Not a Gallows, but a Decision Tree- part 2

The ISO 22000 implementation guide was updated by FSSC in 2019, and the standard known as the General Principles of Food Hygiene – HACCP Codex was revised by WHO in 2021.

For this reason, we wanted to share the continuation of our article titled “Not a Gallows, but a Decision Tree,” which we published in 2017 on risk analysis methods.

Since 2019, the concepts of hazard, risk, and preventive measures have been frequently discussed in our homes, workplaces, and even friendly conversations due to the global impact of the Covid (a type of SARS virus) pandemic. Risk assessments, preventive measures, and even the adequacy of these measures were debated worldwide simultaneously. While mask-wearing, social distancing, and handwashing were declared as prerequisites, patient isolation was managed like a Critical Control Point. Although isolation did not reduce the rate of illness or death, it certainly helped prevent the spread.

In terms of food safety, the Codex states that any methodology can be used to determine a Critical Control Point. What matters is the ability to prevent the hazard and whether the control point is appropriate.

The FSSC standard has updated the decision tree previously published in the ISO 22004 implementation guide, which we had simplified into four questions

We recommend reviewing the old and new questions below.

ISO 22000 Risk Assessment Decision Logic

The new five-question decision tree, which highlights the approach of ISO 22000:2018, also reveals the differences between OPRP (Operational Prerequisite Program) and CCP (Critical Control Point) definitions.

Previously, it was crucial for the control point to be the final stage, whereas now, the ability to conduct logical monitoring has become more important.

Action criteria, potential nonconforming product separation, and informing the customer or consumer about the risk when necessary have been detailed for the OPRP control point. For CCPs, frequent monitoring of critical limits and serious management of nonconforming products in case of deviation have been emphasized.

Here, we find it useful to remind the question: “What would be the probability and severity value if there were no preventive measures?” This question must be correctly defined. Sometimes, when monitoring is not performed, it is difficult to detect the risk at that point. For example, imagine you are producing beverages and receiving complaints about foreign matter. Suppose you analyze this hazard at the filling point and install a filter. Complaints previously received from customers will now be filtered and recorded in your monitoring logs. Physically observing the hazard on the filter at monitored points makes it somewhat easier to detect.

In food processing methods involving microbiological hazards, these analyses often lead to debates. For instance, one might think, “Without cooking, there wouldn’t be a meal or cake anyway, so cooking isn’t done for microbiological purposes.” However! If a raw or undercooked cake contains spore-forming bacteria, it may pose a risk to the consumer. Therefore, the cooking process must be analyzed in terms of which microbiological hazard it targets. In this regard, food science sources that explain product safety rationality with scientific foundations should be considered.

Validation studies of preventive measures should be aligned with product safety rationality. Food businesses are not expected to conduct such studies like a laboratory or university. However, it is expected that these studies be accessed from reliable sources and reviewed by a technically competent Food Safety or HACCP team.

Ultimately, what matters is conducting a food safety hazard analysis and monitoring the preventive measures as planned. When there are changes or developments in the scientific knowledge underlying the hazard analysis, a review is also expected. If risk analyses conducted with the knowledge of business owners show that certain hazards cannot be prevented, then sharing the risk with the customer or consumer becomes the most important issue. As the importance of risk communication has been recognized worldwide, we hope that this communication will also reach better levels in food production.

Together and in good health…

Fatma İnceoğlu 10.4.2021

Ulaşmak isteyebileceğiniz Kaynaklar:

FSSC: https://www.fssc22000.com/wp-content/uploads/19.1210-Guidance_ISO-22000-Interpretation_Version-5.pdf (has been updated)

HACCP Codex: http://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXC%2B1-1969%252FCXC_001e.pdf