A HACCP overview for line employees
By: Mary Kay Folk, MS and Lynn Knipe, Ph.D.
HACCP: Plan, Control and Document safe food processing.
HACCP: Hazard Analysis and Critical Control Points
HACCP is a system for managing a process, to prevent problems by controlling defects. HACCP involves planning, controlling and documenting safe food processing. If done properly, the HACCP process documents that a company has done everything possible to produce a safe food product (also called “due diligence” in legal terms). HACCP was initially developed for NASA, through a contract with the Pillsbury Company, as a means of providing the safest food possible for space travelers.
In the U.S., HACCP is mandatory for all inspected meat processing facilities, under the Pathogen Reduction/HACCP Regulation of 1996 (also referred to as the MegaReg), as a means to improve the safety of meat products, while shifting the responsibility for safe meat products to the industry. While HACCP is not required it is recommended for other food processing, even some restaurants have implemented HACCP programs.
The Seven Principles of HACCP
1. Conduct hazard analysis
2. Identify the critical control points (CCP)
3. Establish the critical limits(CL)
4. Establish the CCP monitoring requirements
5. Establish corrective actions
6. Establish verification procedures
7. Establish effective recordkeeping procedures
Physical: metal shavings, glass, wood, bone, pens, flashlights, clipboards anything that a consumer could break a tooth, get cut, or choke on if bitten into or swallowed.
Chemical: cleaning supplies; not food grade lubricants; allergens like peanuts, milk, or soy; restricted ingredients (nitrate or nitrite).
Biological: mold, yeasts, viruses, and bacteria such as Salmonella (mainly on pork and chicken), Escherichia coli (E.coli) O157:H7 (mainly on beef); Listeria monocytogenes (L. mono) (mainly on cooked products, especially those that are Ready-to-eat)
Hazards can cause a person to become sick, permanently injured, or in some cases cause death. Though all three hazards are important, the most emphasis is placed on biological hazards.
Good Manufacturing Procedures (GMP): Not required to be written, and not a justification for unlikely hazards, but if GMP are written, easier to teach to new employees, and records kept can be an additional source of documentation to justify unlikely hazards.
Some examples of GMPs are store cleaning supplies in different areas than dry ingredients, using nitrite premix instead of pure nitrite, require employees to wash hands, and wear gloves and hair nets (this is a requirement, however monitoring this could be a GMP).
Sanitation Standard Operating Procedures (SSOP): Required for inspection. Cannot have clean product if equipment and processing areas are not sanitary. Must keep accurate records to show what has been done, and that it has been done correctly. This includes corrective actions. Inspectors expect that there will be mistakes, but records must show that the problem was found, and fixed. This record keeping must be signed by the person responsible.
- SSOP includes: 1) equipment disassembly, 2) reassembly after cleaning, 3) acceptable cleaning chemicals and techniques, and 4) application of sanitizers
- SSOP Corrective Actions include: 1) restore sanitary condition 2) prevent reoccurrence of direct product contamination and 3) properly dispose of affected product.
HACCP Plan: Required as part of inspection. Includes a) a flow chart of the path that a product takes through the plant, b) an analysis of where and to which hazards the product may be exposed, c) steps that must be monitored to prevent that exposure, d) methods to measure and e) limits at those steps, f) procedures for recording and g) ensuring the accuracy of those measurements and h) plans for when the measurements exceed the limits. The HACCP plan also includes scientific information to justify the placement of CCP and the CL. This plan must be evaluated each year and updated if necessary. The plan may need to be updated more frequently due to circumstances such as a new product line, new equipment, unforeseen hazards, or repeated noncompliance.
Control and Document:
A critical control point is the last step that control can (or is needed to) prevent, reduce or eliminate a hazard.
Critical limits are levels that must be met for each CCP.
- A method of measurement must be established (monitoring).
What to measure
When to measure
What instrument to use to measure
AND Where and How it is recorded.
