2000 December Report of the Auditor General of Canada
Exhibit 25.9—Approach Based on the Principles of Hazard Analysis and Critical Control Points (HACCP)
The key element of a HACCP-based system is its preventative nature and control throughout the manufacturing process at each critical step, called a critical control point (CCP). By identifying CCPs, the processor can easily detect and correct food safety concerns at these points before it processes and packages the product.
A HACCP-based system has seven basic principles:
1. conduct a hazard analysis;
2. determine the CCPs;
3. establish critical limits;
4. establish a system to monitor control of the CCP;
5. establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control;
6. establish procedures for verification to confirm that the HACCP-based system is working effectively; and
7. establish documentation concerning all procedures and records appropriate to these principles and their application.
These principles are also used by Canada's trading partners, such as Australia, New Zealand, the United States and countries of the European Union.
Food Safety Enhancement Program (FSEP): A program for the industries of beef, pork, poultry, processed fruits and vegetables, dairy, egg, honey and maple syrup
To participate in this program, the processor identifies each CCP in an operational plan. These plans are reviewed and, if deemed adequate to control hazards, are recognized by the Agency. Processors must also develop a prerequisite plan to prove that their transportation, storage, sanitation, and other systems meet the Agency's criteria. These plans are also recognized by the Agency.
Once a processor has adopted a HACCP-based system, the Agency can replace traditional inspection with HACCP-based inspection. Under HACCP-based inspection, the Agency will check the adequacy of the controlling and monitoring procedures of the processor and verify the processor's records of the monitoring procedures. End-product testing is completed as necessary. The design of an inspection program determines how often the Agency inspects a processor.
Quality Management Program (QMP): A program for fish processors
Under this program, the processor must develop and implement a QMP plan, which includes an operational plan, a prerequisite plan and a regulatory action plan. The QMP plan outlines control measures that are necessary for the production of safe and wholesome product. The Agency assesses the plan for compliance with the Fish Inspection Regulations.
Regular audits by the Agency are designed to verify that these plans have been implemented as written and that they are effective in maintaining compliance with regulatory requirements.
Modernized Poultry Inspection Program (MPIP): Further program redesign of the HACCP-based approach for the poultry industry
Under current poultry inspection programs, Agency inspectors perform ante- and post-mortem (before and after death) inspection of the animal. Under the MPIP, trained and accredited industry staff conduct post-mortem detection, while Agency inspectors provide continuous monitoring and oversight of industry's activities. It is intended that industry will also perform ante-mortem detection, although the current MPIP pilot establishments do not yet do so. The MPIP also incorporates a pathogen reduction effort.
The MPIP is running as a pilot project. Research and development for the MPIP began in 1996; the pilot began in September 1997. The Agency set a goal of having 20 percent of poultry establishments participating in the MPIP pilot in 1999-2000. Today, participation is 11 percent (seven establishments).
The development of the MPIP has been a significant undertaking for the Agency. In developing the MPIP, the CFIA consulted industry, consumers and the unions representing CFIA employees. Pilot establishments were identified, and prepared to participate in the program. Training programs for staff, accreditation programs for industry detectors and presentation and finished product standards have also been developed. The Agency developed a pathogen reduction program. Flock sheets have been developed that extend the impact of HACCP on the production to consumption continuum. Regulations of the Meat Inspection Act are being updated, and equivalency for the inspection program from the United States (U.S.) is pending. The lessons learned in developing the MPIP will be useful to the Agency in developing similar programs for beef and pork.
Ante- and post-mortem inspections
Ante-mortem inspection involves the visual inspection of live animals for evidence of illness. It is effective in identifying conditions that cause abnormal behaviour. Post-mortem inspection involves an examination by sight, touch and smell of a carcass and organs. It is effective in detecting carcasses affected by diseases that are visible to the naked eye or can be detected by smell or touch, such as tuberculosis and cysticercosis. However, fewer animals going to slaughter have these diseases because of healthier livestock. Post-mortem inspection is not effective at detecting food-borne microbial pathogens of public health significance, such as certain strains of E. coli or salmonella. Generally, microbial hazards that cannot be detected through this means are a greater risk to consumers than those that can. Laboratory testing is the most common way to detect these hazards.
A pathogen-reduction effort involves laboratory testing to verify the effectiveness of control measures taken to control microbial hazards. Laboratory testing programs have been developed by the U.S. government in response to concerns raised by the National Academy of Science in the United States that new methods to supplement ante- and post-mortem inspection were needed to better detect microbial hazards. This is one of the reasons why the United States introduced its own Pathogen Reduction Program as part of the introduction of the HACCP-based approach. The U.S. program illustrates some of the important elements of a pathogen-reduction effort.
The U.S. government completed national baseline surveys of the prevalence of food safety hazards for eight categories of slaughtered animals. Using this data, the U.S. Department of Agriculture (USDA) established a salmonella performance standard and required establishments to achieve a prevalence for salmonella contamination that is below the prevalence rates shown in the baseline surveys. Salmonella has been targeted because it is the leading cause of food-borne illness among microbial pathogens, has a known presence on most types of raw meat, and it can be tested in a variety of products.
The USDA is also requiring establishments to test for generic E. coli because it is a good indicator of the adequacy of the establishment's process controls for fecal contamination. The USDA is adopting generic E. coli verification performance criteria based on the results of the baseline survey. The criteria are guidelines, not regulatory standards. The program is designed so that the USDA routinely tests for salmonella and the establishment regularly tests for generic E. coli to ensure that the product does not exceed the standards or guidelines. The routine testing also allows the USDA to measure the success of the implementation of its program. It is considering an expansion of microbial testing to include other pathogens, such as campylobacter.
Source: CFIA's documents and other sources