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HACCP implementation in the production of fresh-cut fruits and vegetables

Mara S Tapia, Vicente M Gmez-Lpez and Cristina Olaizola Instituto de Ciencia y Tecnologa de Alimentos, Facultad de Ciencias, Universidad Central de Venezuela Abstract Purpose of the review: This review focuses on the complex task of the final implementation of HACCP by fresh-cut processors. In the face of recent episodes involving safety of produce and fresh-cut products, HACCP has been highly demanded for this industry by regulators, politicians, consumers and the market. Findings: The incidence of illnesses caused by foodborne pathogens associated with produce and fresh-cut fruits and vegetables has increased. A great amount of research continues to be done on interventions and on a hurdle approach to prevent contamination by microbial and other hazards. In the literature the importance of the prerequisite programs: GAPs, GMPs and SSOPs, as part of any quality and safety integrated system wherein HACCP may be the last step, is continuously stressed. Limitations/implications: The adoption of integrated safety systems by the fresh-cut industry is very important. Apart from GMPs (mandatory), specific legislation and guidance for these products is necessary (microbiological criteria, guides for GAPs, SSOPs, HACCP). This may be a problem since the market exerts a lot of pressure on produce and fresh-cut processors, and the system may act functionally as a trade barrier for small and medium size businesses and for developing countries. Implementation of HACCP system should occur in later stages. Directions for future research: The dynamic of the fresh-cut market and the severe safety requirements imposed especially by con-sumers, will lead and it is already observed in recent literature, to reflections and analysis on food safety management systems and safety strategies using new approaches and philosophies. Keywords: Hazard Analysis Critical Control Points (HACCP); fresh-cut; produce; Good Manufacturing Practices; Good Agricultural Practices; Sanitation Standard Operating Procedures

Abbreviations

*Correspondence to: Mara Soledad Tapia, Instituto de Ciencia y Tecnologa de Alimentos, Facultad de Ciencias, Universidad Central de Venezuela, Calle Suapure frente al ramal N 2, Colinas de Bello Monte, Caracas, Venezuela. Tel: +58 212 7534403; Fax: +58 212 7533871; Email: maria.tapia@ciens.ucv.ve Stewart Postharvest Review 2009, 4:6 Published online 01 August 2009 doi: 10.2212/spr.2009.4.6

CCP Critical Control Point CGMP Current Good Manufacturing Practice GAP Good Agricultural Practice

