Constraints to HACCP Implementation in Developing Countries Part II
By Richard F. Stier, Morad S. Ahmed and Herbert Weinstein, Ph.D.
In the previous article, Constraints to HACCP Implementation in Developing Countries, Part 1, (April/May 2002, p. 36, Food Safety Magazine), the authors described why HACCP development and implementation in developing countries tend to lag behind programs in developed nations. Concerns were divided into four basic areas: regulatory, educational, cultural and production/technical issues. The constraints discussed were based on observations made over a number of years during “work in the field.”
The ideas that will follow on how to remove or minimize the constraints that we addressed in Part 1 are not programs that can be accomplished overnight. They will take commitment on the part of people from both developed and developing nations, but more importantly, the people who have the power and authority to effect change will have to step back and acknowledge that there may be a better way to do things. That will probably be the hardest of all. But most important, if changes for the better are going to be made, they will need to be driven by people who care about the countries with whom they are working and/or in which they live. These are not changes that can be made during an “in and out” consulting visit.
In Part II, we will further discuss the regulatory and educational issues and pose some solutions. Part III, the final installment of this series of articles to be published in the December 2002/January 2003 issue of FSM, will explore the cultural and production/technical issues, and draw conclusions as to how developed nations can help undeveloped ones.
The regulatory authorities in developing countries bear a large part of the burden for the failure of developing nations to have Hazard Analysis & Critical Control Points (HACCP)based food safety systems in place. For these nations to succeed in upgrading their food safety programs, they need a strong, stable, coordinated and credible food authority. Unfortunately, trust is a “commodity” that in developing nations exists in small amounts. The distrust between government and industry has deep roots that requires both a shift in prevailing attitudes and an ability to look at the present paradigms with a different view in order to make the necessary changes. This is the kind of model that the food regulatory agencies in developing nations should try and emulate. Honesty, integrity and openness will go far, but the question is, “How can this be done?”
Strengthen Technical Abilities. The regulatory agencies in developing nations need to strengthen themselves technically, especially where HACCP is concerned. Regulators in developing nations have learned HACCP “by the book.” They have taken workshops, many of which have been offered through government agencies in developing nations, like our own Food Safety and Agricultural Inspection Agency. But these persons and the agencies that they represent just don’t quite get it. Efforts need to be made to help these individuals understand not only basic HACCP principles, but other programs. Areas in which they need to build capacity include prerequisite programs, as well as how processors can implement such programs and where they can go for help during implementation. They also need to make the commitment to develop a real understanding of the industry. If governments in developing countries wish to be part of HACCP development and implementation, they really need to take the time and effort to understand the processing industries in their nations. When we say “understand,” we mean that they must go beyond the minimal understanding of how a plant makes canned soup, for example. They need to acquire a more in- depth understanding of the problems that processors in that industry must address during the normal course of doing business.
Partnership. Partnering with industry is a difficult concept to grasp for many nations, but it is especially true for developing nations where regulators and the industries they regulate are like “oil and water.” Now, one might say that this also is how things are in developed countries, but you would be wrong. The HACCP models developed in the U.S. and elsewhere by regulators came about because industry cooperated with them in the process. Perhaps the best example of industry and government cooperation is the Memorandum of Understanding (MOU) established between the U.S. Food and Drug Administration (FDA) and the Dried Fruit Association of California (now called the American Council for Food Safety and Quality). Their MOU allows the association to inspect member facilities as if they were government inspectors, and avoid having agency people inspect their facilities. Developing this program required commitment from the association, their member processors and the agency, but it has paid benefits for all involved. The agency has a reduced inspection burden, and the industry is almost self-regulating. Today, industry will report problems to the agency, and the plants have better sanitation and safety programs than non- member counterparts.
The key to building partnerships is building trust, and this cannot be done if potential partners do not communicate. Facilitating such discussions is absolutely essential to making this work. In some Latin American countries, projects dealing with public health programs, like fortification of salt, wheat flour and sugar were used as examples of how the government can talk and trust the private sectors, as long as it benefits the consumer and the welfare of the nation. This is a good, constructive beginning to creating trust.
Process Control, Not Testing. The heart of HACCP is process control. Safety and quality must be built into the process, not tested into finished products. The National Academy of Sciences’ 1985 report specifically stated that HACCP, not testing, was the best means for assuring food safety. As we alluded in our first article, regulatory staff in many developing nations do not really understand this basic concept.
