Food Safety Management
Developing an audit method to validate the usefulness of the CookSafe systems using the
indispensable HACCP format or steps would require an extensive look at how they obtain their
HACCP findings. Like in the case of establishing a Critical Control Point in the flow chart, what
is the critical point at which a Microbiological, Chemical and Physical hazards would most likely
occur? Another extensive look that must be focused (during operation) is the method being
employed to produce a result. Like in the case of microbiological testing, what means or
indicators are they exploiting to signify hazards? What are its limits? Are physical and chemical
hazards properly identified? And lastly, another extensive look must lie in seeking to indicate if
management is committed to implement the system.
There is really no homogeneous scheme in auditing these establishments for it is
necessary that they tailor their system according to their size, location, product, processing and
distribution conditions. But nonetheless there are common prerequisite conditions that each
segment of the food industry must provide, like the facilities must be located, constructed, and
maintained according to sanitary designs principles; the guarantee of effective supplier control;
precise use of tools and regular calibration of it, etc. This prerequisite program should be
properly documented and regularly audited though treated somewhat separately for it lies more
closely to Good Manufacturing Practices than in the work flow of processing the food.
Therefore, as a whole, both the HACCP and the prerequisite program combined in the
CookSafe would stand more superior when it comes to guaranteeing an effective and safer food
for consumers that these catering companies, either big or small, can provide. (National Advisory
Committee on Microbiological Criteria for Foods, 1997)
It should be mentioned that the role of auditing a catering business is not just a going-
over inspection but rather a “regulatory verification” since it involves the risk and the safety of
consumers at large. Therefore, standards of safety and quality reached by the regulatory board or
authorities and its model of operation must be narrowed down on how well the business is
maintaining these standards in its daily operation (Dillon 2001)
EC 852/2004 and CookSafe
Following are sections 12 and 13 of the EC 852/2004 which deals with food safety
requirements based on the HACCP principles (Official Journal of the European Union 2004)
(12) Food safety is a result of several factors: legislation should lay down minimum hygiene requirements;
official controls should be in place to check food business operators’ compliance and food business
operators should establish and operate food safety programmes and procedures based on the HACCP
(13) Successful implementation of the procedures based on the HACCP principles will require the full
cooperation and employees. To this end, employees should undergo training. The HACCP system is
an instrument to help food business operators attain a higher standard of food safety. The HACCP system
should not be regarded as a method of self-regulation and should not replace official controls
To come up with the requirements of the EC 852/2004 which seeks to incorporate the
HACCP system in good business operations, guidance materials were developed for use for
different types of food businesses. This guidance manual was given the name CookSafe which
was developed by the Local Authorities and the Scottish Food Advisory Committee. In a
nutshell, CookSake provides a step-by-step way of complying with food safety requirements. It
is suitable for us by caterers of all sizes and can be customized for particular business needs. This
method uses standard HACCP language and it provides ways to routinely monitor and record
business activities. CookSafe programs include flow diagrams, HACCP charts, house rules
which include 9 principles of good hygiene practice and records to be used for information
gathering, verification and review (Sprenger nd)
Auditing is not policing, it is a device to determine how efficient your business is in
terms of operation and economy. In auditing a food business for compliance to government
regulations it was discussed in the report of a joint FAO/WHO consultation on the role of
government agencies in assessing HACCP (Guidance on Regulatory Assessment of HACCP
1998) that such assessments may be carried out at two levels, either (1) internal assessments are
carried out by the industry and (2) independent assessments carried out by either regulatory
agencies or third parties.
It should be noted that competence is required in the auditing work, whether an auditor is
a single individual or a team. Due training is needed in order to be able to achieve competency.
Training is focused on the following areas (Guidance on Regulatory Assessment of HACCP
1998): (1) knowledge of and experience with HACCP systems and applications; (2) knowledge
of assessing prerequisites for HACCP; (3) ability to assess the effectiveness of control measures
and HACCP plan verification; (4) knowledge of auditing methodologies and (5) knowledge of
industry processes and (6) knowledge of industry codes of practice, legal requirements, etc.
The frequency of audit depends on many factors and subsequent frequencies could be
considered according to the results of their finding in the use of HACCP principles and plans. It
could also happen that an adverse occurrence or incidents of food poisonings in a certain locality
may call for the reassessment of food business affected by such. A set timeframe for audit cannot
be put in place, factors have to be considered for such an activity. Suffice it to say that all food
businesses need to have a regular assessment made in order to guarantee that they are complying
with strict food safety standards.
