HACCP — What You Need To Know

By Laurel Maloy, contributing writer, Food Online

Hazard Analysis and Critical Control Points can be confusing and difficult to implement. Food Online wants to help make sense of it all

With the many food processors and manufacturers currently focused on food safety’s new and upcoming regulations, a lot of questions remain unanswered. Specifically, manufacturers and processors are asking, “What constitutes a Critical Control Point (CCP),” and, “What are the regulatory requirements for them?”

According to the FDA, and the National Advisory Committee on Microbiological Criteria for Foods (NACMCF), there are a number of steps to take in order to identify CCPs. The most important realization is that this is not a one-man-job. Depending upon the size of the company, be prepared to assemble a team to accomplish the initial hazard analysis. Once the HACCP team is established, its job will be to:

• Define the food and its distribution — Put together a complete list of food ingredients, the processing methods, and the form in which it is distributed (frozen, refrigerated etc…).
• Define the intended consumers — Who will be using the food? Is it a product primarily for infants, for children, for the elderly, for the general population, or for animals?
• Develop a flow diagram — Create a concise outline of each step involved in the processing of each item being produced. A schematic of the facility may be helpful in identifying each and every step. The simpler and clearer the schematic and chart, the better. This may also include where the raw material is acquired and may go so far as identifying the entire warehousing and distribution process.
• Verify the diagram and processes are complete and accurate — if this is being done off-site, an on-site review is highly recommended.

Now, the hazard analysis can be conducted. This critical step must be done thoroughly and correctly. The definition of hazard for HACCP is: “A biological, chemical, or physical agent that is reasonably likely to cause illness or injury in the absence of its control.” The FDA has provided a list of examples of questions to be considered when conducting the hazard analysis.

Once the hazard analysis is complete, the CCPs can be determined. A critical control point is defined by the FDA as, “a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.” The FDA suggests using a CCP Decision Tree as a way to determine the CCPs. An example of a CCP might be a point where a specified heat process and temperature would destroy a specific microbiological pathogen. The same would be true for refrigerating a precooked food item to prevent bacteria from growing.

Are you prepared to meet FSMA requirements?

Establishing critical limits is the next step. This is simply a matter of assigning a maximum or minimum value for control in order to prevent, reduce, or eliminate a food safety hazard. It is used to draw the line between safe and unsafe operating conditions at any given CCP. Scientifically-based, critical limits may be derived from regulatory standards, experts in the field, experimental results, or other scientific publications. For each CCP there is at least one criterion for food safety that must be met. For example: a reduction in E. coli O157:H7 in cooked beef patties may include a CCP of applying a thermal process to heat the inside of the patty to 155°F for a certain period of time. That may also require adding a CCP at the point where the density of the meat patties is controlled, a CCP for humidity control and a CPP for belt speed.

Finally, a process and/or schedule for monitoring each CPP must be put in place, as well as a system by which corrective actions will be taken. At a minimum, it should be decided what is to be done when a deviation occurs, who is responsible, and how the records of each corrective action are to be maintained. Verification procedures should be put in place in order to evaluate the effectiveness of the HACCP plan and to determine if changes are needed.

The primary goal of HACCP is to prevent any unsafe food product from reaching the consumer. An effective HACCP plan will require little end-product testing because sufficient CPPs and safeguards have been identified early in the process. HACCP is a prime example of Benjamin Franklin’s thinking, when he said, “An ounce of prevention is worth a pound of cure.”