Strengthening the Food Safety Management System with ISO

Top management conducts periodic management reviews of the food safety management system. The management review is a top level review that is designed to assess the overall effectiveness of the FSMS. In addition, it provides a mechanism that allows every one to commit to the food safety issues that are a priority to top management. The standard lists the following outcomes for the management review:

• Assuring food safety;
• Improving the effectiveness of the FSMS;
• Providing the resources needed to maintain and improve the FSMS;
• Revising the food safety policy and/or objectives.

The day-to-day management of food safety is the responsibility of the food safety team leader. This individual has the responsibilities to mange the food safety team, ensure that the team has relevant training, and report to top management on the effectiveness and suitability of the food safety management system.

The food safety team has responsibilities that go beyond just conducting the hazard analysis and developing the HACCP plan. The team is responsible for the development, implementation and maintenance of the FSMS. These responsibilities include reviewing and assessing all internal communications that can affect food safety. Relevant internal communications can include: the development of new products, changes in specifications, processes, or packaging materials, changes in regulatory requirements, increase in knowledge of food safety issues that impact products and processes, and relevant inquiries from customers or other external individuals. The review is provided to top management for use in the management review process.

The food safety team is responsible for approving all prerequisite programs, or all of the programs that support the HACCP plan. In addition, the team has the responsibilities for planning and implementing the process to validate control measures, and verify and improve the FSMS. As part of this latter process, the team is provides reports to top management on the status of the FSMS and recommendations for up-dating and improving the system.

A Systems Approach to Food Safety

ISO 2200 takes a systems approach to the development of a FSMS (Figure 1). The FSMS is defined as a continuous process which includes a requirement for continual improvement. The improvement step provides direct input into the start of the process, which is the planning and realization of safe food. In addition, there is a process control loop which is shown as a dotted line in Figure 1. This check ensures that the hazard analysis address is effective in meeting the original planning step for food safety,

ISO 22000 links the prerequisite programs and the HACCP plan into a FSMS. In addition, a number of the prerequisite (PRP) programs “shoulds” become “shalls” or in standards terminology, optional requirement become mandatory requirements.

ISO 22000 separates the prerequisite programs into two major groups:

• Prerequisite programs that address infrastructure and maintenance of the food safety management system. An example is training.
• Operational prerequisite programs that are used to control potential food safety hazards. An operational PRP is similar to a control point or CP. An example of an operational PRP is the receiving temperature of raw meat at a poultry further processing plant.

A critical control point (CCP) is defined as a step that can be applied to prevent or eliminate a food safety hazard.

The standard recognizes that the food safety management system may or may not have a HACCP critical control point (Figure 1). As a result, hazard identification and hazard analysis is conducted on all products. As part of this process, the food safety team must determine if the hazards will be controlled through the operational prerequisite programs or through the HACCP plan. The selection of the appropriate control system is dependent on a number of factors including the severity of the adverse health effect and the likelihood of occurrence of the hazard. A number of factors can contribute to the likelihood of occurrence including frequency of the hazard associated with the specific product, effectiveness of the PRP programs, method used to prepare the product in the plant, expected conditions during storage and transportation, and additional processing steps that occur before the consumption of the food.

Separation of Validation and Verification

Traditionally, HACCP classified validation as a system under verification. Recently, food safety experts are rethinking this concept and are separating validation activities from verification activities. Currently, Codex is developing a standard that describes the guidelines for the validation of control measures.