DR. P. VINCENT HEGARTY Founding Director and Professor Emeritus SOUTH AFRICA: Pretoria MARCH 2016 IMPLEMENTING SUCCESSFUL FOOD SAFETY SYSTEMS: IMPORTANT ROLES FOR EVERYBODY DR. P. VINCENT HEGARTY Founding Director and Professor Emeritus INSTITUTE for FOOD LAWS and REGULATIONS MICHIGAN STATE UNIVERSITY vhegarty@msu.edu www.iflr.msu.edu
IS OUR FOOD SAFE?
WE ARE ALL PARTNERS IN REGULATING FOOD SAFETY GOVERNMENT Create/Monitorr CONSUMERS FOOD INDUSTRY Implement UNIVERSITIES Analyze/Educate
No, those aren’t my diplomas. Nature Biotechnology,Vol. 17, May 1999 No, those aren’t my diplomas.
I don’t want to know what the law is, I want to know who the judge is I don’t want to know what the law is, I want to know who the judge is. Roy H. Cohn JUDGE
CODEX: SOUTH AFRICA ATTENDANCE (Number of attendees in brackets) CCFFP 2015 YES (5) Norway 2014 YES (4) Norway 2012 YES (6) Indonesia CCFH 2015 NO 2014 YES (1) Peru 2013 YES (3) Vietnam CCFL 2014 YES (2) Italy 2013 YES (2) Canada CCFA 2015 YES (1) China 2014 YES (1) China 2013 YES (1) China CCPR 2015 NO 2014 NO 2013 NO 2012 NO 2011 NO 2010 YES (2) China CCCF 2015 NO 2014 NO 2013 NO 2012 YES (1) Netherlands 2011 YES (2) Netherlands
CODEX: SOUTH AFRICA ATTENDANCE (Continued) CCNFSDU 2015 YES (3) Germany 2014 YES (3) Indonesia 2013 YES (1) Germany 2012 YES (3) Germany 2011 YES (3) Germany 2010 YES (4) Chile CCRVDF 2015 YES (1) Costa Rica 2013 YES (3) USA CCFFV 2015 NO 2014 YES (1) Thailand 2012 YES (2) Mexico CCFICS 2015 YES (4) Australia 2013 YES (1) Thailand CCPFV 2014 YES (1) USA 2012 NO CCMAS 2015 NO 2014 NO 2013 NO
SOUTH AFRICAN FOOD: US FDA IMPORT REFUSALS (2015) www. accessdata. fda SOUTH AFRICAN FOOD: US FDA IMPORT REFUSALS (2015) www.accessdata.fda.gov/scripts/importrefusals Medical Foods Misbranding Raisins Filthy Dates Filthy Vegetables Adulteration Candy List of ingredients Dietary Food Misbranding Mushroom Soup Unsafe color Dried Fruit Filthy Soft Drinks Unsafe color
WHY ARE THESE COMPANIES ON THE FDA REJECTION LIST? THEY ARE: IGNORANT CARELESS CRIMINAL OR SOME OR ALL OF THE ABOVE
THE BOTTOM LINE ON FOOD SAFETY: UNSAFE FOOD COULD COST YOU: YOUR life YOUR business YOUR job YOUR industry’s and YOUR country’s reputation
FOOD SAFETY: SOME HUMAN COSTS (2011) WHO: 200 diseases are spread through food EU: E.coli 0104:H4 750 deaths; >4,000 sick USA: Listeria, cantaloupes 31 deaths; 146 sick CHINA: Food safety law violations 290 people sentenced to prison or to death
REMEMBER YOU are an important link in the food chain from Farm to Fork Do NOT be its weakest food safety link Know YOUR food safety role in the food chain
ACTIVE MANAGERIAL CONTROL OF FOODBORNE ILLNESS RISK FACTORS YOUR FOOD SAFETY GOAL ACTIVE MANAGERIAL CONTROL OF FOODBORNE ILLNESS RISK FACTORS We should collectively keep in mind that the performance goal for enhancing the effectiveness of the nation’s retail food safety system is the reduction of foodborne illness risk factors. One of the most effective ways to postively impact continuous progress toward this goal is to ensure the individual operators responsible for the day-to-day management of foodservice and retail food store facilities implement food safety program that attain active managerial control of foodborne illness risk factors.
RISK ASSESSMENT (SOME EXAMPLES) HIGH RISK = 3; MEDIUM RISK = 2; LOW RISK = 1 PRIMARY PRODUCERS: Meat, poultry, dairy, fish/seafood 3 Fresh fruit and vegetables (primary producers 3 Honey (Production only) 1 MANUFACTURERS: Baby food (Non-milk based) 3 Cereal products 2 Bakery/Confectionery (Egg/cream based products) 3 Bakery/Confectionery (Chocolate/sweets/sugar) 2 Bakery/Confectionery (Bread, cake, etc) 1
RISK ASSESSMENT (Continued: RETAILERS: Delicatessen 3 Food stall (Ready-to-eat) 3 Food stall (Fruit and vegetables, sweets, etc) 2 Grocery (With portioning/open food) 3 Grocery (Pre-packed food only) 1 Ice cream sellers 3 SERVICE SECTORS: Caterers (Serving to final customer) 3 Hotel (Breakfast only) 1 Day Care (Regenerating and serving meals) 2
With respect to the Poor Personal Hygiene risk factor in full service restaurants, the food safety procedures that are most in need of attention include: -Proper adequate handwashing; and -Prevention of hand contamination – or in other words – eliminating bare hand contact with ready-to-eat foods. Assessing procedures related to employee hygienic practices, such as eating, drinking and smoking in food preparation areas is also worthy of attention.
