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HACCP: Chemical Hazards Management

Development – To define detail, scope and purpose.

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Training participants will gain a basic understanding of HACCP: Chemical Hazards Management and its applications within food safety and quality systems. Basic knowledge competency will be verified through successful completion of the accompanying HACCP: Chemical Hazards Management assessment activity. Basic skill competency can be verified through the HACCP: Chemical Hazards Management competency checklist available as a resource for this training activity.

Key Definitions For HACCP: Chemical Hazards Management
- Biological Hazard: The danger posed to food safety by the contamination of food with pathogenic microorganisms such as viruses, bacteria, spores, fungi or naturally occurring toxins.
 - Carcinogenic: A carcinogen is a chemical known or believed to cause cancer in mammals. Some chemicals are proven carcinogens, but many more are suspected to be carcinogenic.
- Chemical Hazard: The danger posed to food safety by the contamination of food by chemical substances, such as pesticides, detergents, additives, and toxic metals.
- Hazard Analysis Critical Control Point or HACCP: HACCP is a food safety methodology that relies on the identification of Critical Control Points in all stages of food business processes.
- Physical Hazard: Particles or fragments of items not supposed to be in foods.

HACCP: Chemical Hazards Management Development  
When considering the development, documentation and implementation of HACCP: Chemical Hazards Management within food safety and quality management systems, the following information should be considered to ensure effective outcomes:

About HACCP: Chemical Hazards Management
When considering the hazards associated with the process steps in the HACCP plans, the three traditional groupings of hazards to consider include biological, chemical and physical hazards. As HACCP plans evolve and customer standards and regulatory requirements become more stringent, often allergens, regulatory hazards, quality hazards and engineering hazards are also commonly considered in HACCP Plans.

Chemical hazards are quite often viewed by the consumer as posing a significant food safety risk, where as in reality, they more often pose a very low immediate health risk at levels likely to be found in food. Some chemicals are harmful to health and others simply affect the quality of food as judged by consumers. It is possible for chemical contamination of foodstuffs to occur at any stage of their production, from the growing and cultivation of raw materials, through to the consumption of the finished product. The effect of chemical contamination on the consumer can be long term chronic effects that are extremely damaging to the body, such as for carcinogenic or accumulative chemicals including heavy metals, which can build up for many years, or it can be short term acute, such as the effect of allergenic foods. Improper use, storage, location, display, and labelling of poisonous and toxic materials, first aid supplies, medicines and cosmetics presents public health risk due to food and food contact surface contamination.

Examples of accidental chemical food contamination situations could include:
- An aerosol pesticide stored in a discount basket of a retail market with food items in which the spray mechanism had been depressed and the surrounding food containers saturated with the chemical;
- Garden insecticides and herbicides located above a produce storage area with several of the containers laying on their side;
- Assorted veterinary medicines displayed above a frozen food display case;
- An insecticide container stored on an ice machine top next to the ice scoop;
- Unlabelled clear cleaner in a spray bottle on the same shelf with plain water in the same type of spray bottle; the water is used to spray on the grill to produce steam while cooking food;
- Pest strip located over a food preparation table dripping chemicals onto food contact surfaces; and
- Employee medicine located on a shelf above a food processing area.

Any of the above situations could potentially result in disastrous consequences.

