What food safety really demands

In our projects with food businesses, we frequently encounter claims that have taken on a life of their own over the years.

 "That is required by law."

"That is what the standard requires."

"You have to do it that way in HACCP."

"That is what the auditor wants."

 Some of this is true. Some of it makes technical sense but is not mandatory. And some of it is simply a simplified rule that has little to do with actual risk assessment. We have also covered this in a series on LinkedIn called "OBLIGATION. PRACTICE. PANIC?"

Safety is not created by individual numbers

72 °C core temperature.

2 °C for minced meat.

Continuous monitoring at the CCP.

Such numbers provide guidance and can be highly relevant from a legal or technical standpoint. However, they must not be viewed in isolation from the process.

In thermal processes, temperature and time count together. For minced meat, a maximum of 2 °C generally applies to storage and transport, while short-term process steps must be evaluated separately. And a CCP requires effective monitoring, but not necessarily continuous measurement in every case. The decisive question is therefore not: "Do we have the right number?"

But rather: "Can we demonstrably control the relevant hazard?"

Analysis provides information, but not absolute safety

Microbiological testing can also quickly lead to false certainties. Taking more samples does not automatically make a batch safe. Initially, it only increases the probability of detecting existing contamination. Conversely, a positive finding does not automatically mean that every unit in the entire batch is contaminated. And while finding Listeria in the environment is a serious warning signal, it is not automatic proof of contaminated product and therefore not automatically a reason for a recall.

Sampling must therefore always answer a clear question: "Is this for release, verification, root cause analysis, or trend monitoring?"

Without this question, a lot is quickly analyzed but little is understood.

Deviation means taking action, but not automatically escalating

A deviation at a CCP is serious. It requires immediate correction, which means a direct response to the deviation and an assessment of the affected product. This is distinct from corrective action. This eliminates the root cause so that the deviation does not recur.

A product recall, however, is not an automatic consequence of every CCP deviation. The deciding factor is whether unsafe product was actually created and whether it has already been placed on the market. Consistent action

More chemicals do not mean more hygiene

The situation is similar with cleaning and disinfection. Disinfection does not replace thorough cleaning. Product residues and deposits must be removed first. Effectiveness depends on the interplay of mechanical action, chemistry, temperature, and time. This becomes even more critical when dealing with biofilms.

Using more disinfectant alone will neither remove the protective matrix nor a structural niche. The biofilm must be made accessible, removed mechanically, and the root cause eliminated. Afterward, you must verify that the procedure actually works.

The common denominator

All these examples show the same thing: food safety does not work like a cookbook. Laws and standards set requirements. Science provides insights. The facility must use these to develop a suitable, justified, and effective solution.

That is why the most important question is not, "What do I have to do to comply?", but rather:

 "What hazard am I trying to control, how do I do it effectively, and how can I prove that it works?"

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