food rules issue 6

8/9/2019 Food Rules Issue 6

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IN TRODUCTION FROM T H E EDITOR

January 2006 is a major time for the food sector as EU legislation mow

requires all food businesses to have a food safety management system,based on Hazard Analysis and Critical Control Points (HACCP), in place.

For the small company developing such a plan for the first time can be

daunting as the range of expertise required both to identify hazards and

their associated risk can be daunting.The initial steps in developing a

HACCP plan are outlined in this issue. In addition the Y&H Food

Technology Advisory Service (FTAS), authors of this ar ticle, can arrange

support to take you through the process.The law also now requires

that all food handlers must receive adequate supervision, instruction

and/or training for their work.

In the final part of this series on the BRC Global Food Standard, advice

on supplier assurance is covered. For many food products, particularly

those requiring little or no further cooking, supplier assurance will be a

major control point for ensuring the safety of your products.Again thislinks to your HACCP plan.

The sector is characterised by intense product innovation. By continuing

to enhance and develop new products even the small manufacturer can

remain competitive. However, each product does require some thought

to ensure it complies with the requirements of food legislation. A simple

check list describing the main requirements is included. If these products

include food colorants then the final article gives a more definitive

statement on their use.

This newsletter is primarily trying to raise awareness and bring new

developments to your attention. If it raises issues which need

clarification or further thought please phone 0114 225 4226.

Queries will be dealt with in two or three stages

1. Following a telephone request from you we will contact you to

obtain an understanding of your areas of concern.

2. If the enquiry is relatively simple we will give you a statement of the

position within one week.

3. If the enquiry is more complex then we will consult the food law

section of Leatherhead Food International for a definitive position

statement.Answers that are backed by an expert team with many years

experience in food law.

This stage may require further consultation with you but should

normally be concluded within two weeks.There is no charge for this

basic advisory service for a small company.

Areas we cover include

a summary of the current requirements in key areas including

labelling, claims, additives and composition

indications of relevant developments in forthcoming legislation food hygiene requirements

lists of E-numbers, applicable regulations and guidance - i.e. what

additive is allowed in what product.

It is not possible to give definitive advice on some aspects relating to

meat hygiene. However, Moira Stratford, at Humber (FTAS) Ltd,

telephone 01472 311222 extension 192, is able to give a more

comprehensive advice in this area. Other support, such as HACCP,

development quality management systems such as BRC or other

technical advice can be obtained from FTAS.

Previous issues can be accessed electronically either from FTAS or the

Food Innovation and Research Centre at Hallam:

www.ftasyh.co.ukhttp://www.shu.ac.uk/research/firc/food/food_legis.html

Prof Geoff Le Grys

FOOD RULES

The food legislation newsletter and adviceservice for Yorkshire and Humber

ISSUE 6

JANUARY 2006

Telephone: 0114 225 4226 E-mail: [email protected]

Supported by

CONTENTS HACCP - What is it?

Supplier Assurance

New Product Development and

Legislation for the Small Business

Colours in Food

Whats New


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H ACCP - WH AT

IS IT?

Probably the most used acronymin the Food Industry! Andprobably the least understood. Itis based on seven principles thatform the basis of any HACCPplan.

HACCP is a management tool that facilitates

the SAFE manufacture of food.

PRINCIPLE 1 - It identifies hazards, where

they come from, or what causes them.

It should measure the likelihood and severity

of risk posed by each identified hazard.

PRINCIPLE 2 - It should establish at which

points in processing that control is absolutely

critical to food safety (Identify the critical

control points).

PRINCIPLE 3 - Prevention and control

measures must be measurable to determine

unacceptable and acceptable processing

parameters (critical limits). PRINCIPLE 4 - The critical control points

must be monitored by a defined procedure.

PRINCIPLE 5 - Procedures should be

established to return processes to within

acceptable parameters. Corrective actions

must ensure products are rendered safe or

disposed off.

PRINCIPLE 6 - Procedures must be verified

to ensure that they are working effectively.

PRINCIPLE 7 - It is usually documented and

will always form the core of any quality

management system in the food industry.HACCP will not:

increase profits, although it will help new

product development result in safe products

improve or define quality

save money but it may reduce wastage,

complaints and product recalls

cover traceability

ensure BRC accreditation, although it will

give compliance to the HACCP section of

any standard

protect from prosecution if food safety fails

but may form part of a due diligence defence

If properly implemented, HACCP will ensure

staff are more closely involved in food safety

management and provide increased confidence

to managers. HACCP needs to be a living

process which needs continuous challenging

and review and requires someone on site to take

ownership for its management.A HACCP plan

is only as good as its day to day implementation.

