Professional Documents
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Risk Based Food Inspection System
Risk Based Food Inspection System
INSPECTION SYSTEM
Practical Guidance
for National Authorities
RISK-BASED FOOD
INSPECTION SYSTEM
Practical Guidance
for National Authorities
Risk-based food inspection system: practical guidance for national authorities
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Contents
List of figures and tables ������������������������������������������������������������������������������������������������ iv
Abbreviations ����������������������������������������������������������������������������������������������������������������� v
Glossary ������������������������������������������������������������������������������������������������������������������������ vi
List of contributors ������������������������������������������������������������������������������������������������������ viii
Preface �������������������������������������������������������������������������������������������������������������������������� ix
Executive summary �������������������������������������������������������������������������������������������������������� x
1. Objective ���������������������������������������������������������������������������������������������������������������� 1
2. Introduction ����������������������������������������������������������������������������������������������������������� 2
3. Generic framework of a risk-based food inspection system �������������������������������������� 4
iii
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
FIGURES
Fig. 1 Generic framework of a risk-based inspection system ��������������������������������������������������� 4
Fig. 2 Definitions of hazard and risk and examples ������������������������������������������������������������������� 8
Fig. 3 Definitions of absolute risk and relative risk �������������������������������������������������������������������� 9
Fig. 4 Example of decision tree to rank biological hazards in food, by risk level ��������������� 10
Fig. 5 Decision tree to rank chemical hazards in food, by risk level ������������������������������������� 11
Fig. 6 Food risk definitions ����������������������������������������������������������������������������������������������������������� 16
Fig. 7 Traffic light system indicating the food safety performance of establishments ����� 24
TA B L E S
Table 1 Example of dairy product categories ����������������������������������������������������������������������������������� 7
Table 2 Generic quantitative risk matrix������������������������������������������������������������������������������������������� 12
Table 3 Numerical scale and definitions for probability based on the prevalence
of the hazard���������������������������������������������������������������������������������������������������������������������������� 13
Table 4 Numerical scale and definitions for severity��������������������������������������������������������������������� 13
Table 5 Examples of risk matrix to evaluate raw material contamination and the
possibility of recontamination �������������������������������������������������������������������������������������������� 14
Table 6 Risk categorization of fishery and aquaculture products����������������������������������������������� 17
Table 7 Classification of the size of establishments based on the number of
employees and production volume ���������������������������������������������������������������������������������� 18
Table 8 Example of a risk categorization of establishments�������������������������������������������������������� 19
Table 9 Example of a quantitative GMP checklist��������������������������������������������������������������������������� 20
Table 10 Example of inspection frequencies������������������������������������������������������������������������������������� 22
iv
Abbreviations
CCP critical control point
GMP Good Manufacturing Practices
HACCP Hazard Analysis Critical Control Points
MCDA multicriteria decision analysis
MRL Maximum Residue Limit
RTE ready-to-eat
UHT ultra-high-temperature
WHO World Health Organization
v
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
Glossary
Critical control point (CCP): a step at may contain harmful chemicals. Raw meat,
which control can be applied and is essential fish, oysters, poultry and milk are examples
to prevent or eliminate a food safety hazard of high-risk foods. Other examples include
or reduce it to an acceptable level. tofu, meat pies and salami. These foods
pose a particularly high risk if they are not
Control: an element of the food process processed or cooked adequately (1).
that reduces, eliminates or removes a food
safety hazard. High-risk food businesses: food
businesses dealing with high-risk foods or
Food businesses: undertakings, whether for high-risk production methods where the
profit or not, and whether public or private, potential exists to put vulnerable groups,
carrying out any of the activities related to such as infants, elderly people, pregnant
any stage of production, processing and women and people who are sick, or large
distribution of foods. numbers of consumers at serious risk.
Note: in the Association of Southeast Asian
Food business operator: the entity Nations (ASEAN) context, food businesses
responsible for operating a business at any that have a history of misusing prohibited
step in the food chain. chemical additives or adding excessive
amounts of food additives in the preparation
Food control: a mandatory regulatory of food are also categorized as high-risk
activity of enforcement by national or local food businesses.
authorities to provide consumer protection
and ensure that all food is safe, wholesome Inspection: the examination of food or
and fit for human consumption during systems for control of food, raw materials,
production, handling, storage, processing processing and distribution, including in-
and distribution; conforms to food safety process and finished product testing, in order
and quality requirements; and is labelled to verify that they conform to requirements.
honestly and accurately as prescribed by law.
Low-risk foods: foods that are unlikely to
Hazard: a biological, chemical or physical contain pathogenic microorganisms and will
agent in food, or a condition of food with the not normally support their growth because
potential to cause an adverse health effect. of food characteristics and foods that are
unlikely to contain harmful chemicals.
