Food is said to be fit for consumption, or safe, only when it is free from hazards. The implementation of a Hazard Analysis and Critical Control Points (HACCP)-based Food Safety Management System (FSMS) has become a mandatory requirement; however, there are a few critical questions that must be discussed while HACCP is being implemented or maintained:

  1. Have food business operators (FBOs) read and understood the specific food safety standard (e.g., ISO 22000, FSSC 22000, BRCGS, IFS, etc.)?
  2. Is the HACCP team involved in completing its tasks, as per the requirements of the food safety standard?
  3. Have all possible hazards been identified?
  4. How is a food safety complaint handled?
  5. Is the HACCP team motivated?

It is critical that FBOs have solid answers to these questions to ensure efficient and effective implementation and maintenance of the FSMS. These questions are discussed in more depth below.

Have FBOs Read and Understood the Specific Food Safety Standard?

As per the Codex Alimentarius Commission's Recommended International Code of Practice General Principles of Food Hygiene, "[FBOs] should be aware of and understand the hazards associated with the food they produce, transport, store, and sell, and the measures required to control those hazards relevant to their business, so that food reaching consumers is safe and suitable for use."1

FBOs/senior management should take interest in reviewing the list of identified hazards prepared by the HACCP team. This will give them an idea about the possible hazards their products may have if not controlled through HACCP. Table 1 summarizes some of the differences when the top management is well aware vs. not aware of the food safety standard and potential hazards. 

Table 1. Differences in Senior Management Awareness of Food Safety Standard and Potential Hazards

Senior Management Aware of Standard and Hazards

Senior Management Less Aware/Unaware of Standard and Hazards

Will be fully supportive 

May be less supportive 

Will understand HACCP as a mandatory requirement to ensure supply of safe food 

May use HACCP as only a regulatory requirement or even a marketing tool

Will provide all of the required resources as and when required 

May hesitate to provide resources 

Will always follow standard operating procedures (SOPs), work instructions, plant policies, etc.

May not closely follow SOPs, work instructions, plant policies, etc.

Will take special interest in the maintenance of Critical Control Points (CCPs) 

May not be aware of the CCPs

Will ensure maintenance of documents and records, as per the requirements of the food safety standard

May be more interested in successful completion of audits, and records may be maintained specifically for the auditors

A strong food safety culture will be evident 

Food safety culture will be lacking

Spares time for management review meetings and internal audits

Does not get involved in management review meetings and internal audits

Establishes people for food safety training 

Reluctant to spare people for training 


As the senior management is responsible for running the day-to-day business, it is essential that senior management read and understand the food safety standard being implemented in the organization to ensure effective and efficient implementation of the FSMS. Senior management must know that HACCP is a mandatory requirement to ensure that their company's products are safe for consumption. 

Is the HACCP Team Involved in Completing its Tasks?

The HACCP team plays a critical role in food safety. Team members should be chosen for their collective knowledge of:

  • Specific product and ingredients, including primary production conditions 
  • Processing, storage, and transport 
  • Emerging hazards pertaining to the target product
  • History of product recalls
  • Relevant research, literature, and scientific data on the target product.

Senior management should ensure that a dynamic, knowledgeable, well-trained, and highly motivated HACCP team fulfils all of the above following requirements. The HACCP team should know the product, should have reviewed available literature, and should understand and outline all of the known and possible hazards reported globally. The HACCP team should also have a good understanding of each ingredient and packaging material and their processing details, as well as the food safety systems implemented by the company's suppliers and vendors. 

The team should outline all of the possible hazards in the ingredients and packaging materials. Suppliers and vendors must provide their HACCP plans for review. The HACCP team must also know the history of global issues, including product withdrawals and recalls, so that these considerations may be included in the hazards outline. Additionally, the HACCP team should be motivated to propagate food safety norms horizontally and vertically across the organization to promote a collective food safety mindset. 

Have all Possible Hazards been Identified?

If all of the hazards—including physical, chemical, and microbiological hazards—have not been properly identified, then the HACCP implementation will be inadequate and address only those hazards that have been identified and evaluated. If a possible hazard has not been identified, there will be a permanent risk of supply of unsafe food due to the presence of an unidentified hazard not covered in the HACCP study. Therefore, it is critical for the FBO to ensure that all of the existing and possible hazards have been identified. 

As per the Codex Alimentarius Commission's Recommended International Code of Practice General Principles of Food Hygiene, "The HACCP team should list all potential hazards. The HACCP team should then identify where these hazards are reasonably likely to occur at each step (including all inputs into that step) according to the scope of the food business operation. Hazards should be specific, e.g. metal fragments, and the source or reason for presence should be described, e.g. metal from broken blades after chopping."1 It is also important for the HACCP team to keep the list of identified hazards updated at all times (Table 2).

Table 2. Possible Hazards and their Sources

Hazard Categories 

Possible Hazards 



Action Items for HACCP Team 

Physical hazards

Hair, metal, plastic, paper, stones, sticks, glass, etc. 


equipment, processes, materials, environment

Primary production, storage, transportation, processing 

  • Identify the specific hazards
  • Think and discuss
  • Review and update the list

Chemical hazards 

Pesticide residues, mycotoxins, antibiotics, veterinary drugs, etc. 

Microbiological hazards 

Bacterial pathogens such as Salmonella, E. coli, and Listeria; molds; viruses, etc.


How is a Food Safety Complaint Handled?

Once a HACCP system has been implemented in such a way that all of the possible hazards have been identified and evaluated and control measures have been implemented, the flow chart for various hazards should appear as shown in Table 3. Ideally, there should be no complaints related to food safety. 

Table 3. Implementation of HACCP System to Address Possible Hazards


Before HACCP 

After HACCP Implementation

Hazard Status after Effective HACCP Implementation

Physical hazards

Possible in each supply of product 

Identified physical hazards and control measures implemented; system is in place 

Not possible 

If complaints are received despite HACCP implementation, it means that either HACCP has not been properly established or adequately implemented, and reassessment is needed

Chemical hazards

Possible in each supply of product

Identified chemical hazards and control measures implemented; system is in place

Not possible 

Microbiological hazards

Possible in each supply of product 

Identified microbiological hazards and control measures implemented; system is in place

Not possible 


If a complaint is received, the FBO should first check whether the hazard for which a complaint has been received was identified. If the hazard was previously identified, then the FBO must determine if adequate control measures were in place. The FBO should carry out root cause analysis to ensure that the complaint is not repeated. If the specific hazard was not identified, then the list of identified hazards must be updated, and control measures should be established after a risk assessment is conducted. 

 Is the HACCP Team Motivated?

An FBO may have well-defined policies and well-documented SOPs; however, there is no point in having these unless they are implemented exactly as per the requirements of the food safety standard. No system can be implemented without highly motivated human resources. To ensure that food safety is top of mind for everyone in the company, it is critical to ensure that the HACCP team and all executives, managers, operations staff, and other personnel are highly motivated to consistently comply with the requirements of the food safety standard. 

An FBO that does not understand the importance of a HACCP-based FSMS is deviating from food safety standard requirements. An FBO that understands the importance of HACCP but does not ensure its adequate implementation and maintenance is guilty of a crime. Let us ensure accurate and effective implementation of the FSMS day in and day out for confident FBOs and healthy consumers.


  1. Codex Alimentarius Commission. Recommended International Code of Practice General Principles of Food Hygiene. 1969.