HACCP - a little of how youdo it!

There is little doubt that to an inexperienced

person, completing a HACCP study that worksis difficult. Here are some easy steps that you

can take before you get some help.

Decide which products you really need to

study first (either by highest volume or

greatest risk), in the full knowledge that you

will have to do them all eventually. If you

can, group like products and processes

together to limit the number of studies.

Define who eats your products: there are

more risk factors to consider in feeding the

very young, very old, and very ill than the

general population.

Decide where you want to start the study,

usually intake, and where it will end,

normally despatch.

Draw up a process flow diagram that

accurately represents how you manufacture

the product. It may also be useful to mark

the progress of your product on a factory

floor plan.

Now is the time to call for a little help.

FTAS has developed a HACCP technique for

small businesses. It provides your team with the

appropriate experience, keeps the project on a

timetable to completion, and empowers,motivates and mentors small business owners

to manage safe food manufacture.

In the next issue:HACCP Pre-requisites.

SUPPLIER

A SSURA N CE

What is Supplier Assurance andwhat benefits can it have to mybusiness? Supplier Assurance

means taking simple steps to tryto ensure that you only purchasegoods or materials from supplierswho are capable of consistentlysupplying good quality, safe andlegal products.

Companies who are already trading with major

retailers and foodservice buyers are likely to

have experienced, first hand, the Supplier

Assurance techniques employed by these

companies. Probing questionnaires, and site

visits are designed to minimise the risks to the

buyer.The BRC standard is, in itself, a Supplier

Assurance system which is designed with the

same purpose in mind. Buyers would not be

prepared to invest significant resources in

Supplier Assurance if there were not business

benefits associated with it.

Finding suitable suppliers can be a time-consuming

task and when at last what seems the right

product has been found at the right price, there

is great temptation to do a deal and place an

order. Resist it! Time spent now will avoid problems

in the future. Check out the product and the

supplier first, by getting a specification for the

goods and asking some probing questions.

A specification is important for several

reasons. It should describe the nature and

quality of the goods being traded. Check to

make sure it accurately represents the goods in

question. It should form the basis on which the

buyer is spending his/her hard-earned money

and can be referred to in case of disagreement

about quality and nature of the product. If a

specification is not forthcoming, the buyer

should proceed with extreme caution, since

this usually indicates that the supplier either

doesnt know what he is selling or has

insufficient resources to control it.

A supplier questionnaire is a relatively

simple and effective way of finding out about a

supplier. Many manufacturers will have been on

the receiving end of these.The buyer has to

rely to a certain extent on the honesty of the

responder to give a true picture of the

manufacturing site but a visit to the factory by

the buyer always remains an option. Many

smaller manufacturers buy goods from wholesalers

or agents, so an appropriate questionnaire here

should probe their own Supplier Assurance

procedures.Traceability is now a legal requirement

so it is also wise to seek confirmation that a

supplier has a suitable system in place.

Factory visits by trained personnel should

leave the buyer in no doubt as to the suitability

of a potential supplier.They are of course costly

in terms of both time and resources so they

tend to be used where the risks of things going

wrong are higher. Generally speaking therefore,

it is advisable for a buyer to (arrange to) audit

a factory which is proposing to supply high risk

materials or ingredients.These visits are also an

opportunity to test the honesty of the

responses given to the earlier questionnaire.

Risk assessment is something that most ofus carry out every day without thinking about

it. It is relevant here in the context of assessing

what needs to be done to minimise the risk of

a new supplier adversely affecting ones

business. Stop and think about the likelihood of

something going wrong and the severity of the

effect on the business.A HACCP study can

help here but it may not highlight potential

quality and legal risks associated with a

material. Examples include legal limits to

additive levels and minor variations in the

quality of a pre-mix having a major effect on

the quality of the finished product.

Having gathered the necessary information on

the supplier and the material under

consideration, you are now in a better position

to make a decision on whether or not to place

an order and what precautions are necessary

to ensure that any problems related to the

The following reviews arefor guidance only. If youhave any specific issue pleasetelephone0114 225 4226.


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new material are identified and ironed out as

soon as possible.The use of trial periods can

be helpful in assessing a suppliers performance

over a defined period of time.A Certificate of

Analysis or Conformance with the consignment

can also be used to confirm that the material

meets the agreed specification.The receiving

factory may also wish to carry out additional

checks on the goods at the time of receipt andbefore or during their use.

Supplier assessment should be ongoing.

Information gathered from a history of trading

will provide a useful means of assessing a

suppliers ability to meet customer requirements.

Such tools at a factorys disposal include

information recorded at Goods Receipt

(condition, quantity etc), complaint records and,

perhaps, analytical test records.

