Risks arising from an improperly designed, implemented and maintained food safety system can have financially crippling effects - from brand damage, decreased consumer confidence, product recalls, illness, death and legal ramifications. Consequently, there has been a growing interest in an independently verified, process-based, global food safety management standard. However, many of the early schemes and standards developed were either regionally specific or only considered food safety risks within portions of the food sector and its supply chain. In 2005, this began to change when the International Standards Organisation (ISO) published ISO 22000, the first globally recognized Food Safety Management Systems standard that would consider food safety risks and impacts across the entire food supply chain.
Naturally, this was hailed as a great step forward; however, following the publication of ISO 22000, food safety specialists from the food manufacturing sector believed that the prerequisite programs (PRPs) of ISO 22000 standard were not prescriptive enough and did not fulfill the expectations and requirements of food manufacturing stakeholders in particular.
From an assessment and certification body's perspective, the PRPs were not auditable in a consistent manner because of the absence of important key component details on the prerequisites. This was seen as a deficiency and viewed as an impediment in the acceptance of ISO 22000 as a standard by the global food and beverage industry.
In an effort to harmonize the prerequisite programs; realize further acceptance of ISO 22000; and fulfill additional expectations and requirements of food manufacturing stakeholders, the Confederation of the Food and Drink Industries of the European Union (CIAA) sponsored the development of prerequisite programs that would take into account the specific requirements of the manufacturing stakeholders. The resulting PRPs formed the basis of a new Publicly Available Specification (PAS) 220:2008, published in October 2008 by BSI and intended to strengthen the food safety management system for food manufacturers.
Defining a Program for Industry-wide Acceptance
In an ideal world, one food safety certificate would be accepted by everyone. However, the multitude of schemes that are available around the world present a bewildering array of options that could potentially distract from their core objective - to improve food safety.
Although the key elements of ISO 22000 include interactive communication; system management; prerequisite programs and HACCP (Hazard Analysis and Critical Control Point) principles, sub clause 7.2.3 of ISO 22000, which lists the areas that the organization should consider in developing the PRPs, does not detail the specific requirements sufficiently.
To ensure the critical components of the PRP's for food manufacturing processes would be specifically defined and that aspects considered important in controlling hazards would be included within the manufacturing process, drafting of the PRPs was undertaken by representatives from some of the world's major food companies including Kraft, Danone, Nestle, Unilever, General Mills, and McDonald's, and leading experts in food safety and security from the FDF (UK Food and Drink Federation) and the CIAA with input from a wide range of manufacturers' representatives, retailers and certification bodies, including LRQA.
Together, they worked to create PAS 220:2008 which would be applicable to all manufacturing and food handling organizations, regardless of size or complexity.
"PAS 220 provides a common set of pre-requisite programs that can be used by any food manufacturer who wishes to establish an ISO 22000 certified food safety management system," comments Steve Mould, Technical Author of PAS 220 and Worldwide Quality Chain Management Systems Program Manager at Kraft Foods. "What sets this standard apart from others is the wide consultation and public reviews that were conducted by BSI during its development. This is a standard that the industry has created by working together."
PAS 220 details the PRPs used by food and beverage manufacturers and is intended to be used in conjunction with ISO 22000. Its focus is to ensure that processes are in place to minimize, mitigate or eliminate potential food safety hazards from affecting the products, including product contamination, food safety hazard levels and the product processing environment.
PAS 220 addresses concerns that existed with ISO 22000 and is designed, in combination with ISO 22000, to bridge the gap between ISO 22000 and the Global Food Safety Initiative (GFSI) requirements. GFSI was launched in 2000 with the mission: 'Continuous improvement in food safety management systems to ensure confidence in the delivery of safe food to consumers.'
Covering important aspects of food safety which can be often overlooked in the food manufacturing sector such as warehouse requirements, rework, food defense, biovigilance and bioterrorism, the publication of PAS 220 will substantially strengthen ISO 22000 and enhance initiatives to harmonize global food safety standards.
PAS 220 is made up of the core requirements specified in ISO 22000 under sub clause 7.2.3, but with the additional requirements that have been considered important and relevant to the food manufacturing process. A brief summary is given below; however, further details are available at www.food.lrqa.com
The scope - applicable to all food manufacturing organizations.
Normative reference identifies the reference materials.
19 terms and definitions to compliment the 82 in ISO 9001 and 17 in ISO 22000
The construction and layout of buildings for contamination control and prevention.
The layout of premises and workspace
Utilities - air, water, energy covering water quality, approved chemicals, ventilation etc.
Waste disposal - containers for waste or hazardous substances, waste management, drains and drainage.
Equipment suitability, cleaning and maintenance specifies that equipment should be made of material inert to the food being processed.
The management of purchased materials covers the selection of suppliers and the handling of received goods.
Physical, microbiological and allergen contamination is covered in the section dealing with measures for prevention of cross contamination .
Cleaning and sanitizing
Pest Control including pest control programs, preventing access, harbourage and infestations, monitoring and detection, and eradication.
Personnel hygiene and employee facilities - locker facilities, toilets, staff canteens and designated areas. It also addresses work wear, protective clothing, health status, illness and injury, employee cleanliness and behavior in a processing and warehousing environment.
