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Food Control 11 (2000) 353±357

HACCP in Australian food control

Richard Souness *
Australia New Zealand Food Authority, P.O. Box 7186, Canberra, MC ACT 2610, Australia
Received 1 January 1999; accepted 13 September 1999

This paper details the reform of food hygiene legislation in Australia as an example of how Australian governments rede®ned
their roles and responsibilities in assessing Hazard Analysis and Critical Control Point (HACCP) like systems. The paper describes
the process of reform, the current hygiene legislation and the cultural change that the reforms promoted. The shift from inspection
of food business to auditing of food safety systems implemented by business is also discussed. The paper also addresses the scope of
a proposed national audit system, including the audit process, the necessary auditor competencies and training of auditors. The
paper concludes by listing the issues yet to be resolved in the reform process. Ó 2000 Elsevier Science Ltd. All rights reserved.

1. Introduction 2. Food hygiene reforms

This paper deals with issues relevant only to Australia At present the national food standards as set out in
and does not intend to represent any position by New the Food Standards Code apply to the composition,
Zealand on the topic of the paper. safety and labelling of food products. There are cur-
Australia is a federation of eight States and Territo- rently no national standards pertaining to the hygienic
ries, with each having its own food legislation and also production and processing of food in the Food Stan-
the responsibility for enforcing its legislation, resulting dards Code.
in considerable variation. In 1991, the National Food Food hygiene regulations are presently developed and
Authority (now the Australia New Zealand Food Au- enforced separately by the States and Territories, re-
thority or ANZFA) was established by agreement be- sulting in signi®cant variation. State and Territory
tween the Federal, State and Territory governments and health departments have recently sought a nationally
was given responsibility for developing and amending consistent approach that is less prescriptive and have
food standards which form the Food Standards Code. asked ANZFA to develop a new set of food hygiene
The Food Standards Code is included in all State and standards.
Territory food legislation without variation and so na- The new food hygiene standards would promote a
tional consistency is achieved for these food standards. preventative rather than a reactive approach to food
In 1995, Australia and New Zealand signed a treaty safety and ensure that the same hygiene requirements
establishing a joint system for developing food stan- are enforced throughout Australia. In this way regula-
dards in Australia and New Zealand. ANZFA came tory duplication and overlap will be avoided and na-
into existence and was given responsibility for managing tional consistency achieved. The hygiene reforms are a
this system. The arrangement with New Zealand does major change in the way food is regulated in Australia
not cover food hygiene regulations. Each country makes from a Ôcatch us if you canÕ mentality by business and
its own arrangements although there are signi®cant government to a commitment by all food businesses to
similarities in the approach taken by each country. preventing food safety failures from occurring in the
®rst place.
A key feature of the new food hygiene standards will
be the requirement for all food businesses in Australia,
that can identify one or more potential food safety
Tel.: +61-2-6271-2249; fax: +61-2-6271-2685. hazards, to develop and implement food safety pro-
E-mail address: (R. Souness). grams based on the Hazard Analysis and Critical

0956-7135/00/$ - see front matter Ó 2000 Elsevier Science Ltd. All rights reserved.
PII: S 0 9 5 6 - 7 1 3 5 ( 9 9 ) 0 0 0 9 1 - 2
354 R. Souness / Food Control 11 (2000) 353±357

