HACCP System Implementation in Food Businesses

HACCP is no longer simply “another set of documents” for food businesses.

It is a preventive food safety management system designed to identify, assess and control food safety hazards before they become a problem for consumers.

In Georgia, food business operators subject to the relevant requirements are required to implement food safety procedures based on HACCP principles. The National Food Agency has progressively extended the HACCP requirement across different categories of food businesses, and since June 1, 2023, the requirement has applied to food-producing business operators covered by the relevant regulations.

But the most important question should not simply be:

“Do we have a HACCP document?”

The more important questions are:

Is the system actually working?

Does the staff know how to implement it?

Are food safety hazards being controlled every day?

Are deviations investigated and corrected?

And most importantly:

Are we continuously improving the system?

A HACCP system should not exist only for an inspection or audit.

It should be part of the way the business operates every day.

1. Why Do We Need HACCP and What Is Its Purpose?

The primary purpose of HACCP is not to pass an audit.

It is to prevent and control food safety hazards.

Food can be affected by three main categories of hazards:

Biological hazards — such as Salmonella, Listeria monocytogenes, E. coli and other pathogenic microorganisms.

Chemical hazards — such as allergens, cleaning and disinfecting chemical residues, pesticides, toxins and other chemical contaminants.

Physical hazards — such as glass, metal, plastic, stones, bones and other foreign materials.

HACCP requires the business to analyse its processes and determine:

Where can a hazard occur?

How can it be prevented or controlled?

At which stage is control essential?

This is why HACCP is fundamentally a risk-based preventive system.

The Georgian food safety framework also requires HACCP-based procedures to address elements such as hazard identification, determination of critical control points, critical limits, monitoring, verification and record keeping.

However, there is one important principle:

HACCP cannot replace good hygiene and manufacturing practices.

HACCP should be built on appropriate prerequisite programmes such as:

• GMP;
• GHP;
• cleaning and sanitation;
• pest control;
• personnel hygiene;
• water control;
• waste management;
• equipment maintenance;
• calibration;
• supplier control;
• traceability;
• allergen management.

The National Food Agency specifically explains that HACCP implementation should follow the establishment of appropriate prerequisite programmes, including GMP and GHP.

In simple terms:

GMP and GHP create the foundation.

HACCP uses that foundation to control significant food safety hazards.

2. How Should a HACCP System Be Implemented?

HACCP implementation should not start with creating several forms and putting them into a folder.

The first step should be to understand the current situation.

You need to know where the business is today and what needs to be improved.

The business should assess areas such as:

• facility infrastructure;
• zoning and product flow;
• personnel hygiene;
• raw material receiving;
• storage conditions;
• temperature control;
• cleaning and sanitation;
• pest management;
• water control;
• waste management;
• equipment condition;
• calibration;
• employee training;
• traceability;
• allergen management;
• supplier control.

The result should be a clear gap assessment:

What do we have?

What are we missing?

What needs to be corrected before HACCP can operate effectively?

3. What Happens After HACCP Is Implemented?

This is where one of the most important parts begins.

Creating HACCP documentation and managing a HACCP system are two different things.

In some businesses, HACCP documentation is created, placed in a cabinet and remembered only when an inspector or auditor arrives.

That is not an effective HACCP system.

HACCP needs to live within daily operations.

If the procedure states that a temperature must be checked two times per day, it must actually be checked.

If a CCP requires monitoring, the employee must understand:

• what to monitor;
• how to monitor it;
• how frequently;
• what the critical limit is;
• what to do if there is a deviation;
• where to record the result.

A record is not created simply for the sake of having a record.

For example:

08:00 — 4°C
16:00 — 4°C

may look perfect on paper.

But the organization needs confidence that these measurements were actually taken and recorded correctly.

A strong HACCP system requires reliable data.

This means controlling:

• measuring equipment;
• calibration or equipment checks;
• employee competence;
• monitoring procedures;
• record review;
• deviation management.

