11 Food Safety in Malaysia: Challenges for the Next Millennium

Jinap Selamat and Zaiton Hassan

INTRODUCTION Today's world global markets and the World Trade Organization (WTO), where the agreement on the application of the Sanitary and Phytosanitary (SPS) measures and the Technical Barriers to Trade (TBT) are being acted upon, worldwide initiatives have been taken to remove internal and external trade barriers, producing a more open "food market place" by gradual elimination of non-tariff barriers; equal regulatory treatment of domestic and imported products; action such as legislative/regulatory reviews to ensure domestic regulations are consistent with tenants of trading agreements; based on sound science and risk analysis greater transparency in all aspects of food legislation and regulation; harmonization of domestic standards with international standards such as CODEX, unless higher levels of protection can be justified. Under WTO, the CODEX Alementarius Commission has gained greater recognition. The Codex standard guidelines and recommendation including HACCP and Guidelines for HACCP Application has become the benchmark for international food safety requirement. The Malaysian food industry consists of about 5,645 manufacturers and 171,710 food services such as stalls, restaurants, etc. The value is about RM16.8 billion for domestic and RM 11.4 billion for imported foods and contributed to 11.95 of the GDP. Malaysian consumers expenditure on food is about 34.9 percent of their income (Harrison, 1998).

FOOD BORNE ILLNESS Most food borne illnesses are considered as food poisoning. They are caused by harmful microorganisms present throughout the environment in soil, air, water, and in the bodies of people and animals. These microorganisms are invisible and detected only through laboratory testing. Any food can become contaminated if not properly handled before consumption. Sporadic cases of food poisoning often occurs at large social functions, school canteen, or picnics where foods may be kept or handled at conditions that allow the pathogenic bacteria to quickly multiply and can cause someone to be sick after consuming the foods. Symptoms of classical food poisoning (caused by enterotoxin 161

produced by StaPhviococcus aureus) usually appear 2 to 3 hours of ingestion although it may appear earlier or later. The victim experiences nausea followed by vomiting and abdominal cramp; diarrhea may occur. Other symptoms may include fever and chills, weakness and headache. However, different pathogens will show characteristic symptoms for specific pathogen. Fortunately, people seldom get sick from ingesting contaminated foods because most people have a healthy immune system that protects them not only from bacteria on food, but from other harmful organisms in the environment. Food borne illness in healthy adults are self limiting and short duration. However, cases of poisoning if occur especially among the vulnerable groups namely, children under the age of five, pregnant women, the elderly and persons with impaired immune system (such as people undergoing cancer therapy, people taking immunosuppressive drugs and people infected with EV virus), and may result in death or other complications. FOOD SAFETY SYSTEM HACCP The term HACCP (Hazard Analysis Critical Control Points) has caused apprehension to many food industries because of the requirement in HACCP. It is a process control system that identifies where hazards might occur in the food production process and puts into stringent actions to prevent hazard from occurring. HACCP is an effective food safety tool. It is a systematic approach to ensure product safety by implementing preventive measures to manage the hazards associated with foods. It is a system which have been recognized internationally and required under Codex Alimentarius. HACCP application consists of a logical sequence of twelve steps encompassing seven basic principles. The seven principles of a HACCP system are (1) Conduct a hazard analysis, (2) Identify the critical control points, (3) Establish critical limits, (4) Establish CCP monitoring requirements, (5) Establish corrective actions, (6) Establish effective-record procedures, (6) Establishing procedures for verifying. HACCP enables defects which have an impact on food safety to be readily detected and corrected at specific points (critical control point, CCP) during receiving of ingredients, handling, processing, storage and distribution of foods, instead of relying on end product inspection and testing. HACCP have been proven effective in managing food safety because it focuses on real hazards and its management, it needs less inspection and relies more on preventive steps, it conforms with requirements of importing countries, it increases customer confidence with the products. At present HACCP is mandatory for those companies exporting fisheries and products to EU and the USA. In the countries, HACCP is still voluntary.