Naturally Occurring Chemical Hazards
Naturally occurring chemical hazards that may present within foods may include:
- Mycotoxins, for example, Aflatoxin;
- Scrombrotoxin or Histamine in seafood;
- Ciguatoxin in seafood;
- Pyrrolidizine alkaloids such as plant toxins from Patterson’s curse or Crotolaria;
- Phytohemagglutinin;
- Shellfish toxins – Paralytic shellfish poisoning or PSP, Diarrhetic shellfish poisoning or DSP, Neurotoxic shellfish poisoning or NSP, Amnesic shellfish poisoning or ASP Paralytic shellfish poisoning toxins are naturally occurring marine toxins. Single-celled marine plants called phytoplankton produce these toxins. Marine animals that filter their food from seawater may accumulate these toxins. The toxins do not appear to directly harm the animals, but people or some predatory animals eating toxic seafood may become poisoned. PSP toxins and domoic acid are powerful nerve poisons. PSP toxins and domoic acid have no taste or odour. There is no visible difference between toxic and safe seafood. Cleaning seafood in many cases will not remove the toxins. Cooking does not destroy the toxins. Certain one-celled organisms called dinoflagellates produce PSP toxins. Bivalve or 2-shelled shellfish filter these organisms from the water. PSP toxins accumulate in the dark digestive organs of most shellfish. PSP symptoms begin within a few minutes to a few hours after eating toxic shellfish. Symptoms begin with tingling and numbness of the lips, tongue and fingertips. Later symptoms are lack of balance, lack of muscle coordination, slurred speech and problems in swallowing. Complete paralysis and death can occur in severe cases.

Reactions due to allergens of naturally occurring chemical hazards can range from mild to extremely serious, depending on the dose and the individual’s sensitivity to the nominated component. Product analysis and related labelling form the front line in assessing a product’s potential to cause harm. Labelling must be specific in noting ingredients of concern, particularly in nomination. For example, species of fish, and types of nuts should be shown, as certain individuals may be specifically allergic to only certain types of ingredients. The potential for cross-contamination within the processing environment is a major concern within this area, forming a loop through which ingredient nomination becomes invalid if cross-contamination does occur.

Chemical Contamination
Chemicals are usually in solution and cannot be seen unless they are a recognized colour. Food accounts for a high percentage of the total human exposure to most chemicals from environmental sources. Fish poisoning, for example, by Ciguatoxin and Scombrotoxin accounts for a large portion of the reported outbreaks. Scombroid poisoning is most often a result of histamine production in fish that have been improperly refrigerated. Heavy metal poisoning occurs frequently when acid foods such as lemonade and carbonated beverages come in contact with such heavy metals as copper, zinc, antimony and cadmium.

The following form the general basis of concern regarding chemical contamination:

Cleaning Chemicals
Cleaning chemicals are prevalent in any food related operation, and therefore form one of the most significant chemical hazards. Cleaning or sanitising chemical residues may remain on utensils, in pipes or on food contact surfaces and equipment, making transfer to food a very real possibility. Cleaning chemicals may also contact food through splashing during cleaning if the proper precautions are not taken. Taking these factors into account, the use of cleaning chemicals, as it is necessary to support other aspects of the food safety system, should be ratified within the food safety system itself, to reduce the risk of potential contamination. Potential hazards can be significantly reduced through separation by time of cleaning activities and production activities, the use of non-toxic chemicals, correct dosing/dilution ratios, and through the design, application and management of appropriate cleaning procedures. This will include adequate training of staff, and may involve post-cleaning inspections.

This class of chemicals involves any toxic or non-toxic substance that is applied in an effort to control or kill pests.

Pesticides may include the following variants:
- Insecticides and Rodenticides;
- Herbicides;
- Fungicides;
- Fertilisers;
- Wood preservatives;
- Bird and animal repellents;
- Marine anti-fouling paints;
- Commercial or domestic pest control products.

Pesticides are present in varying applications throughout many different industries around the world. The use of most concern in food safety is in agriculture, but contamination from all sources must be considered. Agricultural industries use chemicals as protection, in storage and to improve crop yields. Not all pesticides are safe for use in food production, and even those that are used may leave residues that can be harmful in high concentrations. Most countries have stringent controls over the use of pesticides, including which chemicals can be used in specific applications, and the residual limits that are acceptable. A food safety viewpoint dictates that all information regarding pesticides in relation to raw materials being used, be available for some stage of processing. Permitted pesticides and their accompanying residual limits must be understood in each case, to assert control over such chemicals in production of foodstuffs. In addition to the raw materials that have possibly been exposed to pesticides during the primary levels of their production, there is always the very real threat of contamination with pesticides at any stage of its further processing. This could occur in the form of contact with pesticides on your site. As pesticides are an intrinsic part of any food safety system, it is important to understand and control their role within the system itself.

