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KEY ISSUES

HACCP IN SLDBs  

The HACCP system has been detailed in the basic texts of the Codex Alimentarius Commission in the HACCP Annex of the Recommended International Code of Practice - General Principles of Food Hygiene (CAC/RCP 1-1969, Revision-3, 1997).

The HACCP approach is being increasingly employed in the global food industry, particularly in large manufacturing operations, and its influence in facilitating the international trade in foodstuffs has grown considerably in recent years.

Small and/or Less Developed Businesses (SLDBs) are also coming under increasing pressure to apply HACCP to their operations. However, due to several barriers and limitations inherent in SLDBs, it is recognized that there may be implementation difficulties within these sectors.

The present HACCP guidelines acknowledge that HACCP can be applied flexibly in all food businesses, irrespective of their size or nature. However, as they are directed towards the approach that can be taken in larger food operations, the Guidelines provide little guidance on how the seven HACCP principles can be applied in practice in SLDBs.

The WHO Expert Consultation on Strategies for Implementing HACCP in Small and / or Less Developed Businesses (SLDBs), which took place in June 1999, has reviewed the difficulties and barriers experienced by SLDBs when applying the HACCP system. It has recognized that the current Codex Guidelines on the application of HACCP provide little guidance on how the seven HACCP principles can be applied in practice in SLDBs, and this factor inhibited the more widespread utilization of HACCP by SLDBs.

The Codex Committee on Food Hygiene subsequently acknowledged that the current Codex Guidelines on the Application of the HACCP principles are not well suited to use by small and less developed businesses (SLDBs). The barriers to implementing HACCP in SLDBs have been discussed extensively at recent Sessions of the CCFH (1997-2000), and the recommendations of the WHO Expert Consultation were taken up by the CCFH.

At its 32nd Session (1999), the CCFH considered a Discussion Paper prepared by the Netherlands and its drafting partners (including India) which provided guidance to governments and organizations on assisting small and less developed businesses in the implementation of HACCP. The Committee recommended that the Discussion Paper be revised to provide more explicit practical guidance on the implementation of HACCP by SLDBs

At its 33rd Session (2000), the CCFH considered a substantially revised Discussion Paper, which proposed enhancing the existing text of the HACCP Guidelines to provide additional guidance that reflected the circumstances of SLDBs, without altering the existing HACCP Principles. This Paper recognized that there should be no difference in the principles of HACCP, whether applied in small, medium or large premises.

The committee agreed to an amendment to the existing HACCP guidelines without altering the seven principles of HACCP to enhance the Annex's use by SLDBs. It authorized the drafting group to obtain comments, especially from developing countries, and revise the document. It requested the Committee to assist governments and businesses, particularly in SLDBs, to over-come the identified burdens and to provide additional guidance to facilitate HACCP implementation by SLDBs.

At the 34th Session (2001), a revised document prepared by the drafting group was discussed. This document contains two Annexes to help facilitate HACCP implementation by SLDBs:

Annex I - Proposed Revised Guidelines for Application of HACCP System, proposes nominal changes to the existing HACCP Guidelines to make them suitable to SLDBs.

Annex II - Obstacles to the Application of HACCP, particularly in Small and Less Developed Businesses (SLDBs) and Approaches to Overcome Them, discusses the obstacles to implementing HACCP, particularly by SLDBs, and provides recommendations to governments and businesses to help over come them.

Some delegations were of the opinion that the amended Annex I provided flexible guidance in implementing HACCP in SLDBs, while a number of other delegations, especially from some developing countries, including India, were of the view that still more flexibility was needed and that clarification of the term SLDBs as well as more detailed classification of the SLDBs were necessary.

The Proposed Draft Revised Guidelines for the Application of the HACCP System (Annex1) was advanced to Step 5 for provisional adoption by the 50th Session of the Executive Committee,

The Committee requested further comments on Annex II be sought to facilitate preparation by Netherlands of an up-dated version for consideration at the next Session of the Committee.

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