A New Methode of HACCP

A new method of HACCP for the catering and food service industry

Eunice Taylor *

Professor of Food Safety Management, International Centre for HACCP Innovation, The University of Salford, Greater Manchester MS 4WT, UK

Received 26 September 2006; received in revised form 13 February 2007; accepted 16 February 2007

Abstract

This paper presents the rationale and use of a new method of applying Codex HACCP principles designed specifically for caterers. It

charts the process by which the method was developed, set against the backdrop of international efforts to give support to initiatives that

more appropriately meet the needs of small and less developed businesses (SLDBs). The method was extensively piloted, evaluated and

validated by the UK Food Standards Agency (FSA) and deemed compliant with 2006 EU HACCP requirements. The original ‘Salford

Model’ was extended and published as Menu-safe, a system that can be used by catering businesses of all types and sizes. Its shortened

version, Safer Food Better Business (SFBB), has been developed by the FSA into a ready-to-use package for very small catering

businesses.

_ 2007 Elsevier Ltd. All rights reserved.

Keywords: HACCP; Catering; Menu-safe, Safer food better business

1. Introduction

In 1993 the European Union issued a food hygiene

directive (EU, 1993) establishing a general requirement

for all food business to adopt a risk based food safety management

system with the principles of the internationally

accepted system hazard analysis critical control point

(HACCP) recommended. However, each country in the

EU interpreted the Directive into their national regulations

in different ways – some requiring all the principles of

HACCP others only some of them. This led to widely differing

levels of interpretation. As a consequence members

of the EU, as part of a wide consolidation of food safety

legislation, negotiated legal requirements that could be

applied to all businesses across the food industry. This

Regulation, with no option for national amendment, came

into force across Europe in January 2006 (EU, 2004). It

requires all food businesses to implement a ‘system based

on HACCP principles’.

1.1. HACCP

In 1993 the Codex Alimentarius Commission elaborated

a 12-part method for the application of HACCP (See Fig 1).

This has achieved international recognition and as such, has

become the definitive method of applying HACCP principles.

In many countries of the world it is now a standard

for both export and the supply of food to major retailers.

However, whilst ‘the primary movers in the HACCP system

tended to be the larger food manufacturers. . . the applicability

of the HACCP system to small and medium sized

enterprises (SMEs) has always been questioned’ (Mayes &

Mortimore, 2000). Indeed, extensive research and practical

experience led the Codex Food Hygiene Committee to initiate

the production of guidance documents that would promote

flexibility in the interpretation of the method (WHO/

FAO 2000, 2006) for such businesses. The term small and

less developed businesses (SLDBs) was coined to encompass

the scope of this target group.

The Codex 12-part method was coined ‘Classical

HACCP’ by the Food Standards Agency (FSA) at the start

of this project and has served as a useful benchmark for the

development of alternative systems of applying HACCP

principles. It is used throughout this text to ensure clarity

and consistency with FSA documents and texts.

1.2. The catering industry and HACCP

The UK catering industry is the largest sector of the

food industry and accounts for approximately 60% of all

food businesses. It comprises restaurants, cafes, take-aways,

street vendors, hospitals, schools, prisons, residential

homes, hotels and other premises where food is produced

for immediate consumption. Many of these businesses are

small (Airey, 2001), yet commonly operate a far more complex

‘production’ system, with large numbers of inputs,

processes and outputs, than the typical food manufacturer.

It is hardly surprising, therefore, with no contractual incentives,

that there has been little progress with HACCP

within catering businesses, as evidenced in a recent review

by Taylor (2006).

1.3. UK Government initiative to improve HACCP uptake

in the catering industry

With ambitious targets to reduce food borne disease and

increase HACCP uptake, the Food Standards Agency

announced plans (FSA, 2001) to target the well-documented

problems of food safety management within the

catering industry. These were summarised by the Chair of

an existing Working Party that had, in 2001, failed to find

a successful model of HACCP for the industry. This was

despite the adaptation and wide scale testing of materials

used successfully by large caterers such as McDonalds,

Whitbread’s, Greenhall’s and others.

