Developing a HACCP Plan

The hazard analysis and critical control points (HACCP) system was established in 1959 by NASA to protect food for astronauts in space. It is a science-based systematic approach and risk assessment tool designed to identify and assess specific hazards, including chemical, microbiological, physical, and, now, often radiological hazards. Its focus is on control and prevention throughout the food production process, instead of reliance on finished product testing only.

As a result of its initial success, the process was soon adapted to include not only “space food,” but also traditional food production. Given the fact that HACCP was first developed more than 60 years ago, is this method now an outdated risk assessment tool?

Over the years, the approach to HACCP use has changed slightly. In the past, a large number of critical control points (CCPs) were often identified and defined in food facilities. Now, the tendency is to limit these CCPs and ensure that they are each continuously under control.

To conduct a HACCP assessment, the Codex Alimentarius suggests 12 steps:

1. Assemble a multidisciplinary team;
2. Describe the product;
3. Identify the indented use, including consumer groups and vulnerable groups such as infants;
4. Construct a flow diagram;
5. Perform an on-site verification of the flow diagram;
6. Conduct a hazard analysis;
7. Determine the CCPs;
8. Establish critical limits;
9. Establish a system to monitor and control the CCPs;
10. Establish corrective action for any case in which the CCP is not under control;
11. Establish a verification procedure to confirm that the system is working effectively; and
12. Establish documentation concerning all procedures and records appropriate to these steps.

Based on the questions most often asked by manufacturers, a number of these steps warrant additional consideration and clarification in the development of your HACCP plan.

How do I conduct the hazard analysis? As defined by the Codex Alimentarius, the analysis needs to be conducted by a multi-disciplinary team. The team approach is important to bring different experiences, knowledge, and backgrounds to the process. Involving a technical manager will provide different experience and areas of focus than that of a production manager. A quality manager can then include points from literature and scientific information, which are necessary in a HACCP study to demonstrate that more than just site knowledge is used to inform the process. This diverse team approach supports completion of a well-rounded analysis.

To ensure a good understanding of the basics of the HACCP philosophy, training is also key. The first group in need of training is the core HACCP team, as they will need a detailed understanding of the hazard analysis process and each step of the assessment. The next training group will be those responsible for conducting CCP controls, as they need to know why they are conducting the check and how to best do so. They will also need to know the consequences of improperly completing the check, which may lead to severe health issues for consumers. It is also crucial for this group to understand that if there is any problem or issue related to a CCP, they may need to withhold or recall products from distribution and also then work with their teams to adequately address the problem. To fully implement your HACCP plan, all production employees will need to have completed basic HACCP training so that they understand why such a risk assessment is done and the consequences if it is not properly executed.

Is it sufficient to check only for the intended use of the product? While the intended use should be the focus of your plan, unintended uses should also be taken into consideration. This does not mean that you’ll need to check every bizarre idea about the potential use or misuse of the product. You will, however, need to consider those that are likely to occur. A good example of a likely unintended use is marshmallows. These fluffy treats are not only directly consumed; they can also be heated by microwave or grill, and recipes are published regarding this use. The hazard analysis process should take this unintended use into consideration. If there could be a risk from this heating process, the formula may need to be changed or a warning will need to be published on the product label, stating that the product is not intended for heat treatment.