Control Point (HACCP) principles. The details and · second party, where food safety auditing required by
scope of individual programs would vary according to a government agency is undertaken by employees of
the size and nature of the business and the level of risk it the agency; and
posed to the community. It is recognised that for some · third party, where an audit is carried out by an inde-
food businesses it is bene®cial to integrate a food safety pendent, external individual or organisation.
program with an appropriate quality management sys- The compliance audit can be a second or third party
tem, although government would only assess for com- and is a focussed, in-depth inspection of the food busi-
pliance with the food safety program component. ness against the requirements of the food hygiene reg-
The requirement for food safety programs will be ulations. The compliance audit would either determine
supported by two additional food hygiene standards the e€ectiveness of the implemented food safety system
currently being developed requiring food businesses to or verify that non-conformities identi®ed in a previous
engage in good hygiene practices (GHP). These proposed audit have been recti®ed as agreed.
GHP standards focus on outcomes to be achieved rather An important consideration for food safety auditors
than speci®cally prescribing detailed requirements. relates to the issue of con¯ict of interest in relation to
All three hygiene standards will be enforced by o- audit activities. To avoid the possibility of con¯ict of
cers authorised by relevant authorities which in most interest, auditors, where possible, should not be in-
cases will be the State and Territory health department. volved in the design or implementation of food safety
Enforcement ocers would be encouraged to shift from programs they audit. In general, auditors must avoid
an inspectorial role to one involving education, facili- any activities that con¯ict with their independence
tating the implementation of food safety programs and of judgement and integrity in relation to their audit
auditing food safety systems. Implementation of the activities.
standards would be phased in over a six-year period To achieve cost eciency governments may choose to
using criteria based on the risk classi®cation of food provide a choice for food businesses between second and
businesses. third party compliance auditors. It will be necessary for
To support the implementation of the food hygiene regulatory agencies to ensure that there are appropriate
standards in a nationally consistent manner several in- management systems in place to support both second
frastructure initiatives are being developed. These ini- and third party auditors. Auditors must be certi®ed and
tiatives include the development of industry guidelines, a possess the key competencies relevant to the food op-
food business risk classi®cation system, training com- erations they audit.
petency standards for food industry workers and a na- Both EHOs and third party compliance auditors will
tional food safety audit system. have to meet nationally agreed competencies for par-
The audit system currently under development will ticular types of food businesses to audit those types of
require a shift from a Ôsingle point in timeÕ inspection to businesses. Health departments may seek to be accred-
government being responsible for auditing the food ited by a recognised accreditation body as a certi®cation
safety management system of all food businesses in body in their own right for third party food safety
Australia. To ensure national uniformity the audit sys- compliance auditors or seek to rely on other accredited
tem will need to be consistently applied in all Australian certi®cation bodies for certi®cation of auditors (relying
States and Territories. on nationally agreed auditor competencies for particular
These food hygiene reforms are occurring in an en- types of food businesses to audit those types of busi-
vironment where governments are seeking to ensure that nesses).
the regulatory burden on industry is e€ectively targeted, As the HACCP system is increasingly accepted as the
monitored and reviewed to ensure intended outcomes preferred food safety management system individual
are achieved at least cost to industry. food businesses are experiencing costly multiple audits
both by a range of government agencies and food in-
dustry customers. There is a need for reciprocal recog-
3. Scope of food safety auditing nition of food safety audits performed by second and
third party auditors where these audits meet the re-
An audit is a planned and documented activity per- quirements of the regulations.
formed in accordance with written procedures to verify,
by investigation of objective evidence, that a food safety
management system has been developed, documented 4. Audit process
and e€ectively implemented. There are three main types
of audits for food safety managements systems: It is generally recognised that programs encompass-
· ®rst party, where an internal audit which involves the ing GHP can successfully support the development and
food business relying on its own sta€ to verify its own implementation of HACCP based food safety programs.
system; If GHP programs, such as cleaning and sanitation
R. Souness / Food Control 11 (2000) 353±357 355