Hazard Analysis Critical Control Point
(HACCP): a system that identifies, evaluates Low-risk food businesses: food businesses
and controls hazards that are significant for involving operations where the potential to
food safety. cause harm to consumers is low.
High-risk foods: foods that may contain Medium-risk foods: foods that may contain
pathogenic microorganisms and will support pathogenic microorganisms but will not
the formation of toxins or the growth of normally support their growth because of
pathogenic microorganisms and foods that food characteristics; or foods that are unlikely
vi
Glossary
to contain pathogenic microorganisms strategies that, along the entire food chain
because of food type or processing but may (including production, handling, storage,
support the formation of toxins or the growth processing and distribution), ensure that
of pathogenic microorganisms (1). food is safe, wholesome and fit for human
consumption, conforms to food safety and
Medium-risk food businesses: food quality requirements and is honestly and
businesses involving operations with accurately labelled as prescribed by the law.
the potential to pose a significant risk to
consumers. These establishments are those Risk-based inspection: inspection
where high-risk, ready-to-eat foods are activities focused on food products and legal
not prepared, but the scale of the business food businesses that pose the highest risk to
is large. Such foods include shellfish/fish consumers’ health.
(cooked and raw), raw meat, cooked meat/
poultry and meat/poultry products, milk and Risk categorization framework: a
milk products, and egg and egg products. supporting tool to qualify and document
the different risk categories that have been
National food control system: the identified, and to subsequently insert the
integration of mandatory regulatory registered food business operators into a
approaches (i.e. official food control risk-based inspection programme.
activities) with preventive and educational
vii
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
List of contributors
Fernando Sampedro, PhD, MS
Associate Professor, Department of Veterinary Population Medicine (VPM), Center for Animal
Health and Food Safety, St. Paul, Minnesota, United States of America
Frida Sparaciari
Food Safety Consultant, Division of Health Security and Emergencies, WHO Regional Office
for the Western Pacific, Manila, Philippines
viii
Preface
Foodborne illness is a major public health the principles of national food control
concern and contributes to loss of life, systems, including principles of risk analysis.
loss of work time, undue expense in terms
of government health care and loss of Risk-based inspection is an alternative that
productivity in the workforce. Globally, it is uses available resources more efficiently and
estimated that there are 600 million cases modernizes inspection systems, through the
of foodborne diseases and 420 000 deaths application of a scientific and risk-based
each year due to the consumption of unsafe approach in inspection activities, focused
food. In the Western Pacific Region alone, on food products and legal food businesses
there are an estimated 125 million cases of that pose the highest risk to consumers’
foodborne diseases and more than 50 000 health. Risk-based food inspection, as
deaths every year. opposed to traditional food inspection,
provides opportunities to build systems to
Food safety authorities implement prevent food safety incidents by identifying
regulatory activities to achieve the key risk factors and assessing the effectiveness
objectives of food control throughout the of control measures in place.
entire food chain to protect the health of
consumers against foodborne illness and The application of the scientific and risk-
ensure fair practices in the food trade. On based approach to design and implement
this, governments are seeking to modernize a risk-based food inspection system that
and integrate their food control activities uses the available resources efficiently is the
under harmonized Codex Alimentarius scope of the current practical guidance.
guidelines and to improve their efficiency,
sustainability and robustness by applying This document is in line with:
The regional vision For the The Asia Pacific Strategy for The document also
Future: Towards the Healthiest Emerging Diseases and Public directly contributes to the
and Safest Region and fits under Health Emergencies (APSED III) implementation of the Regional
the priority area of “health as it comprises its multisectoral Framework for Action on Food
security, including antimicrobial approach, including food and Safety in the Western Pacific,
resistance”; water safety; and particularly in action area 2,
risk-based food inspection and
enforcement.
ix
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
Executive summary
Food inspection plays an important role as estimate the inspection frequency based
part of food control activities, in ensuring on risk. In addition, guidelines for review
that food businesses are implementing and adjustment of an inspection plan are
appropriate processes, collecting evidence, provided. Considering that the risks inherent
and verifying compliance with standards in food and food processing are particular
and requirements to ensure that the foods to each country and production chain, as
are safe and wholesome and fit for human well as the characteristics of the producing
consumption. Risk-based inspection is based establishments, it is recommended that this
on the application of a scientific and risk- guidance may be adapted to suit individual
based approach to focus inspection activities country needs. An annex is also included
on food products and food businesses that describing the main considerations that
pose the highest risk to consumers’ health. inspectors must take into account when
preparing a food inspection. Finally, this
The purpose of this practical guidance document concludes that the keys to a
is to assist national authorities on how successful risk-based inspection system
to design, implement and communicate start with political commitment and an
a risk-based food inspection system. adequate regulatory framework to support
This document provides step-by-step the process, designing the model based
guidance, specific examples and case on the collection of adequate and relevant
studies, as well as understanding risk information, and periodically subjecting the
prioritization tools to categorize the risk model to a process of adjustment to allow
of food and establishments, and how to for continuous improvement of the system.
