Constraints to HACCP Implementation in Developing Countries
By Richard F. Stier, Morad S. Ahmed and Herbert Weinstein, Ph.D.
Food safety professionals around the world agree that Hazard Analysis & Critical Control Points (HACCP) is the best management system available for assuring the production of safe foods. This is supported by the large number of food processing and handling operations who mandate HACCP for not only their own operations, but for their suppliers. Included among this group are not only food and ingredient processors, but foodservice and restaurant operators and grocery chains. The economics are simple: Implement HACCP or find another outlet for your products.
The value of HACCP also has been acknowledged by food regulators around the world as many nations have mandated HACCP for certain types of foods produced within or shipped to their country. Perhaps the greatest indicator of international support for HACCP has been its adoption by the Codex Alimentarius Commission (CAC). CAC delegates to the Committee of Food Hygiene, which drafted the HACCP guidelines, were shocked at how rapidly the system’s principles were adopted. For a group in which change is “glacial,” the HACCP document literally sailed through committee. To further underscore the importance of HACCP, the International Organization for Standardization (ISO) has taken the first steps to develop an international HACCP standard.
All of these actions are essential to assuring a safe and wholesome food supply, especially in a “shrinking” world. International trade in foods and ingredients is at record levels, so the importance of a program such as HACCP is further underscored. But, there are problems with the route that has been taken, and these problems are especially evident in developing nations. There are many processors and regulators who perceive HACCP as a technical barrier to trade that has been imposed upon them by wealthier nations. They see only their own situation and that mandating such programs are burdensome and costly. They do not see or understand the emphasis on food safety in the developed world. Of course, we and other developed nations, are guilty of the same lack of vision. We have not made an effort to fully understand why developing nations think the way they do, nor have we taken the time and effort to look at why developing and implementing HACCP in these nations will be such a burden.
This article is an effort to identify and discuss the issues in developing nations that are constraints. Readers may not agree with the observations, which are based upon personal experience working in a number of countries, but if we, the authors, can make people think, we feel that we have accomplished something.
The Basic Constraints to Implementation
There are many constraints to developing and implementing HACCP in developing nations. The first that most food safety professionals will think of is the technical issues. The sanitation standards, quality systems and commitment to safety in food processing and handling operations in these nations are often well below those in developed countries. The problems go much deeper, however. There are regulatory issues, cultural concerns, problems in the educational systems, economic pressures and good old politics. In fact, one could probably develop a lengthy treatise on each and every one of these issues. If developed countries are going to “help” these countries upgrade both the quality and safety of their food supplies, keeping problems “under wraps” is certainly not the way to proceed.
Regulatory Issues. Regulatory issues and the agencies responsible for food safety are, ironically, one of the major constraints to developing and implementing HACCP in developing nations. This is not to imply that they do not care about assuring food safety; it is simply a statement of a failure to understand what is needed to encourage HACCP development and how to achieve that goal. What makes this such a stumbling block is that in these nations a strong and knowledgeable food regulatory agency is an essential element for driving HACCP development.
Companies that have developed HACCP programs in these countries have done so because they realized that it was good business or because they could implement the program through their relationship with a developed country, not due to government pressures. For example, in Egypt, most of the companies that have developed and implemented HACCP are those that are suppliers to international restaurant operations in the Middle East and North Africa.
There are several issues that agencies in these nations need to address before they can realistically mandate HACCP programs. One of the primary hurdles that must be addressed is the importance of process control, which is the basis of HACCP. This lack of understanding was underscored at the January 2001 Codex Coordinating Committee Meeting in Cairo. The delegates initiated a movement to develop sampling procedures and microbiological guidelines to assure food safety. After a rather lengthy discussion, Alan Randall, Ph.D., from the Food and Agriculture Organization (FAO) of the United Nations in Rome explained that the Codex Committee on Food Hygiene adopted HACCP because it is the best tool for assuring food safety and that testing was not the way to go. The bottom line is that there are inherent biases throughout the world when it comes to a systematic and proactive approach to food safety employing either HACCP or Good Agricultural Practices (GAPs). There is one more issue that relates to their love of testing: Most of these countries have extensive laboratory systems that carry out thousands of tests each year. Emphasizing process control could undermine the importance of these operations.