‘. . .the basic tenants of HACCP are dissonant with

many small businesses, who rely on common sense,

experience and a modicum of good luck to meet their

requirements in relation to food safety. The structured

approach. . .[is]. . .alien. . . and can seem like a succession

of mountains of which they have no inclination – or confidence

– to climb. . .’ (Miller, 2002)

In 2002, a team at Salford University funded by the

Food Standards Agency were tasked with rethinking the

problem and developing an innovative new approach to

the application of HACCP principles in the catering

industry.

2. Methodology

This research study utilised an ‘action research’ methodology

(Lewin, 1947) whereby experiential learning took

place through the creative integration of ‘theory and practice’.

It involved an iterative process of development, piloting,

evaluation and review that was conducted over a 3-

year period. In total over 300 practitioners, researchers

and stakeholders were actively involved in the process.

Some of the key milestones are discussed briefly below.

2.1. Stage 1. Review of existing data

This involved a documentary analysis of 50 existing

‘packs’ that had been designed to overcome the problems

of using HACCP within the catering industry, and a review

of existing literature and research. Barriers, limitations and

best practice were identified.

2.2. Stage 2. Creation of new method: the ‘Salford Model’

version 1

A practitioner led, multi-disciplinary team, conducted a

series of workshops over a six-month period. The team

included caterers, food safety and HACCP experts, management

specialists, psychologists, teachers, and representatives

from the FSA, Health Protection Agency and the

Chartered Institute of Environmental Health. The initial

workshop lasted one week and produced a framework on

which to build the components of the model. Each subsequent

workshop was preceded by further stakeholder

review in relation to best practice and technical issues.

The output of this stage was the first version of the Salford

Model. The scope of the work was restricted to independent

restaurants in the first instance. This large sector of

the industry had previously been established as having

the lowest levels of hygiene standards and staff training

(Taylor, 1994) and it was considered that a solution found

for this sector would have wide applicability.

Further stages of the project were carefully planned to

facilitate rigorous evaluation. This involved selecting

appropriate ‘success criteria’, establishing base line data

and undertaking process evaluation at regular intervals

over a five year period. The validity of this approach was

secured through gaining 100% access to a representative

sample of businesses and adopting both qualitative and

quantitative methods. The methods used were (1) documentary

analysis of food safety information within the

business, (2) overt video filming of practices, (3) in-depth

narrative interviews, (4) cultural audits, (5) micro-biological

sampling and (6) analysis of inspection records.

2.3. Stage 3. Piloting and evaluation

A random sample of 50 independent restaurants was

identified as pilot sites. The sample was selected from three

wards within urban local authorities and this reflected a

1 Assemble HACCP team

2 Describe product

3 Identify intended use

4 Construct flow diagram

5

Preliminary

Procedures

On-site confirmation of fl ow diagram

6 Principle One List all potential hazards

Conduct a hazard analysis

Consider control measures

7 Principle Two Determine Critical Control Points (CCPs)

8 Principle Three Establish Critical Limits for each CCP

9 Principle Four Establish a Monitoring System for each CCP

10 Principle Five Establish Corrective Actions

11 Principle Six Establish Verification Procedures

12 Principle Seven Establish Documentation and Record Keeping

Fig. 1. The Codex protocol for the application of HACCP principle

diversity of cuisine including Indian, French, Swiss, German,

Turkish, Chinese, Italian and British. The model

was tested in these businesses by experienced caterers

(‘mentors’) who spent between 20–30 h working with the

owner-manager/chefs. In parallel, numerous researchers

were involved in the on-going evaluation.

2.4. Stage 4. Modification and validation: ‘Salford Model’

version 2

The utility, appropriateness and technical accuracy of

the Model were determined through detailed analysis of

the outputs of the field-testing. A process of technical validation

was undertaken by the FSA. The Model was then

reviewed extensively. In particular it was presented to

numerous Professional Bodies, representatives from the

devolved Governments of Scotland, Wales and Northern

Ireland, FAO and WHO, national and international conferences

and importantly, to the EU members responsible

for drafting the imminent HACCP legislation. The FSA

also commissioned further wide scale testing in Local

Authorities across England. The outcome of this process,

although having very few amendments from the original,

was Version 2 of the ‘Salford Model’.