x
1. Objective
This practical guidance provides a generic Also, from an inspector-oriented approach, this
framework to assist national authorities on guidance document will assist food inspectors
how to design, implement and communicate in carrying out risk-based inspections. The
a national risk-based food inspection system. guideline provides information on inspection
It provides step-by-step guidance, specific elements and prompts for inspectors to
examples and case studies, as well as risk make a risk-based assessment of food safety
prioritization tools to categorize the risk of food risks and control measures and determine
and establishments, and how to estimate the an outcome, including specific guidance on
inspection frequency based on risk. the following.
R
O D E AT E
M
Establishing the scope of the risk-based inspection system
R
O D E AT E
M
Principles, tools (qualitative and quantitative) and practical examples for
HIGH
LO W
1
2. Introduction
Foodborne illness is a major public health of government health care and loss of
concern and contributes to loss of quality productivity in the workforce.
of life as well as undue expense in terms
REMEMBER: There are 600 million cases of foodborne diseases and 420 000 deaths
each year due to the consumption of unsafe food. The Western Pacific Region has an
estimated 125 million cases of foodborne diseases and more than 50 000 deaths every
year. (2,3)
Food inspection plays an important role with food safety national regulation. These
in ensuring that food businesses are inspections are carried out at a certain
implementing appropriate processes frequency. The inspection frequency needs
to ensure that the foods they produce to be related to the food safety risk of the
are safe. National regulatory agencies food being prepared and the inherent
develop inspection plans to schedule food risk of the business facility (for example,
inspections. The challenge faced by many equipment, personnel and separation of
countries is a lack of resources to inspect production areas). This is known as a risk-
food establishments. A scientific and risk- based inspection system, which is a method
based approach to design and implement used for prioritizing inspection using a risk-
a risk-based food inspection system that based approach.
uses the available resources efficiently is
the scope of the current practical guidance. The aim of a risk-based inspection system is
While developed primarily for the Western to assign inspection frequencies according
Pacific Region, this document provides to the assessed risk (food and facility). As
general guidance for any country looking a general principle, the higher the risk, the
to undertake the design, implementation higher the inspection frequency. Thus,
and communication of a national risk-based priority and focus of inspection should be
food inspection system. placed on high-risk foods and processor
facilities to minimize public health risk. The
Government-appointed food inspectors intent of this document is to assist national
have a crucial role to play by visiting food authorities on how to design, implement and
businesses to check food preparation areas, communicate a risk-based food inspection
food-handling practices, food processes system. It provides step-by-step guidance,
and equipment to determine compliance specific examples and case studies, as well
2
Introduction
as risk prioritization tools to categorize the Shared training and regular meetings
risk of food and establishments, and how to between agencies allow common goals
estimate the inspection frequency based on and priorities to be established. Sharing
risk. The guidance may be adapted to suit resources, including transport, can have
individual country needs. economic benefits and allow for a more
focused approach to food safety. It also
Food safety regulatory agencies may provides clarity on the role of each agency.
need to work collaboratively with other Data or intelligence information may provide
governmental agencies/ministries, such as an insight into food safety issues and
business licensing and regulation, primary problems. Resources for inspections can
industries, including agriculture, fisheries then be focused in areas where there is the
and horticulture, imported and exported greatest need. The sharing of information
foods, transportation, environment and between government organizations and
industries, as relevant, to establish common other support agencies is encouraged.
goals in line with government priorities.
3
3. Generic framework of a risk-
based food inspection system
This manual will explain step by step how to design, implement and communicate a
national risk-based food inspection system. The information included in the present manual
and framework has been also proposed by the Pan American Center for Foot-and-Mouth
Disease and Veterinary Public Health of the Pan American Health Organization/World Health
Organization (PANAFTOSA/VPH-PAHO/WHO) for the Latin America region.
The use of harmonized risk-based food inspection systems in different regions has many
advantages as it standardizes the use of risk analysis principles in food inspection and
allows countries to recognize inspection systems implemented by their trade countries.
These actions will ultimately facilitate the safe trade of food products and reduce the public
health impact of foodborne diseases. Fig. 1 shows the generic framework proposed by this
manual for the implementation of a risk-based food inspection system.