Outline of Audit approach, and how it will work
There are 6 areas that should be covered in auditing the performance of any establishment
to successfully draw a conclusive score and implement sanctions: The area of (1) Management
(2) Documentation (3) Usability (4) Training (5) Implementation and (6) Changes. All 6 areas
must contain a policy or the plan; a procedure of accomplishing the plan; and how it will be
recorded and for what purpose. Good audit however aims to seek out to confirm and to validate
the establishment according to this extensive scope (ISO22000 2005) in paper and in practice.
Tantamount to good audit is to first identify how the company has developed its control
system to carry out a standard quality product from the time they receive goods from their
supplier to the time when they serve their product to their clients. A good example to
demonstrate an effective food safety management system based on CookSafe that incorporated
HACCP is what Garrett (as quoted by Dillon 2001) has reported in his shift away from “end
product microbiological testing in determining individual lot compliance, as against
microbiological in plant process standards.” In other words, there are two ways of determining
compliance in processing; one is to determine whether there is complete absence of
microbiological organism while the other is determining the tolerance limit. Garrett therefore
believes that zero tolerance for specific pathogens may be replaced by regulatory performance
standards. He defines transparency from the rigors of unconditional standard as a ‘unique process
where the reasoning, the common sense of development, constraints, assumptions, decisions,
limitations and uncertainties of measurements are fully and systematically stated documented
and accessible for review.’ This platform however has initiated the establishment of an ongoing
focus within audit on the ‘hazard analysis’ module of key food safety systems, and must be
found as an effective and constructive and even economical component in all audits.
A good demonstration of this is the case of an auditor’s insistence that condensation (a
film of water droplets that forms on a cold surface when warm air is fused in) should not be
found in the processing plant because it is a general assumption that when there is condensation
there is contamination. However, opening and closing the door of a 9 degree centigrade
processing plant would allow the warm air from outside to enter and generate condensation
usually found in the ceiling. From the ceiling, when these droplets of water with microbes fall
into the meat being processed, it would cause E-coli to germinate in the meat and the shelf life of
the meat is shortened. Now if for some reason an auditor sets a standard and places condensation
in its check list as zero tolerance, chances are that either management will have to invest hefty
amounts to install infrared devises to eliminate condensation or fix up a remedy so that when
audited and only upon being audited, these condensation will not occur. Sad to say, but proper
understanding of the problem is just simply tracing back why if there is condensation there
inevitably is contamination. It was however found that the ceiling, being the highest place of the
processing plant, is likely the most difficult to reach by the cleaning team and the more likely
place where the chemist, who gathers specimens for laboratory samples, would likely collect. A
good auditor then should focus in first analyzing the hazard before setting them as standards to
be followed and in continuous review of standards through benchmarking.
Key aspects of HACCP audit and how it was built in audit approach
With the foundational principle stated above which every good auditor must obtain, a
good look at the critical control points being established must be determined and checked how
well it meets a set of expectations. It is primarily being assessed to established whether the food
business has the ability to consistently manufacture and/or distribute safe food, i.e., to ascertain
that the HACCP system is effective. Proper assessment of the HACCP will need to determine
whether (1) all required elements are present in the plan and addressed adequately, (2) the system
will satisfactorily maintain food safety; and (3) the actual events comply with the documented
procedures described in the plan.
Agents responsible for auditing HACCP need to obtain 3 sets of evidences. First are the 7
principles of HACCP and whether this has been effectively applied; secondly is whether or not
the prerequisites for HACCP is adequately observed; and thirdly, whether HACCP plan has been
correctly implemented and maintained. These 3 sets of evidences are explained below:
The 7 principles of the HACCP (Association of food and drug officials 2006) are as
(1) analyze hazards – Potential hazards associated with a food and measures to control
these hazards are identified. The hazard could be biological, such as a microbe; chemical,
such as a toxin; or physical, such as ground glass or metal fragment.
(2) Identify critical control points. These are points in a food’s production – from its raw
state through processing and shipping to consumption by the consumer- at which the
potential hazard can be controlled or eliminated. Examples are cooking, cooling,
packaging, and metal detection.
(3) Establish preventive measures with critical limits for each control point. For a
cooked food, for example, this might include setting the minimum cooking temperature
and time required ensuring the elimination of any harmful microbes.
