Tag Archives: HACCP

How is HARPC Different From HACCP?

HACCP and HARPC share more than just four letters. They’re both food safety standards based on prevention, but they do differ on execution. Their differences and the similarities aren’t as important as the way they fit together for most food processors, though. A HARPC plan shouldn’t be considered as a replacement, but as a necessary upgrade to the conventional HACCP plan. Understanding how the systems fit together is the first step toward implementing both.

HACCP HARPC
(1) Is the preventative approach based on a standard, guideline or a set of laws?
Based on a guideline recommended by CODEX and NACMCF Based on FSMA act and principally, the Final Rule for Preventive Controls for Human Food
(2) What food safety risks are considered using the preventative approach?
Conventional – Biological, Chemical, and Physical Beyond the conventional risks for actual and potential food safety hazards
(3) What is the goal of the preventative approach?
To prevent, eliminate (or) reduce hazards to a safe level (in that priority) Preventive controls that prevent or significantly minimize “known or reasonably foreseeable” risks
(4) Who is primarily responsible for the development and maintenance of the preventive plan?
Primarily, a competent HACCP coordinator with assistance from multidisciplinary team Trained Preventive Controls Qualified Individual (PCQI) as described in the FSMA Act
(5) At what frequency is the preventive plan being reviewed by the facility?
At least once a year, or when required At least once in 3 years, or when required
(6) The plan is mandatory for what type of establishments?
For FDA and USDA mandated establishments, or when required for certification purposes For all establishments along the food supply chain that serve U.S. consumers, unless exempted
(7) The plan is excluded or exempted for what type of establishments?
Unless mandated or required for certification, HACCP is voluntary, and GMPs are mandatory Exemption list is provided by FDA, but this does not exempt facilities from following at least CGMPs
(8) Who is the interested party here? For whom is the plan for?
Stakeholders: auditors, inspectors, and customers The FDA
(9) What is the documented approach for making the preventive plan?
12 Steps of HACCP (includes 7 Principles) 7 Steps of Developing a HARPC Plan

HARPC as an Upgrade to HACCP

HACCP, or Hazard Analysis Critical Control Points, is already widely used due to requirements from retailers, auditing standards, and inspectors, though the USDA and the FDA only mandate it for meat, seafood, and juice products. As a global standard conceptualized the 1960s, HACCP has been continually developed and updated. HACCP requires a multi-disciplinary team for implementation and follows prescriptive steps.

HARPC covers food safety concerns beyond Critical Control Points and is mandated by the FDA for most facilities, with some exemptions. Instead of only looking at process steps where controls can be applied (as in HACCP plans), HARPC relies on the applicable FDA regulations, standards, and guidance documents to develop a Preventive Controls Plan.

How HACCP Works

HACCP is a globally recognized risk-based preventative approach recommended by the Codex Alimentarius Commission (or the ‘Food Code’) and the National Advisory Committee on Microbiological Criteria for Foods. It commonly focuses on controlling the three main food safety hazards: biological, chemical, and physical. The primary goals (in order of priority) are to prevent occurrences of the hazard, or eliminate, or reduce the food safety hazard to acceptable or safe levels.

 The HACCP plans are developed, implemented, and maintained by a multi-disciplinary team and the entire process is facilitated by a HACCP Coordinator, a person who is sufficiently knowledgeable and skilled in food safety concepts and principles and has undertaken a training program that has preferably been accredited by the International HACCP Alliance. The responsible person must review the HACCP plan at least annually, or whenever there are significant changes in food safety design layout, processes, product composition, or technology.

 The HACCP program is legally mandated for meat and poultry establishments (under USDA jurisdiction) and juice and seafood processing establishments (under FDA’s jurisdiction). Even though the HACCP program for several food establishments may be voluntary (unless specified by regulations, industrial standards, or by customers), it does not absolve a facility from implementing Current Good Manufacturing Practices (as provided in the 21 CFR 110 legal document) and other relevant pre-requisite program requirements necessary to maintain the safety and legality of the food products. In the Food Code, prior to HACCP recommendation, there are General Principles of Food Hygiene (provided in 10 sections) that have to be followed. Auditors, inspectors, customers, and other stakeholders may inspect the HACCP or food safety plan.

