When you think about the food safety requirements that manufacturers must meet to stay compliant with government regulations, your thoughts may go directly to the Food Safety Modernization Act (FSMA) and the newest FDA rollouts of prevention-based mandates. You’d certainly be focusing your attention on the right concerns.
But if you apply a broader perspective in the arena of FDA, USDA and CFIA regulations, you’ll find that most of the food safety requirements your organization is obligated to fulfill are grounded in the time-tested principles of HACCP.
Ultimately, having a food safety program that’s based on the HACCP approach is fundamental to reducing risk, improving food quality and protecting profitability.
So, what does an HACCP-based food safety program look like? That’s what we’re going to explore. First, let’s review the defining principles of the Hazard Analysis and Critical Control Points system:
Principle 1: Conduct a hazard analysis.
Principle 2: Determine the critical control points (CCPs).
Principle 3: Establish critical limits.
Principle 4: Establish monitoring procedures.
Principle 5: Establish corrective actions.
Principle 6: Establish verification procedures.
Principle 7: Establish record-keeping and documentation procedures.
By actively applying these systematic steps, you are empowered to develop a food safety program that addresses the analysis and control of biological, chemical and physical hazards – from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.
In fact, doing so benefits all aspects of your operation. Addressing food safety and quality control risks within a facility helps to thwart more monumental issues down the line, like production halts, recalls and non-compliances that often result in severe reputational and profitability consequences.
Acknowledging the critical need to develop a food safety program based on HACCP is essential, but it’s just the first half of the equation. Next, you have to design and implement an effective plan for carrying out these seven principles in your company’s everyday processes. Here are some expert insights to help direct your efforts.
An HACCP-based food safety program is one that …
… identifies potential hazards that may occur in all stages of food handling.
You must develop a list of hazards that are reasonably likely to cause injury or illness if not effectively controlled. Doing so requires consideration of:
- Ingredients and raw materials
- Each step in the production process
- Product storage and distribution
- Final preparation and use by the consumer
The key to an effective analysis, which sets the stage for the entire food safety program, is thoroughness. Because if the hazard analysis is not completely comprehensive, the overall plan will not be effective regardless of how well it is followed.
It is also important to remember that hazards may evolve or change over time, based on a number of production and environmental factors. So it will be necessary to ensure that your analysis is periodically reviewed and updated to reflect:
- Emergent employee and equipment sanitation hazards
- New ingredients that may pose allergen risks
- Ineffective control measures and preventive controls
- Actual versus documented production flow processes
- Changes to compliance requirements or industry standards
… identifies the points at which these hazards can be controlled.
According to the FDA, critical control points (CCPs) are located at any step where hazards can be either prevented, eliminated or reduced to acceptable levels. Examples may include:
- Thermal processing
- Testing ingredients for chemical residues
- Product formulation control
- Testing product for metal contaminants
These and other relevant CCPs must be carefully developed and documented. Your hazards and CCPs will be unique to your facility’s layout, equipment, selection of ingredients, processes, etc., so it’s vital to approach the identification process with great vigor and attention to detail.
… monitors the control methods adequately and consistently.
Once the control points and critical limits for each potential hazard are established, they need to be monitored rigorously to identify and correct any deviations that emerge. The FDA asserts that, ideally, monitoring should be continuous:
“For example, the temperature and time for the scheduled thermal process of low-acid canned foods is recorded continuously on temperature recording charts. If the temperature falls below the scheduled temperature or the time is insufficient, as recorded on the chart, the product from the retort is retained and the disposition determined … Likewise, pH measurement may be performed continually in fluids or by testing each batch before processing. There are many ways to monitor critical limits on a continuous or batch basis and record the data on charts. Continuous monitoring is always preferred when feasible.”
