There is an ongoing trend for the implementation of food safety management systems including prerequisites programs (PRP) and procedures based upon HACCP principles, including flexibility /ease of implementation in the certain food sector companies.

Every time those prerequisites (either complemented or not with Good Practice Guidelines) reach the aim of controlling risks and hazards inherent to food, one should consider, based on a proportionality principle, that the rules and obligations for food hygiene have been followed and, there is no need for going further and create, to implement and maintain a permanent system according to full HACCP rules.

A risk analysis should be in place to justify the no-need for PPC (critical control points) and demonstrate that, the prerequisites will be enough to guarantee all necessary control in the process.

The set of HACCP Principles embodies a practical model for identification and control of significant hazards on a permanent basis but, anytime this goal is achieved through different but equivalent actions that substitute for HACCP rules in a simplified, but tested way, one should consider that the legal obligation as stated on article 5, nr.1, CE Regulation nr.852/2004 has been fulfilled.

The hygiene package establishes general objectives with minimum requisites. The focus on the official control must henceforth be on the objectives instead of the procedures used to fulfill it, using proportionality and flexibility:

  • Those procedures must follow a regular schedule proportional to risk;
  • The sanctions should be effective, proportional and dissuasive

Vitoria Pinhao, Partner Auren Portugal