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Part 2 HACCP on the farm and in primary processing © 2000 Woodhead Publishing Limited

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Page 1: Part 2 HACCP on the farm and in primary processing

Part 2

HACCP on the farm and in primaryprocessing

© 2000 Woodhead Publishing Limited

Page 2: Part 2 HACCP on the farm and in primary processing

4.1 Introduction

Safe food produced on a farm, whether from animal or vegetable origin, mustbe free from pathogens which infect man and from contamination withpoisons and residues. There is a general consensus that microbial agentsconstitute the major hazard to human health, but there must always be anawareness of possible hazard from residues or toxins. The production of meat,milk and eggs, regardless of new technology or changes in productionmethods, cannot be expected to achieve zero bacterial or chemical risk, but itmay be easier to avoid residues. There is, however, the need to reduce the riskand, where possible, eliminate it at the farm level. The current use of the terms‘farm to table’, ‘stable to table’ and ‘plough to plate’ clearly identifies thefarm as one part of the production chain which must be considered in terms offood safety. Farming practices, in particular the apparent reliance in recentyears on intensive farming systems, have been linked with the rise infoodborne illness in humans. The assumption of the on-farm risks that have tobe considered, however, must be limited to those that might have an impact onhuman health. The difficulty frequently is to separate out the risks thatinfluence only animal health on the farm from those which impact on humanhealth, or both human and animal health, or may be perceived as being a riskby the consumer.

The majority of HACCP implementation to date has been within theproduction and manufacturing sections of the food industry. HACCP offers arisk assessment and management system that can be implemented prospectively,unlike other programmes such as animal herd health schemes on the farm thatusually work retrospectively.

4

HACCP and farm productionA. M. Johnston, Royal Veterinary College, University of London

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Beside the hazard identification and location of the exposure, there is theneed to investigate along the food chain the critical steps where contaminationoccurs. In the end the decision must be taken where to situate inspection andwhat is the best way to ensure human health. The ‘stable-to-table’ concept relieson the evidence that the final product, which is consumed, results fromsubsequent steps of a longitudinal process. In order to further improve animalhealth and food safety for the consumer, HACCP is now being considered foruse in the farmyard situation, because, after all, the farm animal either produces,or is itself, the product. With the need for food manufacturers to show duediligence throughout the food chain, as a defence the HACCP system hasbecome the recognised standard and is increasingly being extended toencompass the entire farm-to-table continuum. In the United States, forexample, the 1996 USDA food safety HACCP regulations which deal withslaughterhouses are seen to have an inevitable impact on farm productionpractices.1

Correct implementation of the HACCP system requires that scientificallydocumented steps and preventive measures exist that can be effectively appliedat known critical control points (CCPs). Determination of critical control pointsfor on-farm implementation for chemical, physical and certain biologicalhazards is currently possible but is considered lacking for microbiologicalhazards.2 Much of the actions on farm are good manufacturing practice (GMP)or, in this case, good farming practice, and will never be CCPs.

4.2 Hazard analysis in animal rearing

Microorganisms are widely present in animals and in their environment. Withanimals disease is inevitable; perfectly healthy animals can also be carriers, andmay be asymptotic excretors, of pathogens. The prevalence of pathogens on thefarm, or a unit within a farm, depends on many factors, not least the type ofhusbandry, the environmental pressure on that farm and the standard ofstockmanship. The human pathogen Escherichia coli O157 which is found onfarms3 and associated with ruminants demonstrates the problems of an organismthat has a highly variable prevalence but is able to maintain itself in the herd, yethas a transient nature of shedding which appears to be influenced by feeding,transport and weather.

The diseases of animals which affect the safety of food are predominantlythose that cause enteric disorder in the animals. In addition, the veryenvironment in which animals are reared will always have a bacterial loadwith some level of pathogens. There will be organisms which are pathogenicto man but do not cause clinical illness in the animals, though they are presentin the animal excreta and in the animal environment, such as E. coli O157. Onthe other hand, zoonoses such as Chlamydia psittaci or Toxoplasma gondiican cause significant losses on the farm but are most unlikely to affect foodsafety directly. Other pathogens may be excreted in large numbers before

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there is evidence of clinical illness in the animal or following apparentrecovery from an illness.

In livestock production there are a number of points where controls can beapplied. The first is at the birth of the animal, or at hatching in the case ofpoultry, and extends through all stages of animal production and includes thefoodstuffs fed to the animals. The aim should be to have the young born fit andhealthy with good levels of maternal immunity. In addition to their appropriateuse in the neonate, vaccines can be given to the pregnant dam, such as thebovine combined rotavirus and K99 E. coli vaccine for calf scours, to help toprotect the young in the first weeks of life. Animals and birds are usually kept ingroups, either outside in fields or housed for all or part of the year. Access to thehoused accommodation or to the pasture may be voluntary or controlledaccording to the farming system in place. Whichever system is used, the animalsmust be kept in the very best conditions with an overall aim to prevent disease inindividual animals or in the whole herd or flock. The type of husbandry directlyimpacts on this. The most certain way to reduce or remove the risk ofintroducing disease organisms to animals is to use biosecure housing. This, ofcourse, is contrary to the trend towards more extensive systems where there isthe inevitable exposure to wildlife and vermin which are vectors of a number ofimportant pathogens. The use of production systems which have biosecurehousing does allow an ‘all in all out’ policy, followed by thorough cleaning anddisinfection of the house before restocking. The original method was to applythis practice to each house on the site as it was emptied of animals or birds.More recently this practice has been extended to involve all animal accom-modation on the site, every unit being emptied of livestock, then all cleaned anddisinfected before any unit on that site is restocked.

In addition to keeping animals healthy, a critical part of husbandry is also tomake sure they are kept visibly clean. This is of particular importance to reducethe possibility of contamination of milking animals and animals destined forslaughter so that they do not have dirty outer coats. A major influence on thecleanliness of the animals is the type of housing, the material used as beddingand, if the animals are kept outside, the underfoot conditions. There is a varietyof housing systems used in practice, including straw bedded or deep litter yards,cow cubicles with straw, sand, rubber mats or even waterbeds as bedding, andsheds with slatted floors, or a combination of these. Straw bedding is a much-favoured system for comfort and cleanliness but is only satisfactory if theexisting bedding is regularly replaced with clean straw. Failure to use goodquality straw or empty out the yards regularly, as dung builds up, will lead to aproblem with environmental organisms. This is of major concern for dairy cowshoused in such a system, where failure to completely change the bed at regularintervals results in clinical mastitis caused by the environmental organisms. Insome regions straw may not be available locally, which requires it to betransported from arable areas. A major factor in the effectiveness of any systemin keeping the animals clean is the standard of management. Failure to attend todetail will lead to an increase in environmental organisms and inevitably also

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pathogens. The stockman therefore has a crucial role to play from both theanimal health and public health perspectives.

Foodstuffs which are fed to animals must be free from both pathogens andundesirable residues. The role of animal feed in food safety has been highlightedin relation to both Salmonella, in particular S. enteritidis phage type 4 inpoultry,4,5 and bovine spongiform encephalopathy (BSE) in cattle6 and morerecently dioxins in animal feeds in Belgium.7,8 Following the BSE epidemic, thelong-established practice of using recycled animal protein has been questioned,with a ban on the use of ruminant or mammalian derived protein in animal feedsin some countries. Animal feeds are compounded from both home-grown andimported ingredients most frequently produced as a compounded, nutritionallybalanced ration from commercial feed mills. The farmer may well prepare thefeeds on the farm using either home-grown or purchased forage and cereals. Ithas been well documented that the ingredients for animal feeds may carrypathogens. The process of producing some forms of compounded feed, such aspelleted feed, requires a heat treatment stage which is effective against bacterialpathogens, but subsequent handling stages may allow recontamination. Thefarmer has a role to play in making sure the feed is stored in a manner thatprevents contamination from external influences such as wildlife on the farm.

The bringing on to the farm of new animals, whether as replacement breedingstock or as animals to be fattened for slaughter, is frequently a way by whichdiseases are introduced. In most cases the major impact will be from diseaseswhich affect animals but frequently such infections can include zoonoticorganisms. It is of the utmost importance that incoming animals are keptseparate from those already on the farm for the necessary period of quarantineand where possible that they come from a farm with a known health history.

With animals, whether farm animals or companion animals, disease is inevit-able; perfectly healthy animals can also be carriers and may be asymptomaticexcretors of pathogens. The prevalence of pathogens on a farm depends on manyfactors, not least the type of husbandry, the environmental pressure on that farmand the standard of stockmanship. It is also most important to recognise thedifference between animal health, or disease control measures, and humanhealth considerations when considering the legislation. There are, however, nospecific statutory food safety controls applicable to on-farm production.

One of the easiest and perhaps more clearly defined parts of the farmingoperation to which the HACCP concept can be applied is the use of medications.This must include the decision-making process on whether to use and if sowhich medication as well as the mechanics of delivering the medications to theanimals. While the treatment of bacterial disease in man and companion animalsis invariably directed to the individual patient, the treatment of food-producinganimals, especially pigs and poultry, is generally applied on the group or herdbasis.9 The three main reasons for antibiotic use in animals are therapy,prophylaxis, or strategic medication, and in farm animals performanceenhancement. Therapy usually involves individual animals or a defined groupof diseased animals for treatment of a previously identified disease. Prophylaxis

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or strategic medication is usually to contain the spread of infection and preventillness in advance of clinical signs. Prophylactic treatment involves themedication of a herd or group of animals following the diagnosis of illness inone or more animals in the group, or on the basis of previous experience, usuallywhen a proportion of animals are diseased during a defined period and theprobability of most, or all, animals getting infected is high. The animal diseasesrequiring the most extensive use of antimicrobials for therapy or prophylaxis arerespiratory and enteric diseases, especially of pigs and cattle, and mastitis indairy cattle.