programs, have been properly implemented then the production of safe food back to government. This could
team developing a food safety program can concentrate be avoided by the ®rst audit being used to assess or
on the application of the HACCP principles directly to verify the appropriateness of the food safety program,
the product and process in question, having some con- but not approve the program.
®dence that hygiene matters pertaining to personnel and
the surrounding environment are being controlled.
Consequently GHP programs should be audited in
conjunction with HACCP based food safety programs. 5. Auditor competencies
The diculty in assessing compliance with hygiene
requirements is to determine what aspect of GHP and Both public and private sector auditors will have a
HACCP an authorised ocer can assess through the role as compliance auditors, although public sector au-
audit process. Successful auditing will depend on the ditors (EHOs) who are authorised under relevant food
presence of appropriate documentation of GHP pro- legislation will still form the backbone of the compliance
grams. A food business should document their GHP audit process.
programs and ensure that the program is being fol- Private sector independent (third party) auditors who
lowed. Records detailing the checks carried out and the want to undertake compliance auditing would have to
action taken must be kept to demonstrate compliance. seek Ôcerti®cationÕ by a relevant government agency,
The compliance auditor will ensure that the GHP pro- normally a health department. EHOs would not have to
gram is adequate, the program is being followed and any be certi®ed by their health department in addition to
non-compliance is detected and corrective action taken. already being authorised ocers.
If appropriate records are not provided, an auditor The degree of assurance in the safety of food pro-
would have to rely on traditional inspection to con®rm duced by the food industry depends not only on the
compliance with hygiene regulations, which could incur comprehensiveness and appropriateness of the food
greater inconvenience and cost to the business. safety program in place but also on the competence of
An auditor will essentially be seeking to verify the the auditing personnel and the integrity of the auditing
e€ectiveness of a food safety program as it is being process. Regardless of whether the auditors are gov-
followed. A business will be expected to make available ernment ocers or private sector compliance auditors
to the auditor appropriate records which particularly their technical competence needs to be established be-
pertain to critical control points, deviations from critical yond question.
limits and corrective actions. The scale and frequency of ANZFA is currently developing a set of technical
the audit must be related to the nature, size and the risk competencies for compliance auditors. It is proposed
the businesses poses to public health. that the food industry will be broadly divided into
An auditor will seek answers to questions about is- classes of businesses based on the complexity of the
sues such as: business and the overall risk it poses to public health.
· the implementation of GHP programs; Auditor technical competencies for each class of food
· product description and speci®cations; business are to be developed and auditors will be ap-
· production ¯ow diagram; proved to audit businesses up to and including the food
· the hazard analysis process; business class for which they meet the competency
· the identi®cation of critical control points for signi®- standard.
cant hazards; To meet the growing demand for HACCP auditors
· the establishment of critical limits and monitoring by the Australian food industry the Quality Society of
procedures; Australasia (QSA) has already developed a set of certi-
· the development and implementation of corrective ®cation criteria for food safety auditors. The QSA uses
actions; and these criteria to assess and certify auditors of HACCP
· validation and veri®cation activities. systems for the food industry in Australia.
This question and answer approach to auditing could The QSA system establishes three classes of food
encourage a check-list approach for auditing which may safety auditor, associate auditor, auditor and senior
be appropriate, especially for less complex food busi- auditor. Each class of auditors has to meet certain pre-
nesses. It is important though that this approach does requisite for the following requirements:
not evolve into a simple Ôtick the boxÕ approach where · tertiary or on-the-job training;
there is no critical evaluation of the food safety man- · auditor training;
agement system. · general work experience;
The ÔapprovalÕ of a food safety program by a gov- · food safety experience; and
ernment agency is an issue yet to be resolved in Aus- · auditing experience.
tralia. There is concern that in approving a food safety The QSA also prescribes a set of key competency
program a food business may pass responsibility for the standards (Appendix A) for food safety auditors. Once
356 R. Souness / Food Control 11 (2000) 353±357