Efforts must be made to help these persons to both understand and accept the importance of process control. Part of this process must be programs aimed at weaning government reliance of testing; especially testing that addresses non-safety issues. As an example, testing imported jams and jellies for Brix does little to protect the public health. This is a true double-edged sword, since many governments in developing nations have extensive government laboratories whose sole mission is to test products. The tests that they conduct include quality, safety and other tests that often are undefined.
In May 2000, we participated in a program in which the purpose was to present industry viewpoints to Egyptian regulators. They made many of the points that were just noted, suggesting that testing could be reduced in many areas. One area that was specifically addressed was Egypt’s law that all food imports be tested for radiolytic products. The regulators were emphatic and very vocal in their belief that such testing was essential to protect the public health, but when asked how many positive samples had been found in the almost 20 years of testing, they were very quiet. Apparently, although the agency responsible for testing has never found a positive, they continue to test. Changing sampling and testing rules could have regulated a whole lab out of existence. A possible way of evaluating the test being performed is by having the regulators ask, “What do we do with the test results? If the answer is “Nothing,” stop performing the test.
Along these same lines, we strongly encourage developing nations not to eliminate their testing laboratories, but to redefine the labs’ roles. If the energies that are currently devoted to testing could be channeled into basic or applied research that could be used by food processors, handlers, distributors, growers or those involved in animal husbandry, everyone should benefit. Again, this kind of change would take an enormous commitment from stakeholders. It would also need to incorporate the element that we just mentioned, that is, partnering with industry.
Database Building. Rules, regulations, laws and any decision, in fact, should be based on good data. Far too many developing nations simply do not have the background information necessary for good decision making. This is especially true in the food industry. Years ago when working in North Africa, we were told that the nation had no statistics on foodborne illness. They simply assumed that everyone got sick, so there was no need for such information. Developing nations need to make a concerted effort to build databases that relate to foods, foodborne illness, food quality and food safety. Harking back to the comments made on the emphasis on testing made in these nations, they need to use the data that they gather. It makes no sense if a country analyzes 200,000 samples in a year if they fail to look at the data statistically.
Developing nations need to understand where the problems lie, why products are being detained and whether they should increase or reduce sampling. Remember the example of Egypt’s testing food for radiolytic products. Along the same lines, is it really worth the effort to test for a pathogen like E. coli O157:H7 or BSE if it has never been isolated in products from your country and there are no indicators that it might be present? Developing nations need to build databases on pathogens, chemical hazards, incidences of foodborne illness and pathogens of concern before imposing regulations. Blindly following the lead of a developed nation is not wise. First, regulators must determine whether an issue is a real problem in their nation.
Change in Regulatory Process. In many of the developing nations, new laws and regulations seem to be passed based on “whim” rather than taken through an organized process. By this we mean there is little opportunity for organized commentary, which means that when something actually becomes law, it may come as a surprise to the food industry. For example, there are probably very few persons who believe that the U.S. HACCP regulations are “perfect,” but there also are very few who can realistically complain that they were not allowed to comment or were caught by surprise when it became law.
On the other hand, Mongolia recently enacted legislation to create an organization called the Food Safety and Agricultural Inspection Agency. This organization was created to regulate the meat processing industry and, it was hoped, to help build exports of meat products from the country. Unfortunately, the persons crafting the new agency did not encourage the participation of industry, nor did they include a mechanism for implementation of the program in the final document. The meat processing industry literally woke up one morning and found themselves operating under new guidelines administered by a new agency. The same can be said for Mexico, where a new “FDA type agency” is being formed; unfortunately, industry was not made an adequate “partner” in its inception.
Developing nations need to create a situation that encourages participation to create laws and regulations that are both enforceable and meet the needs of all stakeholders; that is, industry, government and consumers. The best regulations are those that are designed with all parties involved. There are many donor agencies around the world that offer assistance in the areas of policy. Helping a nation change their polices so that these countries can enact programs that allow commentary, make changes based on comments, and include programs for training, implementation schedules and budgets would be beneficial to all.
Corruption. Corruption is something that must be addressed by each country in which it is an issue. As greed is one of the oldest vices known to man, it is endemic throughout the world and will probably never disappear, but governments can take steps to reduce it. The first step would be to pass legislation defining what it and what is not allowed, and making it clear that violators will be prosecuted.
One criticism that a consultant to Mongolia had on that country’s regulation for the meat industry was that the final law eliminated the provisions governing corruption. Enforcement is essential and must address all offenders. When high government officials or people with influence escape the law or help their friends or family to do so, the credibility of the law and the nation are compromised. Nepotism is an unfortunate and all-too-common problem in developing nations. It not only encourages cheating, but discourages qualified and caring people from getting involved or staying with an agency. These people understand that even if they work harder and do their jobs well, it is often the nephew of the ranking official who gets the promotion.