In the same way that you are assessed by some

of your customers, you can and should do the

same to your own suppliers in order to avoidthe problems caused by trading with unsuitable

companies.

If you are interested in learning more about

Supplier Assessment and how it can benefit your

business contact Sarah Knapper at the Food

Technology Advisory Service 01937 830799.

N EW PRODU CT

DEVELOPMEN T

AN D LEGISLATION

FOR TH E SM A LLBUSIN ESS

W hat is a new product?

A new product could be any of the following:

1. A completely new, innovative idea for your

company using ingredients and processes

which you currently arent using.An

example of this could be a product being

manufactured by a start up business or a

business diversifying into a new field.

2. It may be an existing product using an

existing process with a new ingredient in it

such as a range extension or a recipe

reformulation to improve cost and/or quality.

3. It also can be an existing product in a

different size format such as a smaller or

larger pack size to increase marketplace

penetration.

Depending on your new product and the

degree of change from your existing product

portfolio, the following legislation should be

considered:

Key legislation1.The labelling and marking of food

A new product will need a new label and all of

the below are required to comply with the

Food Labelling regulations 1996.

the name of the food

a list of ingredients

the quantity of certain ingredients or

categories of ingredients

the appropriate durability indication

any special storage conditions or conditions

of use

the name and address of the manufacturer

Other points to consider:

special dietary claims also carry

conditions in these regulations

QUID also needs to be considered where

proportions in a recipe have been changed

Awareness of the latest additive legislation

and flavouring legislation governing the

formulation of new or existing products is also

vital in todays tightly regulated markets.

2. Composition and labelling of

particular foodsSome foods have specific regulations for their

labelling which must be complied with , for

example - meat, fruit juices, confectionery,

slimming foods, jam, and bread - the list is

extensive and it is recommended that any new

product is checked for legality against their

relevant regulations.

Likewise, use of some new ingredients may fall

within the Food and Environment

Protection Act 1985 for foods which have

been imported from areas where

contamination may or not have been

controlled.Novel Foods which are currently not regulated

by any specific legislation must be assessed

under the Novel Foods and Novel

Ingredients Regulations 1997.

3. Marketing the new product -

descriptions and designations

Products which make claims such as organic or

make geographical or traditional recipe claims

are covered in specific regulations:

Organic Product regulations 1992

The protection of geographical indications

and designations of origin for agriculturalproducts and foodstuffs 1993

4. Other relevant legislation

The Trade D escriptions Act 1968 makes it

am offence to give false or misleading

statements about goods.

The Weights and Measures Act 1985

makes it an offence to declare the weight of

your product incorrectly.

For further information:

The Food Law Guide issued by the Food

Standards Agency gives detailed guidance for all

of the above see the link:

http://www.food.gov.uk/multimedia/pdfs/foodlaw.pdf

Deb Neeson

COLOURS IN

FOOD

The use of colours in foods iscontrolled under the Colours inFoods Regulations 1995 (+

amendments). Colours areadditives that are used for theprimary purpose of adding orrestoring colour to a food.Ingredients that are used principallyfor aromatic, taste or nutritivereasons are not included, eventhough they may have a secondary,colouring role within the food.Colours that are used in an inedibleexternal part of the food are also

excluded from the Regulations.

Permitted colours have E numbers in the range

E100 - E180, and must conform to the detailed

purity criteria set out in EC Directive 95/45.

Aluminium lakes prepared from permitted

colours are also allowed.These can be used to

give improved colour stability in fat-based foods.

Where relevant, maximum permitted levels of

colour are given, these are given as mg/kg and

refer to mg of colour per kg (or litre) of food

that is ready to eat, having been prepared in

accordance with any instructions for use. For

many colours the term quantum satis is usedfor the permitted level.This means no maximum

inclusion level has been set. However, usage

should be in accordance with good manufacturing

practice at a level not higher than that necessary

to achieve the intended purpose and provided

that such use does not mislead the consumer.

Four Schedules (numbers 2-5) in the

Regulations list the controls on colours and

their use in specific foods.The Schedules are

too long to quote in full but examples from

each are given below. Specific queries can be

dealt with by the Food Rules team, by Trading

Standards Officers, or by viewing theRegulations at

www.opsi.gov.uk/legislation/statutoryinstruments/1

995/3124

Schedule 2 - Foods which may not contain

added colour unless specifically provided for

elsewhere in the Regulations.

Examples include:

Bottled or packed waters

Oils and fats of animal or vegetable origin

(but butter and margarine are exceptions -

see below)

Bread and similar products (but malt breadis an exception - see below)

Pasta and gnocchi

Foods for infants and young children

Honey


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food rules issue 6

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