Large pig herds and poultry flocks, for example, can provide major logisticalproblems of antibiotic medication. Therapeutic or prophylactic antibiotics canbe administered by in-feed or in-water medication. In-feed medication for avalid animal health reason must not be confused, as often happens, with thegeneral term of feed additives.

The legal requirements covering the distribution of animal medicines differaccording to the legal classification of the individual product, which alsodetermines who may sell the product and under what restraint or control. UnderThe Medicines (Restrictions on the Administration of Veterinary MedicinalProducts) Regulations 1994, no person is allowed to administer any veterinarymedicinal product to an animal unless the product has been granted a marketingauthorisation (product licence) for the treatment of a particular condition in thespecies being treated. Under the Regulations the veterinary surgeon is theprimary prescriber of medicines, and in the UK it is usual practice for theveterinarians to prescribe and dispense medicines for animals. This applies toboth food-producing and companion animals. For food-producing animals theveterinarian or person acting under his or her direction may only administer aproduct that contains substances found in products licensed for use in food-producing animals and must keep records.

There has been pressure on the industry to use production methods that willdeliver the animal to slaughter at a predetermined weight with the requiredcarcass conformation in the shortest time and at lowest possible cost. This hasled to the use of growth promotion techniques, including sub-therapeutic levelsof antibiotics in the feed and steroid hormones during the growing phase. Theuse of substances having a thyrostatic, oestrogenic or gestagenic effect forgrowth promotion purposes has been prohibited within the European Union(EU), or for products to be imported into the EU, since January 1989. Thecounter-argument to justify the use of steroid hormones is that they are naturallyoccurring substances and if the withdrawal periods are followed there is no riskto human health. This issue was reviewed by the Scientific Committee onVeterinary Measures Relating to Public Health in 1999. They considered that thescientific evidence necessary to make a balanced scientific judgement is lackingbut it is known that one, 17beta oestradiol, is a complete carcinogen and as suchis able to initiate and promote cancer. The committee considered that there wassufficient uncertainty in terms of consumer public health that the ban on theiruse in the EU should continue.10

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The use of antibiotics, without veterinary prescription, for the purposes ofincreasing growth in food animal production started in the early 1950s.Following an outbreak of food poisoning due to multi-drug resistant salmonella,an expert committee chaired by Professor Swann reviewed the use of antibioticsin agriculture. Their report in 196911 resulted in significant changes in the use ofantibiotics, including their use for growth promotion purposes. More recentlythere has again been considerable concern about the use of antibiotics, especiallyfor growth promotion purposes, in animals and specifically about food being avector of antibiotic resistance from animals to humans. This has led to a numberreports from groups of experts, nationally and internationally, considering theuse of antibiotics in animals, in man and for plant protection purposes.12,13 Thereis agreement that there should be prudent use of antibiotics in veterinary andhuman medicine with little justification for the uncontrolled use of antibiotics atsub-therapeutic levels to promote growth. The major concern is if there isevidence of medical equivalence for the antibiotic, either where the same drug isused in man and in animals or if there is known antibiotic resistance. This isparticularly relevant if there is a possible impact on the effectiveness ofimportant antibiotics used in human medicine, especially when the antibiotic isone of last choice for life-threatening infections. Debate on the growth promotiondebate will undoubtedly continue, but already there is evidence of sectors of theindustry stopping the use of antibiotic growth promoters as part of theirproduction system. It is easy to say that there should be no use of these productsjust to sustain cheap food production systems and make animals grow faster.However, use of some of the very same ‘antibiotic growth promoters’ appear toreduce disease in the animals, and stopping their use would require a greater useof therapeutic antibiotics. There is a balance, which can be achieved between thetwo schools of thought, which requires the husbandry systems to be changed toreduce the need for use of antibiotics in any form. The issue of consumption ofresidues in food of animal origin is perhaps of less concern, as there is mandatorytesting for residues and a requirement only to use drugs which are licensed foruse in food-producing species within EU Member States.

One option would be to eradicate specific agents which cause disease if theyare identified on the farm. This, however, depends first on the agent beingidentified in the herd or flock or in individual animals harbouring the agent. Inaddition to there being an accurate ‘test’ available, there is the need to decidewhether eradication is really necessary for both animal health and human healthreasons. The aim must be to prevent entry of the agent into individual animals,not just into the herd or flock.

The biological way forward for disease control using vaccines promises to bean important alternative to the need for use of antibiotics. While it has alwaysbeen important to use available vaccines in the appropriate manner, with theincreasing efficacy, and at the same time specificity, of modern vaccines precisediagnosis becomes a must. There is therefore a future for the veterinary clinicianon the farm in improving the health status of the food-producing animals,following proper assessment of all relevant factors, including the provision of a

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farm veterinary health plan. The success of any scheme for any farm or unitrequires, as a minimum:

• surveillance of possible diseases or risks;• establishment of a management structure to reduce the need to react but with

action plans in place so that it is possible to react promptly and appropriatelyif necessary;

• active supervision at all levels;• investigation of all possible, or actual, problems or variations from the

normal, which requires accurate records and monitoring.

4.3 Setting up the HACCP system

Before a HACCP programme can be implemented in any system it is essentialthat all personnel be committed to the same goals. Farm resources must besufficient to achieve the correct monitoring steps. The hazards will depend onthe individual farm production system which will vary between farms and withinone farm, in both the species kept and the production system used. It is thereforeimpossible to design one HACCP plan that can be applied to all farms.

The HACCP system derived from Codex Alimentarius 1991 consists of sevenprinciples. The sequence of applying HACCP as described by Noordhuizen andWelpelo14 comprises 12 steps. Use of these 12 steps in relation to farming can beseen in Table 4.1.

With the on-farm situation there are some obvious differences compared withthe traditional food industries that have used HACCP. The people involved withStep 1 are the farm staff, usually consisting of a farmer or farm manager and inmost cases only one to three members of staff, if any, who are often members ofthe farmer’s family. In addition there are external advisers who need to beconsulted, such as the farm’s veterinarian and the animal feed specialist. In Step2 the product is the slaughter animal (more specifically the meat that will bederived from that animal), milk or eggs. The intended use (Step 3) of theHACCP process is to ensure good health for the herd or flock and refers todisease agents or other hazards that the individual animal should be free of toensure that carcase meat and offal, eggs or milk do not pose a threat to consumerhealth. The consumers of meat and offal can include, in addition to the healthy,people who are at greater risk, e.g. the immuno-compromised, children, theelderly, pregnant women, and people with allergies to pharmaceuticalcompounds such as penicillin. The construction of a flow diagram in Step 4 isimportant as it helps to identify all the aspects of the farm production processthat influence product quality as well as animal and human health. In Step 5,while farmers are often unfamiliar with many concepts of food safety andhygiene, it is critical that they are consulted to make adjustments to the flowdiagram as they have a fundamental understanding of their farm and how itoperates.

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The next step is to implement these principles. A good method of doing thisis to construct a flowchart for each species showing where all potential hazardsmay occur. It is essential that the whole plan is practical and readily usable onthe farm, to maximise compliance. The flowchart should identify all biological,chemical and physical risks that can occur, and assess them in terms of CriticalControl Points (CCP). An action can only be classified as a CCP if it is possibleto eliminate or significantly reduce it and this is likely to be a major stumblingblock in a farm situation. The problem with following the HACCP principles onfarms is that they are usually controls which are good working practices and notCCPs. The three factors that are required before a hazard can become a CCP areidentification, measurement, and control measures. Each farm system will havedifferent CCPs as a result of specific managerial and environmentalconsiderations.

Table 4.1 Steps in applying HACCP

Steps Examples and specification

Step 1 Identification of persons involved Farmer and employees. External experts.

Step 2 Description of products Animals, meat, eggs, milk, wool.

Step 3 Identification of intended use Disease agents the herd should be free of.

Step 4 Construction of flow diagram Description of animal production processas communication tool.

Step 5 On site verification of flowdiagram

Allows specific adjustments and firstreview of potential hazards.

Step 6 Listing of hazards at each processelement [Principle 1]

Check hazards for severity and probabilityrisk quantification needed.

Step 7 Application of a HACCP decisiontree [Principle 2]

Selection of CCP for each hazard.

Step 8 Establish target levels andtolerance for each CCP[Principle 3]

Animal replacement: free of specificdisease agents.Diagnostic tests: antigen-testing vs.serology.

Step 9 Establish a monitoring system[Principle 4]

CCPs are linked to a monitoring system.Monitoring aims at detecting loss ofcontrol at an early stage, and at providinginformation for correction action.

Step 10 Establish corrective actions[Principle 5]

Needed for each CCP selection. Correctionalso needed when monitoring indicatestrend towards loss of control.

Step 11 Verification of the application[Principle 6]

Check correct functioning with respect tosteps 6–10 necessary for introducing andmaintaining system.

Step 12 Documentation [Principle 7] Relevant processes, demonstrable control,certification and insurance.