3. Results

3.1. Outputs

The results of Stage 1 showed that previous HACCP for

Catering ‘packs’:

(1) Were based on ‘rules’ rather than ‘safe practices’.

Rules such as ‘chill within 90 min’ were often cited,

but with no practical guidance on how to achieve this

in a small kitchen.

(2) Used language inaccessible to the end-user.

Complex HACCP and microbiological jargon were

used throughout all of the texts.

(3) Failed to address many critical practices.

Cross contamination was only addressed in one of 36

texts.

(4) Focused on what was easy to measure rather than on

risk.

Routine monitoring focused on fridge temperatures

but did not deal adequately with other high risk measurements

such as cooking, chilling times and contact

times for cleaning products.

(5) Expected caterers to make technical decisions and

validate them.

Material relied on caterers with no technical knowledge

or expertise to undertake a full hazard analysis.

(6) Involved incomplete control of specific hazards.

Critical cleaning activities such as cleaning chopping

boards or knives were not considered in the HACCP

plans or pre-requisite cleaning schedules.

(7) Were based solely on food safety with no reference to

how it could be managed.

The role of the manager in terms of supervision,

responsibility and review were not considered.

An innovative new ‘model’ of managing food safety for

the catering industry was the output from stages 2–5. The

‘Salford Model’ consists of a set of documented safe working

methods with a record-keeping diary. A brief description

of each is presented in Section 3.2–3.5 below with

relevant examples. Section 3.6 summarises some of the

main findings of the on-going evaluation.

3.2. Salford model documentation: safe methods

The documents form a set of working procedures for all

practices in the kitchen that are related to food safety. These

are designed in a standard format, based on the well-established

concept of Standard Operating Procedures (SOPs),

and termed ‘safe methods’. These are categorised into five

sections: Cooking, Chilling’, Cleaning, avoiding cross Contamination

and management Control. They are designed to:

• Document safety aspects of all practice with reasons

why.

• Describe how the manager ensures control of these.

• Plan for if things go wrong.

Version II consists of a ‘bank’ of 40 validated and

approved safe methods that were found to cover most

practices within the sector. The number of safe methods

required within a particular business depends on the size

and nature of the operation, with the option of creating

new methods as and when necessary. Businesses are, however,

responsible for the validation of additional methods

as they are for the regular verification of cooking and chilling

methods to ensure critical limits are being achieved.

The set of safe methods, when completed, fulfil the

requirement of HACCP for documentation. They also

incorporate the general good hygiene practices that are controlled

separately from HACCP when applying the ‘classical’

method. The requirement to record significant food

safety information is dealt with in the Record Keeping Diary

that accompanies the safe methods (see Section 3.4). The

next section illustrates the component parts of the methods

using one typical example that is illustrated in Figs. 2 and 3.

3.3. Example of safe method: COOKING SMALL BIRDS.

Menu item: roast chicken

3.3.1. Safety messages: cooking kills harmful bacteria

(hazard identification)

Each method has a simple food safety message about the

main hazard and how to control it. The team psychologists

and FSA communication experts used extensive background

experience and research in the development of

appropriate safety messages. In this example it is that

‘cooking kills harmful bacteria and makes food safe’.

Whilst this is not scientifically accurate in all situations it

has been found to effectively communicate the importance

of cooking and improve practice (FSA, 2005). The issues of

heat resistant toxins and spores are dealt with in the chilling

section, and throughout the safe methods there are

prompts that highlight the need for all parts of the system

to be followed in order to achieve food safety.

3.3.2. Safety points (control measures)

Each safe method contains a list of safety points, which

are simple, practical steps taken in most catering operations

to make sure food is safely made. Documenting safe

catering practices in this format removes almost all of the

effort of documentation for small businesses, and also

serves as a ‘prompt’ and ensures that all steps are followed

every time. Each safety point is supported immediately

with a reason for its necessity, based on the caterers’ and

food scientists’ combined experience. This reinforces the

importance of each point, and helps to provide an understanding

of how to adapt the methods if one step is changed.

For example, if pre-heating the oven is not an option

for practical or quality reasons, extra cooking time is then

required to make the food safe. The juxtaposition of ‘rules’

and ‘reasons’ is also a useful training tool.

