CODEX HACCP 2020 – What you need to know

A lot has changed since 2019. Including HACCP.

In 2019, the Codex Committee on Food Hygiene presented a final draft update which resulted in a 2020 Revision of CODEX HACCP. The HACCP methodology is now a chapter in it’s own right (not just an annex) along with GHP (Good Handling Practices). Martin Stone and Rachel Harris of HACCP Australia take a look at these changes.

Firstly some definitions of interest;

  • Disposing and disposal are now; disposition,
  • loss of control is now; deviation
  • validation is now; validation of control measures
  • Food Business Operator (FBO): the entity responsible for operating a business at any step in the food chain.

Some noteworthy changes have been made to the principles of HACCP and can be summarised as follows;

  • Principle 1 was ‘Conduct a hazard analysis’ and is now: ‘Conduct a HA and identify control measures’.

In regard to the Hazard Analysis, unintended use of the product must also be considered at this step. Examples of unintended use include using frozen corn as a Ready-to-Eat ingredient in a salad, using a soup mix as an ingredient in a dip without a heating step or having a frozen cookie dough consumed as an unbaked item.

A new CCP Decision Tree is to be re-published sometime this year. Where a control measure at a step in the process is used in combination with a control measure at another step in the process, both steps are considered CCPs.

  • Principle 6 was ‘Verify procedures of the HACCP system are effective’ is now: ‘Validate the HACCP Plan and then establish procedures for verification to confirm that the HACCP system is working as intended’

This is a requirement for the FBO to be able to demonstrate that the HACCP Plan can be implemented effectively in the factory environment. During the initial implementation of the HACCP system and after verification procedures have been established, evidence should be obtained to demonstrate that control can consistently be achieved under production conditions.

Some additional significant changes within the 2020 Codex HACCP revision include;

  • The inclusion of Food safety culture: human behaviour and its influence on producing safe food with requirements to
    • establish and maintain a positive food safety culture,
    • ensure management and personnel commitment,
    • provide leadership,
    • ensure food hygiene awareness by all,
    • have strong communication with respect to deviations and expectations and
    • confirm the provision of sufficient resources to ensure food is produced and handled safely.

FBOs should be prepared for audit evaluation in order to establish compliant food safety culture. Elements which may be assessed under audit include the presentation of site, observations of staff behaviours, discussions with staff, assessments of problems impacting staff, solutions available to overcome these problems and minutes from meetings where FSC has been discussed.

  • More focus on competency training of food handlers with a strengthening of requirements. Staff must understand the nature of hazards associated with the food, process and storage conditions, use and maintenance of instruments and equipment and all staff must be aware of food hygiene and personal hygiene.
  • Manufacturers need to ensure consumers have clear and easily understood information to identify the presence of allergens in the product. In regard to allergen management, Codex Alimentarius has published; A Code of Practice on Food Allergen Management for FBOs CXC 80-2020 which can be sourced from their online publications. It is generally felt that indicated allergen hazards will typically be managed by Pre-Requisite Programmes and not CCPs.
  • Some key aspects of GHPs could be considered as control measures applied at CCPs in the HACCP system.
  • The 2020 revision only refers to unintentional contamination, there is no integration with food fraud/defence.

Any FSP that references Codex will need to be updated to comply with the 2020 revision. No timeline for this but it is indicated that FSPs referencing the old version will be non-compliant.

Please contact a Project Manager at HACCP International for more information on the 2020 revision and how it might affect your business compliance status and certification.

This update was compiled by Martin Stone and Rachel Harris of HACCP International.

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