Accelerated Haccp implementation schemes in Wales and England have helped prepare butchers for new licensing regulations. Matthew Mortlock, Adrian Peters and Chris Griffith look at the implementation of these initiatives across the Welsh and English butchery sectors

Since 1 May, new licensing regulations(2) have required many English butchers' shops and retail food outlets to operate a fully documented food safety management system in keeping with the seven principles of the Hazard Analysis Critical Control Point (Haccp) approach detailed by the Codex Alimentarius Commission.(1)
The regulations apply to businesses handling and selling a combination of unwrapped raw meat products and ready-to-eat foods. Businesses have until 1 November to obtain a licence, by demonstrating their compliance with this requirement as well as with existing food hygiene legislation, enhanced staff training requirements and the payment of a £100 fee to their local authority. Similar regulations are proposed for Wales, although these are unlikely to be introduced until 2001 as they are being passed separately through the legislative process of the Welsh Assembly.

To help accelerate Haccp implementation, in preparation for licensing and in response to the recommendations of the Pennington report into the 1996 E. coli O157 outbreak in Lanarkshire(9), Haccp initiatives have been designed and implemented across England and Wales. These schemes provided businesses with free training and consultancy to help them design and implement their own Haccp system. The English scheme was managed by the Meat and Livestock Commission, while in Wales the process was delivered by individual local authority environmental health departments.

Aware of the development of these initiatives, the Food Research and Consultancy Unit at the University of Wales Institute Cardiff (UWIC) identified the need to carry out a systematic evaluation of the implementation of these initiatives. To the unit's knowledge, such research had not previously been planned across either region, despite the large sums of capital funding being provided, although those responsible for local delivery of the initiatives may have planned their own evaluation.

The main aims of the research were to:

• gather background data on the butchery industry and its practices prior to the accelerated Haccp initiatives
• estimate the economic impact of Haccp implementation
• assess managerial beliefs and attitudes towards Haccp and their involvement in the accelerated initiatives
• evaluate the impact of the training and advice provided, upon the Haccp and hygiene-related knowledge and ability of business managers.

The remainder of this article presents a summary of the main results and conclusions drawn from the Welsh research, although it should be noted that these largely mirror those from the English study. The recommendations for future research and policy development are relevant to both the English and Welsh contexts.

METHODOLOGY
The questionnaire design and methodological approach adopted for the study were developed in consultation with the Welsh Food Safety Technical Panel, including a small scale pilot study in three South Wales authorities.

Nineteen of the 22 unitary authorities in Wales accepted the invitation to take part in the research. A total of 730 questionnaires were distributed to all the businesses from those authorities that had participated in the Haccp initiative, with the exception of some larger supermarket chains whose Haccp implementation had not been the direct result of their involvement.

Questionnaires were delivered by mail or where possible in person by environmental health officers in the course of their normal duties.

The EHOs involved were encouraged to actively remind businesses in their areas to complete the questionnaires in a bid to improve response rates, which, though relatively low at 18.5 per cent, compare with other recent Haccp- related food industry studies.(5, 6, 8) The English study yielded a response rate of 33.4 per cent from a total sample of 1,000 businesses, an improvement that was attributed to the different methodological approach used.

Despite the low response rates increasing the risk of non-response bias, the parity identified between the English and Welsh results and the range of attitudes and costs expressed by respondents supported the overall validity of the survey findings.

PRE-HACCP PRACTICES
Before implementing Haccp, 23 per cent of businesses had no cleaning schedules in place, 22 per cent were not monitoring the temperatures of their food products and 32 per cent apparently had no food hygiene training provision in place. Four per cent of businesses stated that they were carrying out microbiological testing.

Only 63 per cent of businesses could positively identify that they had conducted a hazard analysis prior to formally implementing Haccp, while only 56 per cent had identified critical control points (CCPs) and only 40 per cent had documented their food hygiene systems.

The average number of the seven Codex Haccp principles in place before formal Haccp implementation was 3.4, while only 22 per cent of businesses believed that they had previously implemented all of the Haccp-based requirements of the 1995 Food Safety (General Food Hygiene) Regulations.(3)

ECONOMIC IMPACT
The direct capital costs of Haccp implementation averaged £630 per business, up to a maximum of £4,130. The most significant component of these costs was expenditure on new equipment or physical changes to the business environment, at an average of £488.

These direct costs were greater in businesses that had fewer of the Codex Haccp principles in place before formal implementation of the system. Nevertheless, in 75 per cent of businesses these costs represented less than 25 per cent of one week's turnover.

