If you are developing a HACCP (Hazard Analysis Critical Control Points) plan, it is good to go into the process with realistic expectations. Senior management must understand that it is more than a few pages of a document provided to your customers. HACCP plans are an entire food safety management program that includes prerequisite programs, such as standard operating procedures, policies and procedures and all production and training documentation that goes along with those programs. Many facilities maintain a HACCP manual that can be up to 3 inches thick, which indicates the ongoing work required to maintain a HACCP program. And more work and documentation is required in a food safety plan that would comply to FSMA (Food Safety Modernization Act) standards.
According to the International HACCP Alliance, “HACCP is a process control system that identifies where hazards might occur in the food production process and puts stringent actions to take to prevent the hazards from occurring. By strictly monitoring and controlling each step of the process, there is less chance for hazards to occur.”
First step is to establish a team and ensure that at least one goes through formal training. The team will work through the 7 principles that are the foundational to HACCP programs. Below are the 7 principles with explanation of the efforts it might take to go through the exercise in your facility with your team.
- Conduct Hazard Analysis – in order to conduct a hazard analysis, you first need to identify all processing steps and raw materials used to create your finished product. This will include collecting specifications from suppliers for each of the raw materials (ingredients and packaging) to understand what hazards are associated with the specific raw material. You need to review physical, chemical and biological hazards. If you are creating a food safety plan in accordance to the Preventive Controls Rule for FSMA, you will need to include radiological hazards as well.
- Identify CCPs (Critical Control Points) – once each step is identified in your process flow, you will assess if any control the hazards that were identified in step 1. It is recommended to go through HACCP training to fully understand how to identify the CCPs.
- Establish Critical Limits – your HACCP team must determine what the limits are for the identified CCPs. These limits are often set by scientific authorities. Oftentimes, companies set the limits more stringent to give themselves cushion from missing the limit requirement.
- Establish CCP monitoring Requirements – Once the limits are identified, you will have to set up ways to monitor that the limits are met. This might include recording devices.
- Establish Corrective Actions – if the limits are not met, you must have written procedures around each limit to ensure that you are prepared to ensure that the hazard does not get to the consumer.
- Establish Effective Recordkeeping Procedures – there is a cliché phrase that says “if it isn’t documented, it didn’t happen.” This is the case with recordkeeping for HACCP. All CCPs must be proven that they are met and that the corrective actions were performed if necessary, to correct it.
- Establish Procedures for Verifying – Verifying that the hazards were controlled is also a critical step in the process and must be recorded. This might include lab test results after a lethality step to ensure that the bacteria levels are at acceptable levels. All verifications need to be recorded and maintained in the HACCP documents.
It may not be completely obvious by reading this article, but a HACCP plan from ground zero could take 400 hours or more to create when there are multiple production lines with different types of processes and developing the prerequisite programs. Because HACCP plans are foundational to most 3rd party audit programs, it is important to spend the appropriate time developing those programs and to get appropriate training for your team. Bottom line, this is a team effort.