HACCP principles by Codex and the National Advisory Committee on Microbiological Criteria for Foods,
3, 4 and it was through these texts and some early regulatory
standards that HACCP really started to take off in the 1990s. Early on, HACCP was
reported by the World Health Organization (WHO)
5 as an effective and economical
way to prevent foodborne disease; this was a widely shared view that led some governments to believe that its implementation was a remedy for all food safety issues.
In some markets, HACCP was microbiology and compliance driven, while others
recognized its role in continuous improvement and doing the right thing.
Through the 1990s, there was much focus on HACCP training and the development of formal HACCP plans, with the later understanding of the importance of
also formalizing the supporting prerequisite programs to control the general operational hygiene conditions. However, foodborne illness outbreaks continued to occur, and auditors of HACCP systems started to see problems with both the design of
HACCP plans and their implementation.
HACCP was, and is, a logical approach to food safety control. By identifying the
hazards that could occur and potentially make consumers ill, appropriate control
measures could be designed and implemented. While great in theory, this was not
working well in practice; steps needed to be taken to ensure that systems were working effectively.
7 What was missing was the social science side and an understanding
of the crucial role of people from a scientific perspective.
Some aspects of people systems, such as knowledge and training, have long been
associated with food safety management systems (FSMSs) and HACCP in particular;
3, 6, 8–10 these are also items that have been identified as barriers to successful food
11 Also identified as important in early HACCP guidance was
3, 4, 8 which was thought to come from an understanding of the potential impacts of unsafe food on the consumer and the business: In
other words, senior managers seeing food safety management as the right thing to
do. HACCP awareness training was often suggested for senior managers and the
workforce in general to help share this understanding and commitment throughout
food companies, and the demonstration of commitment by managers was seen as
important for workforce commitment and behavior. These early clues to the impact
of people and culture on effective FSMSs have evolved into the considerations of
organizational and food safety culture today.
Even though the U.S. has started implementing the Food Safety Modernization
Act (FSMA; signed into law in January 2011) and numerous other countries have
updated their food safety systems, we continue to have increasing numbers of major
foodborne illness outbreaks. According to the WHO, there are about 420,000 deaths
a year from foodborne disease and about one-quarter of those deaths (~125,000) are
children under 5 years old.
Some key questions on the table are: Do HACCP-based FSMSs (
HACCP-FSMSs) still work? Is the problem with the core principle of our HACCP-FSMS?
Or is our food safety culture not truly developed? We propose that HACCP-FSMSs
work, but our food safety culture is currently in disarray. We need to be working
together to deliver safe food 24/7, and we need measurement systems to understand
the maturity and effectiveness of the food science and culture elements.
Some Symptoms of a Food Safety Culture in Disarray
Food hazards and business risks
While we might have good systems to identify, assess, and control food safety
hazards through HACCP, we need to recognize that our systems might not work if
our food safety culture is poor. We also must recognize business risks where procedures are not effectively understood, honored, or enforced. Economic adulteration
is a good example where food safety may not initially appear to be an issue, but the
melamine incident13, 14 proved otherwise. Another business risk example relates to
the arbitrary extension of shelf life of
frozen meat to prevent financial loss.
Food safety science may not have had
a problem with extending the code life,
but customers receiving the finished
product and the consuming public
reacted differently. Through not understanding the potential consequences,
the loss for both the manufacturer and
its customers was extreme. These two examples have their roots in culture. The
foundation of a company’s food safety
culture is defined in corporate values,
but other factors such as customs of a
population may play a role in employee
actions. Managers must recognize the
scope of actions that can create a food
safety hazard and business risk.
Quality department is the policing department
In the two prior examples, loss of
life and loss of business were the consequences of failing to have science and
values effectively deployed. These are
extreme examples, but each recall, withdrawal, and food safety-based embargo
represents a failure to effectively deploy
the necessary process to prevent. Does
our organizational culture promote
prevention? Do programs and projects
reflect an understanding of our values?
Our goal in manufacturing is to create
habits within our employees based on
doing the right thing. This applies to
every production worker and management associate or team member rather
than just food safety and quality. When
correct actions are performed without
thinking, then the culture has reached a
new level of maturity.
Settling for executing programs at the
existing level – Compliance vs. continuous
The development of preventive
practices designed to address defined
hazards and reduce business risk is
primarily led by the food safety department. Some misguided management
priorities that we have encountered include team members not having time to
work on a project that will significantly
improve food safety as well as provide
data to reduce risk because they are too
busy preparing next month’s customer