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As identified by Noordhuizen and Welpelo,14 herd or flock health manage-ment requires the identification of specific disease hazards and their relatedpreventative measures concerning the occurrence and spread of undesireddisease agents. Risk assessment and risk management achieves this. It isimportant to understand the limitations of the HACCP system on farms.Mitchell15 highlights the major reasons for failure which in relation to the farmwould be as follows:

1. Failure to establish relevant monitoring systems (Principle 4).2. Failure to establish proper corrective actions (Principle 5), despite

monitoring systems highlighting the need for correction.3. Failure to consider all hazards appropriate to the farm.4. Difficulty in implementing theoretical aims practically in the farm

environment.5. Over-complication of HACCP plan leading to failure of compliance.6. The farm system is not yet ready for the HACCP system.

4.4 HACCP plans for cattle

The various production stages for cattle are summarised in Table 4.2 whichshould be considered with Table 4.3. The issues on the beef farm are verysimilar to those for the meat production systems of other species of animals butvery different from the issues for lactating animals.

4.4.1 Beef cattleThe beef farm may raise the animals on farm as a sucker herd followed by thefattening stage. Animals may be sold on for the final stages of the fatteningprocess. The farmer may have no breeding animals and rear through to fat animalsbought in as baby or weaned calves. Whichever system is used, it is crucial thateach animal is identified, and full records of any movements between farms,auction markets and the abattoir must be kept. Cattle going for slaughter are gradedby conformation criteria. In addition to deciding that the cattle are ready forslaughter, they must be inspected to ensure they do not have any condition makingthem unfit for human consumption. To avoid contamination of the carcase duringthe slaughter process the animals should be unsoiled on leaving the farm and notbecome soiled during transport or at auction.

4.4.2 Dairy unitThe dairy industry has had many years of experience of working to highstandards of milk quality and safety. This has been helped, at least for milk fromcows, by a combination of financial inducement for high standards or financialpenalty for failure(s) along with legislative control. Although there is the single

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Table 4.2 Summary of production stages for cattle

Procedure Problem Prevention

Replacementbreeding animals orpurchased forfattening

Buying in disease, e.g.salmonella, tuberculosis,pneumonia

Purchase from known disease-free source – checkidentification. Do not introduceto herd until certain they arenot carriers or excretors

Vaccination Viral diseases, pneumonia,possibly clostridialrotavirus/E. coli

Vaccination of breeding stockto ensure maximum passiveimmunity transfer to calves andbefore risk period

Feed Contamination of incomingfeed and when in store withenteric bacteria and mouldsTransmissible spongiformencephalopathy

Vermin-proof stores; goodquality hay and silageNo mammalian derived proteinin feed

Environment Spread of disease by directcontact between cattledischarges, aerosol or byhandler

Use good quality straw forbedding. Clean pens using ‘allin all out’ principle. Goodventilation if housed

Use of medicines Injection site abscessResidues in meatAntibiotic resistance

Sterile needles and goodtechniqueWithdrawal periods adhered toAvoid need for antibiotics bygood husbandry, cleanenvironment and goodcolostrum intake by neonate

Pasturecontamination

Waterlogged pastureencourage coccidia and fluke

Nematode infestation

Hydatid, C. bovis, infestation

Adequate drainage or fence offand use of coccidiostat andflukicidePasture management and use ofanthelminticRegular worming of dogs andappropriate exclusion period ifsludge applied

Foot care WelfareArthritis possible

Early recognition andtreatmentRoutine foot trimming anddipping

Housing duringfattening

Build up of faeces on hide Good housing and husbandryto avoid soiling. May benecessary to wash or clipbefore dispatch for slaughter

Housing beforeslaughter

Cattle coming off wet fields orfodder crops can be very soiled

Put out deep, clean, dry strawbedding for a few days or untilsuitable to go for slaughter

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Table 4.3 Farm HACCP

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

1. Breedingfemale

In poor healthand/or carriers ofdisease/parasites.Susceptible toSalmonellainfection (H)

GMP All animals ingood health. Freefrom signs ofclinical infection

Therapeutictreatment ofanimals sufferingfrom infections. IfsuspectSalmonellaisolate animal(s)from otherlivestock and seekveterinary advice

Daily inspectionof all animals byspecified person

Veterinary advicewith clinicalinfections orunknown causesof ill health

Medicines book.Diary of illness inanimals enteredinto databaseweekly

GMP Improve herd/flock resistance toclinical and sub-clinical disease

Minimise risk ofdisease byoptimumhusbandryincluding, e.g.,control ofparasiticinfestations

Daily inspection.Feedback of meatinspection datafrom abattoir

Seek veterinaryadvice ifprophylaxisappears to beineffective, e.g.parasiteinfestationdetected duringPM meatinspection

Medicines book.Diary of illness.Keep record of allmeat inspectionresults. Enter intodatabase daily

GMP Good bodycondition

Maintain idealcondition score(CS)

Daily inspectionof all animals inflock by specifiedperson

If condition scoreincorrect adjustdiet appropriately

Keep record of CSand diet ondatabase

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Table 4.3 Continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

2. Breedingmale, in additionto 1 above

Can introducedisease onto farm(H)

GMP If rented orbought in shouldbe disease freeand in goodhealth

Do not rent sires.Quarantine newsires afterpurchase,appropriatevaccination andprophylaxis

Specified personto inspect

If bought in siresshow signs of illhealth isolateimmediately andseek veterinaryadvice

Keep record of allmovements ondatabase

3. General Animals in poorhealth and/orcarriers ofdisease/parasites.Susceptible toSalmonellainfection (H)

GMP All animals inflock in goodhealth. Free fromsigns of clinicalinfection

Therapeutictreatment of sickanimals. Isolationof animals whichare ill or abort.Cull barrenanimals or thosewith history ofmastitis

Daily inspectionby specifiedperson.Pregnancydiagnosis

Veterinary advicewith clinicalinfections orunknown causesof ill health

Movement records.Diary of illness andresults ofpregnancydiagnosis. Enterinto databaseweekly. Medicinesbook up to date

GMP Animals kept ingood conditions

Provide highstandard ofhusbandry

Monitoring ofstaff performance

Train staff beforestart job andupdate asnecessary

Document training

4. Parturition

Cleaning anddisinfection ofpens

Environmentalbuild up ofSalmonella (M)

GMP No environmentalcontaminationwith Salmonella

Pens cleanedbetween groupson an all-in/all-out basis

Weekly visualinspection of pencleanliness bymanagement

If cleaninginsufficient,repeat cleaningprocess

Keep record of pendisinfection andcleaning

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New-born Poor passiveimmunity.Risk of infectionwithenterobacteriacea(H)

GMP Ensure sufficientquantity andquality ofcolostrum withinfirst 6 hours

Help to suckle ifhaving difficulty.Store colostrumto feed if extracolostrum notavailable fromdam

Designatedperson to checkwhether neonatehas fed withinfirst 5 hours afterbirth

Feed withmother’s, boughtin or storedcolostrum usingstomach tube

Keep record ofwhen colostrumgiven

Hypothermia (H) GMP Ensure adequatecolostrumreceived withinfirst 8 hours

Help to suckle ifhaving difficulty.Store colostrumto feed if extracolostrumrequired

Designatedperson to checkwhether neonatehas fed withinfirst 5 hours afterbirth

Feed withmother’s or storedcolostrum usingstomach tube

Keep record ofwhen lamb receivescolostrum

GMP Temperaturebetween 39–40ºC

Temp. 37–39ºC:ensure fed, placebelow warminglamp.Temp. below37ºC: place inwarming box,giveintraperitonealinjection ofglucose solution

Designatedperson to checkand taketemperature ifsuspecthypothermia

If neonate hashypothermiacarry out controlmeasures

Keep record ofanimals treated forhypothermia

GMP Sufficient teatsand milk

Check udder andnumber of teats

Check beforeparturition

Foster extrapiglets, lambs

Record reason forfostering

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Table 4.3 Continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

Bedding in pens Build up ofinfective materialon surface layerof bedding

GMP Clean drybedding (straw) inpen

Place largequantities of freshgood-qualitystraw bedding toall pens everyday, twice per daywhen weatherwet. Individualmothering pens:add fresh strawbefore every newewe and lamb(s)

Designatedperson to checkcleanliness ofbedding in pensdaily

If bedding in pennot clean, addsufficient straw tocover pen surface

Keep record ofnumber of strawbales used per day

Place mother andnewborn inmothering pen

Poor bondbetween neonateand motherleading to poorperformance/health in lambdue to rejection

GMP Good bondbetween motherand neonate

Place inmothering pen for48 hours ifmother does notaccept progeny

Designatedperson to checkfor rejectednewborn

If rejected, placemother andprogeny intofoster pen or feedartificially

Record all rejectedneonates andsuccess of fostering

Identification Difficult todetermine whichnewborn belongsto which mother

GMP Mother andprogeny shouldbe clearlyidentifiable

Apply visible IDsuch as markerspray soon afterbirth. Use ear tagsfor individualanimalidentification

Dailymanagementobservation toensure that staffidentify lambscorrectly

Applyidentification tolambs or ewesthat are unmarkedor incorrectlymarked. Replaceidentificationequipment ifnecessary

Record all lamband eweidentificationmarks, ear tags, etc.