As well as direct costs, businesses had to commit an average of 47 man-hours to implement Haccp, up to a maximum of 300. Most of this time was spent on training (21 hours average) and general planning/design of the Haccp system (20 hours average). This time represented an estimated average of 45 per cent of the man-hours available in any one week, based on an average working week of 41.2 hours for a full-time member of staff 7 and interpreting two part-time employees as equivalent to one full-time employee.

Using an estimated wage of £5.50 per hour across the butchery sector, the total costs to business arising from Haccp implementation, including the value of the time spent, were estimated at £890 per business.7

ATTITUDES
Seventy-nine per cent of respondents agreed that it would not have been possible to implement Haccp without the help provided by EHOs, while 50 per cent (in particular smaller businesses) agreed that Haccp would not have been implemented if they had been made to pay for the training and consultancy they received.

Forty per cent of respondents felt their business would need more help in the future to maintain and update their Haccp system with a further 24 per cent being undecided. Thirty-seven per cent believed that it would be difficult to keep up with the documentation required with a further third being undecided.

Twelve per cent of respondents disagreed that Haccp was a cheap system to implement. Where Haccp implementation had cost more, respondents were more likely to disagree. While 52 per cent felt that the benefits of Haccp implementation did not outweigh the costs, 83 per cent agreed that food hygiene was under greater control since implementing Haccp. Also, 84 per cent agreed that Haccp reduced the risk of causing a food poisoning outbreak in the future and 91 per cent agreed that Haccp systems increased staff awareness of food hygiene issues.

MANAGERIAL KNOWLEDGE
Significant improvements were identified in managers' knowledge and ability, relating to a range of Haccp and general food safety related issues, as a result of the training they received. Pre and post training knowledge or ability on a range of issues was assessed using a scale from 1 (none) to 5 (complete).

The most significant improvement in knowledge was in overall knowledge of Haccp, increasing from a pre-training mean of 2.5 to a post-training mean of 4.4. The greatest improvements in ability were in the ability to manage a Haccp system from day-to-day, increasing from a mean of 2.8 pre-training to 4.4 post-training, and in the ability to verify that a Haccp system is working, increasing from a mean of 2.7 pre-training to 4.3 post-training.

CONCLUSIONS
Economic arguments are frequently put forward as one of the key barriers to Haccp implementation within smaller food businesses such as butchers shops. (5, 6, 10) However, the findings of this study suggest that, with training and consultancy costs met by central funding, Haccp implementation was within the reasonable financial means of most businesses, although it placed a greater strain upon smaller businesses. It is worth noting that in many cases the time commitment required to implement Haccp is as significant an issue as any direct financial input.

Without the support and financial subsidy provided, many businesses may have been reluctant to commit themselves to implementing Haccp or would have struggled to implement the system alone. With private training and consultancy costs beyond the means of most small businesses, most butchers would have been forced to implement Haccp without external support. This would have been likely in turn to have a negative impact upon the quality and effectiveness of their systems and potentially prevent them from being able to obtain a licence under the new regulations. While the results clearly demonstrate the positive endowment in terms of improved knowledge and ability that the initiative provided for business managers, a significant proportion of businesses are likely to require further support in the future to maintain the long-term effectiveness of their systems.

Business size alone is not the only issue that can increase the cost and time burden required to implement Haccp. The survey results support the view that the prior level of business development in terms of the systems and culture in place can also have an effect, something recently recognised formally by the World Health Organisation.(10) It is clear from this study that before implementing Haccp, a substantial proportion of businesses were not carrying out good hygiene practices, such as the use of cleaning schedules. Similarly, many were not able to demonstrate their compliance with previous hazard analysis based legislation. While the figures presented may paint a pessimistic view of the situation before the initiative, it is possible the process of Haccp implementation had, in itself, affected their retrospective responses to these questions. Managers may have been less positive than they would otherwise have been about the extent to which their previous practices fulfilled the definitions provided.

Despite not identifying any tangible short-term economic benefits to butchers arising from Haccp implementation, it is clear from the views expressed by managers that the majority do at least recognise the less tangible benefits provided by improving control over food safety. Furthermore, by having implemented Haccp well in advance of the arrival of the licensing regulations, it is likely that most businesses will benefit from a smoother and less costly transition to these requirements than would otherwise have been the case. This benefit applies as much to the local authorities responsible for enforcing the regulations as it does to the business community. Indeed the use of documented Haccp systems may help reduce the time, costs or frequency of routine hygiene inspections in the future. These systems and the documentation they require will also enable businesses to mount a due diligence defence under the 1990 Food Safety Act in the unfortunate event of a food poisoning outbreak.(4)

The results of this research have highlighted the value of carrying out quantitative evaluations of programs such as the accelerated Haccp initiative. They have also helped demonstrate the pivotal role that EHOs and trade associations, in partnership with the academic community, can play in helping to conduct primary research within the food industry. The research has provided data that would have otherwise not have been collected, against which to draw conclusions about the impact that the initiative has had upon the industry, the regulatory authorities and the consumer.

