Transitioning to HACCP Compliance: An Overview of Updates to Codex Standard CXC1, 2022 Revision
published at - 23 March 2024

An Overview of Updates to Codex Standard CXC1, 2022 Revision

Given the remarkable advancements introduced in the Codex standard, "General principals of food hygiene CXC1, revised in 2022", we are transitioning our system to HACCP compliance from the outset of the year. Accordingly, we will conduct a comprehensive review of the new requirements and modifications in concept classification. Notably, all Pre-requisite programs are delineated in GHP format within the initial section of the standard, while the requirements of the 12 steps are outlined in the subsequent section. This article endeavors to provide an overview of these alterations.

This document comprises two sections: Good Hygiene Practices and the Hazard Analysis and Critical Control Point (HACCP) System along with Guidelines for its Application. The former lays the foundation for all food hygiene systems, ensuring the production of safe and appropriate food. Meanwhile, the latter delves into HACCP principles applicable across the food chain, from primary production to consumption. Implementation should be driven by scientific evidence regarding health risks. Annex I's Table 1 offers a comparison between control measures employed as GHPs and those applied at critical control points (CCPs), complete with illustrative examples.

1- MANAGEMENT RESPONSIBILITIES

This section introduces a significant update to the standard, particularly emphasizing the management's robust commitment. Under the category of Management Commitment to Food Safety, it highlights the importance of establishing a positive food safety culture, emphasizing the influence of human behavior on ensuring the safety of food. Key components for fostering this culture include firm commitment from management and staff, effective leadership, awareness of food hygiene, transparent communication, and resource availability. Management's responsibilities encompass ensuring the effectiveness of existing food hygiene systems, which involves clear communication, system integrity maintenance, control implementation verification, personnel training, regulatory compliance, and continual improvement.

In summary, the latest revision underscores the critical role of management commitment in fostering a positive food safety culture and ensuring the efficacy of food hygiene systems through clear communication, verification, and continuous improvement efforts.

2- GOOD HYGIENE PRACTICES-GHP

-ESTABLISHMENT –DESIGN OF FACILITIES AND EQUIPMENT: Attention to good hygienic design and construction, appropriate location, and the provision of adequate facilities is necessary to enable contaminants to be effectively controlled.

-TRAINING AND COMPETENCE: Training plays a fundamental role in every food hygiene system and the proficiency of staff members. Sufficient hygiene training, along with proper instruction and supervision of all personnel engaged in food-related tasks, are essential factors in guaranteeing food safety and its appropriateness for consumption.

-ESTABLISHMENT MAINTENANCE, CLEANING AND DISINFECTION, AND PEST CONTROL: To establish effective systems that encompass appropriate establishment maintenance, cleanliness, and, when required, sufficient disinfection, pest control, waste management, and monitoring of cleaning, disinfection, pest control, and waste management procedures. The rationale behind this approach is to enable the ongoing, effective control of food contaminants, pests, and other agents that may pose risks to food safety and suitability. These comprehensive systems are essential in safeguarding the integrity of food products throughout their production and handling processes, ensuring that they meet the required standards for safety and quality. By implementing rigorous protocols and continuously monitoring their effectiveness, food businesses can mitigate potential risks and uphold their commitment to delivering safe and suitable food to consumers.

-PERSONAL HYGIENE: It is imperative to guarantee that individuals who have direct or indirect contact with food adhere to specific standards, including maintaining optimal personal health, upholding a satisfactory level of personal cleanliness, and conducting themselves in a manner appropriate for their role. The rationale behind these requirements stems from the understanding that personnel who fail to maintain adequate personal cleanliness, are afflicted with certain illnesses or conditions, or demonstrate inappropriate behavior, pose a significant risk of contaminating food. Such contamination could potentially lead to the transmission of illness to consumers through the consumption of contaminated food items. Ensuring compliance with these standards is vital for upholding food safety and protecting public health. By promoting and enforcing practices that prioritize personal health, hygiene, and appropriate conduct among food handlers, businesses can significantly mitigate the risk of foodborne illness outbreaks and uphold consumer confidence in the safety and quality of their products. Additionally, fostering a culture of accountability and diligence in maintaining these standards reinforces the commitment of food establishments to delivering safe and wholesome food products to their customers.

-CONTROL OF OPERATION: In order to manufacture food that meets safety and suitability standards for human consumption, it is essential to establish design specifications concerning raw materials, ingredients, composition, production methods, processing techniques, distribution channels, and consumer usage that align with the requirements of the food business. Additionally, it is necessary to develop, enact, monitor, and periodically reassess effective control mechanisms tailored to the specific needs of the food business. The underlying rationale for these measures is to prevent the possibility of food becoming unsafe or unfit for consumption due to inadequate control over operations. By implementing comprehensive control systems, businesses can ensure that all stages of food production and distribution adhere to the necessary standards, thereby minimizing the risk of potential hazards and safeguarding the integrity of the final food products.

-PRODUCT INFORMATION AND CONSUMER AWARENESS: Adequate food information is crucial to ensure safe handling, storage, processing, preparation, and display for both subsequent Food Business Operators  in the food chain and consumers. This includes clear identification of allergens and easily recognizable lot or batch information for potential removal or return if needed. Additionally, consumers must receive sufficient guidance on food hygiene to understand label information, make informed choices regarding allergens, and prevent contamination or growth of foodborne pathogens through proper storage, preparation, and utilization. The rationale behind this emphasis is to mitigate mishandling risks in the food chain due to insufficient information or knowledge of food hygiene, which could lead to illness or render products unsuitable for consumption, posing serious health hazards, especially for allergic individuals.

-TRANSPORTATION: During transportation, precautions should be implemented as needed to: safeguard food from potential contamination sources, including allergen cross-contact; shield food from damage that could compromise its suitability for consumption; and maintain an environment that efficiently regulates the proliferation of pathogenic or spoilage microorganisms and the production of toxins in food. The rationale behind these measures is to prevent food from becoming contaminated or arriving at its destination in an unfit condition for consumption. This underscores the necessity of adopting effective hygiene protocols before and during transport, even if proper hygiene measures have been observed earlier in the food chain.

3-HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM AND GUIDELINES FOR ITS APPLICATION:

In the 12 steps, no fundamental change has occurred except in step 11, where significant emphasis has been placed on validation. Validation of the HACCP plan is a prerequisite before its implementation. This involves ensuring that various elements collectively provide control over significant hazards relevant to the food business. These elements include hazard identification, critical control points, critical limits, control measures, monitoring frequency and methods at CCPs, corrective actions, verification frequency and methods, and the information to be recorded.

During the development of the HACCP plan, validation of control measures and critical limits takes place. Methods for validation may involve reviewing scientific literature, utilizing mathematical models, conducting validation studies, or employing guidance from authoritative sources. If external HACCP guidance is utilized to establish critical limits instead of input from the HACCP team, caution must be exercised to ensure these limits are applicable to the specific operation, product, or product groups. Following the establishment of verification procedures during the initial implementation of the HACCP system, evidence should be gathered during operations to demonstrate consistent control under production conditions. Any changes with potential implications for food safety necessitate a review of the HACCP system and, if required, a revalidation of the HACCP plan.