Developing a HACCP Plan

How do I identify a CCP? The determination of CCPs can be done with the help of a decision tree. This process will guide the HACCP team through a series of questions to help define whether the step is a CCP or not and whether there is a further process step that can prevent, eliminate, or reduce the risk to an acceptable level. This important question helps focus the process on the critical production steps.

Are there rules for the monitoring of CCPs? For the monitoring and control system, a continuous control is often requested. This could involve a process such as permanent temperature control, including pasteurisation and sterilisation. However, controls such as strainers can also be regarded as permanently controlled units if they are checked prior to production and are also in good condition after the production run. This means that, throughout the duration of the production shift, the strainer was in place and all product was properly strained. However, to properly manage it as a CCP, the controls of that strainer need to be completed during the shift, before the product is released, and while it is still the responsibility of the facility. If the product is released automatically 24 hours after production, but the strainer is only checked at the end of the week, it is not an adequate and allowed control of a CCP. In this case, it would be required for the strainer to be checked following each shift, or daily, before the product is released.

Do corrective actions need to be predefined? Prior to any incident, it is mandatory for the HACCP team to clearly define the corrective actions that would be taken in case of a non-compliant CCP. The team will need to discuss and define the possibilities for either the retreatment or destruction of the product in question. For example, milk that isn’t properly pasteurized could be sent back through the process to be pasteurized again, but only after the equipment is cleaned and working properly. Other products, such as one that passes through a free-fall metal detector and is packed in a metallized packaging material and cannot be unpacked and repacked again, will have to be destroyed, as there is no retreatment possible for that product. In a case where a rework is possible and not too costly, the control frequency of the metal detector should be much more frequent, as it should ultimately save product and resources. The advantage of defining these corrective actions prior to an incident is that it can be done in a calm environment, rather than the “panic” mode of an incident or crisis situation. Making senior management aware of this process will gain their support for the consequences of a failed CCP and the defined corrective actions.

What do the verification procedures include? The first verification check is the responsibility of a supervisor or other trained and identified individual or individuals on the team. These controls need to be completed as defined in the HACCP plan. This includes verification by set timelines, whether hourly, by shift, or otherwise as predetermined in your plan. The next level of verification is the control that the calibration of the equipment used is done in the defined frequency, such as the temperature probe calibration for a pasteurizer or the proper calibration of test probes for the metal detector.

The last level of verification/validation is the analysis of complaints that should have been eliminated by the defined CCP controls. For example, if the company has defined 2.5 mm as the critical limit for the metal detector check and there are no metal complaints larger than 2.5 mm, that means the system is working properly. However, if there are several complaints of metal parts between 1.0 and 2.5 mm, the HACCP team should further analyze whether the critical limit of 2.5 mm is an adequate limit to control the risk. For many companies, this verification/validation step is completed, but not necessarily to the required level to control the risk. This step is crucial to finish the cycle of the risk assessment and adequately define further control steps or other limits as needed.