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Good Manufacturing Practices (GMP)/Good Handling Practices (GHP) GMP and GHP contain basic requirements in any food safety program and it is the prerequisites of HACCP. It encompasses premises, cleaning and sanitation, food hygiene, preventive maintenance, personnel training, waste disposal, pesticides control programs. The companies, which have either GMP or GHP in place, would be able to adopt HACCP faster and having higher rate of success.

GOVERNMENT AGENCIES AND FOOD SAFETY There are three main government agencies involved in food safety enforcement, i.e. Ministry of Health, Veterinary Department and Fishery Department. SIRIM is involved in the preparation of Malaysian Standard for HACCP implementation, which have been circulated for public comment. Currently Malaysian government is looking for its own legislation and the legislation of its major market. Food safety in Malaysia is governed by Food Act 1983 and Food Regulation 1985. Food Hygiene Act once approved would elevate the importance and the status food safety system in Malaysian food industries (from voluntary to mandatory). Malaysia is also participating in the preparation and elaboration of international code of practices and standards in various international committees such as those of Codex Alimentarius Commission (CAC). The Codex Committee on Food Hygiene formulated a Code of Practice General Principles of Food Hygiene that provides Good Manufacturing Practices (GMP) for food hygiene and a HACCP system to ensure food safety. As far as food safety in concern, Ministry of Health has been given the mandate to coordinate the HACCP verification and the certification program for foods exported to EU countries and fisheries products to USA in 1998. MOH is currently doing the HACCP surveillance audit for food products. It also conducts Food Hygiene courses for food operators under their training program. Ministry of Health in its effort to lead and harmonize the HACCP implementation has established National HACCP Certification Scheme in collaboration with other relevant government agencies, SIRIM, MARDI and academia. The scheme involves three stages, a) food industry must establish HACCP program following the Malaysian Standards by SIRIM. Once they are ready they would send an application for certification from MOH; b) the HACCP system is then assessed by the independent assessors through compliance audit and a follow-up audit to check the corrective actions c) surveillance audit is then carried out by the government agency. Presently, there is no single government authority that is responsible for the quality and safety control of fish and fish products. The roles are fragmented to various agencies namely Department of Fisheries (DOF), LKIM, MARDI, Ministry of Health and SIRIM. Each has different roles to play, but no one agency is responsible for coordinating (Hamdan and Balachandran, 1992). DOF has been given the task of developing a quality

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control system for its raw matefial marine fisheries and aquaculture products by incorporating HACCP to assure control of food safety (DOF, 1999). DOF is also conducting extenuation programs in their effort to provide information related to HACCP, GMP, GHP, hygiene and sanitation and other food safety related subjects to the various levels of personnel from the industry and the fishermen. Among the programs are awareness programs in Hygiene and Sanitation, HACCP and also HACCP Competencies Course and Fish Handling Training program (DOF, 1999). The Department of Veterinary Services (DVS) is the leading agency responsible for the development of livestock sector in the country and is also responsible for ensuring food safety and quality of livestock products such as meat, poultry, milk and associated products for public consumption (DVS, 1995). The Food Safety Program of the DVS is aimed at controlling microbiological and other contaminants associated with foods of animal origins, from production to slaughter / processing. The program encompasses both preharvest control - for both commercial farms and smallholders, post-harvest control in production and disease control and post-harvest control - quality control at the slaughter house/processing plants by inspecting and monitoring and testing of contaminants and residues. In the late 1980's DVS has introduced Quality Assurance Programs (QAPs) to encourage farmers to participate in food safety program. The Plant Accreditation Scheme was introduced since 1988 to improve the products standard. The Veterinary Health Mark, VIIM logo is given to the plants, which have been accredited by DVS (as of June 1999, 5S plants have been accredited). HACCP requirement has been included in the accreditation scheme since it was launched by the department. DVS is also monitoring the hygiene and safety of the products through their laboratory (Veterinary Public Health Laboratory, VPHL) and branches. National Residue Program was implemented to conduct sampling and testing of antibiotic residues (milk), organochlorine pesticides (cattle, pig and poultry) and veterinary drug residues such as tetracyclines, chloramphenicol, nitrofuurans, sulphonamides, macrolides, Beta-lactams, aminoglycosides, aflatoxin M1 and beta-agonist. In 1992 the Department launched Quality Association Program for the producers, wholesalers, retailers and consumers. DVS have also launched the blue print of HACCP to ensure meat and dairy products are safe for consumption.