GMP Good Manufacturing Practice HACCP Hazard Analysis Critical Control Points

RAC Raw Agricultural Commodity

SSOP Sanitation Standard Operating Procedure

MAP Modified Atmosphere Packaging

VTEC Verotoxigenic Escherichia coli

RTE Ready-to-eat

EurepGAP Euro Retailer Produce Working Group-Good Agriculture Practices

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Introduction The fresh-cut produce industry is facing severe scrutiny from regulatory agencies and consumers to improve food safety. Each time any fruit or vegetable is implicated in a foodborne illness outbreak, all produce commodity sectors suffer from loss of consumer confidence in the industry. In the USA, the outbreak of Escherichia coli O157:H7 in September 2006 that was traced back to commercially-bagged spinach [1], and the multi-state outbreak of Salmonella Saintpaul in 2008, which implicated jalapeo and serrano peppers as major ve-hicles, with tomatoes as a possible vehicle early in the out-break [2] represented severe blows for consumers and the industry. Assuring safety is essential to accessing the market, and global recognition of standardised protocols to eliminate risk at every step from farm to fork has translated into food safety policy for many countries [3*]. Although the Hazard Analysis Critical Control Points (HACCP) system is not yet mandatory and not currently required by law for the process-ing of fresh-cut produce, the industry itself has been encour-aging their fresh-cut processors to voluntarily implement HACCP programs in their facilities, as well as to demand safe practices by partners throughout the supply chain. Many segments of the fresh-cut produce industry have adopted HACCP principles [46]. In produce operations, however, HACCP systems have lim-ited application since specific critical limits cannot be estab-lished and monitored to ensure that the hazard is reduced to acceptable levels. Instead, Good Agricultural Practices (GAPs) voluntary , Good Manufacturing Practices (GMPs), mandatory , and Sanitation Standard Operating Procedures (SSOPs) voluntary , provide the primary levels of risk management [710*, 11] for operations in the field that will directly impact the fresh-cut processing plant. In the present review an attempt will be made to revisit those as-pects. Food safety issues facing the fresh produce and fresh-cut industry Fruits and vegetables play an increasingly important role in todays diets. Epidemiological studies indicate that the regu-lar consumption of adequate amounts could help prevent ma-jor chronic diseases [12]. The scientific communities, and governmental and multidisciplinary publicity campaigns around the world, recommend consumption of at least 400 g of fruit and vegetable (five servings per day) [13]. The food industry has responded to this with fresh-cut fruits and vege-tables. As the public has become more health conscious, con-sumption of fresh produce and fresh-cut products have in-creased, and fruits and vegetables have also become increas-ingly important vehicles in foodborne disease statistics [1416]. The World Health Organization (WHO) and the Food and Agriculture Organization of the United Nations (FAO) [17] concluded that leafy green vegetables (lettuce, spinach, cabbages, chicory, watercress and leafy fresh herbs like ci-

lantro, basil and parsley) present the greatest concern in terms of microbiological hazards associated with fresh pro-duce, with berries, green onions, melons, sprouted seeds and tomatoes being of the second of highest concern. Carrots, cucumbers, almonds, baby corn, sesame seeds, onions and garlic, mango, paw paw, celery and mamey, even if having been implicated in cases or outbreaks of foodborne illness, the public health impact was considered to be low. Studies have demonstrated that human pathogens can survive in contaminated fields [18, 19], and reach edible parts of plants [20]. Preharvest damage enhances microbial survival in plants [21, 22]. Spreading of pathogens may have several patterns, from using contaminated manure or irrigation water in fields to more complicated patterns such as those involving nematodes [23] or ruminants [24] as reservoirs. Once there, they can also survive and grow [25]. Prolonged stay of mi-cro-organisms onto vegetable surfaces allows their attach-ment and biofilm formation [26], which makes them more resistant to decontamination [27, 28]. It has also been proved that human pathogens can be internalised into plants, survive and proliferate there [29], and migrate to edible parts of the plant [30]. Very comprehensive reviews about this problem have been written by Beuchat [31], Tyler and Triplett [21], and Aruscavage et al. [32]. Since many decontamination techniques act only on surfaces, internalised micro-organisms get protected from disinfection. Moreover, harvesting tech-niques [34] can contaminate produce. Fresh-cut produce: A challenge for safety The minimal processing industry unlike most other proces-sors have the difficult task of ensuring product safety without having a true kill step in processing operations [3540]. GAPs, GMPs and HACCP systems are among the primary methods for controlling pathogens in fresh produce and in the fresh-cut industry [6, 41, 42**44*]. Secondary interventions to prevent vegetables from becoming contaminated with pathogens (eg, Salmonella spp., Listeria monocytogenes, Vero cytotoxin-producing E. coli, Campylobacter spp., pro-tozoa and virus), during production rely on control measures taken during pre- and postharvest in a hurdle approach. Fresh-cut hurdles include purchasing produce from certified growerpackers, implementing plant sanitation programmes, using physical removal, chemical decontamination and an-timicrobial agents in the wash water, using modified atmos-phere packaging (MAP) techniques and consistent refrigera-tion management [44*49]. As discussed by the United States FDA [44*], raw agricul-tural commodities (RACs) are considered as any food in its raw or natural state. They are not subject to the Current Good Manufacturing Practice (CGMPs) requirements for foods (21 CFR Part 110) [50] that establish food safety prac-tices applicable to processors who manufacture, process, pack or hold processed food. Fresh-cut fruits and vegeta-bles are not RACs because they are no longer in raw or natural state and have become processed food. The United

