The Specialist Cheesemakers Code of Best Practice

Hazard analysis and your business

INTRODUCTION

CRITICAL CONTROL POINTS (CCPs)

BENEFITS

WHAT YOU NEED TO DO

WHERE TO START

IDENTIFYING POTENTIAL HAZARDS

CONTROLS

REVIEW

RECORD KEEPING

WHERE TO GET HELP

TALKING TO YOUR FOOD AUTHORITY

INTRODUCTION

3.1 All food businesses have the responsibility for ensuring that the food they produce is safe to eat. The Regulations focus on the need to identify and prevent food safety hazards.

3.2 There are a number of food safety management control systems you can use. These systems involve identifying and controlling hazards critical to food safety, in a structured way. One such system is HACCP (Hazard Analysis and Critical Control Points), which is a formal system requiring comprehensive documentation. However, the Regulations do not require that you use any specific or formal system. The system you use will, in practice, depend on the nature and the complexity of your operation. Hazard analysis and its documentation is not a legal requirement for milk production holdings, but it is recommended. It is legally required for dairy establishments, e.g., where cheese is manufactured on farms.

CRITICAL CONTROL POINTS (CCPs)

3.3 These are the steps in the production process which, if controlled, will eliminate a hazard or reduce it to an acceptable level. To ensure product safety, these are the points where you should focus your effort of monitoring and control.

BENEFITS

3.4 By taking an organised approach to assessing hazards, you will be able to identify potential problems. It will certainly help you to check that your controls are working properly. This is particularly important at points in your operation after which no further controls are applied which would eliminate or control food safety hazards.

3.5 Hazard analysis should help you comply with other requirements of the Regulations. In particular, if all the hazards have been identified and all the control measures have been put in place you should not experience difficulty in meeting the microbiological standards laid down in the Regulations.

3.6 An effective hazard analysis system will demonstrate that preventative measures are in place and working effectively. This will give added status to your business by demonstrating that all reasonable precautions have been taken to ensure food safety. This is important since, the principal defence in food safety law is that all reasonable precautions and due diligence were taken to avoid committing an offence. An effective system will also help demonstrate your positive approach to food safety to your Food Authority.

WHAT YOU NEED TO DO

3.7 The Regulations require you to carry out your own checks to:

• identify critical points where control is required to ensure food safety in your establishment or process;
• make sure that these critical points are regularly monitored and controlled (you need to keep records of your checks and controls, and review and amend the system to take account of changes in your product or process).

WHERE TO START

3.8 The easiest way to start is by drawing a flow chart of your operation, showing the different stages of any processing handling and storage. If you make a number of different products you may need to draw a chart for each one. You can check your chart by going through the operation as you do it to make sure you have not missed out any stages or ingredients. Simple examples of flow charts can be found at Annex A.

IDENTIFYING POTENTIAL HAZARDS

3.9 The next step is to identify potential hazards which might harm the consumer. These fall into three basic categories:

• microbiological: could harmful bacteria be present in or get into the raw milk or the cheese? Could harmful bacteria or their toxins survive processing and grow to dangerous levels in the milk or cheese?
• chemical: could toxic chemicals, such as cleaning chemicals, get into the milk or cheese?
• physical: could foreign bodies, such as glass shards or insects, get into the milk or cheese?

3.10 You need to identify potential hazards at each stage of the process. It may be advisable to follow a systematic approach by identifying potential microbiological hazards first, then going though the process again identifying chemical hazards, and finally identifying physical hazards. Dairy Industry Federation Guidelines (see Part 11 'USEFUL PUBLICATIONS) also contain examples of flow charts which you may find useful. See also Parts 4, 5 and 6 of this code.

CONTROLS

3.11 Once you have identified possible hazards, you need to decide:

• how you can control them;
• the types of controls needed relating to time, acidity, etc., and how they can be regularly checked;
• what tolerances are acceptable and what action should be taken if these limits are exceeded.

3.12 When introducing controls, remember:

• they must be effective. They should either completely eliminate the hazard or reduce it to a safe, acceptable level. Examples are: ensuring the acidity during the cheesemaking process is correct, or avoiding a dangerous build-up of sources of harmful micro-organisms which may lead to contamination (e.g., from slurry, sewage, pigs, poultry, bought in calves, or other sources);
• they should be practical. Try to ensure that controls can be applied to your business in a reasonable and sensible way;
• in many cases they do not have be complex. They can be simple as long as they are effective (e.g., covering a tank of milk to prevent contamination from foreign bodies, dust, dirt, etc.);
• they should be understood. You should tell staff about the importance of the controls in place, particularly any for which they are responsible. You should also detail what action should be taken when the targets and tolerances you set are not met (e.g., if the rate of acidity is not achieved or if cleaning water temperatures are not high enough);
• that acidity levels in soft and mould ripened cheeses are such that bacteria may grow. Production of these cheeses is therefore a higher risk operation than the production of hard cheese of high acidity and salt content.

3.13 You may not have direct control over all potential hazards. For example, a supplier of raw milk or starter is responsible for the safety of that product. To ensure you take delivery of safe raw materials it is in your own best interest wherever possible to specify conditions of supply, e.g., milk storage temperature, microbiological specifications and hygiene standards. You should check to ensure that the specification is met. Remember, once you have accepted any materials they become your responsibility. You should handle and store them in a way which ensures their safety.

REVIEW

3.14 The system should be monitored and reviewed regularly, and particularly if the process changes in any way, or a different ingredient is used.

RECORD KEEPING

3.15 The extent of the documentation necessary will be determined by the scale of your operation, and the risk associated with the milk or cheese produced. You will need to be able to demonstrate that food safety hazards have been identified, that controls are in place and checked, and that appropriate action can be taken if something goes wrong.

WHERE TO GET HELP

3.16 Experts from your local Food Authority, the SCA (who can advise on independent consultants in your area), trade associations, ADAS, food research associations and educational establishments such as agricultural colleges can give further advice or sources of advice on how to carry out hazard analysis and control.

TALKING TO YOUR FOOD AUTHORITY

3.17 You will know your product and processes better than anyone. It is important however to establish and maintain a dialogue with your Food Authority. The Food Authority can help and advise you on the safe production, distribution, and sale of cheese. Enforcement officers will be able to advise cheesemakers on the requirements in the Regulations, and have a duty to assess compliance with them. Officers will be able to provide advice on how to approach identifying and controlling hazards. They may want to discuss procedures and operating practices in some detail and can give advice on how to improve them. However, it is still your responsibility to ensure that any activity critical to food safety is under proper control. In some cases it may be necessary for you and/or enforcement officers to take action to help avoid any risks to consumers.

Specialist Cheesemakers Association    17 Clerkenwell Green    London EC1R 0DP

Tel: 020 7253 2114    Fax: 020 7608 1645    Email: info@specialistcheesemakers.co.uk