Food Control 11 (2000) 137±142

www.elsevier.com/locate/foodcont

The role of government agencies in assessing HACCP

Lahsen Ababouch *
Institut Agronomique et V
et
erinaire Hassan II, P.O. Box 6202, Rabat, Morocco
Received 1 January 1999; received in revised form 10 March 1999; accepted 3 August 1999

Abstract
There is worldwide evaluation and reorganization of food inspection and control systems geared towards improving eciencies,
rationalizing human resources and introducing risk analysis-based approaches. The HACCP principles play a pivotal role in these
preventive approaches. Their application is a responsibility of the food industry, whereas government control agencies are re-
sponsible for monitoring and assessing their proper implementation. This paper reviews some of the issues pertinent to HACCP
assessment, namely its purpose, activities involved, frequency of assessment, HACCP approval/certi®cation, quali®cations and
training of assessors. It is based on the experience of the author in training and assisting industry and government agencies in
implementing HACCP-based quality systems, especially in developing countries, where food export has a major impact on the
national economies. Ó 2000 Elsevier Science Ltd. All rights reserved.

Keywords: HACCP; Assessment; Veri®cation

1. Introduction · For export, an additional control is exercised by the

Many countries have undertaken a comprehensive
evaluation and reorganization of their food inspection
and control systems in order to improve eciency and
harmonize approaches.
This evaluation of food control systems has resulted
in the convergence towards the necessity to implement a
preventative approach based on the HACCP principles
and away from the traditional approach that relied
heavily on end-product sampling and inspection. The
new approach requires that:
importing party (country or economic pole such as
European Union EU, North Atlantic Free Trade
Agreement, etc.). This additional control involves
an audit of the national control system of the export-
ing country to ensure that it is at least equivalent to
the control system applied by the importing party.
The approval of the exporting countryÕs control sys-
tem will lead to its accreditation in the case of exports
destined to the EU or to the signature of a memoran-
dum of understanding (MOU) in the case of coun-
tries, such as Canada and the USA.

· Food products be prepared/processed in certi®ed
plants and establishments. The certi®cation process
requires that the plant meets minimal requirements
in terms of layout, design and construction, hygiene
and sanitation.
· The industry takes responsibility in food quality con-
trol and implements HACCP-based in-plant quality
control programs.
· A regulatory competent authority be in charge of cer-
tifying food plants and establishments, approving
and monitoring in-plant quality control programs.
*
Tel.: +07-771758/59; fax: +07-778135.
E-mail address: barreda@mtds.com (L. Ababouch).
Consequently, it is now recognized worldwide that the
development of HACCP programs and their implemen-
tation is the responsibility of the food industry while
government inspection agencies are responsible for
monitoring and assessing their proper implementation.
This paper discusses some of the issues pertinent to
HACCP assessment and the role of government agencies
in this respect. It is based on the experience of the author
in training and assisting industry and government
agencies in implementing HACCP-based quality sys-
tems, especially in Northern and West African coun-
tries. It should be recognized that HACCP development
and implementation in these countries is still in its in-
fancy, mostly in the export sector and especially in the
®sh processing industry. Few countries have started

0956-7135/00/$ - see front matter Ó 2000 Elsevier Science Ltd. All rights reserved.
PII: S 0 9 5 6 - 7 1 3 5 ( 9 9 ) 0 0 0 7 1 - 7
138 L. Ababouch / Food Control 11 (2000) 137±142

