Building your HACCP Plan—Part 2

In our last blog entry, we covered tips for completing the first steps of a HACCP Plan. We asked the question, “How do we develop a HACCP plan? Here’s a quick recap of Part 1. First, we suggested gaining an understanding of the seven HACCP principles. Second, from our experience working with various food processors, we’ve seen it’s important to involve your key department managers from quality control, engineering, maintenance, and operations in developing the plan. Third, if your company produces multiple products, you may consider identifying and including all products that will be part of your HACCP Plan. We even heard from one reader that he found it helpful to complete a HACCP review on each ingredient for better control.

HACCP compliance verification produce processingWhere should your HACCP planning go from here? The next key steps in developing an effective HACCP Plan involve honest, disciplined and critical thinking about your entire production process —from the time ingredients enter your facility, to when your finished products are shipped. In thinking through your production process, ask the following questions with your team:

  • Do we have thorough documentation of our processes?
  • Where might potential hazards exist in our processes?
  • Do Critical Control Points (CCPs) exist, and if so, what control measures should we establish to minimize those hazards?
  • Do we have sufficient documentation to communicate our processes and food safety initiatives to new employees and visiting inspectors?

Asking these questions and discussing them with your team should lead you in the right direction for developing a HACCP plan to fit your business. You may also find the next suggested steps to be helpful in providing some direction based on the experiences of other food production companies.

1. Visualize every step of your process.

Many businesses that have been producing food for decades have found it helpful to do a thorough, objective review of processes even if they understand those processes inside and out. By sitting down and literally mapping out every step, potential food safety issues that went previously unnoticed are able to be identified. It’s been our observation that successful food processors find it helpful to use a Process Workflow Chart to illustrate each step of their processes. From the time ingredients, packaging and other raw materials enter your facility to the final stages when your products are packaged, labeled and shipped, you can strengthen your food safety by accounting for every step in your food process. What does one of these Process Workflow Charts look like? Below is a simplified version as an example.

Process workflow chart example

2. Evaluate potential hazards and identify CCPs.

At a minimum, it’s suggested by the International HACCP Alliance that your HACCP Plan identify and prioritize hazards and their critical limits, as well as establish actions to eliminate, prevent or reduce the hazards. How does one do this? Many food processors use what is called a Decision Matrix, as suggested by the FDA. A Decision Matrix (see example below) begins by reviewing each step in the workflow process, then it assists you in evaluating the likelihood of hazards that could occur. Once a hazard is identified, then it is evaluated whether or not it is a CCP.

FDA Example of Decision Tree

3. Create a Hazard Analysis Worksheet.

At this point you may be thinking, “Isn’t every hazard also a CCP?” Not necessarily. If a control measure is already in place to address the hazard, then the hazard is not a CCP. If a control is NOT in place to secure food safety, then it is a CCP and a control measure should be considered to reduce the hazard. CGMP’s (Current Good Manufacturing Practices) are one of the many control measures that can often address hazards and eliminate the need to identify hazards as a CCP. We’ll cover CGMP’s in more depth in future blog articles.

To help evaluate the severity of each hazard, many food processors use a Hazard Analysis Worksheet. Below is an example. You’ll see that along the top of the worksheet are the key areas of analysis, starting with the ingredient/step in the process being evaluated through to the final determination of whether or not it is a CCP and its risk rating (1 through 5). Look through each line of the worksheet and you’ll discover why not all hazards are CCPs.

Hazard analysis worksheet example

4. Keep up your HACCP Plan.

Putting together your HACCP Plan is one thing. Monitoring it regularly is a good way to reinforce food safety efforts in your organization. We have found that ongoing maintenance by a dedicated HACCP Coordinator within your organization can help you stay one step ahead of new potential risks that may quietly enter into your processes. Anytime anything changes within your process (i.e., you add new employees, change vendors, update packaging, etc.), it’s suggested to re-evaluate your HACCP Plan.

For a more thorough review of the HACCP planning process, be sure to check out our HACCP Planning white paper.

Five Things You Maybe Didn’t Know About HACCP

If you work in food processing, chances are you’re probably familiar with the concept of a Hazard Analysis Critical Control Point or HACCP. Here’s a little about what we’ve learned about HACCP.

HACCP food safety sample verificationAs part of a HACCP Plan, a Hazard Analysis identifies “Critical Control Points” or CCPs — those points, steps or procedures in food manufacturing process at which control can be applied and as a result, a food safety hazard can be prevented, eliminated or reduced to an acceptable level. With CCPs identified, a HACCP Plan provides a series of procedures to control the process and sensitive points in the food chain, with the ultimate goal of producing foods that are safe for consumers’ health.

HACCP is a part of the Food Safety and Modernization Act (FSMA) proposed by the Federal Drug Administration (FDA) in 2011. While FSMA is fairly new, did you know the concept of HACCP has actually been around for some time? Here is the answer to that question along with some other interesting things about HACCP that many people may not be aware of.