certi®ed, auditor's details are included in a register ac- found liable does not appear to have been tested in the
cording to their relevant industry experience. courts. Presumably the main issue a court would con-
This system has been favourably received by the sider is whether the negligent approval of the food safety
Australian food industry although relevant government program 'caused' the loss, or whether the loss would
agencies are cautious in how they view the role of the have been caused despite the auditor's negligence any-
QSA system in compliance auditing. Governments way and therefore the auditor should not be liable.
generally consider they must have the ultimate role in
approval of compliance auditors because of their legis-
lative responsibilities. It would be undesirable though to 8. Issues to be resolved
have a number of di€erent certi®cation systems for au-
ditors of HACCP based food safety systems. The following issues remain to be resolved in the
development of food hygiene reforms in Australia:
· the approval/assessment of food safety programs;
6. Compliance auditor training · the accreditation/certi®cation of auditors;
· the legal liability of auditors;
National consistency in the application of food hy- · the concept of compliance auditing versus enforce-
giene reforms in Australia is an important objective. ment;
Having food safety compliance auditors operating in a · the implication for the primary industry sector of
consistent manner is an essential contribution to this food hygiene reforms;
objective and to this end a training competency standard · the costs resulting from the implementation of the
for auditors is being developed. The competency stan- new food hygiene regulations, particularly the costs
dard includes components on food safety program implications for small business; and
management, HACCP based quality assurance and · the need for government services to be open to com-
GHP, food safety programs and auditing. petition and to ensure competitive neutrality.
The audit component of the draft competency stan-
dard requires that the auditor has the ability to conduct
an audit of a food safety program and speci®es the Appendix A. Key competencies for food safety auditors
following performance criteria:
· describe how to prepare to conduct an audit of a food 1. The ability to identify and assess potential hazards to
safety program; safe food production, handling, preparation, storage
· explain the importance of veri®cation of a food safety and transportation including:
program; and · biological hazards;
· describe any relevant administrative arrangements · chemical hazards; and
for auditing accountability. · physical hazards.
Each performance criteria has an evidence guide 2. The ability to assess the e€ectiveness of methodolo-
(Appendix B) to assist in the assessment of the perfor- gies for controlling the hazards identi®ed above.
mance criteria. The competency standard would be used 3. Knowledge of, and experience in, auditing methodol-
to guide the development of curricula for training new ogies as described in ISO 10011 part 1.
auditors and up-skilling practicing enforcement ocers 4. Knowledge of relevant industry processes and the
to become auditors. ability to assess the adequacy of records for process
5. Knowledge of relevant industry codes of practice, le-
7. Legal liability of auditors gal requirements, guidelines and standards.
6. The ability to demonstrate the personal attributes
Concern has been raised about the legal liability of necessary for the e€ective performance of HACCP
auditors who approve food safety programs at a food or other recognised food hygiene and safety system
premises from which unsafe food is later produced, de- audits (ref ISO 10011 part 2 clause 7).
spite compliance with the approved program. 7. The ability to identify food safety objectives in the
The liability of all auditors will depend upon their context of quality assurance programs.
role. If it is decided that the role of food safety program 8. An understanding of the principles and practices rel-
auditors is only to verify that food businesses are fol- evant to HACCP or other recognised food hygiene
lowing their food safety programs, then their liability and safety systems.
will be limited.
However, because food safety program auditing is a
relatively new concept, whether or not an auditor who
negligently approves a food safety program would be 1
Developed by the Quality Society of Australia.
R. Souness / Food Control 11 (2000) 353±357 357

Appendix B. Compliance auditor draft competency stan- manuals and product speci®cations before and
dard performance criteria and evidence guide during auditing a food safety program.
2. Explain the importance of veri®cation of a food
1. Describe how to prepare to conduct an audit of a safety program:
food safety program: · list the necessary elements required on forms used
· identify the steps to be taken in an e€ective audit for documenting food safety audits;
of a food safety program; · explain the issuing of non-conformance notices
· explain what is required when seeking objective and follow-up procedures.
evidence; 3. Describe any relevant administrative arrangements
· describe various questioning techniques applicable for auditing accountability:
to auditing; · describe required reporting responsibilities;
· recognise the desirable skills and attributes of a · explain the relevant accreditation process for
good auditor; auditors.
· explain the need to review records, food safety