training inspectors of food export on HACCP assess- Veri®cation of the HACCP manual can include the
ment. However, It has been recognized that improve- following activities:
ment in the control of food export will ultimately have a
positive impact on the control of food destined for the · Development of the HACCP manual by the food
local market. company
Also, the paper provides a list of publications · Submission of the manual to the appropriate inspec-
(Ababouch, 1995, 1996a,b, 1997, 1998a,b, 1999) that tion agency
can prove very valuable to food inspection agencies, · Veri®cation by the food inspector(s) of
especially in developing countries. Indeed, these publi-  the management commitment
cations describe speci®cally practical approaches, ways  the competency of the HACCP team
and means that some African countries have adopted to  the decision-making system in implementing con-
implement HACCP-based quality and safety assurance trol, monitoring and corrective actions
systems, including training on HACCP development,  description of the products
implementation, auditing and veri®cation.  process ¯ow diagrams
 hazard analysis
 critical control points
2. Purpose and activities of HACCP assessment  critical limits
 monitoring procedures
The main purpose of HACCP assessment is to verify  corrective actions
whether the food processor is able to manufacture and/  veri®cation procedure
or distribute safe and quality products.  record keeping procedure
This implies speci®c and complementary roles for the · Assessment report
food industry and the government agencies. · Meeting with the food processor to discuss the assess-
Food processors will carry out in-house HACCP as- ment results
sessment using internal resources and/or an external · Assessment follow-up
source of expertise. It must be stressed that proper
HACCP implementation requires that the food proces- The on-site veri®cation of HACCP implementation
sor should establish procedures to verify that the HA- will include the following activities:
CCP system is working e€ectively. This internal
· Opening meeting
veri®cation exercise should provide sucient informa-
· Veri®cation on site of the
tion to assess HACCP implementation e€ectiveness.
 management commitment
The government inspectors have the responsibility to
 competency of the HACCP team members
ensure that the HACCP program used by the food
 decision-making system
processor is properly designed and properly imple-
 ¯ow diagrams
mented. In this respect, assessment of HACCP pro-
 CCP monitoring records
grams can be done in two steps:
 preventative measures records
· assessment of the HACCP manual which is basically  corrective actions records
a document review,  HACCP modi®cation records
· an on-site veri®cation to establish whether the ``ap-  HACCP veri®cation records
proved'' HACCP manual is properly implemented.  HACCP team meeting minutes
 training records
Although some food inspection agencies consider the · Closing meeting
food processor as solely responsible for developing an · Assessment report
HACCP manual and verifying its adequacy, ®eld expe- · Assessment follow-up
rience indicates that a preliminary HACCP manual re-
view by food inspectors could prevent, at an early stage, Both the veri®cation of the HACCP manual and its
de®ciencies in the HACCP program. implementation can be assessed using checklists. These
In this respect, the assessment should establish that have proven to be necessary and useful tools that will
the food processor has developed an acceptable HACCP provide a harmonized approach within the inspection
system and is able to properly implement it. This will agency, especially for the beginning assessors. However,
encompass assessment of the management commitment they are not sucient and the competency of the in-
to support the system and assessment of the knowledge, spector should enable him (her) to detect de®ciencies
competency and decision-making capabilities of the and address them properly. An example of checklists
HACCP team members to apply the system and main- that were used to train food inspectors in Morocco,
tain it. Tunisia, Mauritania, Senegal and Guinea are presented
 L. Ababouch / Food Control 11 (2000) 137±142 139

Table 1

Component to assess In compliance Out of compliance

comment(s) and observations
Yes No ??

(1) Commitment of the management

Moral commitment
Financial commitment
Awareness/conviction
(2) HACCP Team
Designation of the HACCP team leader
Decision-making power of the HACCP team leader
Training and quali®cations of the HACCP team leader
Competency of HACCP team
(3) Composition of products
Composition (qualitative and quantitative)
Physical and chemical characteristics
Treatments the product(s) underwent
Packaging
Conditions de storage and distribution
Shelf life
Instructions for use of the product
Microbiological and chemical criteria applied
(4) Intended use
Normal or predicted use of the product by the consumer
Target consumer groups
Adaptation of the product(s) by certain consumers (caterers,
canteens, travelers, sensitive people,. . .)
Possibilities of abuse by the target consumers
(5) Process ¯ow diagram(s)
Drawing of the plant facilities and its annexes
Disposition et pertinent characteristics of the equipment
Number and nature of the processing operations
Sequence of the processing operations
Duration and delays between processing operations
Pertinent technical data of the processing operations
Flow of products
Separation between clean and dirty areas
Technical data of cleaning and sanitation
Hygienic environment of the facilities
Hygienic conditions of the personnel
Circulation ¯ow of personnel
Conditions of product storage
Conditions of product distribution
(6) Hazard analysis
Identi®cation of all potential biological hazards*
Identi®cation of all potential chemical hazards*
Identi®cation of all potential chemical hazards*
Identi®cation of the cause of each hazard (contamination,
survival, re-contamination, multiplication, persistence, etc.)
Identi®cation of the control measure(s) for each hazard
Description technical details of the control measure(s)
Designation of persons responsible for control measure(s)
*A potential hazard is a hazard whose elimination or reduction to an
acceptable level is essential for the production of safe food
(7) Critical control points
Identi®cation of all critical control points (CCP)
Utilization of a logical approach (i.e decision tree) for identifying
CCP's
Useless multiplication of CCP's
(8) Critical limts
Identi®cation of critical limit(s) for each measure intended for the
control of each hazard
Critical limits comply with regulations and/or recommended by
appropriate codes of GMP
Validation of critical limits
140 L. Ababouch / Food Control 11 (2000) 137±142

Table 1 (Continued)

Component to assess In compliance Out of compliance

comment(s) and observations
Yes No ??