FOOD SAFETY CONCERN Public health concerns pertaining to food safety centers around chemical residues, antibiotic resistance and emerging pathogens. A number of food safety issues received attention worldwide, for example, the recent scare of cancer-causing dioxin contamination of animal feed from Belgium, E. coli 0157:H7 outbreak with beef burgers in pacific northwest America in 1993 of which the outbreak had otherwise normal children dying or becoming permanently disabled, and Listeriosis which can cause miscarraige and even death. The cost of food borne illness is tremendous which include

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in loss of productivity, cost of hospitalization, long term disability and even death. Earlier on people only knew that food poisoning or food spoilage was caused by germs. As knowledge progressed people began to identify specific organisms that cause the problems. With the advancement of science more sophisticated tools and techniques are developed which enable us to identify with good accuracy causative organisms that were not recognized 20 years ago. Currently, there is great concern of food poisoning caused by Escherichia coli 0157:H7, Salmonella enteritidis, Listeria monocetoaenes and CamPylobacter jejuni worldwide. Others of equal importance are pathogens Vibrio vulnificus, Yersinia enterocolitica, Clostridium perfringens and StaPhviococcus aureus. Some of these patlhogens grow inside the intestinal tract and irritate the lining of intestines, while others produce toxins in the foods. Microorganisms continue to adapt and evolve and therefore, increase their degree of virulence. These pathogens found new modes of transmission i.e. not just from raw meat but from other sources. For example, Saimonella enteritidis was found to contaminate outside the eggs, but now it is found inside many eggs, making uncooked eggs no longer safe. An analysis on S. enteridis outbreaks reported to Center for Disease Control (CDC) investigators between 1985 to 1989 revealed that grade A shell eggs were responsible for 77.0 percent of outbreaks (Bean et al., 1990). In 1986 a large mulffstate outbreak of S. enteritidis was traced to stuffed pasta made with raw eggs and labeled "fully cooked". This outbreak affect 3.000 persons in seven states, let to the documentation that S. enteritidis was present on egg-laying farms and the outbreak was associated with shell eggs (CDC, 1996). Verocytoxin-producing Escherichia coli (VTEC) 0157:H7 has been recognized as agent of haemorrhagic colitis (HC), which can progressed to the hemolytic-uremic syndrome (HUS) or thrombotic thrombocytopenic purpura (TPP) (Griffin and Tauxe, 1991). E. coli 0157:H7 was first identified as a pathogen in 1982 in an outbreak of bloody diarrhea traced to hamburgers from a fast-food chain (Riley et al., 1983). The bacteria can survive the gentle heating of raw beef-burgers. A variety of foods have been implicated as vehicles of infection, contaminated ground beef is the most important. In 1992, an outbreak caused by apple cider showed that this organism could be transmitted through a food with a pH value less than 4.0, possibly after contact of fresh produce with manure (Besser et al., 1992). Recent multistate outbreak of Listeriosis in America (December 1998 January1999) involving hotdogs and luncheon meat, resulted in 100 illness with 21deaths (15 adults) and 6 miscarriagesistilbirth, and recalls of about 65 million pounds of the ready-to-eat meat. Molecular typing of the Listeria monocytoaenes isolate indicates a rare strain of serotype 4b (CDC, 1999). V. vulnificus is a marine organism and Biotype I is pathogenic to human while Biotype II is pathogen to eel, and has been isolated from other marine animals such as oysters and cockles (Buchrieser et al., 1995; Radu et al., 1998). The bacterium may enter skin lesion and cause wound infections and often fatal. It seems that these emerging pathogens demand even greater food safety

