Hazard Analysis Critical Control Points (HACCP) regulations help introduce procedures to make sure the food produced by the food industry is safe to eat.

HACCP forms part of the Food Hygiene (England) Regulations 2006 and is centred on safe consumption and control measures during manufacture. The use of food grade heat transfer fluid (HTF), such as that sold by Global Heat Transfer, forms part of this plan.

From 1st of January 2006, new European Community Food Hygiene Regulations replaced the existing UK food safety laws. In practice, the main change related to food safety management, and required the documentation of arrangements for making sure that food sold to customers is safe.

“HACCP is a recognised way of making sure that the food safety hazards in your business are being managed responsibly, and of showing that this is being done day-in, day-out,” explains Dr Chris Wright, group head of R&D at Global Heat Transfer

“It is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.

“We have yet to establish whether the HACCP process was ignored or whether the process itself failed. According to European Community Food Hygiene Regulations, HACCP is a tool to assess hazards and establish control systems that focus on prevention rather than relying mainly on end-product testing.

“However, it was this very end-product testing that exposed the abuse. The question is, did HACCP itself fail or was it deliberately flouted by the food supply chain.”

HACCP involves the following seven principles:

  1. Identify the potential food hazards in a food business that must be prevented, eliminated or reduced to acceptable levels. A food hazard may be biological, physical, or chemical, thermal fluid is a chemical hazard for example.
  2. Identify the critical control points (CCP) at the process step(s) where control is critical to ensure food safety; by preventing, eliminating or reducing the hazard an acceptable level.
  3. Establish critical limits; targets set at each critical control point which guarantees to eliminate or reduce the hazard to a safe level, for example less than ten percent incidental contact with food gradeHTF versus nil incidental contact with mineral or synthetic HTF.
  4. Establish and implement effective monitoring procedures at CCPs, for example, system and fluid analysis and audits.
  5. Establish corrective actions when monitoring indicates that a CCP is not under control, if old fluids have not been replaced for example.
  6. Establish procedures to verify that the measures outlined above are working effectively, records of thermal sampling for example.
  7. Establish documents and records commensurate with the nature and size of the food business to demonstrate the effective application of the measures outlined above.

These seven principles are analysed in more depth, with reference to both heat transfer fluids and the horsemeat scandal in the Global Heat Transfer white paper The Seven principles of HACCP.