Dr Declan Bolton, Principal Research Officer at Teagasc, member of the safefood Knowledge Network Expert Facilitation Group and Member of the EFSA Biohazard Panel, discusses the importance of new guidelines for small food retailers proposed by the European Food Safety Authority (EFSA).
It was recognised that the implementation of food safety management systems by small retailers can be very challenging, therefore EFSA has proposed a simplified approach. Lack of expertise and technical hurdles can mean that small businesses – such as grocery shops and butchers – cannot fully implement the current requirements under European hygiene legislation. In acknowledgement of this, the European Commission requested that EFSA develop simpler rules for five types of business – a bakery, a fishmonger, an ice cream shop, a butcher and a grocer. The result is a more streamlined system that can be easily managed by these types of businesses.
Dr Declan Bolton chaired a working group with the support of the EFSA secretariat, to address this mandate. As he explains: “I think there was a realisation that HACCP as legally mandated in EC 852/2004 presented real difficulties for small food retailers, not least because of lack of staff expertise, staff turnover, costs/limited resources, etc.” According to Declan, there are five key changes. Firstly, that the retailer need only be aware that a hazard (biological, chemical, physical or allergen) may occur at a particular stage. Being aware of this hazard is sufficient, without having an in-depth knowledge of that hazard: “for example, knowing there may be a biological hazard associated with raw meat without knowing it is Salmonella.” Retailers also need to be aware that a failure to perform certain activities – separating raw from cooked meat – presents a hazard. In addition, allergens can be treated as a separate hazard, as opposed to a chemical hazard.
Declan also points out that controls may be based on pre-requisite programme (PRP) activities such as good hygiene practices (GHP) etc., thus recognising that there may not be a specific intervention that can be relied upon to reduce/eliminate a given hazard.
Finally, he notes that the draft legislation removes most of the requirements for validation and verification and minimizes the need for record keeping. “Most PRP activities are based on qualitative and not quantitative parameters and thus are evaluated as being ‘acceptable’ or ‘unacceptable’. Cleaning, for example, may be based on visual inspection. Other PRPs (e.g. cooking or chilling) are based on quantitative parameters (e.g. temperature) and their correct application may be assured by setting critical limits that must be achieved to ensure food safety. In the simplified approach the former PRPs, based on qualitative parameters, do not require record keeping but for the latter, based on quantitative parameters, monitoring is required to ensure critical limits are achieved and records should be kept to demonstrate compliance.”
Commenting on the fact that the food retailer can only control one step in the chain, Declan states: “We must recognise that hazards often enter the chain during primary production and the key intervention, e.g. cooking, is at the other end of the chain. Thus processors, retailers, etc. must ensure they do everything to minimise any hazards through proper cleaning and hygiene procedures.”
The new legislation, based on the EFSA Opinion, is still in the draft stage. When passed, Declan believes it should result in a more effective and user-friendly food safety system for small food retailers.
For further information, visit https://www.efsa.europa.eu/en/press/news/170302
About Declan
Hobbies/Interests: Coach/Member of Metro Saints Brigid’s AC, Porterstown, Dublin.
Favourite ways to unwind: Running marathons, reading and watching movies.
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