DETERMINE
INSPECTION CATEGORIZE
FREQUENCY RISK
4
3.1 ESTABLISH THE SCOPE
5
3.2 COLLECT INFORMATION
z Food Standards Australia New Each product should be linked to only one
Zealand – Priority classification category. For example, dairy product categories
system for food businesses (7) can be grouped by their manufacturing
https://www.foodstandards. process and other process conditions, such as
gov.au/publications/pages/ final product moisture, particular processing
thepriorityclassific352.aspx conditions (artisanal with raw milk), addition
z Department of Agriculture, Water of post-heat treatment ingredients, among
and the Environment, Australian others. An example of dairy product categories
Government – Imported Food is shown in Table 1.
Inspection Scheme (8)
https://www.awe.gov.au/biosecurity-
trade/import/goods/food/inspection-
testing/ifis
Group 3 Rennet edible casein, acid edible casein, lactic edible casein, edible caseinate
7
3.3 CATEGORIZE RISK
Hazard Risk
z A biological, chemical or physical z The combination of the
agent in food with the potential to probability of the hazard to be
cause an adverse health effect to present in the food and the
the consumer. severity of the disease
z Examples: Salmonella sp., z Examples: What is the risk
Trichinella spiralis, mycotoxins, of acquiring an infection
allergens, Clonorchis (liver fluke by Salmonella spp. from
parasite). the consumption of raw or
undercooked poultry?
8
Generic framework of a risk-based food inspection system
hazard in the food, that is, the percentage In case of a chemical hazard, the severity can
of positive samples for a pathogen in a food be defined as:
product or percentage of samples above the
Maximum Residue Limit (MRL) for a chemical z health effects related to the chemical
in a food product. hazard such as carcinogenic, organ
toxicity, neurotoxic; and
Severity can be defined as how serious the z toxicity of the molecule with
health symptoms of the disease are. Severity acceptable daily intake, tolerable
can be evaluated by a qualitative assessment daily intake defined as the maximum
(low, medium or high risk) or by using concentration of the chemical
public health data from the official national allowed to be consumed daily,
statistics. In the case of a microbiological expressed as µg/kg body weight/day.
hazard, the severity can be evaluated from
the following information: Risk can be expressed in absolute risk or
relative risk terms, and understanding the
z Health effects related to the difference is important to interpret the
pathogen such as gastrointestinal meaning of the risk being evaluated. Fig. 3
symptoms, sequalae shows the differences between both terms
z Number of outbreaks and cases and how to use them. Relative risk will
related to the pathogen be used in this manual to rank foods and
z Number of hospitalizations related establishments based on the food safety
to the pathogen risk they pose.
z Number of deaths related to
the pathogen.
9
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
REMEMBER: When using a decision tree, the regulatory agency must consider that the
establishment complies with Good Manufacturing Practices (GMP). For example, if the
decision tree is used to categorize the risk of pasteurized milk, it is assumed that the
establishment uses adequate temperature and time to pasteurize the milk and keep
the milk refrigerated.
Fig. 4 Example of decision tree to rank biological hazards in food, by risk level
Food product
DECISION TREE BIOLOGICAL HAZARDS
YES
Is the thermal treatment done in
Is the
the foodthermal treatment
already packaged with Is there any possibility for NO
done in the food already
no possibility of NO recontamination that allows the
packaged with no possibility
recontamina�on?? reintroduction of the pathogen?
of recontamination?
YES
YES
YES NO
10
Generic framework of a risk-based food inspection system
As shown in Fig. 5, a similar decision tree can reduce the presence of chemical substances
be built for chemical hazards. In this case, as cooking will not destroy them.
there are few control points or strategies to
Raw material
DECISION TREE CHEMICALS
NO
Is the thermal treatment done in
Is there any further process
the food already packaged with
that produces a toxic
no possibility of Is there any treatment (e.g. washing) or process
substance or introduction
YES (e.g. partitioning) that reduces the chemical to
of arecontamina�on??
chemical because
an acceptable level?
of cross-contamination
(e.g. allergen, packaging)
or addition (e.g. additives)? YES
YES
NO YES The way of food preparation
and cooking eliminates the
chemical or the amount
NO consumed doesn’t exceed the
maximum tolerable level?
YES
NO
11
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
REMEMBER: Risk matrices use relative risk, so the numeric scale that they use does
not have biological meaning or units.
It is recommended that each country using that the pathogen has been found
this manual build its own risk matrices based in the food).
on the examples provided in this manual. 5. Define a mathematical relationship
As each country has its own realities, such between occurrence and severity to
as information available, food production estimate the final relative risk.
practices and food consumption, a generic risk
6. Define risk levels and their associated
matrix will not be suitable for all the countries.
scores (for example, low risk <0.25).
