The proposals put the onus on managers to have Hazard Analysis and Critical Control Point (HACCP) systems in place, mapping out all critical segments of the supply and manufacturing chain where food safety could break down. Food companies might find they get inspected more or less stringently, depending on their history of compliance to the rules and to any problems that might have resulted in a breakdown of food safety. "The proposed changes aim to replace the current enforcement policy focussed primarily on inspections, with a new policy for a suite of interventions," the Food Standards Agency stated in publishing the consultation. "This will allow local authorities to choose the most appropriate action to be taken to drive up levels of compliance by food establishments with food law." The FSA is making the proposals to update the current code of practice on food law enforcement by local authorities, who are responsible for inspections. The code serves as a guide for inspectors, and for food businesses. The changes would also bring UK policy in line with the specification of EU regulation (EC) 882/2004 on official controls. The most significant proposed change to the code of practice is the development of a suite of interventions including inspections, to maintain or improve the compliance of food establishments with food law, the FSA stated. Under the proposals food businesses would be classified into four categories, depending on a risk-based system, the FSA proposes. Local authorities would determine the frequency and level of inspections of particular establishments based on the system. "There should be a clear division between what food authorities must do in enforcing food law, which must be included in the statutory code, and other advice which can be published as practice guidance," the FSA stated. The FSA also proposes moving establishments requiring approval to start a business into the new risk assessment system. "This is likely to reduce the frequency of interventions at these premises," the FSA stated. The new revisions also introduce provisions for dealing with the enforcement of food law at the primary production level, completing the link from farm to fork. The proposals would also reduce the amount of information an establishment is required to provide when registering a new food business. The reduction in paperwork is meant as a means of reducing the administration burden placed on new businesses. Another amendments relates to the use of permanent transport authorisation in relation to live bivalve molluscs and a new annex containing a fishing vessel hygiene checklist. Overall inspectors would rate businesses as "A", "B", "C" or "D" or "E", based on hygeine or food standards. The level of inspections would be based on the rating given, with "D" and "E" requiring the most attention. However, when an inspector is satisfied that an establishment is broadly compliant with relevant food law, including HACCP, the officer may choose to alternate between the use of inspections and other official controls. In such circumstances the reasons for not carrying out an inspection, the justification for and details of the official control selected must be recorded on the establishment file. HACCP is a systematic preventative approach to food safety aiming to spot physical, chemical and biological hazards at the during the manufacturing process, rather than at final product inspection. The deadline for comments is 10 December. The code of practice on inspections is among one of a number of official industry guidances published by the FSA, and th e Institute of Food Science and Technology (IFST). Details of additional guides and industry codes can be found in the IFST publication "Good Manufacturing Practice".
The level of inspections of UK manufacturing plants would depend on the level of risk a particular processor poses to public health, under proposed rules published for consultation.