Food Protection Trends - August 2008 - 579

food contamination. Hence, none of the techniques can provide an assurance of absolute safety. Therefore, in the interest of food safety, an “appropriate level of protection” (ALOP), a term that was introduced by the WTO, must be achieved (14, 32). Expression of an ALOP should be based on the best knowledge available at the time and on public health goals/targets and should be defined after risk analysis carried out by scientists who are experts both in the topic and in the methodology of risk assessment and after consultations with relevant stakeholders. Based on this information, ALOPs can be expressed in the form of laws, regulations, codes of practice and guidelines, which are primarily the responsibility of legislators (32, 44). In the European Union, for instance, ALOP is mentioned in the Food Hygiene Regulation (EC 852/2004), which is discussed further in a later section. Nevertheless, the translation of an ALOP into food safety objectives and more specifically into microbiological criteria regarding hand hygiene is extremely complex, and the methodology to do so is still in debate (102, 117). Moreover, because the currently achieved level of consumer health protection may change (for example, new technologies may change the level of a contaminant detected in a food), an ALOP may need to be revised over time. Legal requirements of the European Union The “hygiene package” of 5 laws adopted by the EU and in practice since January 1, 2006 aimed to merge, harmonize and simplify very detailed and complex hygiene requirements that were scattered over seventeen EU Directives. The overall aim was to create a single, transparent hygiene policy applicable to all food and all food operators, together with effective instruments to manage food safety and potential future food crises, throughout the food chain. Regulation (EC) No 852/2004 of the European Parliament and of the Council on the Hygiene of Foodstuffs contains common principles in relation to structural, operational and hygiene requirements for establishments. These principles constitute a common basis for the hygienic production of all food, including products of animal origin. In addition to this common basis, specific hygiene rules are necessary for certain foodstuffs. Regulation (EC) No 853/2004 lays down specific hygiene rules for food of animal origin. The general hygiene requirements for all food business operators, contained in the 12 chapters of Annex ll of Regulation (EC) No 852/2004, cover the Prerequisite Programmes (PRPs) and the basic principles of operational and structural hygiene. Chapter 1, Section 4, which specifispecifically relates to hand hygiene requirements, states: “An adequate number of washbasins is to be available, suitably located and designated for cleaning hands. Washbasins for cleaning hands are to be provided with hot and cold running water, materials for cleaning hands and for hygienic drying. Where necessary, the facilities for washing food are to be separate from the handwashing facility.” Personal hygiene is covered in sections 1 and 2 of chapter 8. Section 1 states: “Every person working in a food-handling area is to maintain a high degree of personal cleanliness and is to wear suitable, clean and, where necessary, protective clothing.” Section 2 states: “No person suffering from, or being a carrier of a disease likely to be transmitted through food or afflicted, for example, with infected wounds, skin infections, sores or diarrhea is to be permitted to handle food or enter any food-handling area in any capacity if there is any likelihood of direct or indirect contamination. Any person so affected and employed in a food business and who is likely to come into contact with food is to report immediately the illness or symptoms, and if possible their causes, to the food business operator.” Legislation covers not only hands, but also materials that come in contact with hands. Gloves, similarly to other materials in contact with food, are subjected in some countries to strict regulations, e.g., materials used, limits of migration, and labeling. Manufacturers of gloves are legally required to perform necessary tests to demonstrate compliance with legal requirements. However, this regulation is not widely known to end users (43). governments. The most important federal agencies that have responsibility for food safety are: The Food Safety and Inspection Service (FSIS) of the United States Department of Agriculture (USDA), which is responsible for regulations regarding safety of meat, poultry, and egg-based products; Food and Drug Administration (FDA), responsible for regulations regarding other foodstuffs; Center for Disease Control and Prevention (CDC), responsible for prevention and control of disease outbreaks; and Environmental Protection Agency (EPA), responsible for regulations regarding pesticides. The coordinated action of these authorities results in a coherent and effective policy. The Food Code is a reference document published by the FDA in collaboration with FSIS and CDC to assure food safety and is implemented in national law in most states. The Food Code contains several regulations concerning hand hygiene specifically, such as regulations specifying that when, how and where hands should be washed; fingernails should be kept short and clean; handwashing facilities should be present in sufficient numbers; handwashing infrastructure cannot be used for other purposes than washing hands; and except for a plain ring, food operators may not wear jewelry. Voluntary quality management systems The Codex Alimentarius (Latin, meaning Food Law or Code) is a collection of internationally adopted standards, codes of good practice, guidelines, and recommendations regarding food safety that was developed and is administered by the United Nations’ Codex Alimentarius Commission. Its purpose is to protect the health of consumers and to ensure fair practices in the food trade (31). Although the Codex has no legal authority, it gains importance with increasing globalization. For instance, in several countries it is required that imported food is produced and processed in compliance with the Codex (45). In addition to the Codex Alimentarius, there are also voluntary quality managements systems (QMS), such as BRC (British Retail Consortium), IFS (International Food Standard) or ISO22000, which incorporate the Codex Legal requirements of the United States Food Safety Regulation in the United States is complicated because it involves federal authorities as well as several local AUGUST 2008 | FOOD PROTECTION TRENDS 579
Food Protection Trends - August 2008

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