There are certain rules that need to be followed
to build a risk matrix (10,11): A generic quantitative matrix can be built
using the probability and severity concepts
1. Use the same scale for probability
covered earlier in this manual. First, we need
and severity (for example, between
to define a numeric scale for probability
0 and 1).
and severity and then add the meaning of
2. Use a numerical scale that reflects
each level in the numeric scale. Probability
the nature of the risk to be assessed
is multiplied by severity to calculate the
(such as prevalence 0–100%).
final score, and finally, different risk levels
3. Use the equidistance rule in the are assigned depending on the score (low-,
levels of the numerical scale (for medium- or high-risk). Table 2 shows a
example, 0, 0.5, 1). generic quantitative risk matrix where final
4. Define the numerical scale (for risk is calculated by multiplying probability
example, 0 = There is no evidence by severity.
Tables 3 and 4 provide examples of a numerical scale and definitions for probability and
severity, respectively.
12
Generic framework of a risk-based food inspection system
Table 3 Numerical scale and definitions for probability based on the prevalence of the
hazard
Score Definition
1 There is no evidence of the presence of the hazard in the food or it has been found sporadically
(prevalence <1%).
10 There are reports of the presence of the hazard in the food (prevalence 1–10%).
100 The hazard is frequently found in the food (prevalence >10%).
Score Definition
1 Hazard results in hospitalization rate <1% and mortality <0.1%.
10 Hazard results in hospitalization rate up to 10% and mortality up to 1%.
100 Hazard results in hospitalization rate >50% and mortality >1%.
REMEMBER:
Biological hazards: In case of a pathogen, prevalence can be calculated by the number
of positive samples:
Here is an example calculating the prevalence of Salmonella sp. in fresh chicken from
Prevalence = 50 = 0.05 x 100 = 5.0%
a national surveillance study: 1000
Number of samples higher than the MRL for aflatoxin B1: 10 samples (each country may
% of sample above MRL = Number of samples above MRL x 100(%)
Total number
have a MRL or may use the MRL established of samples analysed
by Codex)
13
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
Table 5 Examples of risk matrix to evaluate raw material contamination and the
possibility of recontamination
* Handling means any operation in which a piece of equipment, utensil or operator comes into direct contact with the food.
** Equivalent critical control point means a control measure in the Hazard Analysis Critical Control Points (HACCP) plan that controls
the hazard to an acceptable level.
*** For example, milk pasteurization is an enclosed system where milk is always within a piping system and the product is never
exposed to a worker or the environment.
14
Generic framework of a risk-based food inspection system
Once the risk factors and the numerical scale risk. For example, four risk factors identified
have been identified, they should be combined (Fn) can be combined by adding the scores
to make a numerical estimate of the relative obtained for each factor on a scale of 0.25–1:
Relative risk = F1 + F2 + F3 + F4
REMEMBER: The value of 2.75 has no units, as it expresses a relative risk related to a
numerical scale created by the user.
In the example shown, each risk factor is The different weights usually reflect the
considered to have the same weight (for opinions of the risk manager (regulatory
example, four factors with a relative weight of agency) and experts. For example, foodborne
0.25 or 25%). However, on many occasions, outbreaks and recalls that have occurred in
there are factors that may have more weight the country usually have the highest weight
than others in the risk estimation. It is in the risk estimation due to the impact
possible to assign weights to each factor as a they have on public health. The equation
percentage (%), bearing in mind that the sum presented earlier in the manual can be
of the weights should be 100%, and, therefore, modified to include different weights:
the final risk score is between 0 and 1.
Relative risk = F1 x P1 + F2 x P2 + F3 x P3 + F4 x P4
The relative risk values obtained from the use, including decision trees, risk matrices
equation will be used to classify foods or and MCDA. The use of one specific tool will
establishments based on risk. depend on the data available in the country
and the level of expertise in using these
In summary, there are various risk types of tools.
categorization tools that a country can
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
food may be contaminated with a pathogen during processing or shelf life. In turn, the
or chemical hazard, the control measures fact that a food is ready for consumption
used during processing to reduce the hazard may present a higher risk because it does
(such as pasteurization and cooking) and not have a subsequent heat treatment that
the possibility of recontamination or growth destroys pathogenic microorganisms.
REMEMBER: The process of assigning a risk level is done based on the food categories
and not on each individual product.
An example of risk levels is shown below assigned to each level. Fig. 6 shows a score
(Fig. 6). If using a decision tree to categorize of four for high risk, two for moderate risk
each food by risk, a numeric score can be and one for low risk.