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States Food and Drug Administration considers that the rec-ommendations in the Guide to Minimize Microbial Food Safety Hazards of Fresh-cut Fruits and Vegetables [44*] complement the CGMPs by suggesting more specific food safety practices for processors of fresh-cut produce. On the other side, in Europe, Commission Regulation (EC) 2073/2005 [41] on the microbiological criteria for food-stuffs, effective for all European Union (EU) states since January 1st, 2006 [40], includes fresh produce, in particular sprouted seeds, and unpasteurised fruit and vegetable juices among the food categories where verotoxigenic E. coli (VTEC) represents a hazard to public health. Microbiologi-cal guidelines aim at reducing the faecal contamination along the food chain which can contribute to a reduction in public health risks, including VTEC. While as for ready-to-eat foods (RTE) that are able to support growth of L. mono-cytogenes, in which pre-cut fruits and vegetables (RTE) are included, the Regulation requires the absence of the patho-gen (in 25 g) before the food has left the immediate control of the food business operator, who has produced it, but permits for up to 100 cfu/g for products placed on the mar-ket during their shelf-life. As for Salmonella, pre-cut fruits and vegetables the Regulation demands the absence of the pathogen (in 25 g) in products placed on the market during their shelf-life. The incidence, survival and competitive growth of patho-gens on fresh vegetables and on fresh-cut produce are well documented. E. coli O157:H7 has been implicated in con-sumption of celery, herbs, spinach and white radish sprouts, Salmonella species with consumption of sprouts, cabbage, lettuce, salad greens, tomatoes, cantaloupe, mamey, apple juice and orange juice; shigellosis has been associated with lettuce, scallions and parsley; cholera with strawberries; parasitic diseases with raspberries, basil and apple cider; hepatitis A virus with lettuce, raspberries and frozen straw-berries; and Norwalk/Norwalk-like virus with melon, salad and celery [35, 51**, 52]. This situation calls for increased efforts from the food industry in developing effective meth-ods for controlling pathogens in these products. When fresh produce is washed, cut and sliced, the natural defence mechanisms on the plant material are removed. The high level of handling increases the potential for product to be contaminated by micro-organisms in the ambient making it imperative that the best process control techniques are util-ised to promote safety, maintaining food safety standards with preventive programs [38]. Decontamination by physical or chemical methods has been widely used in the food industry to try to inactivate human pathogens present in fruits and vegetables [53] and to in-crease produce shelf-life by decreasing spoilage microflora [54]. For a long time the food industry relied on chlorine dips as a simple and cheap method to pursue these goals. Researchers have realised, however, that chlorine has lim-ited antimicrobial efficacy when used in vivo [55], and for-