RECOMMENDATIONS
1. Longitudinal studies are needed to assess whether the investment made by the Government and the butchery industry in implementing Haccp, delivers tangible long-term benefits to businesses, the Government and the consumer.

2. In Wales particularly, almost two years are likely to have passed between the delivery of the accelerated initiative and the introduction of licensing procedures. A systematic assessment of the problems that butchers may have faced in maintaining and updating Haccp is therefore recommended to ensure that the introduction of licensing is as smooth as possible, both for the industry and the regulatory authorities.

3. To help enforce the licensing regulations, the development of a generic Haccp audit tool for butchers is recommended. This would provide consistency of enforcement across all regions, a common complaint of many businesses and something which is likely to be especially important in Wales, where EHOs will have played the dual role of trainers/consultants and enforcers.

4. Research-based pre and post delivery evaluation techniques should be incorporated from the outset into any future initiatives of this kind across other industry sectors.

5. In terms of the risk to food safety, the catering sector is an important target for any future Haccp initiatives or regulations that may be considered by the new Food Standards Agency. Haccp has not yet made a significant impact upon this sector (6) and yet the sheer size of this sector is likely to prevent funding support on the scale seen for the butchery initiatives. Similarly, the diversity of business practices within the sector mitigates against the largely generic approach used to address butchers. In light of these potential difficulties, any future initiatives being considered for caterers should plan in an extensive consultation across the whole of the sector to help identify the most appropriate sources of information for catering businesses; the training materials required to facilitate Haccp implementation; and the factors that would motivate catering businesses to be involved in such initiatives.

ACKNOWLEDGEMENTS
The authors would like to thank David Worthington, deputy chief environmental health adviser at the National Assembly for Wales, the Welsh Food Safety Technical Panel and all the environmental health officers across Wales without whose co-operation this research would not have been possible. Thanks are also expressed to David Baines at the Meat and Livestock Commission and John Barnes at the Department of Health for their support in the parallel study of English butchers. The sentiments expressed in the paper are those of the authors.

REFERENCES
1. Codex Alimentarius (1997) Hazard Analysis and Critical Control Point (HACCP) System and Guidelines For Its Application. Alinorm 97/13A, Codex Alimentarius Commission, Rome.
2. DoH (2000) The Food Safety (General Food Hygiene) (Butchers' Shops) Amendment Regulations 2000, SI 2000 No. 930, HMSO: London.
3. DoH (1995) The Food Safety (General Food Hygiene) Regulations 1995, SI 1995 No. 1763, HMSO: London.
4. DoH (1990) The Food Safety Act 1990, HMSO: London.
5. Henson, S, Holt, G and Northen, J (1999) "Costs and benefits of implementing Haccp in the UK dairy processing sector", Food Control, 10 (2), 99-106.
6. Mortlock, M P, Peters, A C and Griffith, C J (1999) "Food hygiene and Haccp in the UK food industry, practices, perceptions and attitudes", Journal of Food Protection, 62 (7), 786-792.
7. Office for National Statistics (1998) New Earnings Survey 1998, HMSO: London.
8. Panisello, P J, Quantick, P C and Knowles, M J (1999) "Towards the implementation of Haccp: results of a UK regional survey," Food Control, 10 (2), 87-98.
9. Pennington Group (1997) Report on the circumstances leading to the 1996 outbreak if infection with E. coli 0157 in Central Scotland: The implications for food safety and the lessons to be learned, HMSO: Edinburgh.
10. WHO (1999) Strategies for Implementing Haccp in Small and/or Less Developed Businesses: Report of the WHO Consultation in Collaboration with the Ministry of Health, Welfare & Sports, The Netherlands, The Hague, 16-19 June 1999, WHO: Geneva.

Matthew Mortlock was previously a research assistant in the food research and consultancy unit at the University of Wales Institute Cardiff (UWIC) and is currently a project officer in the Innovation, Creativity and Enterprise Centre at the University of Wales College Newport (UWCN).
Dr Adrian Peters is director of graduate studies for the school of applied sciences at UWIC.
Dr Chris Griffith is head of the food research and consultancy unit at UWIC.