Food Protection Trends - May/June 2024 - 172

TABLE 12. Lead instructor perceptions of which courses SVS food processors would find
to be beneficial before taking the FSPCA PCHF course
Course title or topic
Risk-based identification of food safety hazards
GMPs
General HACCP
Food science and technology
Food microbiology
Number of respondents
(3) motivation to address challenges and engage in PCHF
compliance. Survey results also suggest strategies for training
SVS food processors on food safety and the PCHF Rule
based on preferences for educational resources.
Awareness of the PCHF Rule and its requirements
Food safety communicators and regulators surveyed in this
study reported widespread lack of awareness of the PCHF
Rule among SVS food processors (Table 6 and Fig. 1). This
is an important finding given the studies that recognized
awareness as the first of several steps needed to achieve
compliance (2, 9).
Small-scale businesses, especially start-up operations,
may not be aware of new regulations if they are not involved
in food industry or trade associations or if they do not
regularly visit online government or university extension
sites. Without awareness of the regulations and the specific
requirements that apply to SVS food processors, motivation
to act on their own or to seek external resources will be
hindered. Increased collaborative efforts by food safety
communicators and regulators that leverage the expertise
and experience within each group will be needed to raise
awareness and therefore begin the process of achieving
PCHF compliance.
Knowledge of hazards and risk-based food safety
approaches for controlling them
Following awareness of the PCHF Rule comes a range of
challenges on learning about food safety hazards and developing
methods to prevent them from occurring. The results
in Fig. 1 showing that processors appreciate the importance
of producing safe foods is consistent with other studies
(19). Yet both food safety communicators and regulators
agreed that SVS food processors lack knowledge in basic
food safety and sanitation standards and, to a greater extent,
risk-based food safety management approaches for producing
safe foods (Table 6 and Fig. 1). This is not unexpected
172 Food Protection Trends May/June
None
11
11
16
16
Slight
5
Percentage of respondents
Moderate
16
21
21
42
42
19
Strong
53
58
47
37
21
Very strong
26
21
21
5
11
given the greater complexity of risk-based HACCP and
HARPC approaches compared with GMPs. Furthermore,
this aligns with earlier studies that found implementation
of food safety management programs by smaller food
businesses is often hampered by regulations and guidance
documents that contain technical jargon that is difficult to
understand and that may be judged as overly burdensome
and unnecessary (11, 24). The recommended approach of
the National Advisory Committee on Microbiological Criteria
for Foods to HACCP plan development is to assemble
a collaborative multidisciplinary team in which viewpoints
and expertise taken from all levels of the company can contribute
to a full understanding of risks associated with the
process and the product (17). Yet smaller companies with
few in-house technical resources often find it challenging
to evaluate their own food safety risks (22). This is consistent
with the observations of food safety communicators
and regulators that SVS food processors most often desire
template or model PCHF food safety plans and prefer oneon-one
advice and consultations that address the specific
products and processes relevant to their operations (Tables
9 and 10).
Lead instructors and regulators who perform inspections
agree that three core elements of a risk-based food safety
plan, namely, conducting a hazard analysis, verification
of monitoring activities, and science-based validation of
preventive controls, present the most challenges for SVS
food processors (Tables 7 and 8). This was not unexpected
given the earlier studies on HACCP implementation that
found that conducting a hazard analysis and establishing
procedures for verification and validation were the top
three subject areas that processors found most difficult to
understand and implement (6, 11, 31). The FSPCA PCHF
training manual similarly acknowledges the difficulty of
conducting a complete and accurate hazard analysis and
the complexity of establishing verification and validation
procedures (12).
Food Protection Trends - May/June 2024

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