As with other chemicals, pesticides must be stored and handled in a manner that facilitates safe practice. This generally includes storing these types of chemicals in locked, stable and well ventilated storage areas. Procedures for the storage, handling and use of such chemicals should be documented, which include specific nominations regarding skills and training requirements for personnel and contractors involved in providing technical advice and/or applying chemicals.

Toxic Metals
Metals can enter the food chain through a number of sources, and can be a major risk to human health in high quantities. Toxic metals are also commonly known as Heavy Metals.

The most prevalent forms of toxic metal risks into the food chain are:
- Environmental pollution;
- The soil in which foods are grown, or have contact with;
- Equipment, utensils and containers used in cooking, storage and processing;
- Food processing water;
- Chemicals applied to agricultural land.

Toxic Metals of particular concern include:
- Tin;
- Mercury;
- Cadmium;
- Lead;
- Arsenic;
- Aluminium;
- Copper;
- Zinc.

As for other chemical hazards, it is important to assess and understand the particular risks of toxic metals to your products, in raw materials, metal equipment, processing and packaging.

Nitrates and Nitrites
Nitrates occur naturally in the environment and are present in some fruit and vegetables. They are a constituent of many fertilisers, which have increased levels in agricultural soils and associated effluent runoffs. Nitrites and Nitrates have historically been added to a number of food products to aid in their preservation. The process of deliberately adding nitrates and nitrites to foods is strictly governed by legislation as high levels of these substances in foods can produce a variety of toxic effects in humans. Specific examples include carcinogenic effects and infantile blood related disorders. N-nitroso compounds can be formed in food as a result of reactions between nitrites and/or nitrates and other compounds. They can also be formed within the human body when large amounts of nitrites and nitrates are present in the diet. Nitrates can cause significant problems in canned products where it can cause the breakdown of internal lacquer linings, allowing tin to enter the food product via leaching. The food safety management system must include nominations for safe usage that do not exceed legal limits where such substances are being added to product, or run the risk of post contamination from these substances giving an increased overall level.

Polychlorinated Biphenyls
Polychlorinated Biphenyls or PCB's are part of a group of organic compounds that are used in a number of different industrial applications. These are highly toxic compounds, and their use is limited to closed systems. Their production has been banned in a number of countries. The most significant source of PCB's in foods is through absorption from the environment into fish. The compounds then accumulate through the food chain and become concentrated in larger fish with tissues that contain high fat levels. This issue becomes a concern when raw marine products are being used in processing.

Certain plasticisers and other plastics additives can be cause for concern if they are able to migrate into food. The transfer of such substances into foodstuffs depends on the constituents present, and also the type of food, noting that fatty foods promote migration more readily than some other foods. The constituents of plastics that are used in food contact are generally governed by strict legislation regarding availability of possible transfer of substances into foodstuffs. Plastic utensils should also be considered in this area, as they may also permit chemical migration.

Veterinary Residues
Growth hormones, regulators, and antibiotics used in animal treatments can be passed into foods. Hormones and growth regulators have been banned from use in food related animals in some countries, and the use of antibiotics and other medicines is strictly controlled. Antibiotic carry-over in animals for food can cause serious allergic responses in susceptible individuals, and similarly, hormones and growth regulators can cause serious toxic responses when consumed in quantities. The input of quality raw materials from sufficiently registered suppliers usually guarantees that certified product is accepted.

Chemical Additives
Chemical additives are not only used to create safe and hygienic products, but also to assist processing, and to enhance or beautify otherwise bland, though nutritious products. They may also be of substantial nutritional benefit, as in the case of vitamins and/or minerals. The use of specified chemical additives is governed by strict legislation, which not only classifies additives as to their purpose, but also as to their limitations of use across various categories of foodstuffs. Chemical additives also include natural non-synthetic substances, for example, plant extracts that may be acutely toxic. It is therefore advantageous in controlling all such additives to be fully aware of correct applications in dosing, and cross-contamination issues.