For the Contaminated Equipment/Protection from Contamination risk factor, food safety procedures most in need of attention in full service restaurants include: -Cleaning and sanitizing food contact surfaces and utensils; -Preventing contamination by separating raw animal foods from ready-to-eat foods; -Separating different species of raw animal foods; and -Protecting food products from environmental contamination – such as leaking waste water from a condensate drain.
As discussed earlier, each of these foodborne illness risk factor categories is comprised of individual data items. These data items provide insights into what aspects of active managerial control for s risk factor should be assessed and verified to ensure appropriate measures are in place to control the food safety hazards of concern. For full service restaurants, improper holding/time and temperature control was identified as the foodborne illness risk factor with the highest Out of Compliance percentage. If we break this risk factor down into specific food safety practices, there is a need to review food safety systems related to: Maintaining cold holding temperatures for potentially hazardous food; -Cooling potentially hazardous food; -Date marking of ready-to-eat, potentially hazardous foods made on site and open containers of commercially processed, ready-to-eat potentially hazardous food -Maintaining hot holding temperatures for potentially hazardous food
Using the facility type Full Service Restaurants as an example, this bar graph indicates that failure to control product holding temperatures and times was the risk factor with the highest Out of Compliance percentage. Poor personal hygiene, contaminated equipment/protection from contamination and chemical contamination also had notable Out of Compliance percentages. Management systems that were implemented to ensure foods were adequately cooked and from safe sources appeared to be effective when compared to the other risk factors evaluated during this data collection period. The Report is designed to look at each of these foodborne illness risk factor categories as areas that should have a food safety management system in place to ensure their control.
Standards for Continuous Improvement *Self Assess Improve Measure The self assessment and baseline survey allows regulatory jurisdictions to determine where their program stands in relation to all the requirements of the Standards. Then it’s up to them to choose which Standard or Standards to begin working to meet. They decide where to place their resources to achieve the next level of improvement. The idea is to work toward achieving all the Standards over a period of time. What period of time? That’s up to the regulatory jurisdiction and the resources they have available. The Standards are tools that can be used in a continuous improvement cycle. Self Assess, then select the aspect of the program you want to work to improve, meet that Standard. Then self assess and move to the next Standard on your priority list. Plan
“SAFER FOOD, BETTER BUSINESS” (SFBB) www. food. gov “SAFER FOOD, BETTER BUSINESS” (SFBB) www.food.gov.uk/foodindustry/regulation/hygleg/hyglegresources/sfbb SFBB toolkit --- help on food hygiene regulations for: Caterers Retailers Different cuisines Other languages Childminders Care homes Colleges
THE BOTTOM LINE: SAFER FOOD, BETTER BUSINESS POOR FOOD HYGIENE IS BAD FOR BUSINESS Safer food can be achieved (usually) with low costs in time and resources The costs of not achieving are huge, even going out of business www.food.gov.uk/foodindustry/regulation/hygleg/hyglegresources
RECOMMENDATION: Adoption of Food Safety Management Systems (FSMS) and a Safer food, Better business slogan will give: Safer food Higher profits Increased competitiveness in domestic and export markets Better trained staff Consumer confidence Etc, etc, etc, etc.
WHO: 10 FACTS ON FOOD SAFETY www. who WHO: 10 FACTS ON FOOD SAFETY www.who.int/features/factfiles/food_safety/en 1. More than 200 diseases are spread through food Foodborne diseases are increasing worldwide 3. Food safety is a global concern 4. Emerging diseases are tied to food production Minimize the risk of avian influenza Preventing disease starts on the farm 7. Chemical hazards can contaminate food
WHO: 10 FACTS ON FOOD SAFETY (Continued: Everyone plays a role in food safety School is a place for food safety Five keys to food safety: 1. Keep clean 2. Separate raw from cooked 3. Cook all foods thoroughly 4. Keep food at safe temperatures 5. Use safe water and raw materials
CAN UNIVERSITIES ASSIST GOVERNMENTS and FOOD INDUSTRY?: YES by: Neutral analysis of food regulations Global perspectives on food safety / food laws Training courses, workshops, updates Distance education courses in food regulations and in food safety
CODEX DOCUMENTS AVAILABLE OVER THE INTERNET
FOOD LAWS & REGULATIONS The “letter of the law” Policy issues: Scientific Agricultural Economic Political Social Cultural Ethical Religious
THE FINAL “BOTTOM LINE” YOUR attention to food safety issues is important and ongoing YOU are key people in implementing and supporting a successful food safety system for YOUR: Company Industry Customers Country
THANKS GO RAIBH MAITH AGAIBH (Irish) TO: YOU IUFoST SAAFoST