Modifications and updates

Several aspects of the guide changed in the 2020 update from simple structure changes to definitions and even the introduction of new concepts. Below 6 of the most significant  changes are presented but we advise food safety professionals to read the full document afterwards.

1. The structure of the document

Previously the general principles document had 10 sections covering the introduction and the good hygiene practices while HACCP and its application were in an annex. The latest version has a much improved structure which include HACCP and its application as part of the document. The updated structure you will see is as follows:

• Introduction, scope, use and definitions. (All definitions in one place compared to two in the previous version)
• Chapter one covering Good Hygiene practices over 9 sections
• Chapter two which in its first section covers the seven principles of the Hazard Analysis and Critical Control Point (HACCP) system. The second section provides general guidance for the application of the HACCP system and the third section describes its application following the 12 steps, as well as the training recommendations
• Annex 1 – Comparison of control measures with examples.
• Diagram 1 – Logic Sequence for Application of HACCP
• Diagram 2 – Example of Hazard Analysis Worksheet
• Diagram 3 – Example of a HACCP Worksheet

2. Emphasis on the role of the Food Business Operator (FBO) providing safe food.

The document clearly states:

• It is the FBO’s responsibility to provide safe food and to have awareness of the potential hazards impacting their food and the consequences of these hazards on consumer health
• The FBO should ensure that related hazards are well managed
• FBOs should ensure personnel are competent and trained, and to build a positive food safety culture

3. Good Hygiene Practices (GHPs)

Good Hygiene Practices are pointed out right in the General Principles sections. GHPs are included as a part of the prerequisite programmes and therefore as a foundation for an effective HACCP plan. While many businesses who operate to a GFSI recognised certification programmes will be very familiar with the updates and following them already, some organisations will need to do some extra work to meet the expectations of certain recommendations.

Generally, the recommendations around GHPs detailed in chapter two of the new document are better structured, easier to track and definitely more detailed.

The guide explains that some GHPs require greater attention because they have higher impact on food safety e.g. cleaning of a ready to eat meat slicer. For example, this greater attention may be in the form of increased monitoring.

Clear emphasis on allergen management is evident. “Allergen” was mentioned 40 times in the document. In fact, applying the correct label with appropriate allergen information is given as an example of a Critical Limit.

4. Food Safety Culture

In page 4 of the document, the importance of management commitment to food safety culture is highlighted and the following is suggested to create a positive food safety culture.

1. commitment of the management and all personnel to the production and handling of safe food;
2. leadership to set the right direction and to engage all personnel in food safety practices;
3. awareness of the importance of food hygiene by all personnel in the food business;
4. open and clear communication among all personnel in the food business, including communication of deviations and expectations; and
5. the availability of sufficient resources to ensure the effective functioning of the food hygiene system.

5. Definitions

Definitions are super important because they form the language that we will be using. These clarified terminologies will give us the ability to explore certain topics, clearly and with consistency.

In the new general principles there are significant improvements on the language used and terminology in general and particularly when it comes to definitions.

There are 10 new definitions, 13 modified or updated definitions and 3 deleted ones. Changes vary from minor to fundamental

A comprehensive discussion of these definition changes and their impact on your Food Hygiene System and HACCP plans can be accessed in the free Codex 2020 HACCP Forum provided by Food Surety on this link. There you can find a 15 minute video and more related information.

6. HACCP and Guidelines for its application

In section 3 of chapter 2, the document describes the same HACCP 12 steps and 7 principles, reworded in some places. Overall, they look the same except there are fine modifications that can have an impact on HACCP Applications, here are some examples:

1. In step 7 principle 2, the previous emphasis on using a decision tree to determine CCP has been removed. Although it is referenced, “determining whether or not the step at which a control measure is applied is a CCP in the HACCP system can be helped by using a decision tree”. The decision tree example has been removed from the document altogether! Codex is still working on the tree and an example of it might be added back in the near future.
2. Step 8 / Principle 3, while it is not a new expectation, there is a significant emphasis on scientifically validating critical limits. Also, there is an added sentence stating that critical limits can be observable or measurable (which is a clear different approach from ISO 22000:2018).
3. In establishing corrective actions (Step 10/ Principle 5) significant amount of clarifications have been added. A new emphasis on the need to conduct root cause analysis for what caused the deviation. It is explained that understanding the reason|cause for the deviation can minimize or expand the amount of product impacted. Periodically review corrective actions taken to identify trends and ensure effectiveness are expected.
4. 11 Validation of the HACCP Plan and Verification Procedures (Step 11/ Principle 6).
   1. In this principle too, a whole lot of clarification has been added. Further emphasis on validation is clear in the new document. Distinct types of validation have been explained: validating the whole HACCP plan before implementing it, validating the critical limits and also post implementation validation of controls consistent achievement under operation conditions.
   2. When it comes to verification, further clarification added and distinct types of verification described: verification of the implementation of the HACCP Plan, verification of achieving the results expected of controls and verification/review of the adequacy of the whole HACCP system.

Training programmes should be designed to address the concepts at a level appropriate for the knowledge and skill level of the personnel being trained. Training programmes should be reviewed periodically and updated where necessary. Re-training may be needed as part of corrective actions for some deviations.

Final thoughts

The General Principles of Food Hygiene is an unavoidable document for food organizations and food safety professionals who work daily in providing safe food to consumers. The new revision keeps the document updated with current concerns such as allergen management and the relevance of Food Safety Culture in a more clear structure. It also includes aspects that will fuel discussions among food safety professionals as is the case of GHPs that need greater attention (what exactly should it be and how should it be managed?), the removal of the decision tree and the observable Critical Limits.