Another problem is that food regulators in developing nations do not have the technical expertise to draft rules that will work. For example, they may understand basic HACCP principles, but lack an understanding of the importance of HACCP prerequisite programs. Copying a regulation from a “first world” nation is usually not the best route to take. The regulation they are copying is all too often part of a more complex and overriding “food law,” which they do not have in place. Finally, food regulators in developing nations often fail to grasp the importance of time. They pass a law and proudly say, “We have a regulation mandating HACCP for the seafood industry.” Yet, the regulation includes no time frames for training, implementation or industry compliance. They frequently do not even consult the industry when enacting a new regulation, an issue that will be addressed later. The result is a regulation that appears on the books literally overnight, which cannot be properly enforced or with which the industry is not ready to comply.
It also appears that regulators in many developing nations have little or no working relationship with the food industry they are overseeing. There is little trust between regulators and industry. One of the main reasons that HACCP has succeeded in the U.S., Canada and Europe is because it has been a cooperative effort between industry and government. Regulators in developing nations feel that they must control the industry rather than work with them to enforce regulations and upgrade the industry. There also is a belief that certification is their job. Certification and regulation are at cross- purposes, a conflict of interest in other words. Finally, many regulators in developing nations simply do not understand the food industry and basic food processing.
Another concern is that in many nations the regulators fail to “do their homework.” The Codex Principles for the Establishment and Application of Microbiological Criteria for Foods call for the establishment of microbiological criteria based on scientific analysis and risk analysis of foods and ingredients. If a nation has no data on incidence of food- borne illness in the country, there is really no basis for enacting laws or creating standards to control an issue. On the subject of standards, governments in developing nations have a bad habit of creating standards that are not only designed to protect their own industries but that have no relationship to international standards. This mentality can be damaging to an industry’s commitment to food safety and its ability to compete in world markets.
The last issue is sensitive, but one that cannot be ignored: corruption. It is a painful point for many, but for food safety programs to move forward in these countries, it’s a concern that must be addressed. One of the main causes is simple economics. In developing nations, government employees are often underpaid and undereducated. They can “supplement” their income by looking the other way when inspecting plants. Of course, they are not wholly to blame. Processors often find it a less expensive option to pay an inspector off rather than to upgrade a plant to the required standards. These situations further serve to compromise trust between industry and government. Regulatory inspectors can further augment their income by collecting an excessive number of samples. The extra samples are then sold, and at times, are even sold back to the company from which the samples were collected. Since HACCP focuses on process control, this practice could be curtailed.
Educational Systems. The educational systems in many developing nations are another reason that it is difficult to make HACCP work. These problems are a function of the systems and the faculty. The teaching and testing systems are all too often based on rote memory. Students are asked to learn and regurgitate facts, and hence, they do not learn to think and apply what they learn to solving problems. Along this same line, many faculty discourage questions and open discussion. The attitude is “The teacher is always right,” so students are not encouraged to question. For food companies to implement HACCP successfully, they need scientists who have the ability to see and understand what is going on in that plant, plus the ability to use their knowledge of the basic sciences and food safety to develop the program. Part of this problem was alluded to previously; that is, many academics, like their colleagues in the regulatory agencies, do not have sufficient knowledge of the food industry and the realities of “real world” food processing. Without this real-world understanding of food and food processing, their students do not get a complete picture of the industry, its problems and how those issues should be addressed.
In addition, many academics in developing nations simply do not like to go out into factories and get their hands dirty, which one needs to do to really understand an industry. Similarly, most developing nations lack one component of the university system that has been quite useful in the U.S. and elsewhere: There is no university extension system that encourages and facilitates industry and university interaction. Extension staff become industry liaisons and bring that real-world experience to the campus. When they teach, students have an opportunity to learn not only the science, but the technology that allows the science to be implemented.