(4) Establish procedures to monitor the critical control points. Such procedures might
include determining how and by whom cooking time and temperature should be
(5) Establish corrective actions to be taken when monitoring shows that a critical limit
has not been met – for example, reprocessing or disposing of food if the minimum
cooking temperature is not met.
(6) Establish procedures to verify that the system is working properly – for
example, testing time-and-temperature recording devices to verify that a cooking unit is
(7) Establish effective recordkeeping to document the HACCP system. This would
include records of hazards and their control methods, the monitoring of safety
requirements and action taken to correct potential problems. Each of these principles
must be backed by sound scientific knowledge: for example, published microbiological
studies on time and temperature factors for controlling foodborne pathogens.
The following are the prerequisites for HACCP (HACCP, a Food Management System,
and Catering 2006):
1. cleaning and sanitation
3. personnel hygiene
4. pest control
5. plant and equipment
6. premises and structure
7. services (compressed air, ice, steam, ventilation, water, etc.)
8. storage, distribution and transport
9. waste management
10. zoning (physical separation of activities to prevent potential food contamination)
An HACCP plan is a written document that describes how you plan to manage and
control your organization’s food safety hazards. An HACCP plan contains at least the following
1. Critical control points (CCPs).
2. Hazards that will be controlled at each CCP.
3. Control measures that will be used at each CCP.
4. Critical limits that will be applied at each CCP.
5. Procedures that will be used to monitor CCPs.
6. Actions that will be taken when limits are violated.
How it is built in our audit approach
In our audit approach the following areas are to be considered:
1. HACCP management
2. Development of the HACCP plan
3. Hazard analysis
4. Effectiveness of control measures
5. Verification procedures
6. Documentation and implementation.
HACCP management. Compliance in management’s ability to implement HACCP is not
always easy to measure. But there are some measures which can indicate the level of
commitment of the management in ensuring food safety and compliance with HACCP. It is good
to note how the business has fared in previous audits. Have they complied with HACCP
procedures? What is the level of food hygiene training and its application? Is there technical
knowledge within or available to the company? Does it present a satisfactory documented
procedures and food safety management systems?
Development of HACCP plan. This will include an evaluation of the basis for the
development of the HACCP plan, the accuracy of the product and process description, including
information and consideration of the intended use of the product. It also includes an evaluation of
the flow diagram of the process under assessment and consideration should be given to its
accuracy; the expertise used and how this has been utilized in the development of the HACCP
plan. Due consideration should be given to the adequacy of the prerequisites for HACCP.
Hazard analysis. This will include checking whether all significant hazards have been
identified, ensuring that this has been undertaken for all products and processes. All supporting
evidence in the form of records of validation, sampler results, and history of the safety of the
product, generic plans, relevant and appropriate predictive models should be checked and
Effectiveness of control measures. It has to be checked whether control measures
eliminate or reduce identified significant hazards to acceptable levels; all CCP’s have been
identified, that appropriate critical limits have been determined. An evaluation should be made of
the critical limits in relation to how realistic they are their measurability and relevance. There
needs to be a way to validate how these were determined, including the expertise used and any
Evidence should be obtained that the monitoring of critical limits indicates adequate
control of the hazards. The adequacy of training in relation to personnel working at CCP’s and
engagement in monitoring should also be considered as should whether suitable instructions have
been given to such personnel, and their role in relation to appropriate and timely actions.
An assessment should also be made as to whether the corrective actions would
adequately restore control and are adequate to prevent an unsafe product from reaching the
Verification procedures. The audit should consider what, how, when and by whom the
verification procedures have been undertaken, and whether these are adequate and effective. This
may be indicated by an assessment of the validation data, sampling results, internal and external
audit documentation as well as the frequency and thoroughness of all verification activities. The
assessor should also consider whether changes, deficiencies in the HACCP plan, new emerging
hazards, etc. is adequately provided for. Assessors should consider what actions are taken as a
result of inadequacies in the HACCP plan or its prerequisites, or any other non-conformity.
Documentation. The following documents should be assessed:
1. the description of the product and its intended use
2. the process flow diagram with the location of the CCP and related parameters
3. the HACCP worksheet on which are mentioned the hazards, the control measures, the CCP’s,
the critical limits, the monitoring procedures and the corrective actions
4. the list of verification activities
5. the results of monitoring and verification according to the HACCP plan, and
6. appropriate records necessary to assure the adequacy of prerequisites for HACCP
The Implementation. It has to be examined whether the HACCP plan and the
prerequisites for HACCP have actually been implemented in the food business, maintained and
is functioning correctly. Assessors should consider whether records were in order, i.e., whether
recordings of monitoring and verification results were as described in the HACCP plan.