Rework is an integral part of the process with regard to traceability and allergen control. Repackage is also considered as rework material.
Product recall procedures include the requirement for a key contact list and traceability of product produced under similar conditions as the recall product.
Warehousing - cleanliness, dryness, ventilation, dust and temperature control, separate areas for storage of chemicals, and designated areas for non-conforming materials. Warehouse practices such as FIFO/FEFO, vehicle upkeep and maintenance.
Product information/consumer awareness - how information is presented to the consumer to facilitate informed decisions.
Food defense, biovigilance and bioterrorism - protective measures to guard against acts of terrorism, tampering, sabotage and access control.
ISO 22000 and the impact of PAS 220
In December 2008, the Foundation for Food Safety Certification (SCV) announced that it will develop the ISO 22000 and PAS 220 certification scheme for food safety systems of food manufacturers. This development is supported by the Confederation of the Food and Drink Industries of the European Union (CIAA) and the scheme will be submitted to the GFSI to be benchmarked and approved.
Commenting on the initiative, Geoff Thompson, Chair of the CIAA Food and Consumer Policy Committee, said: "The ISO 22000/PAS 220 scheme marks a very significant step forward for all Food Processors. Both large and small manufacturers and retailers now have the opportunity to unite under a commonly agreed set of prerequisite programs for the international control of food safety hazards."
LRQA's Cor Groenveld, Chairman of the Board of the Foundation for Food Safety Certification added: "The objectives of our foundation are to facilitate a certification scheme that ensures high quality food safety audits in the whole food supply chain and to achieve harmonization in food safety standards and audits. Due to the fact that the combination of ISO 22000 and the PAS 220 is very similar to our GFSI HACCP approved standard we believe it is a logical next step to facilitate this harmonized scheme for Food Processors."
The development of a harmonized scheme through ISO 22000 and PAS 220 will deliver substantial benefits to consumers and every member of the supply chain from plough to plate. The prime advantages that can be expected include:
Improved food safety
Reduced costs from waste reduction
Better use of time and resources
Less product failures and better traceability throughout the supply chain (embodies and maintains the Codex Alimentarius HACCP)
As an international standard, ISO 22000 with PAS 220 can be used globally to benchmark organisations and to benchmark different facilities within international companies. This will help to improve performance internationally
Seamless integration with other standards such as ISO 9001, ISO 14001 and OHSAS 18001
Creates a culture of continuous improvement
The next step
In the light of the many food safety schemes that already exist, some organizations may be reticent to adopt a new standard. However, it is important for these businesses to appreciate that ISO 22000 and PAS 220 are not 'new schemes' - they are simply the next step on the path to the integration of a comprehensive food safety standard through the creation of a benchmarking process for food safety management schemes.
A study conducted by Cargill compared the elements found in the different audit standards/programs/schemes with 37 key criteria for PRP and HACCP in the Codex Alimentarius. The study found that most audit standards/programs/schemes meet more than 90% of the requirements for PRP and HACCP.
Any organization with an existing program based on the HACCP principles of Codex Alimentarius will probably have most of the elements of ISO 22000 and PAS 220 and the transition can be made by building on the existing platform. So, importantly, there is no need to start from scratch.
A gap analysis conducted by a reputable certification body will assist in identifying the areas that require further attention in order to meet the requirements of the Food Safety Management System.
In 2007 over 30,000 food safety certificates were issued under GFSI recognized schemes. This represented a 50% increase on 2006 levels, and with the developments outlined above, the global adoption of ISO 22000 is set to increase even more dramatically.
It is no coincidence that a number of important factors are being addressed at the same time: PAS 220 was developed by the industry for the industry; ISO 22000 is likely to be recognized by the GFSI now that PAS 220 has been published and the US food industry has now embraced GFSI standards. It is clear therefore, that the food and beverage industry is making great progress in the pursuit of its objective to deliver good quality safe food through the global harmonization of food safety management systems.
About the Authors
Cor Groenveld, Global Product Manager, LRQA food services, and Vel Pillay, LR QA Manager, the Americas - Food Safety Programs.Cor Groenveld is Chairman of the Foundation for Food Safety Certification, Member of the working group for developing ISO 22000, Member of the GFSI Technical Committee and Member of the PAS 220 Steering Group.
Vel Pillay manages LRQA's Food Safety Programs in the Americas. He has extensive experience in Food Safety Management Systems and represents LRQA in a group of leading North American stakeholders that was established to create harmonisation among food safety standards.
About Lloyd's Register
Lloyd's Register Quality Assurance (LRQA) is a member of the Lloyd's Register Group. Employing over 400 food-safety assessors globally, LRQA helps the food and beverage industry to ensure consumer safety and reduce risk through rigorous evaluation and certification of management systems and processes. Lloyd's Register is an independent risk management organisation that works to help improve its clients' quality, safety, environmental and organisation performance throughout the world, because life matters. Lloyd's Register stands apart: independent, objective, experienced and uncompromising in our commitment to help clients produce an overall positive impact on society and the environment. www.lr.org Registered charity number: 21567 R.
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