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Castration,disbudding ofcalves and tailingof lambs

Stress reducesability to resistinfection (M)

GMP Disbud, castrateand tail withminimum of painand suffering

To be carried outby competentlytrained individualfully conversantwith legalrequirements

Management (ordesignatedperson) to checkdaily whethercastration andtailing donecorrectly

Advise personcarrying outtailing/castrationif incorrectprocedure beingused

Record date ofbirth and time ofdisbud, tailing orcastration

5. Put out intofield

Grazing Contaminationwith pathogens(M)

CCP2 Do not allowpasture to begrazed whenuntreated faecalmaterial has beenapplied

No grazing onland which hashad sewagesludge, slurry ormanure appliedunless within theguidelines forapplication

Check recordsweekly to ensuresheep or cattle arenot grazinggrassland orforage that hasnot beensufficiently rested

If animals aregrazing landwhich has notbeen sufficientlyrested move themto a different field

Date of sludge ormanure applicationon all fields. Sludgetreatment method

CCP2 Contamination ofpasture by geese

Bird scare deviceto deter geesefrom grazingpasture

Weeklyobservation bymanagement forsigns of geese.Weeklyinspection of birdscare device bydesignatedmember of staff

If geese presentuse additionalbird scare or useshooting as acontrol measure.Repair or replacefaulty bird scare

Keep record of birdscare inspection.Keep record ofsightings of geese

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Table 4.3 Continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

Drinking water Contaminationwith Salmonella,Campylobacter,cryptosporidia(M)

CCP2 Drinking waterfree frompathogens

Use mains wateronly. Cleandrinking troughsthoroughlyannually

Sample watertroughs annuallyand test forSalmonella

If trough ispositive forSalmonella cleanand disinfectimmediately.Retest and if stillpositive, re-clean,disinfect and testwater supply.Identify source ofcontamination

Record results ofall water samples

Clean drinkingwater

Ensure drinkingtroughs arecleaned outregularly

Daily visualinspection bydesignatedmember of staffof all drinkingtroughs in use

Removal ofvisiblecontamination.Empty and cleanif contaminatedwith faeces, birds,etc.

Record findings ofdaily visualinspection

6. Prior tohousing orparturition

Pneumonia,clostridialinfection (L)

GMP Animals freefrom pneumoniaor clostridialinfection

Vaccination priorto housing orparturition. Checkventilation ofbuildings

Specified personto ensure thatvaccination is atcorrect time

If not vaccinateddo so at nextopportunity

Diary andmedicines book

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7. Control ofparasites

Infestation withhelminths (H) andectoparasites (L)

GMP Free from clinicaland subclinicalhelminth andectoparasticinfestation

Administration ofappropriateanthelmintic,depending onhelminth speciesof concern, e.g. ifwet grazing needto use flukicide

Daily inspectionof all animals byspecified person.Look for signs ofhelminthinfestation suchas diarrhoea andectoparasites, e.g.hair loss. Post-mortem results ofmeat inspection

Immediatetreatment ifsymptoms ofinfestation. Seekveterinary adviceif treatmentappearsineffective.Helminthinfestation:modifyprophylaxis ifnecessary

Keep livestockmedicines book upto date.Keep record ofmeat inspectionresults for lambs, ifpossible to obtain

8. Weaning Post-weaningstress

GMP — Careful handlingto minimise stress

Implement furtherinspection theweek followingweaning

Prompt treatmentof animalsshowing signs ofill health

Records of any illhealth or treatment

9. Overwinteringoutside

Animals developpoor condition, illhealth due toadverseconditions

GMP Animals have dryarea to shelterfrom wind, rainand snow

Provide sheltersuch as strawbales by hedge orother temporarywindproofstructure.Provide dry lyingareas withinshelter withtarpaulin, tin orother suitablecover to protectfrom rain or snow

Designatedperson to inspectshelter daily.Designatedperson to observeto determine ifsome animals arenot gainingshelter

If shelter isinsufficient ordamaged provideadditional and/orreplacementshelter

Record of dailyinspections ofshelter

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Table 4.3 Continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

GMP Provision of cleanwater

Ensure watertroughs are cleanand that water isnot frozen

Designatedperson to inspectwater supply infields daily

If supply frozenbreak ice and cladpipes ifnecessary. Ifwater in danger offreezing increasechecks to 3 timesdaily. If watercontaminatedclean trough

Record of dailyinspections ofwater troughs

Correct nutritionfor weatherconditions

Ensure thatsufficientroughage isavailable and thatnutrition is atdesired level

Designatedperson to inspectdaily

If in poorcondition providesupplementaryfeed or house

Record of dailyinspections

10. Generalprecautions

Drinking water Contaminationwith entericpathogens (H)

CCP2 Drinking waterfree from entericpathogens

Use mains waterwheneverpossible. Cleanthe drinkingbowls andbuckets onceevery month

Sample waterbowls prior tohousing and testfor Salmonella

If water bowl ispositive forSalmonella cleanand disinfectimmediately.Retest if stillpositive, re-clean,disinfect and testwater supply

Record results ofall water samples

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Clean drinkingwater

Clean anddisinfect alldrinking bowlsand bucketsbefore and afterhousing of sheep

Daily visualinspection bydesignatedmember of staffof all drinkingbowls andbuckets in use

Removal ofvisiblecontamination.Empty and cleanif contaminatedwith faeces

Record findings ofdaily visualinspection

Clean feed Contamination offeed withSalmonella (H)

CCP2 Ensure feed isstored under cleanand dryconditions

Store feed inclosed bins thatare dry and verminproof. Baggedfeed cover withbird-proofsheeting. Useblower so thatloose feed does notcome into contactwith ground.Ensure feed storeis dry and clean

Specified personto check integrityof feed bins/feedstore once perweek

If feed bins aredamaged moveany feed to a newbin and repair orreplace damagedfeed bin

Record findings ofweekly feed bin/feed store checks

Rat/micepopulation

Infection with,e.g., Salmonella,Leptospira (H)

CCP2 Control rat andmouse population

Poison baitsaround buildings.Seek advice ofspecialist pest-control contractor

Weeklyinspection of baitsby specialistcontractor

Replacement ofbaits and poison ifnecessary bycontractor

Keep records of alldead rats and micefound

Have 3 metres ofopen groundsurroundinglivestock buildingand feed storagearea

Keep whole farmtidy. Do not stackpallets or leavefarm machineryby livestockbuildings/feedstorage

Weekly visualinspection bymanagement

Removal ofrubbish andproper storage ofequipment, farmmaterials andmachinery

Record of rubbishor equipmentrequiring removal

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Table 4.3 Continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

Staff Spread ofSalmonella fromother livestock(H)

CCP2 Clean clothes andboots

Staff must changeprotectiveclothing and usedisinfectant footdips before andafter enteringareas

Managerialobservation

Enforcement ofmeasure bymanagement

Record ofoccasions whenhygiene measurerequiresenforcement

Visitors Introduction ofSalmonella (H)

GMP Minimisepresence ofvisitors

Vehicles parkedaway frombuildings

Managerial/staffchecking ofenforcement ofthese measures

Ask unauthorisedvisitors toimmediatelyleave farm area.Remove vehiclesfrom vicinity ofbuildings

Visitors book.Visitors should signin and out

GMP All visitors towear cleanprotectiveclothing

Changingfacilities nearhousing

Managerial/staffchecking ofenforcement ofthese measures

Ask visitors toimmediately goand change intoprotectiveclothing

Record use ofprotective clothing.Sign clothing inand out

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CCP2 Ensure visitors/staff do not treadinfectious agentsinto farmbuildings

Obligation forstaff and visitorsto use disinfectantfoot dip beforeentering intolivestockbuildings.Designatedperson to changefoot dips weekly

Weeklymanagerialinspection of footdips

Replenishment offoot dips whennecessary

Record use of footdip solution.Record inspectionof foot dips

Wild birds Infection withSalmonella,Campylobacter(H)

CCP2 Minimise birdsroosting inbuilding roof

Use bird scaresuch as bird ofprey silhouette orsonic bird scare

Daily visualinspection ofbuilding byspecified person

Shoot pigeons Keep records of alldead birds found

GMP Remove spilt,waste feed

Daily visualinspection ofbuilding byspecified person

Clean up anyspilt, waste feed

Keep record of spiltfeed and disposal

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raw product, milk, which is consumed or will go for processing, it can be from anumber of species of animal. The main milk-producing species is cattle, withsheep and goats also milked commercially. Milk can also be harvested from lesscommon animals such as camels, buffalo and horses and may be done socommercially in the future.

The hazards in milk are mainly from faecal and environmental contaminationof the teat and udder, but both chemical and microbiological hazards can bepresent in the milk within the udder. The chemical contaminants may be due tofeeding practices (aflatoxins, dioxins, nitrates), from husbandry practices(pesticides), from veterinary medicines, and from pollution (heavy metals,radioactive elements). Microbiological hazards include the zoonotic organismspresent in the milk as contaminants of the milking process, and organisms whichare excreted in the milk from the udder.16–19 The form of the milk-producinganimal does not help, with the udder at the rear of the animal and under the anus.The major microbiological risk is from faeces, in particular when the faeces aresoft or very liquid. Sheep and goat faeces are typically voided as pellets whichreduces to some degree the faecal soiling of the animal and the hands of themilker. The relevant aspects of milk production relevant to control of thehazards include routine milking schedules, the importance of an efficient, wellmaintained milking machine, management of the housing, and mastitis control.Bacteria reach the milk from contamination of the udder surface, from within themammary gland and from the inner surfaces of the milking equipment, includingthe bulk storage tank. Milk from a cow with clinical mastitis can easily have 106

organisms per millilitre which if it were allowed to pass in to the bulk tank couldhave serious consequences. Subclinical mastitis is a problem for the farmer, notonly for the health of the udder but also as the presence of an increase in thesomatic cell count of the milk lowers the quality of the product, particularly formanufacturing. Mastitis is considered to be of three types – contagious,environmental and ‘summer’ mastitis. The commonest organisms involved inthe different forms of mastitis are shown in Table 4.4.

