Food quality and safety are the main keys of the healthy and prosperous nation and are perfect opportunity for the country to present itself as a credible partner and producer of the competitive goods on the global market. The implementing of the global quality and safety control system is one of the most important objectives for Ukraine, as it is one of the main exporters of grains, and thus exploring the opportunity to increase grain shipment with high VAT level. One of the systems, such as HACCP, should be implemented under the current legislation by this autumn. The main objects and principles of HACCP were the main topics of our interview with the advisor to the president of the Ukrainian Grain Association (UGA) on feed and food safety, Vadim Turyanchik.
- The Law of Ukraine of the basic principles and requirements for the food quality and safety came into force on September 20, 2015, and it provides the implementation of the model of the European food security management and control system based on the HACCP procedures in Ukraine. What is the main objective of implementation for the enterprises that storage and process grains?
At first please let me clarify the definition of the term HACCP. HACCP is Hazard Analysis and Critical Control Points. This system identifies, evaluates and controls all of the risks that are essential for the food and feed safety. In other words, HACCP system is the instrument to control the food and feed safety that also reduce the risk of the incidents occurring, but not eliminate the risk itself. The effectiveness of the system depends on the way it is implemented and how it works including such background programs as GHP (Good hygiene practice), GMP (Good manufacturing practice), GAP (Good agricultural practice), and GSP (Good storage practice).
The main objectives of the implementation of any system is the creation of the conditions to produce and operate safety goods, to ensure their traceability, to create the response system in case of the dangerous goods appearing that provides the mechanism of the withdrawal and/or recall of the products. The implementation also aims at organizing of the system of the goods production and turnover with the safety indicators that correspond to the governmental and the EU requirements or the ones of the importing country. All of these objectives must provide the Ukrainian market participants with opportunities to export goods to the EU countries and others.
Many of you had probably heard of the notion “from field to fork” which means that firstly it is necessary to provide at the legislative and production level the control over the food safety starting from the harvest and ending by the sales of goods onto the market and their distribution to the customer. Thus, the companies that store and process grains must implement the HACCP system, not including those that store grains in the fields (the primary production).
- What companies must move towards this system, and when they must do it?
Under the Article 21 of the Ukraine Act of the basic principles and requirements for the food quality and safety there are requirements for the implementation of the standing operations based on the principles of the HACCP. In order to provide gradual transition to the HACCP procedures the Law of Ukraine established a certain transition period for the principles. In particular, in terms of the food production companies the transition period will last for the 4 years starting at the next day after the publication of the Law. Consequently, for the elevators this period will start at September 20 of 2018.
- Why does it take so long to oblige Ukrainian companies to transfer to the system?
Frankly speaking, it is not a long time. In order to launch effective, functional and continuously improving system any company needs years to do it. If we speak about the food producers the implementing of the HACCP is not a big deal and many of them are actually have already done it as usually they are obliged to do it by the client-company or the importing country. On the other hand, it is new for the elevators, especially liner one, and they would need some time to establish the HACCP. We know that not all of the companies are ready to transfer to this system and they do not know how to do it correctly and faster. That is why, the UGA, which unites Ukrainian producers, processors and exporters, came as the organizer of the free workshops on the implementation of the HACCP system on the elevators in Ukraine, supported by EBRD under the initiative of EU4Business, and with the support from State Service of Ukraine on food and consumer safety and the Ministry of Agrarian Policy and Food of Ukraine. I should say that the workshops were held in 5 cities in Ukraine (Kyiv, Poltava, Kharkiv, Ternopil, Dnipro) and more than 350 of the participants had attended. We consider it to be a high level of attendance if we take into account the fact that there are more than 800 existing elevators in Ukraine. We have five more cities to attend (Vinnitsa, Kropyvnytskyi, Kherson, Mykolaiv, Odessa), so all of the interested can register and attend the workshop.
- How many companies have already transferred to the HACCP system? How does the effectiveness of the company’s operation change after introduction of the system?
I cannot answer the question precisely, as in 2018 there were no appropriate inspections of the elevators by the State Service of Ukraine on food and consumer safety, thus we do not have the statistics data.
The effectiveness of the company’s operation can be seen in terms of the absence of the non-compliant goods during the processing and storage, and also in terms of the absence of the consumers’ claims or recall and withdrawal of the products from the market.
- What enterprises should do to transfer to the HACCP system? How much time does it need to do it? Is it more difficult to implement new system for the enterprises, which were built 20-30 years ago?
Any effective system implementation starts with companies’ top management commitment to the process. If the management were not interested in the system, it would be blank piece of paper. In this case, the absence of the system will be quite easy to see during the inspection or audit.
There are several steps needed to implement the HACCP system in the world practice – in particular, there are 12 (5 preparatory steps and 7 HACCP principles) or 14 main steps (7 preparatory steps and 7 HACCP principles).
During the workshops I give the example of 12 consecutive steps how to implement the system:
Step 1 – Organize the group HACCP.
Step 2 – Describe the product, the raw materials and the support materials.
Step 3 – Identify the product target purpose.
Step 4 – Design the flow-chart of the technical process.
Step 5 – Examine the flow-chart.
Step 6 – Principle 1: analyze the risks.
Step 7 – Principle 2: establish the critical control points (CCP).
Step 8 – Principle 3: establish the critical limit for the CCP.
Step 9 – Principle 4: establish the monitoring procedure for the CCP.
Step 10 – Principle 5: establish the corrective actions for the CCP.
Step 11 – Principle 6: establish the verification procedures.
Step 12 – Principle 7: introduce the documentation of all the processes and protocols.
More detailed information is available at our workshops.
The timeline of the system implementation and the difficulties that may occur are very specific. It all depends on the maturity level of the company’s workers and the infrastructure. There are companies built more than 60 years ago but the infrastructure condition does not need any considerable investments according to the risk assessment. However, new companies can implement new system easier, because today the equipment manufacturers have already taken many elements of the system into account (for example, covered assembly lines, wire catchers etc.).
- What companies/agencies can help the enterprise to implement the system? Who issues the certificate?
As I have already said, the certification of the permanent procedures based on the principals of the HACCP system is not obligatory. The UGA gives the basic concepts of the system HACCP, background programs and the Law of Ukraine of the basic principles and requirements for the food quality and safety. I should say that there were no free workshops for the elevators before. Many enterprises implement the system independently and later order the audit to evaluate the results after the HACCP implementation. The enterprises can seek outside experts, such as EBRD under the initiative of EU4Business, or SGS, TMS representative offices in Ukraine and others. If the enterprise decides to gain the confirmation certificate of the HACCP system implementation for compliance with the international standard ISO, than the company issuing the certificate must be accredited by the international companies, such as DAkks, UKAS etc., and for compliance with the DSTU/ISO – by the NAAU (National Accreditation Agency of Ukraine).
- Who and how would control the enterprises compliance with all the system requirements? Please, tell about the possible penalty for its non-compliance.
The governmental control is carried out by the competent authority – State Service of Ukraine on food and consumer safety under the act of state supervision. The central executive body approves the forms of the state supervision acts. The control can be conducted without the warning of the market operator during the company’s operation. The exception is possible when the forward warning is the important factor of the control effectiveness guarantee. In particular, when planning the governmental audit of the regular procedures, based on the HACCP principles system. There are penalties provided for non-compliance with the requirements.
- Vadim, what can You wish to the UGA members and grain business participants ahead of the new season?
First of all, I would like to wish the record and good crops! Also, I want to wish high demand rates for Ukrainian grains and the prosperous MY to all of us!
Interviewed by Julia Shevchenko, APK-Inform Agency