Cultural Issues. There is the old adage that says, “For want of a nail, the kingdom was lost.” What this means is that it does not take much to disrupt a program. When Western nations design aid programs to help developing countries upgrade, we often completely ignore the basic cultural issues that will derail the program. Even within these nations, the regulators may fail to see or understand the basic “people” issues that will compromise a program. These issues vary between nations, but they are real. As an example, the project goal established by most non-government organizations (NGOs) are usually quite noble. For example, they seek to increase exports of processed foods or to help food processors upgrade by emphasizing the adoption of new technologies as a means to achieve this goal.
The reality of the situation is that most processors in these nations have more basic problems with which to contend. For example, in one of the author’s experiences working for General Foods in both Mexico and Brazil for a number of years, worker training began at a very basic level: The staff had to teach people not only to wash their hands, but to properly use the toilet. Personal hygiene and a general lack of understanding of the importance of good sanitation is a real and often overlooked aspect of industry, government and foreign aid projects in their efforts to implement HACCP. In many cases, the food processor is dealing with a workforce that still draws water from a community well, uses pit toilets or simply drops trash in a convenient ditch when the time comes. The average person in these countries has no idea that there is a link between hygiene and illness. Changing how people think and act is not something that can be accomplished overnight or can be measured as a deliverable. To make changes in how people think and act is a long-term commitment.
In many nations, compartmentalization also is an issue. Workers will do their job, but don’t look beyond their assigned task, so they don’t respond to problems beyond their scope. This applies for both workers and managers. People are often afraid to take responsibility.
Perhaps the saddest cultural issue that the authors have observed is that there are nations where people simply do not trust their own countrymen, no matter how knowledgeable and talented they are. Until people can put aside this kind of prejudice, growth will be stymied.
Production/Technical Issues. There are a large number of constraints to growth that the industry needs to overcome. These can be placed into three categories: management, information and technical. The first management issue that must be overcome is an inability to delegate authority. The “boss” makes the decisions and everyone must defer to him or bet Clearly, this kind of mentality will not encourage HACCP development. HACCP is a systems approach to food safety and authority must be delegated in order for the system to work.
This same mentality also affects one of the best tools for growth and improvement available to processors in developing nations: the development of industry associations. Managers and owners of food processing plants in these nations know one another and talk, but they do not work together. They need to realize that they and their competitors have the same technical problems, the same concerns about markets and the same regulatory problems, yet they fight these battles alone. There is another management concern that relates directly to one of the most important HACCP prerequisites: employee education. Many managers feel that the average worker is incapable of learning, so there is little or no commitment to education.
Obtaining and using information is a real problem in developing countries, and thus an obstacle to the effective implementation of a HACCP system. The obvious issue is that many processors simply do not have the information they need to upgrade their quality, safety and sanitation programs. They need such information to make decisions, yet it is not there. This is where not having extension support from universities and the lack of trust between government and industry really hurts. These operations also do not use the information they have on hand. Like the government, food processors rely extensively on testing to assure quality and safety, and do not understand the importance of process control. They need to make the transition from testing to controlling the process. These companies generally have volumes and volumes of test results on a wide range of items—incoming materials, finished goods, water quality and on-line samples—yet these volumes collect dust. Collating this wealth of information would give food companies in developing nations a valuable historical reference when the time comes to actually develop a HACCP plan.
There are many technical issues that processors in developing countries need to be addressed. These problems include a lack of commitment to and understanding of the basic GMPs. Many plants do not know how to properly clean and sanitize, have inadequate pest control programs, have deficient sanitary design of equipment or the physical plant, and preventive maintenance often is ignored. Since each of these issues is a prerequisite for HACCP, it is obvious that they are not ready to move forward toward implementing the program. What is worse, these companies and their management do not understand that a lack of commitment to these issues is costing them money and business. For example, they do not understand that failing to maintain and properly clean their equipment will not only rapidly depreciate their investment, but will reduce operating efficiencies, thereby costing them more money. These issues are magnified as many of the developing nations do not have a well-developed and competent service sector. Whereas an American or European company knows they can choose a good pest control operator or industrial chemical supplier, the Central African processor may not have anyone to call.