Auditing 2 businesses and the types of records you would expect to see
I. A takeaway sandwich business employing 2 staff
Eating out has increased considerably over recent years, with 2/3 of the population
occasionally or regularly using takeaways to eat out. Sandwiches are a popular food; a fifth
of the total market volume (1.796 million) of sandwiches are purchased from sandwich bars
or cafés, and chicken sandwiches account for the third most popular sandwich filling.(Little,
et al 2001)
Inadequate cooking or reheating (50%), inappropriate storage (45%), and cross
contamination (39%) have been identified as important contributory factors of foodborne
outbreaks in England and Wales, highlighting the importance of food handlers in good
hygiene practices.(Little et al 2001)
The British sandwich association has provided additional food hygiene guidance for
sandwich manufacturers and sandwich bars. The preparation of sandwiches involves much
handling during preparation of the filling and sandwich assembly, which adds to the
likelihood of contamination unless high standards of hygiene are maintained. Previous
studies have shown that sandwiches frequently have high levels of microorganisms and less
frequently, a range of potential pathogens. These studies also highlighted a lack of awareness
among staff concerning the importance of temperature control in the display of sandwiches.
Sandwiches have been linked to reported outbreaks of food poisoning, with outbreaks of
Salmonella spp. and Escherichia coli O157 traced to sandwiches. (Little et al 2001)
Auditing Takeaway sandwich business
1. Food hygiene inspection – Do they have Food hygiene inspection Certificate to assess
hygiene and compliance with public health protection aspects of food law? Inspection of
food premises must be taken into consideration because they may pose a great risk to
consumers. The nature of the food and the degree of handling it receives, the method of
processing, the potential number of consumers at risk, the current level of compliance,
and the confidence in management/control systems are all taken into consideration.
2. Hazard analysis system – Is there a hazard analysis system in place on critical points
identified in the following: cooking temperature that must be attained or an established
cooking time, appropriate temperature of storage facilities, tools and utensils used for
specific preparation in filling and in the assembly? Are all these properly documented
and clear signs or illustrations visible as reminders to staff or handlers? Are storage
facilities, especially detergents and chemicals, safe enough not to cause contagion
especially in such a small work area? How is handling money set aside from food
3. Food hygiene training – Has the management and staff received some form of food
hygiene training? How is the staff outfitted?
4. Food handlers and hand washing facilities – how many food handlers are there? In our
case there are 2. Are there hand washing facilities accessible and available for use? Is the
water they use analyzed? Is a water heater available?
5. Waste disposal – Are there containers with fitted lids where food waste are placed and
removed frequently from food handling areas? Are food waste containers frequently
cleansed and disinfected? Are food waste units regularly being collected for disposal?
It has been established that sandwiches are a perishable food product. In an audit
assessment report it has to be evaluated whether or not high standards of hygiene are
observed in their preparation. Food ingredients must be of acceptably microbiological
quality; storage and display temperatures must be correct; there should be separation of
low/high risk areas; direct handling of high risk foods and fillings must be minimized;
frequent hand washing by food handlers must be encouraged to minimize contamination
risks; and there should be effective cleaning procedures.
II. Large Restaurant Operation which provides outside catering functions
Operating a catering business subsequently follows a sequence which start with purchase,
delivery, storage, preparation, defrosting, cooking, cooling, reheating, displaying and etc. and
every stage of each step in processing must be a concern for it contains an element of risk,
what can be done about it and at what point must it be rejected, what are the indications and
warning clues that must be observed to either take, discard, or salvage, what means are use to
scrutinize and validate, and what corrective action must be taken. And in a much larger
catering business where various processes are undertaken almost simultaneously, cross
contamination become an inherent intensification of that risk particularly in the use of tools,
instruments, implements, appliances, devices and gadgets. Therefore careful scrutiny of each
stage and the function of completing a process or carrying out a task must be vigilantly
charted, supervise and monitored, and finally recorded.
Auditing large restaurant which also provides hot and cold food for outside catering
In our case, it is very important to take a reputable supplier properly equipped with
business registration in the local enforcement authority, has a safety management system,
supplies a fully referenced invoice, has a certificate or quality assurance, and a reputable
manner of transport and packing their goods in a hygienic way, and their goods are properly
labeled to include production date and expiry dates.