Another means for discouraging corruption is to increase pay and benefits for government inspectors and others who are involved in food regulation and food control. If a person feels that he is obligated to take bribes or other money simply to make ends meet, he will do so. Along these same lines, many governments would be wise to reduce head counts in their inspection agencies. Rather than having a bloated work force whose staff is poorly compensated, a smaller, more elite and better paid group of inspectors might be considered.
Ultimately, the powers-that-be must take a stand against corruption. If they take action against nepotism and lawbreaking, food safety inspection programs have a chance to succeed.
Educating people in developing countries is and has been one of the major efforts of the governments in these nations, but they must also work within their budgets. Education is the key to the production of safe and healthy food. As mentioned, proper hygiene practices should start at home, but the food industry has to be aware of cultural deficiencies and be prepared to implement programs that will consider these needs.
Educational Partnerships. Education is a key element in building quality food safety systems. The process must really begin at the grade school level and at home, but this discussion is beyond the scope of this article. We will focus on the university level, particularly with those institutions that have foods and nutrition curricula. Food science and technology scientists must not only understand food, but they must also understand biochemistry, microbiology, basic chemistry, engineering and other disciplines, and be able to integrate them. It is up to food science educators to develop programs that provide this interdisciplinary approach. Faculty also must make the effort to teach their students to think and apply what they learn, rather than just test their memories. Ideally, food science educators should work with industry to create programs that allow students to see what the real world is like. Their lessons will become more “real” as students see the potential applications of what they are learning.
Of course, this means developing a partnership with industry. Ideally, the local food industry and the university should work together to develop this relationship. Utilizing a facilitator from a trade association or a non-government organization (NGO), might help get the program started. There will be problems in getting such a program started. Many processors in developing countries, even if they are producing basic products like canned fruits or frozen vegetables, seem to believe that there are “trade secrets” that must be protected, and thus do not encourage plant visits. On the other hand, processors in developing countries also may be more open to visitors since liability and worker safety issues are not as strict as they may be in developed countries.
Outreach. The academic community must reach out to industry and demonstrate both competence and a willingness to “give a little.” We say competence because in many places, even developed countries, the food industry does not believe that academicians understand their problems and needs. The most common complaint is that the average academic does not have a practical understanding of the industry and that they are too “ivory tower.” The academics want to “help” the industry and pick up a little extra money as consultants, yet the industry does not trust their competence. The lack of trust may be deserved in some cases. Older faculty may not kept up with changes in the industry and offer advice that is outdated.
To help build confidence in their abilities, members of the academic community who wish to work with the food industry need to do several things. First, they should consider giving some time gratis to help the industry. This first step could lead to additional consulting work for pay, assuming that they do a good job. Another way that the academic community could build confidence and demonstrate competence is to share information. Frequently, workshops and programs offered in developing nations are almost totally lacking in support materials. The professors lecture rather than share, with very little effort to show how their work can be applied in the real world of industry. Handouts often consist of a rough outline, and requests for additional information are met with an answer like, “You will have to pay for that.” These individuals need to understand that information is power, and that power is greater if the information is shared and not hoarded.
University Extension. This all leads up to the establishment of university extension departments in developing nations. These departments would be logical extensions of the food and nutrition departments. Their mission would be to work directly with the food industry on industry issues. This would include developing tools that can be used by the industry, such as bulletins addressing safety, sanitation and quality, conducting applied research for industry segments, teaching workshops in applied science and technology and serving as a reference source for the industry.
The extension food scientists should be individuals who are willing to “get their hands dirty,” who have an ability to teach and share, and who have a real interest in serving their country. It might even be a good idea to pay them better-than-average salaries to encourage them to be extension professionals and discourage consulting for a fee.
Richard F Stier is a consulting food scientist based in Sonoma, CA. Formerly the Director, Technical Services for The Competitiveness Initiative-Mongolia and consultant with the Agricultural Led Export Business project based in Cairo, Egypt, Stier has international experience in food safety food plant sanitation, quality systems, process optimization, GMP compliance and food microbiology He is a member of the IFT’s Committee on Global Interests and a contributing member of the Food Safety Magazine Editorial Board. Stier can be reached via email at email@example.com.
Morad Ahmed has more than 30 years of experience in the international food industry, including positions at seafood and frozen food companies in Egypt and Switzerland. From 1994-2002, he served as the technical co-director of the ALEB-USAID project.
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, logistics, product development quality control, quality assurance and management.