mation of chlorine by-products from the reaction between chlorine and organic matter has raised many concerns [56]. A wide range of alternative decontamination methods have been studied for chlorine substitution, however, once more have shown limited efficacy for pathogen inactivation [5759]. The fresh-cut industry cannot exclusively rely on decon-tamination as well as on other control measures to reduce hazards in facilities for fresh-cut products. The fresh-cut produce industry is being demanded to implement HACCP and promote a farm-to-fork approach. As discussed very well by Sperber [42**], food safety has to be understood as HACCP plus prerequisite programs that focus on effective interventions and critical control points (CCPs) to protect the public health, eliminating possible false expectations that HACCP alone can provide food safety assurance. HACCP: The final stage of an integrated food safety program The fundamentals and principles of HACCP have been dis-cussed elsewhere [5962]. The success of HACCP prevent-ing identified hazards has led to regulators, politicians, and consumers calling for it in a farm to fork approach. How-ever, it is at the processing step where effective controls are available to eliminate significant hazards. The lack of defini-tive CCPs that could eliminate or control identified hazards like presence of pathogens in the field and the cultural habits of the consumers cannot be considered in the plan [7, 42, 63**65]. Many current HACCP plans put more emphasis on sound, well-conceived prerequisite programs and have fewer CCPs than they did historically [5, 10*, 63]. HACCP can only be effective in a fresh-cut facility if pre-requisite programs are in place and functioning properly. HACCP functions as the final stage of an integrated food safety program that begins with the prerequisite programs: GAPs, GMPs and SSOPs. While not a formal part of HACCP, prerequisite programmes must be developed and implemented in a food processing operation before attempt-ing to put a HACCP plan in place. They are defined as pro-cedures including GMPs that address operational conditions, providing the foundation of HACCP or practices and condi-tions needed prior to and needed during the implementation of HACCP and which are essential for food safety [61]. Mortimer and Harris [66], and Wallace and Williams [67**] revise thoroughly the concept of prerequisite programs and their usefulness to the HACCP approach. Varsakas and Ar-vanitoyannis [68**] recommend that fresh-cut processors develop written prerequisite programmes for raw material receipt and storage; wash water quality; equipment mainte-nance; production controls for grading, washing, cutting, drying and packaging; temperature and microbiological con-trols; chemical control; sanitary control for the facility, equipment and employees; product coding and traceability; recall procedure control; and finished product storage and

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distribution control. da Cruz et al., [69**] do an excellent job in revising exhaustively, the importance of GMP, SSOPs and HACCP, which must be accompanied with GAPs in order to implement a quality assurance system for the products. Most agricultural hazards cannot, and should not, be prevented through HACCP. Instead, the use of GAPs has been identi-fied by the United States FDA and the produce industry as a more appropriate way to address these hazards [10*, 70]. Good Agricultural Practices As shown by epidemiological data, the greatest risk to human health derived from consumption of uncooked produce comes from pathogenic micro-organisms which get to fruits and vegetables from an enormous variety of sources of con-tamination (untreated sewage or irrigation water, manure, soil micro-organisms, harvesting equipment, transport containers, processing equipment, human handling) [38, 71, 72]. An ex-cellent chapter on production practices that have the potential to contaminate produce items with pathogens at harvest and postharvest, and in turn, can be considered as risk factors in microbial food safety of fresh and fresh-cut produce, is pre-sented by Suslow et al. [73**]. As expressed by the authors, the specific influence and interactions among the production environments and crop management practices are not suffi-ciently understood to provide detailed guidance to growers and shippers and develop an encompassing assignment of microbial risk to commodities or to crop management prac-tices. In the USA, the acronym GAPSs refers to the Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables published by the United States Food and Drug Administration [10*], which has become a model for focusing on the key areas of presumptive risk potential for fruit and vegetable production and handling. The guide iden-tifies eight principles of food safety in the area of growing, harvesting and transporting fresh produce and suggests that growers use the general recommendations to develop the most appropriate good agricultural and management practices in those areas over which they have control in their opera-tions to prevent or minimise microbial food safety hazards. In Europe, GAP guidance is provided by the normative docu-ment for certification, EurepGAP Fruit and Vegetables, developed by EurepGAP (Euro retailer produce working group-Good Agriculture Practices) Fruit and Vegetables. New versions (V3.0-Mar07) of the normative documents for fruit and vegetables have been approved [74]. EurepGAP Fruit and Vegetables varies from the USAs guidelines by including consideration for issues such as wildlife and habitat protection, genetically modified organisms, and integrated crop management [75]. GAP systems can provide products of higher microbial safety that facilitate the implementation of HACCP procedures in establishments offering minimally processed vegetables [76]. EurepGAP for instance, is becoming an obligatory standard as most European retailers require it as evidence of good ag-