Prevention of mastitis starts with the selection of the replacement animalwhich must have good udder conformation. The teats and the teat end inparticular must be maintained in good condition. Keratin and fatty acids on theskin have antibacterial properties. Most infections, however, are through the teatcanal which in effect is the first line of defence against infection of the udder.Teat end damage is a sequel of poor milking equipment, possibly badly serviced,or incorrect handling of the milking cluster during the milking process. Coatingof the teat end in disinfectant, by spray or dipping, after each milking has theeffect of leaving some disinfectant in the bottom of the teat canal which protectsthe udder while the canal is still open after milking and reduces the pathogens onthe skin of the teat.

The infusion of a long-acting intramammary antibiotic into each quarter ofthe udder at the end of the lactation will eliminate bacteria present in the udderand protect the udder in the early dry period. It has been shown that use of drycow therapy is effective against E. coli and in the subsequent lactation the

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Table 4.4 Common microorganisms involved in bovine mastitis

Contagious mastitisorganisms

Infection occurs during milking

Streptococcus agalactiae Obligate bacteria of the udder which may also colonisethe teat canal and is extremely contagious

Staphylococcus aureus Frequently a chronic infection of the udder but may alsobe involved in peracute or gangrenous mastitis. It is anormal inhabitant of teat skin and can be difficult toeliminate from the udder

Streptococcus dysgalactiae Commonly found in teat lesions and in the tonsil and issometimes considered midway between a contagiousand an environmental organism

Mycoplasma bovis, M.californicum

Highly contagious and a big problem in North America

Environmental mastitis Infection occurs either at milking or between milking

Escherichia coli Present in large numbers in faeces; infection is oftenassociated with faulty milking machines

Klebsiella pneumoniae A soil commensal and commonly found on damp andpoorly stored sawdust which may be used as bedding forthe milking animals

Pseudomonas aeruginosa Less common and is associated with water stored at lowheat and used to wash teats before milking

Summer mastitis organismsActinomyces pyogenes withthe anaerobe Peptococcusindolicus or with Strep.dysgalactiae, or both

Problem of animals during summer months, linked withflies and damage to the teats

Table 4.5 Actions taken during the milking process

Milking procedure Action

Identify cow on entry to milking parlour GMPEnsure correct ration given GMPRemove cows with signs of mastitis CCPDry wipe or wash teats (pre-milk disinfection possible) CPApply cluster immediately after preparation GMPRemove cluster at end of milking or use automatic cluster

removal to avoid over-milkingGMP

Teat end disinfection GMPMilking staff should wear rubber/vinyl gloves CPClean and disinfect plant after each milking session CCPPrompt cooling of milk CCPOn-farm pasteurisation CCPTest for Somatic Cell Counts and Total Bacterial Counts CPTest for residues CCP

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number of mastitis episodes is significantly reduced. For cows in the summermastitis season it is worth taking them through the milking parlour each day andspraying their udders with fly repellent. In addition, if straw yards are used forhousing the cows it must be changed regularly to avoid build-up ofenvironmental organisms.20

The process of milking animals can be divided into a number of definedactions which impact on the product and the well-being of the animal. There arefew control points, with most actions being good practice (Table 4.5). Thefactors which impact on milk hygiene are shown in Fig. 4.1.

Milk is very sensitive to taint which can occur from three sources: chemicals,bacteria and the use of certain feeds. Chemical taint is the most important and acommon cause is use of the wrong chemicals, such as phenols which are bannedfrom use in the dairy or milking parlour, or not following the product data sheetinstructions for use. The commonest feed ingredients which cause taint arebrassica plants, fishmeal and weeds such as wild garlic. The use of home

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remedies or alternative remedies may cause a problem if, for example, theycontain aromatic substances such as aniseed or linseed oil.

4.5 HACCP plans for sheep and goats

The primary output from a sheep farm is the slaughter animals, but sheep may bemilked to produce drinking milk or further processing, whereas it is the conversein goat herds. The comments on milking cows are equally applicable to sheep,although the scale of the operation is usually smaller. There may be a sector ofthe industry in which hand-milking is carried out, but mechanical milkingequipment is readily available. To ensure that a HACCP plan applied to a sheepflock remains simple and workable it must be separated from any flock healthscheme. There are many diseases that pertain to the overall health andproductivity of the flock and, possibly, to the quality of the meat but that will notdirectly affect human health. The production of sheep as summarised in Table4.6 should be considered along with the general production information in Table4.3.

In the sheep flock there is the additional concern for the health of thestockman from zoonoses which cause abortion, such as Chlamydia psittaci,Toxoplasma gondii, Campylobacter spp., Salmonella spp., and the use ofchemicals, e.g. organophosphates, as dips. In terms of the diseases mentioned inTable 4.6, evidence of parasitic infestation will be the most likely indication ofaction being required at post-mortem meat inspection.

Table 4.6 Summary of production stages for sheep

Procedure Problem Prevention

Replacementanimals

Buying in disease, e.g. Maedivisna virus, Caseouslymphadenitis

Purchase from known disease-free source; do not introduce toflock until certain they are notcarriers or excretors

Vaccination Clostridial diseases,pneumonia and abortion agents– cause mortality, morbidityand condemnation at meatinspection

Vaccination of all sheep withbooster of clostridial vaccinebefore lambing to ensuremaximum passive immunitytransfer to lambs

Feed Contamination of incomingfeed and in stores with entericbacteria and Toxoplasmagondii and mouldsLamb feed with coccidiostatTransmissible spongiformencephalopathy agent

Vermin-proof stores; avoidcontamination of hay by catfaeces; good quality hay andsilageApply withdrawal periodNo mammalian derived proteinin feed and genotype breedingmales for susceptibility

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4.6 HACCP plans for a poultry unit

Poultry meat and eggs and their products are recognised sources of humansalmonellosis. One of the big food scares followed the announcement in the UK byEdwina Currie in 1989 about Salmonella in eggs. There then followed a dramaticdrop in egg sales and the subsequent raft of measures put in place by governmentto control Salmonella enteritidis and S. typhimurium, which included slaughter

Table 4.6 Summary of production stages for sheep

Procedure Problem Prevention

Environment Spread of disease by directcontact between sheep, fromdischarges (e.g. uterine fluidsand placenta), aerosol or byhandler

Use good quality straw andremove placentas fromlambing yards. Clean anddisinfect pens.Good ventilation if housed

Antibiotic use Injection site abscessResidues in meatResistance, e.g. followingprophylaxis for watery mouth(E. coli) infection

Sterile needles and goodtechniqueWithdrawal periods adhered toAvoid need by cleanenvironment and goodcolostrum intake

Pasturecontamination

Waterlogged pastureencourage coccidia and flukeNematode infestationHydatid, T. ovis, T. hydatigenainfestation

Adequate drainage or fence offand use of coccidiostat andflukicidePasture management and use ofanthelminticRegular worming of dogs

Foot care WelfareArthritis and pyaemia possible

Early recognition andtreatmentRoutine foot trimming anddipping

Dipping Ectoparasites – fleece damageand possible emaciationPost-dipping lameness(Erysipelas rhusiopathiae)

Routine dipping or injectableproductKeep dip solution clean withpossible use of antbacterials insolution. Use spray

Crutching Ewes

Lambs

Reduce faecal contamination atlambing or at milking; avoidflystrikeReduce faecal contamination atslaughter and flystrike insummer

Housing beforeslaughter

Lambs coming off wet fields orfodder crops can be very soiled

Put out deep, clean, dry strawbedding for a few days or untilsuitable to go for slaughter

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arrangements for infected flocks. Salmonella infections in poultry often remainundetected due to the lack of clinical symptoms in the flock.

The poultry industry has evolved over the years with the result that there is abreeding pyramid with very high health status, elite, grandparent and parentbreeding birds at the top (Fig. 4.2). Recognising the problem of verticaltransmission of S. typhimurium and S. enteritidis, great care is taken to ensurethese birds are free from Salmonella spp.

Control of infections in these breeding flocks can be by slaughter of thebreeding flock, an option which is not reasonable for layer flocks and broilerbirds. Systematic approach at each link in the poultry production chain is

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necessary if the flock prevalence, and the meat and eggs produced, of pathogensis to be markedly reduced. The recommendations contained in the RichmondCommittee Report4 in 1990 dealt specifically with the poultry industry and madea number of recommendations relating to housing, husbandry and feed which arevalid today. The major concern still remains with the likely contamination of apercentage of the meat due to colonisation of the birds at the farm productionwith cross-contamination during transport. Withdrawal of food from theslaughter birds before transport to reduce the excretion of Salmonella by thebirds on arrival at the slaughter plant has been common practice. However,Corrier and his fellow workers identified the crop as being a significant sourceof Salmonella contamination during slaughter and feed withdrawal beforetransport increased the likelihood of contamination.21

As eggs may be consumed raw or used as raw ingredients in uncooked dishesit is essential that they are free from pathogens. The egg industry has movedfrom battery houses with the layer birds in cages to floor-based and outdoorwelfare-friendly systems. The results of investigations have suggested that othersystems have a higher proportion of Salmonella isolations than batterysystems.22 A code of practice was published by MAFF in 1996 which providesguidance on good hygiene principles and practice on the production site, at thegrading and packing station and during distribution and storage. The British EggIndustry Council operates a Code of Practice for Lion Quality eggs. This hasbeen revised to include a requirement by the flocks to use vaccination forSalmonella enteritidis. These measures collectively appear to be reducing theincidence of S. enteritidis in the laying flocks. In contrast some countries do notpermit the use of this vaccine and rely on the effectiveness of control measureson the farm.

