EHJ February 2005, pages 28-29

Evidence suggests that small-to-medium-sized enterprises often struggle to implement Haccp effectively. Alastair Lochhead argues that one solution is to use well-trained specialists to act as mentors

Compliance with food safety legislation varies considerably across the food industry with many businesses failing to ensure adequate standards are met and maintained. Some food sectors have proved more successful than others in implementing Haccp throughout the various stages of food production. These businesses generally have a firm control over the manufacturing procedures. They also tend to be purpose-built and are set up to achieve and sustain high standards of hygiene.

In these premises, raw materials are only sourced from reputable suppliers and business managers make sure there are sufficient refrigerated vehicles with which to deliver the finished product to the customer in a safe and wholesome condition. From the moment food handling staff enter the processing area until the moment they leave, they are carefully managed in their work. Dedicated staff guided by a specialist, based either on or off site, maintains records to demonstrate Haccp implementation. In many cases, the specialist is a food technologist, a nutritionist or a microbiologist. To them, the Haccp document is highly valued and easily understood. But this is not always the case in other sectors.

In businesses where non-specialists are put in charge of maintaining records, the Haccp document is often regarded as a one-off. It tends to sit on the shelf, is seldom read and is only updated when an enforcement officer asks for it to be done or when an external advisor helps out. Managers of small-to-medium-sized enterprises (SMEs) are expected to take on this important responsibility when their priority is often simply ensuring the business' survival. Not surprisingly, many see the whole routine of keeping food safety records as an additional, unwelcome chore. At times of crisis it is likely to be one of the first tasks abandoned.

Dr Robyn Fairman and Charlotte Yapp, from King's College, London, have identified a number of barriers, which prevent SMEs from complying with food safety legislation (EHJ, January 2003, pages 16-19). They note that, "SMEs are extremely diverse in character but are likely to have short track records, low cash flows and a small asset base. Any action required by the SME management that requires internal operational experience, expertise or heavy finance will be difficult to implement". Against this background, they also recognise that food legislation is changing in ways that makes non-compliance greater. In the case of Haccp, which requires self-regulation, this is particularly true.

Dagmar Engel, a freelance journalist who has written about Haccp, food safety and training for a number of German magazines, has suggested that, "everybody, from the cleaning staff to the production managers, needs to know about Haccp" (EHJ December 2002, pages 366-367). While this is a valid point to make, it raises a whole gamut of important questions. For example, to what level should they be trained? What prior knowledge is required before they can be trained? When will they be trained? Can the business afford to release key staff for training? Do staff paid close to the minimum wage want to be trained? In what language should they be trained? There are no easy answers to these questions. Needless to say, well-designed information leaflets in a variety of languages will continue to fall like confetti on the doorsteps of food business managers along with missives from various government departments.

Food handlers who work in successfully run food businesses, come in, change from their outdoor clothing into approved protective clothing, wash their hands at the approved wash-hand basin and handle food in a well lit, temperature controlled area. But how much training is really needed? The regime does not have to be oppressive and can generate great pride in the production of consistently reliable food fit for human consumption.

The Cabinet Office has carried out research on the effect of regulation on SMEs and remains wedded to the notion that simply providing information in a variety of ways to the right people at the right time and in the right language will bring about the required change in behaviour. It does, however, refer to "the need for consistent and helpful enforcement".

Margaret Ryan, director of Trading Law Ltd and author of the Haccp systems manual argues that "due consideration should be given to a significant role for private sector EHOs in the successful introduction of Haccp to small and less developed businesses" (EHJ, October 2001, pages 314-315). She adds that this should be welcomed, as it may ultimately "provide an opportunity for public and private sector sectors to work together effectively, for the benefit of public health."

This supports research carried out by Matthew Mortlock, Adrian Peters and Chris Griffiths, from the University of Wales Institute Cardiff, when the butchers' licensing was introduced, which shows that well directed assistance can bring about a rapid acceptance of Haccp, but it must be sustained (EHJ, June 2000, pages 186-189).

The new EU food hygiene regulations, published in 2004, make changes to the rules on hazard analysis, which stipulates that, "all (food) businesses must put in place, implement and maintain a permanent procedure or procedures based on Haccp principles". The seven principles laid out in the regulations include a verification that Haccp is working properly and being able to produce documents that correspond with the nature and size of the food business to prove it.

Clearly, implementation of Haccp in SMEs will require the ongoing attention of specialists. What's more, the type of person needed to carry out this work will not be available to most businesses from within its own staff. Specialists will have to be brought in from an external source.

Well trained mentors could be made available to food businesses from the private sector or drawn from local government. They would help the food business manager identify the critical control points, as well as declare how control will be exercised at these points, prepare an appropriate Haccp document in addition to suitable documents to monitor the control of critical control points. Their role would not stop there. Mentors could provide suitable training to enable staff to carry out the monitoring accurately and efficiently. They would return at regular intervals to ensure that the monitoring of the critical control points is effective. And they could update the Haccp document as changes take place in the manufacturing procedures.

Food businesses would have to pay an annual fee for this service, which could be administered by the local authority, perhaps through a government loan payable from returns from the first five years. Haccp specialists would be responsible for mentoring a finite number of businesses and would report to the local authority on the success or failure in implementing Haccp. EHPs could take legal action when a food business manager refused to co-operate with a mentor and would also arbitrate if there were a difference of opinion.

Many SMEs find it difficult to implement Haccp effectively in their businesses. Simply bombarding the food business managers with information and demands in leaflets and at seminars, no matter how well designed and in how many languages, is unlikely to achieve the desired results and could even alienate key members of staff. Food business managers will co-operate but they need a more tangible form of help.

Alastair Lochhead works as an environmental health consultant for the European Safety Bureau.