The final column of this section is a space for individual

businesses to fill in the details that are specific to their own

operation. Catering is such a diverse industry that it is

impossible to create generic methods for businesses to simply

pick up and use. There are differences in equipment,

sizes and types of product, cooking methods and styles,

and all of these can have an impact on safety. The safe

methods are designed to minimise the effort required by a

business, but certainly not to eliminate it. Moreover, the

more time a business invests in adding to and improving

their safe methods, the more food safety understanding

and practices will improve as a result. A sense of ownership

of the system, and empowerment of staff within it, fulfils

the underpinning concept of HACCP.

3.3.3. Checking points (critical control point monitoring)

The final safety point in the process requires greater control

as it is the last step where the hazard can be reduced to

a safe level. Such focus is a key principle of HACCP and in

the safe methods these ‘checking points’ incorporate a measurable

output and continuous ‘real-time, every-time’ monitoring.

For many products every item needs to be checked

and haphazard sampling cannot ensure the safety of the

menu-items. Such practice, promoted by almost all previous

‘packs’, negate attempts to improve food safety by

leading caterers toward the false assumption that, for

example, the probe testing of a few cooked items is enough

to ensure safety of the entire meal. Within catering, where

there is little uniformity of ingredients, equipment or recipes

there is rarely the opportunity to ‘sample’ reliably. In

this example, every bird must be checked to ensure safety.

Practical, sensory methods, such as the juices running clear

of blood, are therefore advocated. This ensures that even in

a busy kitchen, with perhaps hundreds of ‘items’ being

cooked every day, all food can be ‘checked’ at critical

safety points.

Businesses can, however, still chose to check a sample

rather than the whole batch, but they would be required

to justify how their method would ensure that every individual

product was safe. For example, if a number of whole

birds were to be batch cooked and it was possible to identify

the bird that would cook at the slowest rate (i.e. in relation

to position in oven and/or size) then that one could be

used as the test ‘sample’ that would indicate all birds were

thoroughly cooked.

3.3.4. What to do when things go wrong (corrective action)

This section of the safe method provides practical

options for what to do if the product, after cooking according

to the prescribed method, fails the safety check. The

documented actions are designed to rectify the problem

and make the product safe, and to prevent the problem

from happening again. There is scope here for the business

to add their own ideas that are specific to their operation,

such as an alternative piece of equipment that can be used

if one is failing, or an alternative dish that can be served if

the customers cannot be made to wait. In this way, if the

manager of the kitchen is away one day and there is a crisis,

the staff can go to the safe method documentation, see

what to do and confidently follow the instructions.

3.3.5. Prove-it (verification)

The ‘prove it’ section of the method facilitates the process

by which businesses periodically verify that their methods

are working and that critical limits are being achieved.

This documented experimentation gives confidence, both to

the caterer and enforcement officer, that the system is under

control. This is also required when a new item is added to

the menu, or at special occasions where products are being

prepared at different sizes and using different methods.

3.4. The Salford Model record keeping diary (record

keeping, verification, review)

In general, large businesses use considerable amounts of

forms, reports and paperwork to control their operations.

In the typical small catering business there is likely to be

much less bureaucracy and associated paperwork. Part of

the reason for this is that the manager knows what is happening

in all parts of the business by personally supervising

activities. However, the minimal records one would expect

in any size of business would include:

• Formalised roles and responsibilities.

• Significant food safety checks and remedial actions.

• Records that can be reviewed to identify commonly

occurring problems that need to be solved.

• Evidence for the inspector/auditor that food safety is

under control.

• Details of communication between staff within the

business.

The output of this project was the identification of the

essential records that would be needed to perform these

tasks and, just as importantly, a presentation format that

would used rather than ‘shelved’ by the business. The output

was an annual diary that includes:

• Page a day or shift format.

• Opening and closing checks.

• Signature of responsibility.

• Exception reporting for when things go wrong.

• Reminders for regular managements checks (pest control,

cleaning).

• Monthly reviews.

• Staff details and training records.

• Supplier and contractor information.

• Attractive user-friendly format.

