An effective, comprehensive hazard analysis that follows the guidelines but zeroes in on your facility or retail location is of the essence, because each facility is different. If potential hazards are overlooked, no amount of adherence to a food safety system will protect you. In the same vein, the severity of the hazard, not in general but in your particular case, should correlate with the amount of effort devoted to it.
2. Determine Critical Control Points (CCPs)
A CCP is a step in your process—whether it is manufacturing or food preparation—where the right procedure makes the difference between controlling a potential health hazard or failing to do so. Attention to CCPs in conducting your business reduces the risk of harm to the public. FDA guidelines illustrate a CCP decision tree useful in diagramming each CCP.
3. Establish Critical Limits
No operating conditions at every point are immutable. When your planning team has identified CCPs, the next step is to establish the range within which your process can vary at a given CCP without tipping over from a safe to an unsafe operation. These limits must be referrable to scientific factors, guidelines, regulatory standards, experts, or experimental results. When challenged, the range you have set must refer to one of these justifications. A few examples might help you to concretize the kinds of factors to consider as you establish the range of allowable variation: humidity, pH, physical dimensions, salt concentration, sensory information (visual appearance, smell), temperature, time, viscosity, or water activity.
4. Establish CCP Monitoring Procedures
Once you’ve identified the CCPs that are relevant to your business and established safe ranges within which the process may vary, the challenge become monitoring them. Continuous monitoring that is accomplished electronically is ideal. The alternative is periodic or intermittent monitoring, which is often performed manually. When you automate, you increase the accuracy, control, and visibility of the process. By monitoring a specific point in the process, you will know if the trend is toward loss of control, and you can act to remedy the problem. You also record when a deviation occurs. Employees trained to conduct monitoring have to have accountability and, for this reason, must schedule their work and documentation outcomes.
5. Establish Corrective Actions
Deviations can occur in any process, so your corrective actions must be available to implement immediately. Determine the cause of noncompliance and correct the situation so that the CCP is back under your control. At the same time, you must decide on the appropriate way to dispose of the non-compliant product, and document what you discovered and how you have managed the process. Your HACCP planning will identify the people responsible for these steps and where you will store the documentation of the steps taken.
6. Establish Verification Procedures
The HACCP process must not only perform its protective function; its performance at any given moment must be verifiable. You may verify your monitoring, but, more broadly, you will need to verify the successful operation of the HACCP system as a whole at your specific location and facility This is not only product testing, as important as that may be. It is a direct, regular review of the HACCP plan itself. Initially, the goals will be to validate the plan’s technical and scientific aspects, which can be done through scientific studies, observations on location, measurements on location, or evaluations on location.
7. Establish Record-Keeping and Documentation Procedures
The systematic approach of HACCP requires objectivity, which makes it crucial to maintain records for all aspects of the HACCP and be prepared to be audited. The FDA guidelines give this enumeration of aspects of the system to be documented: core team, assigned roles and responsibilities, description of the product, intended use and consumer, flow diagram, CCPs, hazards likely to occur, critical limits, monitoring, corrective actions, verification procedure, verification schedule, and documentation procedures.
ACCESS THE FULL VERSION OF THIS ARTICLE
To view this article and gain unlimited access to premium content on the FQ&S website, register for your FREE account. Build your profile and create a personalized experience today! Sign up is easy!
GET STARTED
Already have an account? LOGIN