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Food Standards Scotland & Food Standards Agency Seeks Views on Guidance

Food Standards Scotland and Food Standards Agency are seeking your views on the European Commission’s proposal to overhaul the Guidance document on the implementation of procedures based on the HACCP principles. The Commission are reviewing the current guidance and are seeking comments on the content and structure of the document. To help coordinate the UK’s response to the Commission, FSS and FSA have put together some specific questions below for your consideration. We would be grateful for your views, particularly on the approach, content, and any supporting examples would be appreciated.

We would be grateful if you could provide your comments by the 28 August 2015 to the questions below, responding by email to;

 HACCP principles

1. Do you think the HACCP principles as interpreted in the guidance document are straightforward to follow? What areas present difficulties, particularly for Small Medium Enterprise (SMEs)?

2. Is HACCP the best approach for SMEs to ensuring food is produced safely? If not, what other approaches should be considered and when?

Pre-requisite programmes (PRP)

3. When, if ever, are PRPs sufficient on their own to manage food safety? Can you provide examples?


4. What areas (within HACCP and PRPs) represent a disproportionate burden on businesses? How could the burden be lessened while still ensuring food safety?

5. Can you provide examples of flexibilities applied in your business/sector?

6. Should flexibility limited to SMEs?


7. Can you provide examples of how the use of guides to good practice has helped your business/sector control hazards and/or demonstrate compliance?

8. Any other comments?