EHJ August 2002, volume 110/08, page 235 John Barrow takes a sceptical look at the New Zealand Haccp approach

The approach to Haccp in New Zealand as discussed by Mike Orchard is an intriguing departure from tradition. While it is undoubtedly an interesting model, it will not catch on in the UK, and I am sure it will meet insurmountable problems in its present form in New Zealand.

Why do I say this? Because for any initiative like this to work, it has to be a win/win situation, or at least a win/don't lose situation. But this is clearly a lose/lose situation. Who gains? Clearly not the regulatory agency, which loses influence and power to a series of privately-owned inspection companies. What they do is create a vacuum of inspection resource. If the inspection resource does not exist at the moment to carry out technically sound risk-based inspections, where is it suddenly going to appear from? Not the food businesses either, as they will now have to pay these inspection bodies to assess and approve their food safety plans (FSPs), a service formerly carried out at no direct cost by the local or central government inspectorate. These businesses will also have to shoulder a cost of consultancy input to get their plans to a stage where they meet the standard.

So who does gain? This is an interesting question and in its answer we may see the driving force behind the change. We have seen a very similar process take place over the last few years as supermarket chains have been forced by competitive price wars to cut their head office costs. One way in which they have done this is to transfer the inspection of own-label food suppliers from their internal resource of food technologists to an external resource paid for by the producer.

At first glance, the inspection companies appear to be winners, but even they have seen massive costs in preparing themselves for audits by UKAS to become registered as inspection bodies under EN 45004. Once accredited, they enter a cut-throat competitive market, with prices for inspections controlled by market forces, so margins are tight.

The only real winner appears to be UKAS, whose influence increases as it becomes the only body able to accredit the certification and inspection bodies. But it can only accredit organisations against its competence to inspect or certify against a standard, so the standard must be written first. In the case of the own-label producers this standard was produced co-operatively by the retailers themselves acting as the British Retail Consortium - each retailer making a small contribution in return for huge potential savings in manpower costs and the transfer of liability for product safety to outside agencies.

The similarities to the present situation in New Zealand are obvious and we can extrapolate our experiences:

• a proliferation of commercial inspection bodies;
• a backlog of applications for accreditation;
• dissatisfaction on the part of the food producers with the new burden of paying for inspection/certification services; and
• distrust of the inspection bodies as prices drop and competencies are questioned.

There are parallel situations where such a system works well - the issuing of MOT certificates by private garages, licensed by the Ministry of Transport is one such area, but this was a new system, not a re-development of a long-established and, let's face it, trusted way of central government shouldering their centuries old responsibilities for the provision of safe food.

But the final nail in the coffin of this proposal is Haccp itself. You see, Haccp is not a standard, it is a philosophy. There is no right way to do Haccp; the guidelines tell us we must be flexible in our approach and modify the system to suit the business. Standards are about modifying the business to suit the system. It will prove impossible, I am sure, to maintain the purity of this ethic and accredit companies to certify compliance. If it is forced through, it can only be one view of Haccp, which will become the norm and the entire concept will become the poorer for this loss of flexibility.

John Barrow is editor of The Haccp Practitioner, a CIEH quarterly bulletin published by CHGL. For a free sample copy, e-mail: l.mccann@chgl.com. Annual subscription costs £65. Contact Georgina Butler on Tel: 020 7827 6319.