HACCP importance recognized but implementation criticized in EU.

A key factor is understand differences between prerequisites and HACCP and their respective roles.

Certain HACCP concepts are not clearly understood leading to inconsistencies in implementation and controls, according to a Food and Veterinary Office (FVO) report. However, in all Member States, there is a reasonable level of implementation of Hazard Analysis and Critical Control Points (HACCP) based procedures.

HACCP is a science based and systematic approach to identification of hazards and assessment of related risks, implementation of measures for control and monitoring compliance with set standards. National frameworks for implementing HACCP-based systems vary between and within Member States leading to inconsistencies of interpretation and implementation.

Some core concepts are not always understood, particularly by small food and beverage operators (FBOs), and are not applied in a consistent manner, according to the report.
‘Widespread lack of understanding’. There is a widespread lack of understanding by food business operators and competent authorities of the difference between prerequisites and HACCP and their respective roles. The main difficulties observed by MSs concerned the implementation of HACCP without a prerequisites being in place and the setting of Critical Control Points (CCPs) for hazards which should be controlled through the prerequisites.

Examples were seen of excessive emphasis being placed by some control authorities on the HACCP part of Food Safety Management System (FSMS) with prerequisites being largely ignored.  This is problematic as risks covered by prerequisites could potentially involve greater hazards. There is a widespread lack of understanding of how to undertake a hazard analysis correctly and this process creates difficulties particularly for Small FBOs due to lack of available expertise, according to the report.

The HACCP approach provides business operators the ability to make control measures, which can reduce to an acceptable level or eliminate hazards along the production chain.
HACCP is inherently flexible and consequently it is impossible to devise prescriptive guidelines. Overly prescriptive guidance could undermine the scope to apply flexibility.

Source: http://ec.europa.eu/food/fvo/news_detail.cfm?id=39