A relatively large number of vaccines are used in the poultry industry formajor viral diseases in both breeding and commercial layers. In addition to thevaccine which is available for S. enteritidis there is also a vaccine againstcoccidiosis. The Salmonella vaccine is not used at the very top of the breedingpyramid where control is by very high biosecurity on the site along with rigorouscontrol by careful monitoring of feed, staff and water supply, etc., supported bymicrobiological monitoring.

Organisms identified as potentially hazardous to food production are S.enteritidis, Campylobacter jejuni and Listeria monocytogenes. The hazards andCCPs that have been identified in the on-farm production of broiler meat arewell described by the 1990 Report on the Microbiological Safety of Food.4 Theaim of the HACCP system in broiler production is the reduction ofcontamination of birds leaving the farm, with the previously describedorganisms. Clinically affected birds should be identified before the flock leavesthe farm. The problem will remain with asymptomatic carrier birds which areshedding or become shedders following catching and transport prior to arrival atthe processing plant. In order to prevent the passage of pathogens from old birdsto day-old chicks, the best policy is to implement an all-in, all-out practice, thatis, the cleaning and disinfection of all houses and equipment prior to arrival of a

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new flock. This will prevent residual contamination with dust, dirt andpathogens. Cleaning should include drinkers and feeders, with removal of litter.Bacteriological samples can be taken following cleaning to assess the efficacy ofthe disinfection, and records of all cleaning procedures should be kept.Additionally, adequate cleaning and disinfection of the farm and equipmentbetween each crop will limit the spread of infection between flocks. It has beenthe practice to empty each house, clean and disinfect, then restock. Morerecently the emptying of all houses on a site with a complete clean anddisinfection of the whole site along with composting of the litter beforerestocking has been recommended.

Vehicles bringing birds on to the farm, visiting personnel, and employeesshould all be suitably disinfected and recorded, and all livestock movementsshould be noted. Vermin should additionally be controlled, and in particularbird/rodent proof feed bins should be provided to prevent access by theseanimals resulting in potential contamination of food sources. This will bedifficult, if not impractible, with free-range systems. Additional CCPs thatshould be considered are those involving the use of pharmaceutical (medicinesand food additive) agents. All drugs used should be clearly recorded, andwithdrawal times should be closely adhered to.

4.7 HACCP plans for a pig unit

Diseases are present within swine populations that could pose a potential healthrisk to consumers. These include agents such as Salmonella spp., Streptococcussuis, Yersinia enterocolitica, Trichinella spiralis and Toxoplasma gondii. Inaddition, there must be constant awareness of emerging agents, such as Nipahvirus in the pig population of SE Asia in 1999.

The use of good husbandry practices on the farm is critical in the productionof pigs intended for slaughter. The pig industry is a good example of thedifficulty in applying HACCP on farms with the tremendous variation in thetype of pig production systems in use. Over many years the pig industry in somecountries has developed an integrated production chain involving the farm andslaughter plant and using data from the findings at post-mortem meat inspection.This allows a study of the effects of the production system on disease occurrencein the groups of pigs. The interrelations between the farm-level circumstancesand the health status of animals have been described by many workers.Examples include a comprehensive review by Stark in 1999 of the environ-mental risk factors on respiratory disease in swine,23 while Bandick et al.reported that slatted floor systems without straw bedding were associated withabscesses on the exterior surface of the animals.24 In addition, a number ofadverse factors have been identified in pig production:

• multiple sources of piglets• overcrowding of pigs

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• deficient isolation of groups• continuous fattening (holding back smaller pigs)• large farms with large herds• big barns• adverse climates• dust and handling liquid manure without precautions against ammonia.

There has been considerable pressure on the farming industry from consumergroups to move from the intensive production system to outdoor, extensivesystems. This move to outdoor, extensive production exposes the pigs to a muchgreater challenge from the environment and increases the risk of zoonoticinfections and infestations. The intensive pig production units which havebuildings with a high level of biosecurity are best suited to a HACCP plan.While the aim must be to apply HACCP-like principles on the farm, there is apractical limit to the number of critical control points which can be applied evenin the intensive units. Bacterial contamination of pigs entering the slaughter-house must be carefully controlled to prevent contamination of the carcase andsubsequent introductions of bacterial pathogens into the human food chain. Thiscan be achieved by introducing HACCP onto the farm to limit the spread ofpotentially pathogenic organisms between individuals, and subsequent popula-tions.

Similar requirements to those previously described for poultry can beimplemented in commercial, intensive pig production units, with similar goals.There is then the requirement to identify the responsibility at each stage of theproduction chain. Quality Assurance schemes, including major producer orretailer schemes, are starting to address these concerns by implementing regularveterinary inspections of all accredited farms, with minimum requirements ofhygiene and welfare, thus further raising standards. In slaughter pig production,preharvest food safety has been emphasised with integration of Total QualityManagement and HACCP so that significant improvements can be expected.25,26

This must include a surveillance and control programme for disease andpresence of pathogens. This may be, for example, as the current requirement tosample pig carcases within Member States of the European Union for evidenceof Trichinella spiralis, or the Danish national scheme described by Mousing andhis co-workers in 1997 based on the quantification of the within-herd prevalenceof Salmonella enterica.27 This was the most extensive attempt on a nationallevel to control S. enterica in pork, and the epidemio-surveillance of S. entericacarriage by pigs in Denmark was reviewed by Christensen et al. in 1999.28 Usinga central database, the results were used to assign the herds to one of three levelswhich determined the acceptability of the herd or the action necessary. Inaddition, a clear relationship was shown between antibody levels in serum andthat in muscle tissue fluid, allowing detection of Salmonella infection at the herdlevel through meat juice analyses in the slaughter plant.

Critical to the success of any future system must be the exchange ofinformation from the findings at meat inspection in the abattoir. In fact this is

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not just a trace-back from the abattoir system but also a trace-forward ofinformation about individual pigs or groups of pigs. This would depend on therebeing an accurate recording system on the pig farm which must containinformation on a number of items and events, including health and performanceindicators. The minimum information to be recorded on the farm and availablefor inspection is:

• performance data of pigs, e.g. growth rate, feed conversion• dates of visits by veterinary services• health problems• morbidity and mortality data• results of veterinary examinations• results of laboratory examinations and tests, e.g. serology for Mycoplasma,

Salmonella• treatments, e.g. vaccination, medication• use of feed additives• results of preselection.

For pig production the provision of feed which is microbiologically clean andfree from residues is as important as in other species. This is easier to achieve ifthe pigs are housed with the feed delivered in closed vehicles and delivered tothe feeding trough via an auger from the storage silo. This is not possible forpigs which are outside where the feed may be on the ground and also provides anattraction to birds and vermin. Feeders for outdoor pigs which restrict access bybirds have been developed but will never be totally bird and vermin free. Pigs bynature are rooting animals and will thus be exposed to hazards while rooting andwhen wallowing in water holes.

With housed pigs, major stress factors are the moving of groups of pigs alongwith mixing of litters to form larger groups. This can lead to the onset of entericand respiratory illness. Leaving the piglets in the pen in which they were bornfollowing weaning until they reach slaughter weight is considered to reduce thepossibility of disease and reduce antibiotic use.

4.8 Summary: the effectiveness of HACCP on the farm

The potential benefits of on-farm HACCP for improving the health status oflivestock, for reducing or controlling foodborne pathogens and for qualityassurance has been commented on by several authors.4,29–34 With regard tocattle and sheep, most attention has been focused on dairy cattle, particularlywith regard to antibiotic residues in milk.31,35 None of the papers give examplesof actual on-farm HACCP plans for cattle or sheep farms or consider thepracticality of implementing such a system in a non-intensive farmingenvironment. The poultry industry has applied HACCP-like principles as partof the Salmonella reduction programme. Noordhuizen and Frankena33 give anexample of a generic HACCP-like approach to the control and prevention of

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salmonellosis on pig farms but again not for a specific farm. FurthermorePierson29 stated in 1995 that the animal and feed production HACCP plans thathe had come across were essentially GMP plans in a HACCP format without anytrue CCPs in place. Therefore the provision of actual examples of farm-levelHACCP plans and discussion of the practicalities, strengths and weaknesses ofsuch a system are required.

Farm-level factors and their impact on health of animals intended forslaughter must have flexibility to take into account regional risks but must be avertically integrated production and slaughter chain. Critical to food safety is therecording of the following:

• data on the herd as a whole, including information about administration ofmedicinal products and immunisation programmes

• data on the health status, including information from the disease records andthe general body condition of the animals going to transport

• data on the performance of each group, and the herd as a whole, e.g. dailyliveweight gain, mortality and morbidity figures

• knowledge about farm environmental factors, which are crucial for a goodresult of fattening, including data on the buildings

• feed quality control at the farm level, including feed supplier qualityassurance

• traceability of individual animals and groups of animals at all times,including movements on to the unit.

To this information must be added the ‘feedback information’ from the slaughterplant or the processing plant. This would include findings at post-mortem meatinspection from the slaughterhouse, including any effects of transport such as thepresence of Pale Soft Exudative (PSE) or Dark Firm Dry (DFD) meat or otherdefects such as injuries, filthiness, fatigue or stress. The monitoring of pathogensand residues, identified and agreed as being appropriate to the production systemand to the geographical region in which the animals are produced, is part of thenecessary epidemiological surveillance.

It is perhaps easier for the farm to apply the HACCP concept whenconsidering residues. This will include residues from the use of medications andfrom other sources. A summary is provided in Table 4.7. The legislativerequirements for medications to be used on food producing animals is a majorfactor on the safety of that food from the animal(s) but care has to be exercisedto ensure residues from other sources do not enter the food chain. Theassessment of risk must therefore consider all obvious sources of residues andalso recognise the risk from unintentional access to source of a potential residueor to residues following an illegal act or operation.