1. HACCP is not a new system.

HACCP is a concept that’s been around since the 1960s. It was developed by the Pillsbury Company, the US Army Laboratories and NASA to help produce safe food for space missions. Today, HACCP is a recognized international standard for safe food production. It is endorsed by the Food and Agricultural Organization (FAO), the World Health Organization (WHO), and in the United States by the National Advisory Committee on Microbiological Criteria for Foods (NACMCF).

2. Not every hazard is a CCP.

As part of putting together a HACCP Plan, there’s a thought-process or Decision Matrix one can use to review each step in a food workflow process and determine the likelihood of hazards that could occur. Once a hazard is identified, then it is evaluated whether or not it is a CCP. Going through this evaluation, one will soon discover that not every hazard is a CCP. If a control measure is already in place to address the hazard, then chances are the hazard is not a CCP.

3. It takes a team to put together a HACCP Plan.

Through our experiences working with food processors, we’ve seen that some of the best HACCP Plans are the result of a team effort by the key individuals responsible for food safety within a food processing operation. The team may include managers from quality assurance, plant operations, engineering, maintenance, sanitation, and shipping & receiving. In addition, it’s often advised that someone who works on the line, such as a Line Supervisor and/or Machine Operator, provide input to the HACCP Plan to help assure alignment with day-to-day operations.

4. One person should be responsible for the HACCP Plan.

While it often takes a team to put together a well-structured HACCP Plan, we’ve also observed that maintaining the plan should ideally be the responsibility of just one person within a food processing organization. That person is usually the HACCP Coordinator. However, if there is no HACCP Coordinator, then the responsibility often falls to the Quality Manager, or even the company’s CEO.

5. Review the HACCP Plan regularly.

In a perfect world, anytime something changes within a food process, then the HACCP Coordinator should review the HACCP Plan and update it accordingly. At the very least, it’s suggested that a HACCP Plan be reviewed every 3 to 6 months.

How does your food processing facility deal with HACCP? If you have any additional tips or observations about putting together and maintaining a successful HACCP Plan, we’d love to hear them.

10 Things to Know About Color-Coding: Regulators Love It

If your business is food processing, you are no stranger to government rules, regulations, and auditors.  Complying with federal food safety regulations is crucial to the success—or even existence—of your operation.  Keeping the auditor happy sometimes becomes a top priority (like the day before the audit), because no one wants to deal with the time, money, and marred reputation of a production delay or facility shutdown. If you’re looking for ways to strengthen the food safety efforts at your operation, we think you need to know about color-coding—because we guarantee that your auditor does.

An FDA auditor inspects a food processing plant for possible violations

Even though color-coding is not a standard rule or even a requirement, it is a practice that regulating authorities commonly favor. Regulatory agencies, like the Food & Drug Administration (FDA) and the U.S. Department of Agriculture (USDA), exist to provide guidance for food safety procedures and ensure the compliance with laws relating to the safety of the nation’s food supply. One such law is the Food Safety Modernization Act (FSMA) that is intended to transform the U.S. food safety framework from a reactive damage control approach to more of a proactive prevention of foodborne illness crises. FSMA Section 103 requires food facilities to prepare written plans to evaluate hazards and implement effective preventive controls. It stipulates several steps to ensure a true preventive approach to food safety.

Regulating authorities look favorably upon the practice of color-coding because it is a method that can easily be documented and followed by employees. A color-coding program that is written into a HACCP plan essentially becomes part of the facility’s SOPs (standard operating procedures). A HACCP plan is a written outline that identifies potential food safety threats and critical control points. Color-coding adds an extra layer of preventive protection in addition to other food safety efforts such as the hygienic design of buildings and equipment. Programs that are easily documented are also more easily communicated to employees, and the employees’ adoption of food safety procedures is imperative to the effectiveness of those programs.

Visiting authorities and customers will readily notice color-coding programs upon entering a processing facility, which is precisely why the approach is so effective. Segregating zones by colors offers quick visual confirmation that equipment is where it belongs and is not contributing to the unintentional transport of contaminants throughout the facility. When color-coding is utilized as part of a multi-faceted approach to food safety, it will add credibility to the effectiveness of the operation for regulators and customers alike.

With the new laws and proposed guidelines surrounding food safety, prevention is the preferred approach by regulatory authorities. And in the long run, prevention is a better business practice than reactive damage control. The old saying about closing the barn door after the horse is out comes to mind when thinking about recalls; it’s just better for everyone if a recall doesn’t happen in the first place.

News of recalls can travel in the blink of an eye in the rise of social media.  In that time, the success of your facility can be irreparably damaged. To safeguard your operation from the negative publicity of a food safety crisis, it is imperative to prevent recalls before they happen.  Monitoring any sort of cross-contamination threat inside the facility is fundamental, and color-coding is a simple way to keep those risks in check. To learn more about how color-coding can help, see our preventing cross-contamination blog article.

You can also download our checklist to see if color-coding can benefit your facility.