HACCP Is Dead

In the 1960s, the nascent United States space program required a zero-defect food supply for the astronauts. Diarrhea or vomiting would be life-threatening in a space suit in a zero-gravity environment. HACCP (hazard analysis-critical control points) resulted from collaboration of the National Aeronautics and Space Administration (NASA) with Howard Bauman at Pillsbury and the U.S. Army Natick Labs. A food under consideration for the space program was analyzed for hazards, and a critical control point that would prevent or eliminate the hazard was sought. Thermal processing was sometimes sufficient, but the default CCP was often irradiation. Foods with inadequate CCPs were excluded.

Some industry segments adopted HACCP for other food products, as it afforded greater safety at lower cost than sampling and testing. Distrust of industry’s motives led to imposition of regulatory HACCP, in which some segments of the industry were required to generate a HACCP plan for each product, subject to guidance by the U.S. Dept. of Agriculture’s Food Safety & Inspection Service (FSIS) or the Food & Drug Administration’s Center for Food Safety & Applied Nutrition (CFSAN). If a hazard was identified, the industry had to devise a CCP for it. This sometimes meant redefining CCP as a measure that reduced the hazard to an acceptable level—usually a satisfactory gambit until the next outbreak or recall involving that product.

Hazard analysis is qualitative, whereas risk assessment is now used to quantify risk. However, the public wants and expects a risk-free food supply, so no level of risk is ultimately seen as acceptable. Food companies’ liability has often led—in the U.S. and increasingly in other developed countries—to food safety measures prescribed in the courts or by companies writing liability insurance for members of the food industry.

Traditionally, food safety enforcement was performed by inspectors observing industry practices and occasionally taking food samples for laboratory testing. The new “farm-to-fork” mantra greatly increases the need for inspection and testing and overextends already overtaxed resources. The unreliability of inspection and testing was the concern that led to HACCP in the space program, but consumer advocates insist on more testing.

Pasteurization of milk and retorting of low-acid canned foods are essentially CCPs, but not designated as such in regulatory HACCP because they are already mandated. Both of these measures had proven themselves before HACCP; pasteurization and retorting do not prevent hazards, but eliminate them.

Pasteurization of raw ground beef and poultry with irradiation has long been an option. Such processes have been extensively reviewed by the World Health Organization, the Food and Agricultural Organization, and the International Atomic Energy Agency. In the U.S., implementation has been greatly delayed by Congress’ declaration that irradiation is an additive, rather than a process. This complicated safety testing because neither enhancing the radiation dose to the food nor making the irradiated food a majority of the test animals’ diets was valid. FDA, which regulates additives, has somehow managed to circumvent this illogic and approve irradiation, with FSIS permitting meat and poultry irradiation, but neither agency has advocated its use. In my view, raw ground beef and raw poultry would be sealed in their final sales packages before irradiation—this would simplify dose distribution and obviate any opportunity for recontamination of the product prior to home use.

Why am I not able to buy irradiated raw ground beef or poultry at my supermarket? It seems that both the food industry and the regulatory agencies have been intimidated by self-proclaimed consumer protectionists. Extremely well-funded organizations have frightened the public, claiming that food irradiation causes cancer, etc., and even if it doesn’t, that using irradiation as a CCP will discourage sanitation at the farm level. I do order irradiated ground beef online or by phone, but I don’t have the option of selecting it at my supermarket because a store that announces it might sell irradiated products is picketed by activists. Regulators say they do not have the option to advocate irradiation over other processes, but none of the alternatives is certain to eliminate the hazard of E. coli O157:H7 in raw ground beef and Salmonella and Campylobacter in raw poultry. Diluting the power of the CCP by saying that it may merely reduce risk to an acceptable level has degraded HACCP to a fashionable, hollow acronym.

The farm-to-fork regulatory approach and reliance on microbiological testing have essentially killed HACCP, which survives in its authentic form only in the space program. Irradiation won’t solve all our food safety problems, but it could provide zero-risk raw ground beef and poultry. I surmise that HACCP, one of the brightest food-safety accomplishments of the 20^th Century, has been bludgeoned to death by politics. Does anyone care?

by Dean O. Cliver, Ph.D., an Emeritus Member of IFT, is Professor Emeritus of Food Safety, University of California, Davis ([email protected]).