One major problem is that when HACCP is said to be used it is usually as partof the farm’s Quality Assurance scheme when in reality it is Safety = Welfarewith little consideration of true food safety issues. There is a real need for thewhole area to be properly established so that any HACCP or Risk Assessment orRisk Management approach is set up to manage and not to react.

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Table 4.7 Dairy, beef and sheep HACCP (residues)

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

All animals Animals in poorhealth, possiblesign of toxicsubstance (L)

GMP All animals inflock/herd ingood health, freefrom signs ofclinical infection

Veterinarytreatment ofanimals andidentification ofsource of toxicchemical

Daily inspectionof all animals inherd by speciificperson

Veterinary advicewith apparenttoxic infections orunknown causesof ill health inlivestock

Keep livestockmedicines book upto date.Keep record ofillness in animals.Enter intocomputor databaseweekly

Grazing land Contamination ofpasture with toxicplants leading tointake bylivestock

CCP1 Only allow accessto pasture that isfree of toxicplants

No grazing onland where toxicplants are present

Daily inspectionof fields withanimals bydesignatedperson. Inspectionof new fieldsprior to movinganimals in

If cattle aregrazing land thatis contaminatedwith toxic plantsmove them to adifferent field

Record findings offield inspection ondatabase

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Table 4.7 continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

Contamination ofgrazing land withheavy metals andother toxicelements

CCP1 Only graze landthat is free fromtoxic elements inthe soil such asheavy metals

Take soil samplesfrom all grazingland every fiveyears. Have soiltested for toxicelements. Findout the history ofland use for thefields andsurrounding land(e.g. adjacent toold lead mine)

Designatedperson to checkresults of soiltests. Investigateand corroborateany positiveresults

Do not allowcattle to grazecontaminatedfield. If cattle arealready present infield remove fromfield and seekveterinary adviceregardingpotential animaland public healthconsequences.Investigate sourceof contamination

Record results ofall soil tests

Contamination ofgrazing land withheavy metals andother toxicelements byapplication ofsewage sludge(H)

CCP1 Any sewagesludge applied tothe land should betreated and freefrom heavy metaland other toxiccontaminants

Sewage sludgeshould becertified as freefrom heavymetals and othertoxiccontaminants.

Test sample ofevery batch ofsewage sludgeapplied to land.Designatedperson to check

If heavy metals orothercontaminantsfound in sludgedo not grazeanimals in field

Record date ofsewage sludgeapplication on allfields. Have recordof sewage sludgetests

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Medication fortherapeutic orprophylacticreasons

Antibiotic or drugresidues in milkor meat (H)

CCP1 Adhere towithdrawal times

Record allmedication use infarm medicinesbook. Shouldinclude whoadministered themedication andthe finalwithdrawal date.Ensure that staffcorrectlyadministermedication andidentify animals.Only use licensedveterinaryproducts

Management tocheck farmmedicine book toensure allrequired data iscorrectly entered.Designatedperson to checkthat sufficientwithdrawal periodfor medicationhas been met forall animals beforethey are sent forslaughter ormilked for humanconsumption

If withdrawaltimes formedication hasnot been met, donot send animalsto slaughter ormilk for humanconsumption

Keep farmmedication bookup-to-date andcorrectly filled in

Clean feed Contamination offeed with toxicsubstance such asmycotoxin (M)

CCP2 Ensure feed isstored under cleanand dryconditions

Store feed inclosed bins. Keepfeed dry and outof contact withground. Do notstore withanything else

Specified personto check integrityof feed bins onceper week. Dairyfeeds tested foraflatoxin

If feed bins aredamaged moveany feed to a newbin and repair orreplace damagedfeed bin

Record findings ofweekly feed binchecks

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Table 4.7 continued

Process step Risk: H, M, L Control Criteria Control measures Monitoring Corrective action Records

Contamination offeed with toxicsubstance such aspesticide (H)

CCP1 Safe storage of allfarm chemicals,such asinsecticides,separate fromfeed store,livestock, etc.

Safe and securestorage ofchemicals andother hazardoussubstances inbiulding/containerapproved for suchpurposes. FullCOSHHassessment offarm chemicalsand environment.Do not harvestwithin prescribedwithdrawal period

Weeklyinspection byspecified personof chemicalstorage and farmbuildings andlivestock areas toensure safestorage and use ofsubstancescovered byCOSHH

If chemical spillor contaminationfoundimmediatelyfollow COSHHaction plan andsecure area. Allfeed, bedding orothercontaminatedsubstances to bedisposed ofappropriatelyaccording toCOSHH report/chemicalmanufacturersrecommendations.If animalcontaminatedseek appropriateveterinary advice

COSHH report andaction plan to bekept up to date.Record weeklyinspection findingsin report book,signed and dated byspecified personresponsible forinspection

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Clean water Toxic chemicalsin water leadingto contaminationof animals,resulting inresidues inlivestock productsand animal publichealth risk, e.g.milk (H)

CCP1 Water free fromtoxic impurities,whether heavymetals,manufacturedchemicals orothercontaminants

Use mains wateronly. Clean thedrinking waterbowls once everyweek. Waterbuckets to beemptied andrinsed every daybefore addingfresh water. Donot use lead pipes

Sample drinkingwater tanks,bowls and troughsonce every 6months and testfor purity andtoxins

If water is foundto becontaminated,stop useimmediately andsupply animalswith water fromanuncontaminatedsource. Find outsource ofcontamination, ifdue to on-farmsubstance coveredby COSHH auditimmediatelyfollow COSHHaction plan

Record results ofall water samples inreport book, signedand dated byspecified personresponsible forinspection

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To implement a HACCP system successfully the farm should already beobserving all GMPs. There must also be a real commitment from themanagement to develop a HACCP system with effective communication withand training of the farm staff and others involved in any way with the farmoperation. An effective monitoring system will provide information fromaccurate records for future use. It will also enable management to take timelydecisions before a process gets out of control.

The success of any scheme for any farm or unit requires, as a minimum:

• surveillance of possible diseases or risks;• appropriate measures for necessary actions put in place;• active supervision at all levels;• investigation of all possible, or actual, problems or variations from the

normal.

The success of animal production practices cannot be based solely on thereduction of foodborne disease. The data from the slaughter plant and the furtherprocessing stages must all be linked with the data from the farm. The slaughterplant and further processing can provide valuable data from routine testingprogrammes for zoonotic pathogens such as Salmonella and Trichinella spiralisas well as for residues. For the link to be effective there must be baseline datafrom the live animal stage.

Under such circumstances food safety is critical for any farmer, farm group ornational industry to maintain or increase market share. Therefore farms need notonly to improve food safety but also to provide documentation that verifies whatsteps are taken and what controls are in place. For such purposes theimplementation of the HACCP system on the farm has real potential to improvepublic health and animal health and welfare. The international use of theHACCP system by food manufacturers and producers is a logical progressionenabling harmonisation of international food safety regulations and the removalof non-tariff barriers to trade arising from food safety.36 The considerations mustalso apply to foods and animals imported from countries where the controls, forexample, on antimicrobial use will not always be as rigorous as in the UK.Increasingly agricultural produce, the raw material on which the rest of the foodindustry relies, is a commodity on a worldwide market. There is increasingcompetition for producers of beef and lamb as well as pork/pigmeat and poultrymeat.

A cornerstone of future assurance to consumers, the EU and the rest of theworld will be that proper supervision and checks are being carried out on thefarm with adequate records being maintained. To provide this assurance theminimum aim must be 100% compliance with current legislation with evidenceavailable that this level of compliance is being maintained. There has been inrecent years an increase in the number of farm-assured schemes and the directinfluence by the major retailers on agricultural practices through their producerschemes. These farm quality assurance programmes stress the importance of astrong working relationship between producers and their veterinarians and

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emphasise that efficient management practices on the farm are a way ofimproving the safety of the food supply.

The reputation of the stakeholders – the farming industry and the professions– must not be compromised in any way for whatever reason. However, theconsumer must recognise that there is a cost to all the improvements to the on-farm situation. Often the concerns about the whole food chain are associatedwith food scares and presented as a perceived worry about food-related issuesthat has little if anything to do with the reason for the food scare. On the otherhand, if the controls placed on the industry are too stringent, there will be suchan increase in the cost of production that the result will be increased imports ofproduce from countries where the standards of husbandry and slaughter arelower than in, for example, the UK.

The role for food from non-traditional species must also be considered in thefuture. World supplies of animal-derived protein are limited and in some parts ofthe world under considerable pressure. It is possible to harvest more from thewild provided care is taken while drawing on wildlife reserves. Already gamefarming and fish farming in particular have changed the availability of differenttypes of meat.

It is also most important when considering the need for legislation torecognise the differences between disease in respect of animal health or humanhealth. At present there are no specific statutory food safety controls applicableto on-farm production. It is very easy to say that more control is necessary on thefarm and even to increase the legislative controls on farming, but legislation isnot always the answer, especially if there is no audit of compliance. Equally inthe EU and the worldwide marketplace, there is little point in disadvantaging acountry’s agriculture such that it is priced out of the market and the food isimported from farming systems of lower standards, in terms of both animalwelfare and food safety, but at lower cost. An example could be the banning ofsow stalls on welfare grounds in the UK with a significant extra cost to the UKpig producer, which has not been applied to any other country. Equally ofconcern at this time are the increasing reports of animal medicines availableillegally, even by mail order, with suggestions that they are ‘on the Internet’.They must be very tempting to farmers at this time of economic crisis infarming, not least when they are at less cost than the veterinary surgeon canpurchase the same drug.

