HACCP — The Elephant In The Room (Part Three of Three)
By Laurel Maloy, contributing writer, Food Online
The final three principals of HACCP will bind the entire process into a constructive, efficient, food-safety process
The primary goal of Hazard Analysis and Critical Control Points (HACCP) theory is to identify potentially injurious or adulterated product before it leaves the plant. The hardest part is designing the best HACCP plan for a particular processing facility. Once that’s done, the rest is just a simple matter of working the plan the way it was designed. Yes, it is time-consuming, and, in some instances, it may be expensive to conceive and to execute. The end result, however, can enhance or redeem your brand, reduce recall occurrences, and increase production — all of which directly impact your bottom line.
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The steps discussed so far have included: conducting an analysis of the potential hazards, identifying each Critical Control Point (CPP), and establishing the Critical Limits (CL) for each CPP. Additionally, the CPP-monitoring requirements have been established. The final three elements — Determine Appropriate Corrective Actions, Establish Record Keeping Procedures, and Ascertain Validation and Verification Procedures — for completing your company’s HACCP plan are designed to ensure the plan works.
Determining appropriate corrective actions is the part of HACCP that involves proactive thinking in order to more quickly respond to any deviation from one of the limits established for a CPP. This is the part of the plan that enables certain responsible parties to immediately implement a corrective action quickly and efficiently. The first aspect of this part of the plan will be communication. Many police departments and airports, in this age of uncertainty and terrorism, are encouraging the public, “If you see something, say something.” Encourage the same of every person in your company. Instill a sense of responsibility to the company and to the public. Determine the corrective action to be taken for each and every possible deviation. Draft the document, which is required by law, but also train your employees. If it helps to offer an incentive for the training, do so. The value of a well-trained employee in a crisis situation is invaluable; a processing error that can possibly cause injury, illness, or death is considered a crisis.
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Not only is the establishment of recordkeeping procedures a federal mandate, it can be a way to govern your facility’s success. In the event of a recall or inspection violation, various governmental agencies may request documentation outlining the actions taken. Be thorough and be transparent. The purpose of the recordkeeping is to be able to identify each step, or misstep, that leads to a particular incident. The government will not tell you how to keep records, but know that if they are inadequate, you will hear about it. Each processing facility will be different, but basically, your records should include:
- Date
- Time
- The CPP — inspection or testing schedule for each CPP and the responsible party
CL for each CPP
- Deviation from the CL, be exact
- Chain of Command Notification
- Corrective Action(s) Implemented
- FSIS or FDA persona notified, the date, and the time
- Resolution
- Comments/Recommendations
Utilize this document to perfect procedures as gaps or inadequacies are identified. This is your after action report and a way to measure the success of an HACCP plan.
Finally, each plant will be required to validate and verify the HACCP plan is doing what it is intended to do: identify potentially injurious or adulterated product before it leaves the plant. Verification procedures may include periodic review of the HACCP plan, especially in light of a change in processing procedures. CLs may require review as new, scientific evidence is presented. New and improved testing procedures may become a part of your verification process. FSIS will perform verification testing, but is also requiring each facility to perform its own tests.
The best validation will be an absence of food-safety violation reports, incidents, or recalls. However, internal validation, by way of testing the procedures implemented in your HACCP plan, is essential. FSIS will require all facilities to validate its own HACCP plan, but may review the plan for conformance. In the event of a violation or recall, you can expect your HACCP plan to be scrutinized even more closely; that is what it is devised to prevent.