High risk
z Food category that has a high probability of containing a pathogen or chemical hazard due to the way it is
produced or consumed and thus causes adverse health effects.
Moderate risk
z Food category that has a moderate probability of containing a pathogen or chemical hazard but the way it
is consumed (such as cooked) reduces the risk of causing adverse health effects.
Low risk
z Food category that has a low probability of containing a pathogen or chemical hazard, or the process
lowers the hazards to an acceptable level.
In the event of having a significant number hazards associated with each food category,
of food categories to evaluate, decision trees either by national or regional regulation, or
can be a very useful tool, as they allow foods by including emerging hazards not covered
to be classified by risk relatively quickly. At by the regulation.
this stage, it is also important to identify the
Table 6 shows an example of categorization tree for biological hazards (Fig. 4) and
by risk of food from the fishery and chemical hazards (Fig. 5).
aquaculture chain following the decision
16
Generic framework of a risk-based food inspection system
Raw wild fish: fresh, Biological hazards: Salmonella, Staphylococcus aureus, toxigenic
frozen, glazed, with Vibrio cholerae O1/O139, Escherichia E.coli, parasites (trematodes, Low
additives, minced or nematodes, cestodes)
filleted Chemical hazards: Mercury, cadmium, lead Low
Wild fish and shrimp: Biological hazards: Staphylococcus aureus, Listeria monocytogenes,
Medium
salted and dried Salmonella, E. coli
salted Chemical hazards: Mercury, cadmium, lead Low
Biological hazards: Salmonella, Staphylococcus aureus, Vibrio
High
cholerae toxigenic O1/O139, E. coli, Listeria monocytogenes
Live and raw bivalve
molluscs Chemical hazards: Biotoxins [(okadaic acid (DSP), saxitoxins
(PSD), domoic acid (ASP), azaspiracids (AZP)], mercury, High
cadmium, lead
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
relative importance in the performance of the facility, each risk factor should be assigned a
relative weight (for example, 5–50%).
One of the most important risk factors in the evaluation of establishments is the size and
volume of production. Any contamination occurring in an establishment with a higher
production volume will have a greater impact on public health. Below is an example of
categorizing the size of an establishment by combining production volume and number of
employees. Each country should adapt the matrix to the reality of its establishments.
20–99 100+
1–2 employees 3–19 employees
employees employees*
Micro Small Medium
<100 kg/month
establishment establishment establishment
100–200 kg/ Small Medium Large
month establishment establishment establishment Large
200–500 kg/ Medium establishment
month establishment
Large establishment
Large
>500 kg/month
establishment
* A food establishment with 100+ employees is always considered large regardless of the amount of food produced per month.
Risk = F1 x P1 + F2 x P2 +F3 x P3 + F4 x P4
18
Generic framework of a risk-based food inspection system
Noncompliance z More than two violating results in the last year (7 pts)
with the official z Two violating results in the last year (5 pts)
15%
sampling plan z One violating result in the last year (3 pts)
z No violating results in the last year (1 pt)
Traceability z No traceability plan (7 pts)
z Only partial traceability (5 pts)
5%
z Full traceability (3 pts)
z Full traceability and product recall plan (1pt)
Manipulation z More than two handling points after heat treatment or equivalent
treatment (7 pts)
z Two handling points after heat treatment or equivalent treatment
(5 pts) 5%
z One handling point after heat treatment or equivalent treatment
(3 pts)
z The system is closed with no possibility of recontamination (1 pt)
Status of the z Older plants not remodelled (7 pts)
facility z Older plants remodelled (5 pts)
10%
z Modern plants without zoning (3 pts)
z Modern plants with zoning (1 pt)
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
For example, each checklist item can be process or are involved in direct contact with
divided according to its influence on the the product after heat treatment, may affect
safety of the product (for example, critical, the safety of the final product.
major or minor). Critical items are essential to
ensure the safety of the final product, as well In turn, during the inspection, the inspector
as all items that, because of their location assesses the degree of compliance of each
in the plant (critical hygiene zones), in the item as follows:
Once all the items on the checklist have been scored, the inspector sums up all A and D
entries and then calculates the final compliance percentage by the following equation:
REMEMBER: Sometimes, not all items on the checklist are checked, and in that case,
the percentage of compliance will be calculated taking into account the number of
items checked in the inspection.
20
3.4 DETERMINE THE INSPECTION
FREQUENCY
Once the food and establishments have been classified by risk, the
risk-based inspection system must be set up to assign inspection
frequencies to the food-establishment combinations with the highest
risk. These frequencies, as demonstrated later in this section, are
established by each country according to its inspection capabilities.