In the cold storage facility, is it sufficient to carry the requirement of the restaurant and
capable of generating the required temperature? do they have preventive maintenance?, a
good source of standby power?, etc. It must also have a system in rotating stocks to make
sure that the ‘first in first out’ practice is followed. How is the cold ready-to-eat food
separated to prevent contamination? On their other storage facility, do they carry out stock
checks, and are they properly labeled?
Is there strict implementation of what goes in and out of the processing area? This must
be accounted for, for proper monitoring and control. For example, auditor’s jewelries, tools
that are going to be used inside (portable, small tools like knives, scissors, etc.), etc. are to be
accounted for and inspected.
On food preparation, do they regulate the time the food spends outside the fridge? Do
they try to handle food as little as possible? What about the other areas of food
contamination, are they carefully eliminating possible causes of deterrents coming from
clothes, hands, surfaces, utensils and etc? How are they recording and monitoring their
Critical Control Points? How are they preventing cross contamination? Are they color coding
their chopping boards or knives? Do they have separate tables for various types of foodstuff
or method of sanitizing them from each distinct uses?
On display in their catering business, how are the cold and the hot food being served?
Are they mindful of temperatures and how long can it stay at a specified temperature? Are
these displayed food protected from other contamination? Are serving spoons being use
supervised or monitored? How do they transport their food?
On defrosting, do they thoroughly defrost frozen food to keep fixed cooking time
unvarying? What measure are they using to tell that it is fully defrosted?
In cooking and reheating, do they review cooking and reheating methods and the
Are allergens indicated in the menu? Do they have action plan in case a customer is
having a severe allergic reaction? (Safe Catering Plan 2007)
On cleaning up, do the detergents used adhere to acceptable chemical content of
detergents and other cleaning solutions?
There are various negative reactions in reference to incorporating HACCP into Cooksafe.
Some say that it is never designed for catering because it is not a production line and only
borders on a complex process. Others say that there is high turnover of staff and overly
demanding monitoring requirements; that record keeping is too complex and time
consuming. However, achieving of a comprehensive management system can only result to
the opposite of what they say in terms of production line and the complex processes.
HACCP has stood out as a system that simplifies the stringent need to manage and handle
every possible movement that occurs while preparing and serving food into just a few critical
points where attention is most needed. In terms of economy, getting it right on its earliest
stage reduces the amount of wasted material and time; since there is orderliness created -
there is productivity, customer complaints are reduced, machine efficiency and
manufacturing capacity is increased. In marketing, customers’ needs and confidence are
consistently met and this opens the opportunity to increase sales success. Within operations,
since staff knows what is expected of them, morale and communication is improved, greater
confidence in the operation and continuous improvement is endorsed. And on the
documented written evidence, it not only fulfills the legal requirement when the need arises,
it does not only fulfill the legislative requirements, it also has its ability to improve through
audits and reviews, which is why it always shows to mean that a quality system is not quality
if it does provide documented evidence of its functioning through written procedures. (Dillon
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”Corrigenda to Regulation (EC) No 852/2004 of the European Parliament and of the Council
of 28 April 2004 on the hygiene of foodstuffs” 2004, Official Journal of the European
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Dillon, M, Griffith, C., ed 2001, Auditing in the food industry, Woodhead Publishing Ltd.,
Everything you need to get your safe catering plan up and running 2007, Safe Catering.
Available from: http://www.food.gov.uk/multimedia/pdfs/safecater0703.pdf
HACCP, A Food Safety Management System, Catering nd, Food Safety, Authority of Ireland.
Available from: http://www.fsai.ie/industry/haccp/industry_haccp_meeting020711.asp
Hazard Analysis and Critical Control Point Principles and Application Guidelines 1997.
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Little, CL, Mitchell, RT and Barnes, J 2001, Food Standards Agency Catering Hygiene
Initiative: Microbiological Examination of food from Take-aways and Sandwich Bars,
Food Standards Agency. Available from:
Paterson, GM 2005, CookSafe, Food Safety Assurance System, Food Safety Standards.
Available from: http://www.food.gov.uk/multimedia/pdfs/cooksafe.pdf
Report of a joint FAO/WHO consultation on the role of government agencies in assessing
HACCP 1998, Guidance on Regulatory Assessment of HACCP. Available from:
SALSA (Safe and Local Supply Approval) 2007, Food And Drink Federation. Available from:
7 Principles of HACCP 2006, Association of Food and Drug Officials. Available from:
Spranger, RA nd, Updating Food Safety Legislation and HACCP, EC Regulations. Available