ricultural practices. Producers of fruits and vegetables have learned that without certification most retailers will not buy their products. Kokkinakis et al. [77] monitored certain mi-crobial-flora markers in order to check the efficiency of the Greek protocol AGRO 2-1 & 2-2 GAP system in agricultural farms to check microbial food quality of tomatoes and pep-pers grown in greenhouses, and to evaluate whether overall greenhouses-management under AGRO 2-1 & 2-2, could establish actual farming and handling conditions that are in compliance to basic EurepGAP requirements. Also, increas-ingly, exporters to Europe need to comply with the produc-tion standards determined by the EurepGAP certification scheme [75]. Even if these are only guidelines, importers are requiring from suppliers in developing countries, compliance with safety issues. This could be the first stage of potential changes in the operational standards for developing countries despite the fact that the cost of compliance to EurepGAP is acting as a trade barrier with many developing countries, where smallholders have no capacity to meet the EurepGAP requirements [78]. Other Prerequisites for HACCP: Good manufacturing practices (GMP) and Sanitation standard operating pro-cedures (SSOP) The concepts of GMP and SSOP are considered as support programmes that provide foundations for HACCP in an over-all food safety management program. They connect all fac-tors that assure quality, safety and effectiveness of food, ac-cording to its specification and purpose [67**, 79]. GMPs are listed in Title 21, Part 110 of the Code of Federal Regulations for plant areas like building and facilities, equipment and utensils, employee practices, pest control, production and process controls and warehousing practices [50]. Its success depends on managerial support, specialisation and motivation of personnel, provision of resources and divulging of the pro-gramme [69]. GMPs are not designed to control specific haz-ards; do not provide methods for monitoring hazards and do not require specific recordkeeping procedures; are not used to establish deviation limits and do not describe corrective ac-tion requirements [68]. SSOPs are detailed, step-by-step in-structions for cleaning any given equipment, line, room, de-partment or plant [80] to maintain the utensils free of patho-genic micro-organisms and minimise the amounts of spoilage microflora, with the goal of preventing contamination of food when in contact with these utensils and installations [69]. Standard Operating Procedures are written references used to describe a specific sequence of events necessary to perform a task and are considered the heart of any prerequisite pro-gramme [67**, 80, 81] Varsakas and Arvanitoyannis [68**] revise thoroughly the prerequisites and HACCP concepts and use a preliminary Hazard Analysis to analyse and predict the occurring failure modes in a food chain system associated with a processing plant of RTE vegetables (mixed salads) concluding that the prerequisite programmes are the main difference between the two systems and the incorporation of the prerequisites in the ISO22000 made the system more flexible as a smaller number of CCPs was introduced.

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Other approaches There are other approaches to help ensure safety [8, 82]. As stated by Bertolini et al., [83], Castilho-Gorayeb et al. [84], although HACCP is quite a structured program, it generally depends on some subjective analysis when determining the CCPs. Risk analysis becomes a powerful tool here since sub-jectiveness can be reduced since it deals with the probability of occurrence (risk) of a specific hazard. Basset and McClure [85] used a qualitative risk assessment approach for the haz-ards and risks associated with fresh fruit that could be adapted to consider fresh vegetables. HACCP, GAPs and GMPs are recommended for assuring the safety of fresh pro-duce, but the authors consider that applying a risk assessment approach prior to them, can provide manufacturers with some insight into effective management options. Conclusions This review concluded that more than ever, the fresh-cut in-dustry requires building safety and confidence in order to face the challenges posed by the nature of produce and the conditions associated with growing, harvesting, handling and transporting of fruits and vegetables that go to fresh-cut op-erations in which no lethal treatments are applied. The fresh-cut produce industry is being demanded to implement HACCP and promote a farm-to-fork orientation. However, processors should consider that HACCP for the fresh-cut industry must be constructed around an integrated approach in which HACCP is the last stage of a quality assurance sys-tem. Discussion continues over the issue of mixing safety and quality aspects and the use of safety tools different from HACCP. References Papers of interest have been highlighted as: *Marginal importance **Essential reading 1 U.S. Food and Drug Administration (USFDA). 2006: Nationwide E. Coli

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