The recently revised Food Sanitation Law in Japan requires sanitation control system of Hazard Analysis and Critical Control Point (HACCP) from all food related companies, according to The Gas Review.

The new law covers gases related to food products, such a carbon dioxide, nitrogen, and other gases which have direct contact with foods. Sanitation control procedures based on HACCP must be introduced to the gases during gas production and filling.

Specific procedures require documentation of sanitation control for food additive gases and recording of all processes. Capital investments may be required for filling cylinders indoors or for filling cylinders on separate lines from industrial gases, as is required for medical gases.

The new regulations will come into effect as of 2021. During the three-year waiting period concrete measures are expected to become clear. Quality control departments and food gas managers at all related companies are currently working on collecting information from HACCP seminars and governing public health centres.

HACCP analyses and controls the potential harm in steps from reception of raw materials through processing, storage, and packaging to verify the safety of the final product. A PDCA (plan-do-check-act) cycle is repeated to increase the quality of control. 

No certification for the law is required but all food and beverage related companies are required to adopt HACCP concepts or operate an HACCP system. Companies must follow ministerial ordinances and implement a sanitation control system based on HACCP following guidelines prepared by industrial bodies for every food or beverage handled.

According to the guidelines of the Japan Food Additives Association for filling gases, there are numerous sanitation producers for gas filling plants including, washing hands, organising, systemising, sweeping and more. The daily procedures must be implemented and recorded as proof that HACCP has been implemented.

Each company must establish specific activity contents, meaning concrete work details must be determined to specify factors such as how many times a procedure is carried out and at what times. For plants that handle general food products, detailed sanitation control procedures are required. 

Suitable sanitation control systems for filling stations where filling lines are often installed outdoors will also be studied. It may turn out that separation filling lines from industrial gases or changes in facilities such as filling indoor may be required in the same way as medical gas requires quality control as a medical product.

If the installation of special filling lines is required for food additives with the same control level as medical applications, some companies may withdraw due to the value of food additive gas not being as high as medical gas.

The preparation of sanitation regulations for food product equipment and container packaging part of the legal revision involves using only safety-validated materials for food product equipment and packaging. This requires the introduction of a positive list of materials for which safety can be secured. What materials will be subject to these regulations and to what degree are not currently decided.