(9) Monitoring procedures

Description of the monitoring procedures
Description of the frequency (sampling plans)
Identi®cation the people in charge of monitoring
Validity and reliability of the monitoring procedures
(10) Corrective actions
Identi®cation of corrective actions to implement when monitoring
indicates tendency towards the loss of control
Identi®cation of corrective actions to implement when monitoring
indicates loss of control (results non complying with designed
critical limits)
Identi®cation of corrective actions to apply to product processed
when control was lost
Designation of person(s) in charge of corrective action(s)
Detailed description of corrective action (s)
(11) Veri®cation of the HACCP system
Description of the veri®cation procedure
Validity of the veri®cation procedures
Designation of person(s) in charge of veri®cation
Description of the frequency of veri®cation
Possibilities of taking into account changes in product
formulation, processing, regulations, standards,...
(12) Record-keeping system
Forms for recording monitoring results
Forms for recording the implemented corrective action(s)
Recording HACCP modi®cations
Recording HACCP veri®cation/revision

as Appendices A and B. These provide a comprehensive 4. Frequency of assessment

frame for the things to look for and should be adapted
to speci®c food operations and situations.
Furthermore, food inspectors should use the closing
meetings to inform food processors of new develop-
ments in the ®eld of food inspection and quality assur-
ance, especially as it relates to new hazards, standards
and monitoring procedures.
3. Other activities
The frequency of HACCP assessment should be
based on:
· the risk category of the food being processed;
· the level of commitment of management and the de-
cision-making leverage of the HACCP team;
· the reputation of the food company: previous safety
and quality records, HACCP manual and implemen-
tation classi®cation, training and quali®cation.

An HACCP system can be e€ective only if it is based

on sound Good manufacturing and hygienic practices
(GMP/GHP). Consequently, it is the responsibility of
the government agencies to ensure that these prerequi-
site programs are properly implemented before assessing
HACCP implementation.
The veri®cation of prerequisite programs can be
carried out concurrently with the HACCP assessment in
order to have an overall assessment of safety and quality
management as implemented by the food processor.
This is especially true for processors who use the HA-
CCP approach to address GMP/GHP implementation
as well, by identifying process CCPs and sanitary CCPs.
5. HACCP approval/certi®cation
An HACCP assessment exercise should lead to an
assessment report which should state whether the system
provides enough assurance to control food safety and
quality. However, food processors look for a formal
recognition (validation, certi®cation). It should be
stressed that although this is legitimate, an HACCP
assessment is a snapshot punctual evaluation and any
recognition should not lead to false assurance. It is a
temporary recognition and assessment should be as
frequent as seen ®t.
 L. Ababouch / Food Control 11 (2000) 137±142 141

Table 2

Component to assess Mia Mab Observation(s)

(1) Commitment of the management

Moral commitment ()
Financial commitment ()
Awareness/conviction () ()
(2) HACCP team
The HACCP team leader has e€ective power of decision ()
The HACCP team members are quali®ed ()
(3) Composition of products
Food composition is re¯ective of the one described in the manual () ()
Any modi®cation is recorded and taken into account for HACCP revision () ()
(4) Intended use
Valid description of the intended use () ()
Any modi®cation is recorded and taken into account for HACCP revision () ()
(5) Process ¯ow diagram(s)
The ¯ow diagram description is always valid () ()
Any modi®cation is recorded and taken into account for HACCP revision () ()
(6) Hazard analysis
All control measures are correctly implemented ( )
Personnel in charge of control measures are identi®ed and quali®ed ( )
New hazards, introduced because of changes in product, process,. . . were taken into consideration ( )
Control measures have been identi®ed for these hazards ( )
(7) Critical control points
CCP are conform to those described in the HACCP manual ()
Introduction of new hazard has resulted in CCP analysis to implement proper control measures ()
(8) Critical limits
Critical limits are conform to those described in HACCP manual () ()
Introduction of new hazard has resulted in the revision of the critical limits ()
(9) Monitoring procedures
Monitoring procedures are conform to those described in the HACCP manual () ( )
The reliability of the monitoring procedures has been validated ( )
Personnel in charge of monitoring is well identi®ed and trained ( )
All necessary modi®cations have been made to take into account the introduction of new control ( )
measures
(10) Corrective actions
Corrective actions are conform to those described in the HACCP manual () ()
Personnel in charge of corrective actions has been identi®ed and trained ()
All necessary modi®cations have been made to take into account the introduction of new control ()
measures
(11) Veri®cation of the HACCP system
The method and frequency of veri®cation are conform to those described in the manual () ( )
The validity of the veri®cation method has been con®rmed ( )
Personnel in charge of veri®cation is identi®ed ( )
Changes of products, processes, standards, regulations,. . . were taken into consideration ( )
(12) Record-Keeping System
Forms are as described in the manual () ()
Forms are up to date for recording:
Monitoring results, ( )
Corrective actions, ( )
Modi®cations of the HACCP system ( )
HACCP Veri®cation/revision results ( )
Some records have been tempered with ( )
a
Mi: Minor noncompliance: This refers to isolated cases within a given element of the HACCP system and which will not have any noticeable
e€ect on the control of food quality and safety.
b
Ma: Major noncompliance: This refers to the absence or the failure of an element of the HACCP system. Repetitive or cumulative minor de-
®ciencies can lead to major non compliance situations.