Many processors in developing nations also believe in the “magic bullet.” They believe that a new process or piece of equipment will solve all their problems, so rather than address the root causes of, say, high counts in dried spices, they look for a machine or process that will clean up the spices. The attitude is to ignore the sanitation problems and hope for the new technology, not understanding that investing in quality systems usually pays good dividends.
The last technical issue is that many companies depend on certification. They seem to think that if someone will give them an ISO-9000 or a HACCP certificate all will be well. They do not understand that these are quality or safety systems, and as such, they treat these systems as simply a means to market their products. Of course, when one visits plants that hold such certificates, one must question the certifying agency.
Solutions on the Horizon
As noted, the failure of developing nations to adopt HACCP is not solely the fault of the developing nations. The developed nations must take part of the responsibility. They have failed to recognize and address the constraints discussed here, especially when it comes to addressing basic sanitation issues. It is, however, much more glamorous to sell an aseptic processing and packaging machine than it is to work with a company to install hand- washing sinks and help them to teach their staff how to use them. Usually, there is very poor coordination between the nations supplying aid to these countries. Government and industry may get one story from the Americans and another from a European NGO, for example, so there is confusion on the part of the developing nation as to what approach to ultimately take. When consultants from overseas do arrive to work with industry, they should do just that. All too often, these individuals generate reports for the agency for whom they work, not for the industry. It does the processor no good if there is never any recommendations given by the expert.
In the final tally, the developed nations must make a real commitment to the developing nations. A major part of that commitment is to have people in- country for an extended period of time, so that they not only have an opportunity to understand the industry and its problems, but so that they can develop the trust needed to improve.
We have presented readers with a number of constraints to HACCP development and implementation in developing nations. You may or may not agree with them, but our goal is not to criticize, rather, it is to make people think. Are there other constraints that we failed to discuss? We hope to offer some solutions in a future issue of Food Safety Magazine, and welcome your input in developing the follow-up presentation.
Richard F Stier is the Director, Technical Services for The Competitiveness Initiative- Mongolia. Prior to this, he worked with the Agricultural Led Export Business project based in Cairo, Egypt. He has international experience in food safety, food plant sanitation, quality systems, process optimization, GMP compliance and food microbiology Prior to joining these projects, he worked as an independent consulting food scientist with clients in Europe, Asia, Africa, Mexico and the U.S. Stier was also Director of Quality Assurance for Dole Packaged Foods North American operations, and was Manager of the Microbiology Section for The National Food Laboratory, a subsidiary of the National Food Processors Association. An active member of the Institute of Food Technologists (IFT), Stier currently is a member of IFT’s Committee on Global Interests. He is also a member of the American Oil Chemists’ Society (AOCS) and the International Association of Food Protection (IAFP). He recently served as the councilor representative to the IFT Executive Committee, where he has helped to develop the association’s international programs. He can be reached at [email protected].
Morad Ahmed has more than 30 years of experience in the international food industry, including with seafood and frozen food companies in Egypt and Switzerland. From 1994- 2002, he was the technical co-director of the ALEB-USAID project. He also worked with the Norwegian Trade Center in Alexandria, Egypt from 1988-1998. He can be reached at [email protected].
Herbert Weinstein, Ph.D., has more than 30 years of industrial experience working with food companies such as General Foods and Unilever in most technical aspects of food manufacturing, distribution, product development, QA/QC and management. Weinstein has worked in several countries in Latin America, the Middle East and Africa. He served as the Senior Food Technology advisor for USAID OMNI Project for three years, and has been involved in several projects for the Micronutrient Initiative, Interamerican Development Bank, Asian Development Bank and the Pan-American Health Organization. He can be reached at [email protected].