The national food safety standards create universal requirements that food businesses need to follow to ensure food sold in Tajikistan is safe to eat (see Food Safety Law No. 890 from August 1, 2012).
The current food inspection program is based on a “see, smell and touch” approach that relies more on detection of potential hazards once they are present in food, than on the prevention of food-borne pathogens. In spite of the adoption of new WTO compliant law on food safety (Law No. 890 from August 1, 2012), Tajikistan continues to use food safety regulations inherited from the Soviet Union. The main reason for the failure to implement the provisions of the Food Safety Law is that implementation requires infrastructure investments which are not affordable for the Government now. However, there are number of donor organizations, including ITC, who could be asked to support Tajikistan Government’s efforts on implementation of new Law’s provisions as well as contribute on improving food safety infrastructure.
When countries maintain different food safety regulations when compared to their trading partners, the result is that foreign food producers must spend extra money and time seeking compliance with the domestic regulations. In addition, domestic food producers who wish to export to neighboring countries must conform with multiple regulatory standards. The best way to alleviate these added costs and the associated delays associated, is for countries to adopt a universal and international standard for food safety regulation.
One of the most effective food safety systems is the Hazard Analysis Critical Control Point system (HACCP). The HACCP is a process control system that identifies where hazards might occur in the food production process and puts into place stringent actions to take to prevent those identified hazards from occurring. By strictly monitoring and controlling each step of the process, there is less chance for hazards to occur, and thus less need to inspect every food product as they circulate throughout the economy.
HACCP is a preventive system and assures food safety as close to 100%. The system was developed as an alternative to traditional control systems such as finished product analysis and process controls. Various studies have shown that implementation of the system leads to a decrease in food borne diseases. (Giese, 1998).
HACCP is important because it prioritizes the prevention of potential hazards in food production. By preventing major food risks, such as microbiological, chemical and physical contaminants, the industry can better assure consumers that its products are as safe as good science and technology allows. Moreover, public health policy is strengthened through a proactive foodborne hazards prevention system as opposed to a reactive, inspect and treat system.
HACCP is based on seven basic principles (Pennington, 2000):
- Conduct a hazard analysis
- Determine critical control points
- Establish critical limits
- Establish monitoring limits
- Establish corrective actions
- Establish verification procedures
- Establish effective record keeping procedures
The use of HACCP is not a new concept. Its use dates back to the 1960s and the U.S. Space Program where the Pillsbury Company used HACCP to ensure that astronauts had safe and high quality food. (see HACCP website).
It is worth to mention that Tajikistan in the frame of food safety system reform also recognizes worldwide best practices on ensuring food safety and making Tajikistan origin products competitive.
So, how to prepare for certification?
In order to get certified there is list of requirements need to be completed. The certification process can be completed by either the company itself or by an outsourced company. Today, there are several companies in Tajikistan providing consultancy services for the implementation of HACCP: Public consulting organization “Center for Quality Management”, Group “Kamolot 1”, LLC «ISD Consulting», “Grant Thornton”, “Kharif” LTD.
How to get certified?
The certification process consists of the following stages:
1) Submission of the Application: For obtaining HACCP certification businesses must submit an application to either international certification bodies as SGS, TUV, Veritas, etc or to the national certification body, “Quality Management” with the Agency “Tajikstandard.”
2) Preparatory Work: Since the certifying body is not allowed (due of conflict of interest) to conduct preparation work the company can either itself, if there is a potential or outsource it to an approved third party.
3) The Preliminary Audit: The preliminary audit is a form of practical exercise before the main audit. Usually this is conducted by outsourced certifying company – Agency Tajikstandard does not conduct the preliminary audit. The main purpose of the preliminary audit is to identify omissions and eliminate them prior to conducting the main Audit.
4) The Audit: The lead auditor conducts the audit. If the audit uncovers critical nonconformities, the applicant company will be given time to improve the discrepancies. But if the auditor is satisfied with the result of inspection then the auditor will request the certification body to provide the company with a certificate numbered by unique number and for specified time period.
5) The Certificate: Although each certifying authority chooses its own methodology and steps for certification, the main principles must still be followed. It is also worth mentioning that if the company applies for HACCP certification the first time the company will be certified only for one year period. Only applications submitted for obtaining re-certifications can be considered for a longer period. However, even if the company has obtained a long-term certificate, it will still need to schedule annual compliance inspections.
Implementation of HACCP is impossible without introducing prerequisite programs (PRP). Appropriate PRP condition is a vital element for the successful implementation of HACCP. In addition to those systems which refer to the practice of Good Manufacturing (GMP), PRP may include consideration of the following:
- Construction and layout of the buildings
- Proper planning of premises and working areas
- Infrastructure for air circulation, water and electricity supply
- Waste disposal
- Suitability, cleaning and maintenance of used equipment
- Procurement management
- Measures to prevent cross-pollution
- Cleaning and Sanitizing
- Staff hygiene and equipment’s sanitary condition
- Products subject to processing
- Procedures related to withdrawing of products from the production
- Product information and consumer awareness
- Protection of products, bio-guard and bioterrorism
Prerequisite programs are not part of the official HACCP system, however they are considered part of the inspection and certification process overseen by the main Auditor. The modifications are carried out within the enterprise and do not require any specific process mandated by the HACCP system.
Cost and resources required
It is necessary to understand that implementing HACCP analysis will require an upfront commitment both in the form of cost and time. Generally speaking, the approximate cost to implement HACCP can vary from 3000 to 8000 euros, and can take from 10 to 24 months depending on the size of the company and number of employees. (Information provided by “the Center for Quality Management) However, it is also important to realize that the benefits for implementing the HACCP are spread out among all consumers in Tajikistan and will continue to accrue for as long as such programs are effectively operated. It is also important to realize that by adopting a more international standard for food safety, Tajik exporters will face fewers barriers when exporting food products to other countries.
In July, “Quality Managemen Centert” or “QMC” opened independent laboratory facilities that perform food product analysis. CQM expects that its facilities will be accredited by both international and local accreditation bodies soon. QMC is already proving its worth and capacity, and such companies like: LLC ”Obi Zulol”, LLC “Oro Isfara”, LLC “Tadzhfrukt”, LLC “Barakat Isfara”, LLC “Isfara Food”, LLC “Porsoi Khujand” (Faizi Rasul), LLC “Dusty Alisher”, LLC “Mahmoud” (Javoni), LLC “Dilpisand”, LLC “Yakhmosi 33”, LLC “Obi Shirin”, LLC “Shohshir” are among of CQM’s growing client base, and should be seen as leaders in the industry for putting forth efforts to make their products safer and of higher quality. For additional information on HACCP certification in Tajikistan please visit the Center’s website at: www.qmc.tj
The International Trade Center is thankful for “Quality Management Center” who assisted ITC in developing this Brief, in particular on obtaining information regarding the HACCP implementation in Tajikistan.