The industry has increasingly become a target for consumers campaigning forchanges in animal welfare and husbandry systems as well as expressing concernfor the environment. These concerns about the food animal production systemsand the methods by which the product is harvested, including how animals andbirds are slaughtered to produce meat, are very relevant to the whole subject ofveterinary public health.

In conclusion the application of HACCP ‘behind the farm gate’ is still in itsearly stages; however, as consumer demand for good quality, disease-freeproducts increases the need for the implementation of such control systems willbe higher. The aim is to produce animals in a manner concurrent with these

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aims, with the minimum of medical/pharmaceutical intervention. This willinclude improvements to husbandry, appropriate use of vaccines if available,even changes to the management of the farm. While on-farm HACCP is not apanacea that will remove foodborne pathogens and other health risks from foodof animal origin, it is a system with widely understood principles for identifyingsignificant risks and their control. HACCP allows implementation of aneffective documented system that will eliminate or reduce the likely occurrenceof foodborne hazards. In addition HACCP is an internationally recognisedsystem for quality assurance that is understood and accepted by the rest of thefood industry, including livestock producers and customers.

Disease control in animals is multi-faceted and the more traditional ‘fire-brigade’ responses without consideration of preventive measures are no longeracceptable. In professional hands with diligent attention to Good VeterinaryPractice they are valuable, versatile and safe components with a vital andspecific role to play in control of bacterial disease in animals.

The success of animal production practices cannot be based only on anincrease or a reduction of human foodborne disease. There must be a gatheringof information relating to animal production, including the influence of changesin management practices that may play a role in pathogen prevalence.Epidemiological surveillance will enable the prediction or projection of riskfactors and of emerging issues so that perception can be replaced by realitybased on scientifically reliable data.

Production and health information from poultry units has been used for anumber of years to target the level of post-mortem meat inspection necessary foreach batch of broilers delivered to the slaughter plant. There is a strongpossibility that all inspection systems will change to one based on an analysis ofrisk. An important part of any new system will be the monitoring of salmonellaon the farms of origin. Studies of the type by Edwards et al.37 and Fries et al.38

are required to provide the basis for any alternative system of integrated meatinspection. Such studies might give background for designing a truly targetedorganoleptic post-mortem inspection system that yields a net benefit toconsumer health protection.

4.9 References

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2 CULLOW J S, HACCP (Hazard Analysis Critical Control Point): is itcoming to the dairy? J Dairy Sci, 1997 80 3449–52.

3 CHAPMAN P A, SIDDONS C A, WRIGHT D J, et al. Cattle as a source ofVerocytotoxin-producing Escherichia coli O157 infections in man,Epidemiology and Infection, 1993 111 439–47.

4 The Microbiological Safety of Food. Part I. Report of the Committee onthe Safety of Food (Chairman Sir Mark Richmond), London, HMSO,

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1990, pp 45–58.5 Ministry of Agriculture Fisheries and Food, The Report of the Expert

Group on Animal Feedingstuffs (The Lamming Report), London, HMSO,1992, p 2.

6 JOHNSTON A M, Bovine Spongiform Encephalopathy, CPD VeterinaryMedicine, Rila Publications, London, 1998 1 26–9.

7 ASHRAF H, European dioxin – contaminated food crisis grows and grows,Lancet, 1999 353 2049.

8 ERICKSON B E, Dioxin food crisis in Belgium, Anal Chem, 1999 71(15),541–3.

9 JOHNSTON A M, Use of antibiotic drugs in veterinary practice, BMJ, 1998317 665–8.

10 Opinion of the Scientific Committee on Veterinary Measures Relating toPublic Health. Assessment of potential risks to human health fromhormone residues in bovine meat and meat products. EuropeanCommission, Brussels, 30 April 1999, also on www.europa.eu.int/comm/dg24/health/sc/scv/outcome_en.html.

11 Report of the Joint Committee on the Use of Antibiotics in AnimalHusbandry and Veterinary Medicine, Chairman Professor M Swann.London, HMSO, 1969.

12 Advisory Committee on the Microbiological Safety of Food. Report onMicrobial Antibiotic Resistance in Relation to Food Safety. London, TheStationery Office, 1999.

13 Opinion of the Scientific Steering Committee on Antimicrobial Resistance.European Commission Directorate-General XXIV, Brussels, 28 May 1999.Also on www.europa.eu.int/comm/dg24/health/sc/ssc/outcome_en.html.

14 NOORDHUIZEN J P T M and WELPO H J, Sustainable improvement of animalhealth care by systematic quality risk manaagement according to HACCPconcept, Veterinary Quarterly, 1996 18 121–6.

15 MITCHELL R T, Why HACCP fails, Food Control, 1998 9 2–3 101.16 SHARP M W, Bovine mastitis and Listeria monocytogenes, Vet Rec, 1989

125 512–13.17 EDWARDS A T, ROULSON M and IRONSIDE M J, A milkborne outbreak of

serious infection due to Streptococcus zooepidemicus (Lancfield group C),Epidemiol Infect, 1988 101 43–51.

18 SHARP M W and RAWSON B C, Persistent Salmonella typhimurium PT 104infection in a dairy herd, Vet Rec, 1992 131 375–6.

19 WOOD J, CHALMERS G and FENTON R et al., Salmonella enteritidis from theudder of a cow, Can Vet J, 1989 30 833.

20 BERRY E A, Mastitis incidence in straw yards and cubicles, Vet Rec, 1998142 517–18.

21 CORRIER D E, BYRD B M, HARGIS M E et al., Presence of Salmonella in cropand caeca of broiler chickens before and after preslaughter feedwithdrawal, Poultry Science, 1999 78 45–9.

22 GEUE L and SCHLUTER H, A salmonella monitoring in egg production farms

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in Germany, J Vet Med, 1998 45 95–103.23 STARK K D C, Epidemiological investigation of the influence of

environmental risk factors on respiratory disease in swine – a literaturereview, Vet J, 1999 159 37–56.

24 BANDICK N, DAHMS S, KOBE A, TITTMANN A, WEISS H and FRIES R,Zusammenhange zwischen Mastbedingungen und Ergebnissen der amtli-chen Fleischuntersuchung, Proc. Deutsche Veterinarmedizinische Ge-sellschaft, 38. Arbeitstagung des Arbeitsgebietes Lebensmittelhygiene inGarmisch-Partenkirchen, 29.9–2.10.1999, Vol I, pp 279–85.

25 BARENDSZ A W, Food management and total quality management, FoodControl, 1998 9 163–75.

26 DECLAN J, BOLTON A H, OSER G J, COCOMA S, PALUMBO S A and MILLER A J,Integrating HACCP and TQM reduces pork contamination, FoodTechnology, 1999 53 40–3.

27 MOUSING J, KRYVAL J, JENSEN T K, AALBAEK B, BUTTENSCHON B andWILLEBERG P, Meat safety consequences of implementing visual inspec-tion procedures in Danish slaughter pigs, Vet Rec, 1997 140 472–7.

28 CHRISTENSEN J, BAGGENSEN D L, SORENSEN V and SVENSMARK B,Salmonella level of Danish swine herds based on serological examinationof meat juice samples and Salmonella occurrence measured bybacteriological follow-up, Prev Vet Med, 1999 40 277–92.

29 PIERSON M, An overview of the Hazard Analysis Critical Control Points(HACCP) and its application to the animal production food safety, ProcHazard Analysis and Critical Control Point Symposium, 1995 1–10. The75th Annual Meeting of the Conference of Research Workers in AnimalDiseases, 12 November 1995.

30 TROUTT H F, GILLESPIE J and OSBURN B I, Implementation of HACCPprogram on farms and ranches, in HACCP in Meat, Poultry and FishProcessing, eds PEARSON A M and DUTSON T R, pp 36–57, London,Blackie, 1995.

31 SISCHO W M, KIERNAN N E, BURNS C M and BYLER L L, Implementing aquality assurance program using a risk assessment tool and operations, JDairy Sci, 1997 80 777–87.

32 HANCOCK D and DARGATZ D, Implementation of HACCP on the farm, ProcHazard Analysis and Critical Control Point Symposium, 1995 1–10. The75th Annual Meeting of the Conference of Research Workers in AnimalDiseases, 12 November 1995.

33 NOORDHUIZEN J P T M and FRANKENA K, Epidemiology and qualityassurance applications at farm level, Prev Vet Med, 1999, 93–110.

34 The Microbiological Safety of Food, Part II. Report of the Committee onthe Safety of Food (Chairman Sir Mark Richmond), London, HMSO,1991.

35 CULLOR J S, An HACCP learning module for graduate veterinarians, J AmVet Med Assoc, 1996 209 2049–50.

36 CASWELL J A and HOOKER N H, HACCP as an international trade standard,

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Am J Agr Econ, 1996 78, 775–9.37 EDWARDS D S, CHRISTIANSEN K H, JOHNSTON A M and MEAD G C,

Determination of farm-level risk factors for abnormalities observed duringpost mortem meat inspection of lambs: a feasibility study, Epidemiologyand Infection, 1999 123 109–19.

38 FRIES R, BANDICK A, DAHMS S, KOBE A, SOMMERER M and WEISS H, Fieldexperiments with a meat inspection system for fattening pigs in Germany.World Congress on Food Hygiene, 29th August 1997, Den Haag, TheNetherlands, 9–14.

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