3.5. The evaluation

When evaluating food safety management systems, ‘success’

is often measured in terms of the percentages of businesses

that purport to have implemented them. Whether

the businesses are telling the truth, whether they represent

a valid sample, whether they have fully implemented and

are successfully using the system, and whether food safety

is actually improved, are questions that are often ignored.

From the outset the Development Team were committed

to establishing, not only the utility of the product to

the businesses, but whether it contributed to an improvement

in food safety. Highly experienced researchers from

a range of organisations were involved in developing the

largest, most varied, robust research project ever carried

out in the restaurant sector of the catering industry. The

rigorous evaluation that accompanied this project was

one of the key contributory factors that led to its eventual

acceptance by Government, industry and the wider

HACCP community.

The evaluation of this project is still on-going but some

of the key findings that emerged within the first 6 months

are described below.

3.5.1. Acceptance by caterers

The Salford Model was enthusiastically received by the

businesses at the point when it became apparent to the

owner that the purpose was to establish the safety of methods

used in the business and was not related to an ‘inspection’.

The commitment gained was evidenced by the many

hours spent by chefs/managers both during ‘mentor’ visits

and between them. Many chefs commented on the fact that

‘. . . its great . . . it’s the first time anyone has come to us to

talk about our menu’ and compared this to the confusion

and anxiety that they had felt when enforcement officers

had talked to them about HACCP.

In summary, all businesses were unanimous in their

belief that the ‘pack’ would have a positive effect on their

business, bestowing realistic control mechanisms to manage

food safely. The decision to recruit and train caterers

to undertake the ‘mentoring’ process was confirmed to be

a key factor in the acceptance of the model within the

businesses.

3.5.2. Increase in documentation and record keeping

An essential requirement of any HACCP system is the

need for documents and records (Principle 7). Examining

paperwork is therefore an objective method of finding evidence of control of food safety procedures within a business.

When asked prior to the start of the project to provide

evidence of any food safety documentation and

record keeping, the majority of the 50 restaurants (65%)

had none at all. Of the remaining 35%, there was a mixture

of partially complete and piecemeal Good Hygiene

Practice documents and record sheets, mostly unused.

These ranged from a pest control contract to several sets

of cleaning and temperature charts for staff to fill in.

Many documents were not filled in, or said to be completed

‘sometimes’ or ‘usually’. Indeed, only 17% had

any form of record keeping. Only two businesses had

some form of HACCP documentation but there were no

records to support these.

Within 6 months of the intervention all businesses had

started to document their food safety practices (100%).

Two thirds of these (66%) had a fully documented system,

with the others were at various stages of completion. As

had been anticipated, a correlation was found between

menu complexity and implementation time. The Diary

was put into action immediately by all the businesses upon

completion of the documentation. Half (50%) of the pilot

sites were demonstrating full use of all diary components

within the first 6 months.

These findings are of particular relevance when set

against the backdrop of previous negativity concerning

HACCP focused primarily on perceived demands for

‘excessive paperwork’.

3.5.3. Changes in food safety knowledge, attitude and

behaviour

Food safety knowledge, attitude and behaviour are difficult

to assess using traditional research methods because

of the sensitive issues of legal compliance with many true

thoughts and actions deliberately concealed. Such issues

point towards the necessity for a qualitative, in-depth, discovery-

based method and for this reason the narrative

interview approach (based on Hollway & Jefferies, 2000)

was selected and used.

Narrative interviews were undertaken in a pre and post

intervention scenario in order to evaluate the effectiveness

of the new system in the pilot sites. Initial analysis revealed

several themes that would consequently act as indicators of

change during subsequent interviews. These included (1)

management control (2) knowledge (3) awareness of risk

and (4) food safety behaviours. Some of the initial findings

were:

(1) A change in management style was identified in most

businesses. Managers became more involved, adopting

a ‘stricter’ approach to food safety. Responsibilities

were more clearly defined and staff involvement

increased.

(2) For many respondents the pack and mentoring process

allowed the business to gain valuable information

on aspects of food safety. The idea that ‘its all

common sense’ changed to an acceptance that were

things the respondents did not know and that there

was a need for staff and themselves to be educated

on issues surrounding food safety. Findings also

suggest that the pack bridged the gap between a managerial

instruction and its effective, ongoing implementation.