In international food trade, there is a danger of du- the WTO quality and safety agreements, namely the SPS
plication of HACCP assessment e€orts. This can be al- and TBT agreements.
leviated by the development of an internationally Furthermore, third party certi®cation can comple-
recognized equivalency system within the framework of ment the work of government inspectors in assessing
142 L. Ababouch / Food Control 11 (2000) 137±142
HACCP. However, certifying bodies should demon-
strate proper quali®cations and integrity in HACCP
development and veri®cation. This may require the es-
tablishment of a certi®cation system for third party
HACCP assessors.
6. Quali®cations and training of food inspectors for
HACCP assessment
In order to carry out a proper assessment of HACCP,
a food inspector should demonstrate knowledge and
quali®cations in di€erent areas of food science and
technology. Experience has demonstrated that training
on food microbiology, food technology and GMP, food
safety and quality control methods, HACCP principles
and application and HACCP veri®cation is required to
bring the competency of food inspectors to the level
required for HACCP implementation. The reader is
encouraged to consult the relevant references cited
hereafter.
It should be stressed that any training activity should
provide evidence of satisfactory completion through
examination. Also, the training programs and examin-
ations should be harmonized to allow for easy recogni-
tion and equivalency between countries.
7. Conclusion
Proper implementation of HACCP programs re-
quires complementary skills and quali®cations from
both the food industry and the inspection agencies. The
former should be able to develop practical, yet e€ective
HACCP manuals and implement them correctly. The
latter should be able to assess the validity of these
HACCP programs and monitor their proper imple-
mentation.
Acquiring those skills and quali®cations requires
proper support (documentation, regulation, demon-
stration) and training. The role of research is also of
utmost importance, especially in the development of
practical, reliable and appropriate critical limits, control
and monitoring procedures.
International harmonization and collaboration in
training and in HACCP assessment procedures is re-
quired to form the basis for a mutual recognition and
equivalency system that will reduce the duplication of
e€orts. International organizations such as WHO and
FAO should continue to play a major leading role in this
respect.
Appendix A
Table 1 presents the example of a checklist used for
the assessment of HACCP manuals.
Appendix B
Table 2 presents the example of a checklist for as-
sessing HACCP implementation.
References
Ababouch, L. (1996a). Training on HACCP in Africa. FAO/DAN-
IDA seminar on training on HACCP. 28±30 May 1996, Pasca-
goula, Mississipi, USA.
Ababouch, L. (1996b). Application de la demarche HACCP pour
l'assurance qualite en industrie halieutique. Consultation technique
des experts de la FAO en technologie du poisson, June 1996,
Kisumu, Kenya.
Ababouch, L. (1998a). Fish inspection and quality assurance in
Morocco. Fish Tech News. African Supplement, 5, 2±6.
Ababouch, L. (1995). Assurance-qualite en industrie halieutique, Actes
Edition. IAV Hassan II. Rabat. Maroc. 214 p.
Ababouch, L. (1997). Implementation of HACCP in the ®sh canning
industry in Morocco. In: R. E. Martin, R. L. Collette, J. W. Slavin,
Fish inspection, quality control and HACCP: A global focus. 302±
310. Technomic Publishing Company, Pennsylvania, USA.
Ababouch, L. (1998b). Fish inspection and quality assurance in
Senegal. Fish Tech News. African Supplement, 7, 2±5.
Ababouch, L. (1999). Fish inspection and quality assurance in
Mauritania. Fish Tech News. African Supplement, 1, 2±5.