4. What Fines Can Apply in Georgia for Food Safety Non-Compliance?

This is one of the questions most frequently asked by food businesses.

It is important to explain the legal situation correctly:

There is not one single automatic “HACCP fine” that applies to every business simply because a HACCP document is missing.

The applicable liability depends on the specific non-compliance, its risk level and whether the business operator follows the instructions issued by the authorized authority.

The National Food Agency is responsible for food safety state control and may assess compliance with HACCP-related requirements.

Under Article 66 of Georgia’s Food Products/Animal Feed Safety, Veterinary and Plant Protection Code, when a non-compliance identified during food safety control does not pose a high risk and can be corrected without suspending a specific production process, failure to comply with an authorized person’s instruction can result in:

• GEL 200 for a business operator with small-business status;
• GEL 500 for other business operators.

If the business fails to comply within a new reasonable timeframe, the Code provides for a GEL 1,000 fine and suspension of the specific production process.

Where a non-compliance poses a high risk to human or animal life or health and cannot be adequately controlled without temporarily suspending the relevant production process, the Code provides for a GEL 1,000 fine and suspension of the specific production process until the non-compliance is corrected. A repeated violation can result in a GEL 5,000 fine, together with continued suspension until the non-compliance is remedied.

Failure to comply with an Agency instruction concerning temporary suspension of a production process, preventing food/feed from being placed on the market, and/or withdrawal and destruction of food/feed can result in a GEL 5,000 fine.

The National Food Agency also states that a business operator that is legally required to have HACCP-based food safety procedures but does not have them may be subject to measures affecting recognition, depending on the applicable requirements and circumstances.

Therefore, the better question for a food business is not:

“How much is the HACCP fine?”

It should be:

“What requirements apply to our business, what non-conformities could be identified, and how can we prevent them?”

Because the consequences may involve not only financial penalties, but also suspension of production processes or restrictions related to products on the market, depending on the nature and risk of the non-compliance.

5. How Should a HACCP System Be Maintained?

Maintaining HACCP requires a systematic approach.

1. Regular Monitoring

CCPs and other control measures must be monitored at the defined frequency.

2. Record Review

Creating a record is not enough.

A responsible person should review the records and ask:

Was there a deviation?

What happened?

What corrective action was taken?

Did the problem happen again?

3. Verification

The organization needs to demonstrate that the system continues to work.

Verification activities may include:

• internal audits;
• review of monitoring records;
• laboratory testing;
• environmental monitoring;
• calibration checks;
• observation of processes;
• employee competency assessments.

4. Corrective Action

When a deviation occurs at a CCP, simply writing “corrected” in a record is not enough.

The business should determine:

What happened?

Which product was affected or potentially affected?

What immediate action was taken?

Why did the problem happen?

How will recurrence be prevented?

This is where HACCP becomes more than a monitoring system.

It becomes a system for managing problems and preventing recurrence.

Conclusion

HACCP implementation does not end when the documentation is completed.

In reality, that is when the real work begins.

An effective HACCP system should be built on a strong foundation of GMP, GHP and prerequisite programmes, followed by proper hazard analysis, scientifically justified control measures and CCPs where appropriate, critical limits, monitoring, corrective actions, verification, records and regular system review.

In Georgia, HACCP-based food safety procedures are a legal requirement for the relevant food business operators, and the National Food Agency carries out state control of compliance.

But the main reason to implement HACCP should not be to avoid a fine.

A fine is a consequence of non-compliance.

The real purpose is:

Preventing hazards.
Protecting consumers.
Controlling processes.
Responding quickly to incidents.
Ensuring traceability.
And continuously improving the business.

A good HACCP system is not a system that looks perfect only on the day of an audit.

A good HACCP system is one that works every day — even when no auditor is there.

And the most important principle is:

HACCP is not a document created once.
HACCP is a living system that must evolve together with the business.