Managers reported that staff were ‘now

more inclined’ to change their behaviour as they

aware given valid reasons ‘why’.

(3) Respondents highlighted a marked improvement in

their knowledge and awareness of food safety risks

within their businesses. This was a change from the

initial interviews where many ascertained they

already had a comprehensive understanding of all

food safety and food safety management issues.

(4) Businesses were seen to be taking a more active role

in controlling food safety with routine monitoring

and documentation undertaken, changing practices

where necessary and in some cases investing in new

equipment. Indeed, many businesses took independent

initiatives to experiment, particularly with chilling

and hot-holding, to determine if their practices

met safety limits discussed during ‘mentor’ visits.

In-depth narrative interviews were demonstrated to be

the most effective of all evaluation methods used in this

project. Its successful within this project has led the FAO

to recently recommend it use for measuring behaviour

change (FAO, 2006).

3.6. A new method: from ‘model’ to approved ‘system’

The Salford Model version 2, through an iterative process

of stakeholder review and validation was approved

by the FSA and deemed to comply with the 2006 Regulation

(FSA, 2004). The model was extended to facilitate

its use by catering businesses of all types and sizes and

the complete system is currently marketed as Menu-Safe

(Taylor & Taylor, 2006). A shortened version, Safer Food

Better Business (SFBB) has been developed by the FSA as

a ready-to-use package for very small catering businesses

that are typically independent operations that employ less

than five staff. The relationship between theses systems

and the classical Codex method is depicted in Fig. 4.

4. Conclusions and recommendations

This action research project was the first attempt, anywhere

in the world, to empirically develop a food safety

management system for caterers. It remains the only adaptation

of the ‘classical’ method that has been demonstrated

to have utility to catering businesses and also contribute to

improvements in food safety management. In particular,

the output demonstrates that there are valid alternatives

to the ‘classical’ Codex method and that businesses can

comply with HACCP principles without ever having to

‘hear’ or ‘use’ the HACCP jargon. The removal of technical

decision making from the business with the outputs derived and validated externally, integrated into the system,

is also shown to be a way forward for businesses with

minimal technical knowledge.

The ‘Salford Model’ has had far reaching effects on the

Governments perception of the catering industry and subsequent

policy. In particular the decision to accept the role

of management within HACCP and to legitimise close

supervision, rather than paper, as an appropriate management

style for small businesses. The incorporation of

‘exception reporting’ and a section on management ‘Control’

within the new system-despite there being no explicit

legal requirement for this – is evidence of this new thinking.

This project began with a general review of HACCP

training that concluded that there was a need for better

quality, and greater accessibility, of training across all

industry sectors (Taylor, 2002). With regard to the catering

industry it was recognised that the new system provided a

template for training at a more practical and appropriate

level. As a consequence the FSA has already initiated

action within the Qualifications & Curriculum Authority,

Sector Skills Agency and Professional Bodies and in 2006

new National Occupational Standards for the catering

industry were launched.

Perhaps of most significance is the acceptance that caterers

are not usually ‘out to poison customers’ and will

respond positively to advice and guidance if it is seen to

have come from a credible source and presented in an

appropriate manner.

In late 2005 plans were announced to roll-out SFBB to

businesses across England (FSA, 2005). A £10 million budget

was been allocated to be spread over 3 years with

money going directly to available local authorities. It is recommended

that the success of this initiative be rigorously

evaluated, using some of the tools developed and used so

successfully in the development phase of this project.

Acknowledgements

The project was funded by the Food Standards Agency,

the European Social Fund and the University of Salford.

The author would like to thank the Food Standards

Agency for the two year secondment that allowed this work

to be completed, and the many businesses and stakeholder

representatives that gave up their valuable time to take

part.

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CODEX

Classical HACCP Systems Based on

HACCP Principles

Very Small

Businesses

SFBB

The Salford Model

Small and Less Developed Businesses

(SLDBs)

Manufacturing

Catering

All Catering

Businesses

Menu-Safe

Fig. 4. HACCP methods based based on Codex principles