12 Steps of HACCP:

  • Assemble the multidisciplinary HACCP team
  • Describe the product
  • Identify its intended use
  • Construct a flow diagram
  • Conduct on-site confirmation of the flow diagram, and draw up the plant schematic
  • List all potential hazards associated with each step, conduct a hazard analysis, and consider any measures to control identified hazards (Principle 1)
  • Determine Critical Control Limits (Principle 2)
  • Establish Critical Limits for each CCP (Principle 3)
  • Establish a monitoring system for each CCP (Principle 4)
  • Establish corrective actions (Principle 5)
  • Establish verification procedures (Principle 6)
  • Establish documentation and record-keeping (Principle 7)

How HARPC Works

In brief, this preventive control system mandated by FDA’s FSMA Act is to be implemented by all food establishments unless specifically exempted. Thus, it applies to food facilities in the U.S. that manufacture, process, pack, distribute, receive, hold, or import food, and for those firms exporting foodstuff to the US. The FDA has issued implementation deadlines for each of the different facility types (kindly refer to updated guidelines on the FDA site, www.fda.gov). Within a HARPC plan, the food safety hazards assessment is broader; generally, the following risks are considered:

  • Biological, physical, chemical, and radiological hazards
  • Natural toxins, pesticides, drug residues, decomposed material, parasites, allergens, and unapproved food and color additives
  • Naturally occurring hazards
  • Unintentionally introduced hazards
  • Intentionally introduced hazards, including acts of terrorism

Preventive controls are science-based and shall be adequate to significantly minimize or prevent identified hazards “known or reasonably foreseeable” for each type of food subject to the relevant FDA regulation. The HARPC plan is developed, implemented, and maintained by a team of “preventive controls qualified individuals” as defined in the FSMA act, who have been trained or are sufficiently conversant with the FDA FSMA Final Rule for Preventive Controls for Human Food, and any other relevant rulemakings, such as the Final Rules on Animal Food, Produce Safety or Foreign Supplier Verification Program etc. (for more information, refer to the FDA site, www.fda.gov).  The responsible person must review the HARPC plan at least one every 3 years (if no significant changes occur in the plan) or whenever there is a significant change at the facility that might increase a known hazard or introduce a new one.

7 Steps of HARPC

  1. Assess the hazards—This includes the normal product-specific hazards, along with a broad range of other hazards (listed above) and facility-specific concerns such as food defense and emergency management issues.
  2. Institute Preventive Controls—These include sanitation procedures for food contact points, staff hygiene training, environment monitoring, supplier verification, and more.
  3. Monitor effectiveness of the controls—Not all controls are measurable by critical limit numbers, but these Preventive Controls can be evaluated on a routine basis.
  4. Establish corrective action measures—Recall plans may not seem preventive, but the critical steps between knowing something is wrong with a product and keeping it away from consumers’ hands should involve identifying and correcting the weak spots within the controls. The objective is to prevent occurrences of unsafe and non-conforming food product.
  5. Establish verification measures—The process of verification ensures that the facility is effectively meeting its food safety standards on a consistent basis.
  6. Follow proper and required recordkeeping—As with any FDA ruling, nothing is properly done until it’s recorded.
  7. Reanalyze the plan once every 3 years, or when needed—When changes in process or product happen, HARPC plans should be reevaluated.

Recap of Some Key Differences:

Hazard Analysis Method

The three conventional types of hazards that are addressed in the HACCP plans—physical, chemical, and biological—are accompanied by many more concerns in HARPC plans.

Radiation, natural toxins, pesticides, drug residues, decomposition, parasites, allergens, unapproved food or color additives, naturally occurring hazards, and intentionally and unintentionally introduced hazards round out the list of HARPC-related hazards.

