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operations, or to promote industry-wide actions (18, 43). It may also be used during product development to design the product so as to minimize the formation of processing contaminants. 3. The results of a generic HACCP study on a product category can also be used in health education interventions. They provide guidance on the recommendations that need to be given to domestic or professional food handlers preparing food in households or in food service establishments. 7.4.1 Prerequisites to the Application of HACCP
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For the purpose of this text, the term prerequisite refers to all the measures and activities that need to be in place in order to support the application of the HACCP system, whether these are done in industry or by governments. The prerequisite activities, as expressed by the term itself, are sine qua non conditions for the successful implementation of the HACCP system and management of processing contaminants. Depending on the nature of the product and the hazards considered, prerequisite activities may entail different types of measures. For processing contaminants, the following prerequisites need to be in place: 1. Management Commitment. Raising awareness of high-level decision makers on the health signi cance and importance of processing contaminants is essential, as the outcome of the study may indicate the need for modifying the manufacturing process (formulation, equipment, etc.), with a possible impact on product quality/sensorial properties and/or on the nutritional pro le. Example: Following the concern raised by 3-MCPD formation in the acid-HVP production processes, the food industry changed the production method and moved toward an enzymatic hydrolysis process. This meant millions of dollars of investment in terms of Research and Development as well as changes in the food production facilities. 2. General Good Manufacturing Practices (GMPs). These are basically a set of rules procedures and practices that have been established as a result of previous experiences to ensure that products are safe and t for human consumption. In practice, they refer to generic control measures that apply to a given sector of the food chain, regardless of its speci c conditions (e.g., environment, ingredients, product formulation, production, and processing). However, this does not preclude the fact that these practices may also be identi ed as control measures to speci cally control a hazard in a HACCP study.
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Example: As a GMP in manufacturing confectionary products, material that has been burnt or overbaked, e.g., biscuits and wafers, should be discarded and not reworked. This measure per se can already contribute to reducing the level of 3-MCPD.
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Examples: The rotation of stocks in the warehouse and observation of the principle of rst in, rst out (FIFO) can also reduce the formation of certain processing contaminants. For instance, limiting the storage of potatoes can help to minimize the formation of acrylamide in French fries. Old our may contain higher amounts of glycerol. Limiting its storage through application of the FIFO principle can contribute to minimizing the 3-MCPD amount in bread. 3-MCPD may also be released during storage due to lipase activity. Thus, limiting the storage of certain nished products and applying the FIFO principle can also maintain 3-MCPD at low levels. It is to be noted that ISO 22000 distinguishes between the terms prerequisites and operational prerequisites. The latter refers to control measures identi ed in the HACCP studies (Principle 1 on Hazard Analysis) that are necessary for controlling as a hazard. Since in most cases, processing contaminants will not be considered as a signi cant hazard at the levels present, it is the authors understanding that control measures for processing contaminants would fall under such a de nition. In other words, measures taken at the control points (CPs) mentioned later in this text would be part of an operational prerequisite program. Due to the complexity that such terminology presents, these terms are not used in this text. ISO 22000 de nes the term prerequisite as follows [40]: Prerequisite program Basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain suitable for the production, handling, and provision of safe end products and safe food for human consumption Operational prerequisite program (Operational PRP) These are identi ed by the hazard analysis as essential in order to control the likelihood of introducing food safety hazards to and/or the contamination or proliferation of food safety hazards in the product(s) or in the processing environment
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