The Department of Business Industry and Science (BIS) indicated to the Agency that small food manufacturing businesses required assistance in implementing the requirement for a HACCP based food safety management system.
The Agency already provides a support tool for lower risk food businesses, known as Safer Food Better Business (SFBB) which has been well received. However, the increased complexity of food manufacturing processes is likely to present a higher level of hazard, requiring more sophisticated food safety controls.
The Agency intends to develop a web-based support tool to meet the described need. It commissioned this review to establish what guidance was currently available and if small food manufacturing businesses considered it to be sufficient, useful and whether they were using it.
The objective of the two-part review was to:
Part 1: Identify general and food sector specific guidance that is currently available on HACCP, and its implementation
Part 2: Engage with small food manufacturing businesses to establish whether:
- they had problems with the guidance that was currently available
- there are gaps in the available guidance
- they actually required guidance on the implementation of HACCP-based controls and the associated legislative requirement
- HACCP-based requirements were imposed by their customers and if so to what extent
The approach used for each element was:
A desk top review of sources of information on HACCP, available to business from regulatory authorities, organisations aiming to support small and medium enterprises, trade associations and other relevant organisations.
Websites were searched using specific terms and, where there was no inbuilt search facility the website areas relating to publications, services and training were examined. The following were noted:
- publications or other information available
- accessibility – was the information free to download or order, was purchase required and was it restricted to associates of the site only
- the format of the information
A list of small food manufacturers, employing fewer than 50 people, was compiled. The companies listed were obtained from various relevant sources including trade associations, local authorities, regional food groups and Campden BRI information.
A set of questions, approved by the Agency, was used to achieve Part 2 of the objectives. A hundred food businesses, chosen by geographic region, business size and business sector, took part in the telephone survey.
Interviewees were asked to:
- state the guidance they used
- how frequently they reviewed it
- rate how useful the guidance was on a scale of 1-10
- identify the main types of problems experienced against pre-determined areas
Further questioning revealed:
- if businesses actually still required HACCP guidance
- those which had HACCP-based requirements imposed by their customers
- if those requirements were perceived as beyond the scope of regulations and burdensome
Part 1 – guidance on HACCP is available in a general and sector specific context from numerous sources and formats including publications, training courses, technical advice and consultancy. Where the advice is produced by a trade association it is often restricted to members only but where generally available it may be accessible to download or purchase.
Part 2 - many food businesses rely on their Environmental Health Professional for advice, and consultants were also used frequently. The available guidance actually used was limited in comparison with the number of sources available. Where guidance was used it was found to be helpful but 58% of those interviewed perceived a problem with guidance and 28% relied on consultants to deal with HACCP guidance. Only 14% felt that there were no problems with the available guidance.
Small companies lacked the financial resource to purchase comprehensive guidance offered by larger companies and some businesses felt that they had received poor advice. The limited availability of time to search through guidance and to source updates was cited as a barrier to utilising the guidance already available. 59% of food business operators interviewed said that they still required guidance.
It was found that customers impose HACCP based requirements on 56% of the small food manufacturers interviewed and of those, 51% perceived that the requirements went beyond the requirements of legislation. However 90% of those businesses did not feel that the requirements were over burdensome.
53% of small food manufacturers said that they understood the difference between the legal requirements and those imposed by their customers, 29% did not understand the difference and a further 16% were not sure.