In order for your food safety program’s monitoring methods to meet HACCP requirements, you’ll need to ensure that:
- All monitoring equipment is precisely calibrated for accuracy
- Monitoring responsibilities are carefully assigned
- Responsible individuals are thoroughly trained on their duties
- All associated records and documents are dated and signed by the person performing the monitoring activity
- A reliable monitoring frequency and procedure (e.g., statistically designed data collection or sampling systems) is established in the event that it is not possible to monitor a CCP on a continuous basis
… provides corrective actions when a hazard is found to be not under control.
Corrective actions are a major component of your overall food safety program. Whenever a problem implementing a preventive control is identified, it is your facility’s responsibility to correct it, reduce the likelihood the problem will recur, evaluate the affected food for safety and prevent that food from entering the market.
These corrective actions must be planned thoughtfully and documented rigorously in order to prevent foods that may be hazardous from reaching consumers. The FDA indicates that corrective actions should be developed in advance for each CCP and included in the HACCP plan. As a minimum, the HACCP plan should specify:
- What is done when a deviation occurs
- Who is responsible for implementing the corrective actions
- How a record of the actions will be developed and maintained
The responsibility for oversight of corrective actions should be assigned to individuals who have a thorough understanding of the process, product and HACCP plan, and experts can be consulted to review the information and assist in determining the disposition of any non-compliant product.
… establishes, documents and verifies detailed prerequisite programs.
To determine the validity of your HACCP plan and ensure that the system is operating accordingly, there is a need for design and verification processes that take place during the development, implementation and maintenance of an HACCP-based food safety program. This would include:
- Assembling a HACCP team of individuals with specific knowledge and expertise appropriate to the product and process
- Documenting the food description, distribution, intended use and consumers
- Developing a flow diagram describing the process and outlining the steps involved that are directly under the control of your establishment, as well as the steps in the food chain that come before and after your processing
- Verifying the flow diagram by conducting an on-site review of the operation to confirm its accuracy and completeness and to make modifications as needed
Documentation before, during and after HACCP program implementation is key. It is critical to ensure that records are created to detail every stage, and that all of the elements of your hazard analysis, written plan, testing records, verification activities and processing deviation records are stored, managed and accessed appropriately.
Given the many factors that comprise a comprehensive and fully compliant HACCP-based food safety program, it’s wise to invest in a smart, efficient software solution that streamlines all of these functions and makes record-keeping seamless.
… is reviewed consistently for adequacy and effectiveness.
You should reanalyze your food safety plan at least every 12 months. It’s wise to have a food safety team that meets on a regular basis to assess problems and implement updates. After all, if your facility is following an inadequate plan, you’re not in a good position to proactively address the food safety hazards that could lead to a devastating recall or a compliance nightmare.
… leverages tools that facilitate compliance with all seven principles.
A dynamic and thorough HACCP program is absolutely critical to minimizing your manufacturing company’s food safety risk. Yet, even in this time of unprecedented industry evolution and deepened regulatory responsibility, there are many plants that continue to miss the mark on this.
Ultimately, it is important for manufacturers to adopt a modernized system that equips your company with the controls to completely fulfill the requirements of HACCP. The range of support and value that a food safety solution can engender within your own processes is immeasurable, with capabilities that enable you to:
- Digitize documentation, archival and auditing preparation for efficiency and accuracy
- Visualize preventive control points on an intuitive floor plan
- Quickly identify locations and patterns within your HACCP-based food safety plan
- Set up automated notifications and alerts
- Systematize the scheduling of preventative controls and testing
- Easily access all sampling data, testing results and corrective action records
- Verify performance of your prerequisite plan
- Control document administration and accessibility
- Unify documentation between departments
- Develop customized and detailed workflows
- Create functional checklists for effective change management
- Make informed decisions about corrective and preventive actions
This is the key to overcoming food safety and compliance challenges that interrupt the flow of production and increase your level of risk.
As you continue looking for ways to integrate HACCP into your food safety program, protect against noncompliance and reduce food safety risks, use our ROI calculator to see how automating your program can improve your process and save money.