If the problem of foodborne disease is to be addressed across the whole food industry, then the successful promotion of Haccp to smaller, less developed businesses is vital. Margaret Ryan argues the case

The Haccp approach to food safety has been supported and promoted by governments and trade organisations around the world for many years now. The reasons for this are clear - there is a widespread problem with food safety (foodborne diseases are estimated to affect 10 per cent of the population in the developed world). Furthermore, the
risk-based approach clearly works (as exemplified by improvements apparent in the larger, more developed food industries).
Haccp is successful in larger businesses due to the fact that it was originally developed for sophisticated, large-scale operations - the Codex Haccp system and guidelines on application enabling the merits and method of application to be taken on board.
The fact remains however, that small and/or less developed businesses (SLDBs) make up a large proportion of the food industry, and epidemiological study has reinforced the case that foodborne disease significantly originates from this sector. If this problem is to be effectively addressed therefore, implementation of Haccp within SLDBs must be achieved.
Moves are now under way to achieve just that, with the impetus coming from the European Commission. A European Parliamentary vote on a regulation to this effect is scheduled for November 2001, while support in this country has come from the Food Standards Agency, the CIEH, Lacots, and the food industry itself.
The proposed regulation includes a requirement that: "Food business operators...shall put in place, implement and maintain a permanent procedure developed in accordance with the...principles of...Haccp...". It also states that "member states shall encourage the development of guides to good practice which shall include guidance on the...application of the principles of Haccp...". The fact that licensing has previously been implemented in the UK - as in the case of butchers under The Food Safety (General Food Hygiene) (Butchers' Shops) Amendment Regulations 2000 - means that the required implementation of Haccp systems in all food premises, may well be accompanied by a requirement for a licence.
In the first instance, successful implementation of the Haccp approach within SLDBs will depend largely upon the way it is promoted. Should this sector of the industry perceive Haccp as a problem - as may have been said with respect to the introduction of hazard analysis under The Food Safety (General Food Hygiene) Regulations 1995 - and not something to which there are likely benefits attached, SLBDs will not readily embrace the principles.
It is therefore important to appreciate the need for a change in the current mindset. There must be a "realisation" within the industry consciousness that it is entirely appropriate that the operation of food businesses be controlled; it is only right that competence and management be scrutinised. Licensing and/or the introduction of the Haccp approach must therefore be fully appreciated from the outset as relevant and proper control systems. Furthermore, it should be recognised as likely to increase both consumer confidence and legitimacy within the industry.
Positive signals and information about the benefits of the Haccp method must be communicated to potential users. The Haccp system itself is not complex when applied to SLDBs - it is essentially a staged approach to risk assessment and establishing an appropriate management system in order to ensure safe food. The fact that Haccp concentrates resources on the controls critical to food safety, and may well result in a more cost-effective management system, must be communicated to the business sector (this cannot fail to appeal - given the example of the proven record of the HSE's approach in Successful health and safety management).
Haccp should also be promoted as a useful tool for focusing in-house industry-specific experience and knowledge, ensuring this resource is used to the maximum benefit. It is in these ways that Haccp may be appreciated as necessary, and for the very real commercially orientated improvements it offers.
Transparency of both the way in which a licensing system will operate and the approach that enforcement agencies will take in audit/inspection of Haccp systems, is essential to successfully promoting this aspect of food safety regulation. Enforcement officers need to be seen as the "friend" not only of the consumer, but also of the food business operator. Open and structured communication must be established in order to reduce currently encountered barriers and ensure an effective exchange of information.
The need for the use of plain and consistent language is obvious, not only for the production of national guides and other supporting publications, but also in terms of the necessary discussion between food business proprietors and environmental health professionals. Communication skills attained as an integral element of professional development will need to be capitalised upon in order to meet this challenge. However, the burden on environmental health departments should not be overlooked. Due consideration should be given to a significant role for private sector EHOs in the successful introduction of Haccp to SLDBs (building upon experience gained through their involvement with butchers' licensing). This should be welcomed, as it may ultimately provide an opportunity for private and public sectors to work together effectively for the benefit of public health and the profession in the long term.
In conclusion, it is important that historical lessons be learnt. The introduction of licensing for butchers may have been successfully completed, but does this sector now possess an understanding and/or an appreciation of Haccp as an effective food safety management system? Or, is it simply the case that their critical control points have been highlighted and control methods better defined as a result? The latter would obviously not be workable for all food businesses (often having a significant product and process range), could not take account of change, and the benefits of the holistic nature of Haccp are clearly lost.
Whatever the case, the issues of legitimacy, effective communication, transparency, and cohesive working methods are all crucial if the common goal is to be achieved - safer food across the range of providers.
It is apparent therefore, that there are issues to be dealt with, but there are also many opportunities for real progress. Haccp could well turn out to be a problem for some should the implementation of legal requirements be poorly planned, but the fact remains that it certainly can provide a solution - only time will tell.
Margaret Ryan BSc(Hons) MCIEH, Director of Trading Law Ltd (Tel: 01295 810260. E-mail: info@trading-law.co.uk Web: www.trading-law.co.uk).

Readers may be interested in purchasing Margaret Ryan's book The Haccp systems manual. This book will help provide the user with a method for complying with food safety legal requirements, and therefore prove useful in satisfying both enforcement authorities and customers alike. Available from the publications department for £49.95 each. Tel: 020 7827 5882/3.