Chemical additives may include:
- Preservatives, for example, nitrite, sulphite and sulphates;
- Flavour enhancers, for example, monosodium glutamate;
- Antibiotics for example, niacin;
- Nutritional additives, for example thiamine and folate;
- Natural and synthetic colour and flavour additives.

First Aid Supplies, Medicines and Cosmetics
All first aid supplies, medicines and cosmetics must be stored and displayed in such a manner to prevent contamination and special consideration needs to be given to the following:
- First aid kits and supplies should be properly identified and located away from food, food contact surfaces of equipment and utensils, single-service and single-use articles;
- Human and animal medications must be properly stored and located as previously mentioned for toxic materials;
- Medications vitally necessary for employee use must be stored with personal belongings and / or in designated areas where contamination will not occur; and
- Cosmetics for retail sales in food establishments should be properly stored and located as previously mentioned for toxic materials. Personal cosmetics must be stored with personal belongings in designated areas.

About Chemical Control
The use of chemicals within any food business must include elements which not only promote food safety, but which also promote the general safe use, handling and storage of all cleaning, sanitation, pest control, maintenance and other chemicals. This can generally be facilitated by ensuring documented procedures for chemical control are documented and available to everyone using chemicals.

Chemical usage procedures may include:
- Familiarity with the type of chemical being used, including Composition, Strength, Associated Hazards. This information can generally be gathered from the SDS, labelling and manufacturer’s instructions. Procedures may include appropriate specifications for use such as Do not mix with other chemicals or Do not add water ;
- Labelling of decanted, diluted or prepared chemical mixtures to ensure they are not mistaken for other chemicals;
- Storing, handling and using chemicals away from foods, and in a way which prevents the contamination of foods;
- Defining the responsibility for chemical use;
- Training and competency verification procedures for team members required to handle or use chemicals.

Chemical Storage Segregation and Security
Chemicals used within food businesses must be properly stored and located with insecticides and rodenticides stored separately from cleaning compounds and other chemicals. All chemicals and pesticides must be stored separate from food, food contact surfaces and single-use and single-service articles. In this context, the term separate does not include storage of toxic chemicals above food, food contact surfaces, single-use and single-service articles.

The storage of chemicals must also meet local regulatory and environmental protection requirements.

Where necessary, adequate facilities for the storage and handling of food, ingredients and non-food chemicals including cleaning chemicals, pest control chemicals, lubricants and other maintenance chemicals must be provided.

Where appropriate, food storage and handling facilities should be designed and constructed to:
- Permit adequate maintenance and cleaning;
- Avoid pest access and harbourage;
- Enable food to be effectively protected from contamination during storage and handling;
- Where necessary, provide an environment that minimises the deterioration of food through controls including temperature and humidity.

The type of facilities required will depend on the nature of the food items being stored and handled by a food business. Where necessary, segregated and secure storage facilities should be provided for cleaning chemicals, pest control chemicals, lubricants and other maintenance chemicals. Storage facilities for ingredients, packaging and other materials should also be appropriately secured and adequately ventilated.

Chemical Handling and Usage Training
Specific Chemical Training is a standard requirement for persons involved with the use of chemicals within food businesses. It is important that chemical training is tailored to the specific requirements of the chemicals being used, to ensure that foods do not become contaminated by such usage.

It is important that the application of chemical handling and usage training is completed prior to persons being left un-supervised to use chemicals within a food business. Competency against chemical handling and usage training requirements should also be verified prior to un-supervised interactions.

It is important to consider that specific chemical handling and usage training should be developed, scheduled, conducted and recorded to display compliance for functional chemicals used as food additives or processing aids. The use of such chemicals should be well controlled; it is common for chemicals such as nitrites and sulphites to be stored in secure areas, and only accessible to authorised persons to ensure any accidental or intentional misuse is unlikely to occur.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific HACCP: Chemical Hazards Management Development requirements in relation to their items.

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