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vigilance that what was required before. Knowledge accumulates gradually and with improved laboratory techniques (conventional and molecular characterization) these organisms are much easier to isolate and characterized and faster to confirmed the infections caused by the pathogens and the source of contamination. Growth-enhancing antibiotics are sometime added in animal diets and such antibioticusage may have selected antibiotic resistant organisms. Limited work at our laboratory showed that some of the pathogens isolated from a variety of foods are resistant to more than one antibiotic tested. The impact of the presence of such antibiotic resistant organisms comes from the fact that there are often no therapeutic agents commercially available and/or established efficacy for patients affected by such organism. Prudent use of antibiotics in animal and human medicine should be encouraged to limit antimicrobial resistance.

CHALLENGES AND STRATEGY Food supply has become global and more food is prepared and consumed away from homes. Consumers want food that is good tasting and healthy and safe for their families. Safety is the basic requirement for most people. However, zero risk of microbiologica1 hazard is not possible, and no one method will eliminate pathogens or toxins from the food chain. A combination of safety measures and processing methods is used to ascertain nutritional quality and safe foods reaching the consumers, e.g. a combination of pasteurization, aseptic packing and refrigeration. However, bacteria may survive despite aggressive controls at all processing levels, and food can become contaminated during preparation, cooking, serving, storage and distribution. Controlling food borne pathogens is a constant challenge. HACCP will be required around the globe for seafood, meat and poultry, dairy products, and other high-risk foods. Around the world including Malaysia, HACCP is being inculcated into the corporate mentality of food processing plants, slaughterhouses, restaurants, catering and food services. There is active move to apply HACCP regulations to farm levels. Implementation of the seven principles of HACCP systems will be in time, change the way food is procured, processed and distributed. HACCP certification will be a prerequisite not only for international market but also locally. Additionally, consumers can implement some of the HACCP practices in the hornet from purchase of meat from the market or grocery stores to the time they cook and serve the meal; there are many steps to take to ensure food safety. Food safety should be viewed not only from health point of view but also from economics perspective. A food industry or food selling activities that does not handle food properly can be taken to court or may result in closure of business. If Malaysia is known as a country that lags in food safety standards and enforcement, we cannot enter global market. Frequent reminders to consumer on food safety and safe food handling should be

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continuous rather that seasonal. This would enable the consumers to better select between good and spoiled foods, visually and organoleptically. Educating food safety is best carried out at all levels ranging from food operators and food handlers to the food industries, or may even start early in schools. Food safety is not the domain of regulatory agencies only, but rather a concern of all people right from consumers to the industries. The regulatory exercise is generally a non-revenue entity. As such spending budget on personnel and related activity is not given due priority. Food industries should view regulatory agencies as partners to ensure safe foods for consumers. The implementation of food safety system should be seen as a vehicle or mechanism to increase marketability of their product. Good and safe products are top priority in the market, and this can be achieved in the joint efforts of both the enforcement and the food industry. The enforcement officers should view their job as assisting rather than just to inspect, catch or punish. Similarly, the food handlers should not be defensive when dealing with enforcement. Both should complement each other towards safe foods and more viable industry. Meeting the complex challenges of preventing food borne diseases for the years to come will require a collaboration of regulatory agencies and industry to make food safe at every steps of the industrial chain of production. Food technologist and scientist should consider multiple choices of preventing certain pathogenic organisms available and apply them in the production chain, such as preventing their entry to food, by reducing the amount present, or by destroying that is present. Option may include modifying existing procedures, or processes that will reduce contamination or inhibit growth of the food borne pathogens or addition of additives to animal feeds that with make them less hospitable host of the pathogens. Food safety database information should be expanded to provide more complete information on the incidence of food borne disease by pathogen and by food. Applied research is needed to improve strategies of subtyping and surveillance to allow fast and accurate detection of hazardous organisms and their toxins. More research is needed regarding foods defined as source of large outbreaks to better develop control strategies and better barriers to contamination and microbial growth, and to understand the behavior of new pathogens in specific foods. Basic and applied research should be carried out to determine the mechanism by which pathogens contaminate our food and cause outbreaks of sporadic cases. Better understanding of food borne pathogens is the new approaches to making food safe for the coming century. The consumers should be better informed to allow them to make choices in the type of foods available to them and yet be aware of their relative risk status to food borne diseases. Zero risk of food borne is not possible, but together we can protect ourselves from them. It is clear that operating a food business without food safety system such as HACCP is unacceptable. Therefore it is logical that eventually, HACCP should be made compulsory. However, we must remember that about 86 percent of Malaysian food companies or about 5000 companies are categorized as small medium scale enterprises.