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
22
3.5 IMPLEMENT AND
COMMUNICATE
THE RISK- BASED SYSTEM
23
3.6 REVISE AND ADJUST THE PLAN
ANNUALLY
Once the results of the inspections are obtained for the period
considered, annual, for example, the team in charge of the operation
plan must analyse the risk scores obtained from the system to assess
the performance of each establishment and the situation of the entire
sector or production chain, in order to set new inspection objectives
and reformulate controls. To this end, those establishments that
obtained a higher risk score, and will therefore be subject to more
frequent inspection in the following year, should be identified.
A "traffic light" colour code (such as red, yellow and green) can
also be created by dividing establishments according to their risk
score. The percentage of best, intermediate and worst-performing
establishments can be calculated for the whole sector to set new
targets within the operation plan for following years. For example,
an official entity may identify reducing the percentage of high-risk
establishments by 50% over a two-year period as a target. Fig. 7
shows an example of the traffic light system a regulatory agency may
use to understand the level of risk among food establishments.
z 40% of the establishments are categorized as high-risk and thus need more
frequent inspection
z 40% of the establishments are categorized as low-risk and thus need lesser
inspection frequency
24
Generic framework of a risk-based food inspection system
In turn, an analysis of the results of the “weight” to be given to each factor in the
new system can indicate trends (improving establishment’s risk matrix. For example,
or worsening) in the performance of each new aspects related to emerging hazards
facility over time, allowing the frequency such as allergen management, history of
of inspection to be varied according to noncompliance findings in finished product
compliance results. An analysis of the results and pathogen verification programmes on
can also reveal differences in assessment food contact surfaces are some of the risk
attributable to the inspector during the factors that can be considered for inclusion
inspection (which should be minimized in the risk matrix for categorization of
by exchanging technical criteria) or “weak the establishment.
points” common to all establishments in the
sector, which can be used by inspectors to Finally, it is important to highlight that
emphasize areas for improvement and thus by taking into account the experiences of
reduce risk. countries with implemented risk-based
inspection systems, it has been possible
Periodically, it is advisable to review the to observe better performance of small
inspection checklist to check that all risk establishments, as inspectors are present
factors are included, and to include new more frequently than before, which in itself
regulatory aspects. At the same time, it represents a great achievement in the new
is important to update the weighting or risk-based inspection system.
25
4. Conclusion
26
References
27
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
28
Annexes
29
RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
To allow for a food sample to have an identification label. The sample number
Tape, labels and a
should be written on the label and also recorded in associated paperwork and
permanent marker
notes.
Scissors To open food bags and cut tape for re-sealing bags.
30
Annexes
The inspectors should obtain permission owner of the food business at the completion
before proceeding with the inspection of the inspection to discuss findings.
process. If there are some difficulties in
communication between the inspector and Any potential on-site work environment
the food business operator in relation to hazards including specific hygiene procedures
not speaking or understanding the same such as the required wearing of protective
language, it is recommended to arrange for clothing should be discussed at this stage.
a translator before the inspection.
E. Familiarization tour
The owner/operator of the business or,
if absent, the person with delegated The walk-through is a very important part
responsibility needs to be identified. The of the inspection especially if it is a large
inspector should ask to see the food licence operation. The walk-through should be
or certificate of registration (if applicable) conducted in a direction opposite to the
and check the following: flow of product so that the inspector will
not become a potential source of cross-
z the operator details are correct contamination by moving from raw to
z the approval status and any expiry finished product areas. Care should be taken
dates are current. by the inspector to avoid being injured by
equipment, conveyors, hooks and other
If the legal owner or operator is different hazards. The walk-through inspection
from that recorded on file, instruct them should be timed to allow the inspector a
to renew the premises registration in the complete view of the facility’s processes,
appropriate name. taking into account that certain operations
such as reception of raw materials may
The inspection process needs to be explained take place only at certain times of the day.
to the food business operator or person in The inspector should take any necessary
charge and their collaboration requested. measures to ensure that they do not bring
An outline of the scope and procedure of the contaminants into the processing plant,
inspection and the philosophy underlying including washing their hands and putting
the inspection should also be communicated on a laboratory coat, as necessary.
at this stage. This is a good time to review
the outcome of the previous inspection and In addition to specific aspects of the
discuss any outstanding requirements as facility and processes that the inspector
well as to discuss how the food business must pay attention to as they perform the
is operating and if there have been any walk-through inspection, there are various
changes or planned changes to the process physical characteristics of food processing
used within the food business. facilities that the inspector must keep in
mind throughout the entire inspection, for
During the entry meeting, it is important to example, the state of walls, floors, ceilings,
arrange to meet with senior management/ doors and air quality.