The monitoring record should include:
- the accurate measurement
- time of measurement
- lot or batch that was measured
- instrument that was used (if applicable)
- identification of the person that took the measurement
(initials are commonly used)
Unless a record is written you cannot prove it has taken place. The written record is very important; it should be done immediately when the measurement is taken. The record should be in an orderly fashion, note should be made when something is out of sequence, at the end of production, etc.
The measurement must be done and recorded as accurately as possible, even if it does not meet the critical limit. Again, inspectors expect that there will be mistakes, but records must show that the problem was found, and fixed.
Along with recording the measurements just as important is reporting a deviation. Even if a CL is met, sometimes there are warning signs that the CL might not be met in the near future. A piece of equipment doesn’t work right, doesn’t sound like it normally does, or the product doesn’t look like it should are all examples of things that might be a warning that something could be about to go wrong. There should be a procedure for the monitor to report both deviations from the Critical limit or issues that could lead to unmet CLs.
If the CL is not met (deviation) the product may contain a hazard (adulterated). If the product is adulterated or there is question if hazards are present in the product it cannot be shipped until it is proven that the hazard does not exist.
The hazards are mentioned above. Detectors, if available, can be used to find physical hazards in the product. Once a problem arises, seldom can either physical or chemical hazards be removed and the product salvaged. Biological hazards are slightly different in that many of the hazards are present, and procedures are in place to remove them from the product. Critical limits are set according to scientific information based on the characteristics of the product. In all cases, it is extremely important to follow the procedures laid out in the HACCP plan. The HACCP plan is not a suggestion to what could be done or should be done; it is a detailed plan of what must be done.
If the CL is not met, corrective action must be taken.
- Corrective actions are needed to: 1) identify the cause of the deviation 2) bring the CCP back under control (meet the CL consistently) 3) take measures to prevent the deviation from reoccurring 4) ensure no adulterated product is shipped.
There are also unforeseen hazards, times when a product may become adulterated from causes that were not expected. Corrective action is needed the same as when a deviation from the CL as listed above, with the exception of number 2, there is no CCP to bring under control, however this event triggers a reassessment of the HACCP plan and may bring about a CCP at the point the unforeseen hazard occurred.
§ Corrective actions include: 1) determine how much product and how it is adulterated. Separate the affected product away from other products and ensure that it is on hold (cannot be shipped or mistaken for unaffected product) 2) fix the cause of the hazard and prevent reoccurrence (this is not always possible when the hazard was unforeseen) 3) Maintain records of the corrective action and reassess the HACCP plan.
Verification is also important part control and documentation of the HACCP plan.
· Reviewing the records generated by the monitors
· Directly watch the monitor take the measurement
· Calibration of the monitoring equipment.
These steps ensure that the monitor is correctly measuring and recording, and that the equipment being used is accurate.
Consider the process of driving on the highway an illustration of the concept. In doing a hazard analysis, it is determined that the accelerating process (after you put a vehicle in gear) is a point where a hazard is most likely to occur (Principle #1).
That would also be identified as a critical control point, the last place the process can be controlled to prevent the hazard from occurring (Principle #2).
The critical limits of Principle 3 would be the speed limit that you may drive. Exceeding these limits would make this driving process out of control and cause a ‘deviation.’
Once the critical limit is established, the monitoring requirements must be identified(Principle #4). In this driving example, you could either monitor your own speed, have a passenger monitor it for you, etc., plus you would need to determine how frequently you would monitor your speed.
For Principle #5, you would need to be prepared to take corrective action, in the event that you exceeded your critical limit (speed limit), and it is important to establish what you would do to prevent this deviation from occurring again.
Principle 6, Verification procedures evaluate how well your monitoring system is working. Just remember that your highway patrolman (or your inspector) will be verifying your monitoring process as well.
Establishing effective record-keeping procedures (Principle 7) would involve the method that you would use to keep track of your speed checks, your deviations, the corrective actions taken, etc.
In this example, it is not guaranteed that an accident will not happen, just as HACCP does not guarantee safe food products. It is a framework to ensure the process makes the product as safe as possible. Driving below the speed limit increases the ability of the driver to avoid accidents, maintaining critical limits in processing increases the ability of a meat processor to avoid contamination from a hazard.