When was your HACCP plan last updated because the risk environment changed, rather than simply because its annual review date arrived?
The Ministry for Primary Industries (MPI) Food Safety Insights: Emerging Risks and Current Issues bulletin highlights the importance of monitoring international incidents, recalls and newly recognised hazards that may affect New Zealand food businesses.
A current example is Cereulide, a potent toxin produced by certain strains of Bacillus cereus. Cereulide was associated with international infant-nutrition recalls in early 2026, including a precautionary recall in New Zealand. Unlike the vegetative bacterium, the toxin is resistant to heat, meaning that a standard thermal process may not remove Cereulide once it has already formed.
This raises important HACCP questions:
- Are emerging toxins considered in your hazard analysis?
- Could the hazard enter through a minor ingredient or an overseas supplier?
- Does supplier testing address the actual hazard, or only general microbial counts?
- Does process validation consider spores and preformed toxins – not just vegetative cells?
- Would your traceability system identify every product containing an affected ingredient?
The incident also demonstrates why businesses should not rely exclusively on finished-product testing.
HACCP verification should use a combination of:
- Supplier assurance and ingredient-risk assessments;
- Environmental and product monitoring;
- Regulatory alerts and international recall information;
- Complaince and non-conformance trends;
- Targeted surveillance testing; and
- Documented reassessment when new information becomes available.
The MPI 2024–2025 Food Residues Survey Programme provides another example. The programme collected 300 plant-based food samples and tested them for more than 500 agricultural chemical compounds. MPI assessed the non-compliant findings and determined that they did not present a food-safety risk.
The lesson is not that every emerging issue must become a Critical Control Point (CCP).
The lesson is that every credible new hazard or surveillance finding should be assessed for relevance to your:
Ingredients → Suppliers → Process → Product → Consumers → Markets
Your HACCP plan should be a living risk-management system – not a document reviewed once a year and returned to the shelf.
Produco can assist with:
- Emerging-risk and regulatory horizon reviews
- HACCP reassessment and hazard-analysis workshops
- Supplier and raw-material risk reviews
- Monitoring and surveillance-testing plans
- Validation and verification reviews and
- Mock incident and traceability exercises.
Is your HACCP system designed to identify tomorrow’s hazard— or only manage yesterdays risks?