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
32
Annexes
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
z The inspector needs to determine all is also prepared and is discussed in the
potential hazards that may arise from closing meeting.
staff activities, food processes and
the general working environments. Closing meeting
z The headings detailed on the A meeting is held with the food business
inspection checklist provide a operator (or delegated representative) at
prompt for the inspector as to what the conclusion of the inspection to discuss
requirements are to be checked. the findings. Attendance by all relevant
departments should be encouraged. The
Insect and rodent controls should be inspector provides feedback to the operator
assessed by looking for signs of pest activity or their delegated representative, which
which may include checking for potential should include positive findings as well as a
entry points. Signs include rodent droppings, summary of areas that need to be corrected
urine odour, partially eaten packaging or and the time frame for correction.
product or rodent baits eaten from traps.
The inspector will determine required A discussion on the findings should include
actions based on the risk-based assessment. situations observed and the reasons for
Insects and rodents can carry disease and noncompliance, particularly in relation to
contaminate food areas, so this should be critical control points, any noncompliance
considered when requirements are imposed. with a previously issued report or notice, any
seizure of food and any recommendations
Refer to legislative mandate as a (actions that reflect good food safety practice
reference document to back up any may be recommended). Discussion of
requirements imposed. actions is necessary to achieve compliance
along with appropriate timelines for
NB: During the inspection, it is a good idea to implementation. The corrective action plan
ask food preparation staff what they consider must be agreed upon between the inspector
are the most important points to ensure the and the food business management and
safety of foods in the process. written into the inspection report.
Review findings and prepare reports The inspector must record the outcome
Once the inspection has been completed, of the discussion and note any significant
the inspector reviews, collates and comments that may have a bearing on any
summarizes the findings. The data collected subsequent inspections or enforcement
during inspections, including compliance action. It is necessary to hear and record
outcomes, can be utilized to determine any explanation given by the operator for
compliance action, follow-up inspection any noncompliance. Their opinions are
and when the next inspection should important in understanding the level of food
be scheduled. safety awareness within the business and
are useful for modifying and enhancing the
The inspector makes sure all defects inspection process. The inspector should
and noncompliances are thoroughly and then complete the inspection report,
accurately recorded. This may be useful in including the corrective action plan; if
case evidence is required for any subsequent any corrective action is to be taken by the
legal action. The non-conformity report business, ask the management to sign
34
Annexes
the report and provide the management usually provided a longer time frame. This
with a copy. will also allow the business to budget for any
structural upgrade.
This opportunity may also be taken to
promote food safety. Information resources, It is advisable to discuss and agree on a due
wall charts with food-safe messages, date with the food business operator, but if
stickers or any other food safe resources can this is not possible, then the inspector shall
be provided. assign due date(s).
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RISK-BASED FOOD INSPECTION SYSTEM: PRACTICAL GUIDANCE FOR NATIONAL AUTHORITIES
secure location. The next date for inspection (will require a further follow-up
or follow-up visit should be planned inspection).
at this time. b. If the explanation is unreasonable,
and it is considered that the failure
Follow-up inspection visits to implement the corrective
Proceed with this step when following actions presents a continuing
up on the Corrective Action Plan and significant public health risk, then
Improvement Notice. Follow-up inspections the inspector will report this to
should be undertaken on or shortly after the food regulatory authority. The
any completion dates recorded within a food regulatory authority may
report/plan. consider whether further legal
actions are necessary. This should
z Take the copy of the Corrective Action be dependent on the associated
Plan and Improvement Notice. Write risk to the public.
the date of re-inspection on the form
z Record and report any new
and place a tick or a cross next to each
noncompliance or issues found
item listed to indicate completion or
during the re-inspection as per the
otherwise. At the completion of this
normal procedure. This may involve
process, sign the Plan.
the issue of a new Corrective Action
z Look for evidence during the Plan and Improvement Notice.
inspection that the corrective
actions have been satisfactorily Further actions
implemented. A decision will need to be made by the food
authority management as to whether further
If all corrective actions have been
legal actions such as prosecution, revocation
satisfactorily completed and there are no
of approval or required food business closure
further matters reported, sign the corrective
are appropriate. In the first instance, advise
action plan at the completion of this process
management of the situation and keep
and close the file.
them up to date with information. Further
legal actions may be considered on a case-
If there are corrective actions that have not
by-case basis.
been completed to a satisfactory standard:
The data collected during inspections,
z Ask the food business operator for
including compliance outcomes, can be
an explanation and note the details.
utilized to determine the need for immediate
a. If the explanation is reasonable compliance action, follow-up inspection
and new completion dates are needs and determine when the next
agreed upon, then record this inspection should be scheduled.
36