Food Safety in the Retail World

“We have federally mandated seafood and meat HACCP alliances, but nothing in the retail sector,” Dr. Snyder points out. “The U.S. Food Code identifies controls but not the specific hazard, the levels of the hazards, and the Food Safety Objective or tolerable level of the hazard. We clearly need a certifiable program for contamination control in food service that is based on science, not inspectors’ personal opinions.”

Dr. Snyder believes that USDA processor HACCP regulations (9CFR417) are the direction to go in retail. The FDA and USDA have different process performance standards, he observes, which is confusing to the food industry. For example, the USDA requires a processor to cook ground beef for a 6.5 log reduction of Salmonella, while the FDA requires a 5 log reduction. The USDA requires that chicken be cooked to 160°F, while the FDA requires that it be cooked to 165°F for 15 seconds.

“Today the retail chef innovates new processes and products but must adhere to FDA-dictated process controls whereby specified hazards associated with a process are not always identified, critical levels for safety are not identified, the food safety objective is zero illnesses rather than a tolerable level, and equipment selection is often limited to National Sanitation Foundation certified,” Dr. Snyder says. “The FDA says if a retail food operation implements HACCP and does its own scientifically correct process development, it can do any federal process. Unfortunately, the FDA HACCP literature gives no specific food science guidance for validating a process as meeting a food safety objective.”

New HACCP Programs

The RFA has developed its own science-based HACCP process controls program, based on the HACCP template of the National Advisory Committee on Microbiological Criteria for Foods. “HACCP does not provide actual process controls,” Dr. Snyder says. “It only outlines the steps for developing the controls. USDA has based its processor rules on the level of the hazard in the food, the tolerable level the consumer can eat and still meet a food safety objective. FDA provides no information on the basis for the controls. They really should be the same as USDA.”

According to Dr. Snyder, HACCP can be a self-regulating food safety program customized for individual operations or kitchens, especially if they can purchase food with certified lower levels of hazards. “In such applications, HACCP focuses on keeping food in proper time and temperature zones and on reducing or eliminating contamination,” he says. “HACCP identifies and controls potential food safety problems in food handling before they can occur, while it evaluates and monitors each step in the entire food preparation process. The benefits include lower levels of risk and very consistent products served to the customer.”

Process HACCP is not just seven principles, Dr. Snyder adds. “It is the scientific application of the principles to the design of a process, based on the level of hazard that comes from the supplier and reduces the hazards to a tolerable level of risk, such as less than one ill person in 100,000 consuming that food with that hazard, or only one person in 1,000,000 dying because of the hazard in the food,” he says. “Baseline criteria for biological, chemical, and physical contamination are taken into consideration in a food service kitchen HACCP program.”

Food security and defenses against food sabotage are definitely part of a complete and viable active managerial control (AMC) HACCP plan in food service, Dr. Snyder says. “There is no purpose in having food security and food safety separate,” he adds. “Our current food is contaminated on the farm just as it could be by a terrorist. Cooks know food from the farm needs to be made safe, and that level of intervention will make sabotaged food safe. Using HACCP to control hazards will take care of food security, and all the food security resources can be added to our current food safety control plans.”