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Food service sector also needs a special attention; HACCP does not really fit in their business because their menu items and ingredients used are endless and change frequently. These companies are having many problems in adopting HACCP. The adoption of compulsory HACCP therefore should be in stages, based on the degree of risk and type of food products; for the time being, let the system be a voluntary requirement. The regulatory agencies should plan and monitor the implementation of HACCP and make necessary adjustments. They should play a role in communicating, educating, promote and assist the food industry in food safety issues. The food industry should keep abreast with the development of food safety. They should 'listen' to the consumers increasing demand for food safety. The most important things for the industry is to decide where does the company putting food safety in its policy. Food safety should be put as their highest priority, not quantity and not sales. It is important that the industry obtain the commitment from the top management to ensure the planning and the implementation stage of the food safety system run smoothly. The industry must be prepared to allocate adequate funds and resources for food safety program. The National HACCP Scheme have to be refined and implemented quickly. The differences in managing food safety policy and HACCP accreditation among government agencies: Ministry of Health, Department of Veterinary Services, Department of Agriculture and Department of Fisheries must be resolved at the top level. The responsibility and accountability of each agency should be clearly defined to prevent confusion among the industry people. This also means that the surveillance audit can be done more efficiently. The compliance audit is currently carried out only by few personnel from MARDI; with the increasing number of industries applying for HACCP certification, the country need to have an adequate pool of trained auditors. Training and education in HACCP, GMP and GHP for different category of industry staff need to be enhanced. GMP and GHP should be emphasized; it is important that they understand and implement this basic requirement before HACCP. Research in food safety especially those deal with local foods should be enhanced. Malaysia should also be sensitive and prepare to accept the harmonization of food safety standards and regulations. We should prepare ourselves for incoming challenges coming from international food safety authority to enhance HACCP such as 'risk analysis' and concept of 'equivalence' to fulfil the trade barrer requirement.

CONCLUSION HACCP is currently recognized system for managing food safety. It is the responsibility of the food producers and government authorities to take the measures necessary to supply consumers with a safe product. It is important that the measures are consistent with standards internationally recognized to facilitate trade. The participation of all parties is of prime important in order for the safety assurance system continues to be

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justified. The government agencies should work together to assist the food industries with all aspects of food safety. Their job is to educate the consumers and industries on the importance of food safety. Communicating and promotion of the need of food safety system such as HACCP to the food industry is of prime important.

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Ministry of Health. (1999). Information on National HACCP Certification Scheme. Ministry of Health Malaysia. Radu, S., Elhadi,. N., Hassan,Z., Rusul, G., Lihan, S., Fifidara, N., Yuherman, and PunNati, E. (1998). "Characterization of Vibrio vulnificus Isolated from Cockles (Anadara zranosa): Antimicrobial Resistance, Plasmid Profles and Random Amplification of Polymorhhic DNA Analysis". FEMS Microbiol. Lett, 165:139143

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