Critical Control Points Versus Preventive Controls

Critical Control Points during process steps are central to HACCP. Each control point must include measurable critical limits—the temperature and length of time a sauce must be held at, for example, as a kill step. The objective of each control step is either to prevent, eliminate, or reduce food safety hazards to a safe and acceptable level. Food safety measures that aren’t specific to the process, such as personnel hygiene, are covered under Standard Operating Procedures (SOPs).

HARPC focuses on Preventive Controls that are science- or risk-based, and should be adequate to “significantly minimize or prevent” known or foreseeable hazards for each type of food subject to the federal regulations.

 

To learn more about HACCP, download our whitepaper, “HACCP Planning for Food Safety,” or contact our knowledgeable customer service representatives at cs@remcoproducts.com or at 317.876.9856. Contact us today to schedule a complementary on-site consultation regarding HACCP and HARPC plans.

To view more information about this and other sanitation topics, visit http://www.remcoproducts.com/knowledge-center.

 

SELECTED REFERENCES:

Food and Drug Administration. (2015). FSMA final rule for preventive controls for human food.

Joint FAO/WHO Codex Alimentarius Commission, Joint FAO/WHO Food Standards Programme, & World Health Organization. (2003). Codex Alimentarius: Food hygiene, basic texts. Food & Agriculture Org.

US Food and Drug Administration. (2011). Food safety modernization act (FSMA). Public Law, 2011, 111-353.

Website: www.fda.gov

 

New-Employee-Proof Your Safety Plan with Color Coding

In the food processing industry, like many factory-based jobs, employee turnover is high. When you’re seeing a turnover rate of about 35% yearly, how do you train your staff to follow important safety plans? When you’re in an industry where a simple mistake by a single employee could result in thousands of people getting sick, how do you ensure HACCP compliance?

For many, color coding has become the easiest answer. Color coding offers a simple solution to an otherwise complex problem. Even the newest employee can quickly learn that red products belong with the raw product, and white goes with the finished.

Here are our top 5 tips to using color coding to ensure all of your employees follow CGMPs.

  1. Set up cleaning stations

Cleaning stations serve as a visual reminder that everything has its place. Put a sign over a station filled with blue tools to remind everyone that those tools are used to clean floors in the packing area, and another sign over a pink wall bracket to tell employees that those tools are used in receiving. Cleaning stations also remind employees to hang tools back up once they’ve been cleaned.

  1. Separate allergen control zones

Training new employees on how and why to respect allergen control zones is difficult. Popular culture has made everyone aware of the danger of peanuts, but many people don’t respect the potential harm trace residues of milk ending up in the wrong product can do. Even if your individual employee doesn’t understand why blue tools are only to be used in a certain area, they can at least quickly understand that it’s the way the factory operates. If the new employee still doesn’t respect the separation, they can be quickly corrected, since it will be immediately obvious they’re using a tool outside its zone.

  1. Back up your plan with pictures

It’s riskily idealistic to think every employee who walks through your door will know how to read in English, or know how to read at all. Photos of what to use each tool with will back up your written signs and make them easy to understand for all of your employees, no matter what their background or education level is. Use easy photos like a picture of peanuts with a big red X over them for your peanut-free tools, or a photo of a purple scoop next to wheat grains so employees know what those tools should (and shouldn’t) touch.

  1. Don’t use commonly color-blind colors

When you choose colors, be aware that some are more easily confused than others. Of people with color-blindness, about 99% have trouble distinguishing between red and green. Try not to use these colors in the same color coding plan. Also, be aware of the fact that about one in 12 men are colorblind, and one in 200 women. Choose shades that are contrasting, like white and red, and avoid putting similar shades near each other, like brown and orange or blue and purple.

  1. Use color-coding to spot training issues

Is someone using the brush meant for a different shift or a different area of the facility? It’s time for a small, informal retraining conversation with a floor manager. These easy discussions can essentially boil down to telling the employee the color they should be using for their purpose. Quick one-on-one sessions with a manager will reinforce these guidelines, and with very little time or effort wasted. Floor managers should have color-coded zones memorized so they can make the most of their time on the floor and correct problems where they see them.

 

Food safety is everyone’s job in the plant, but training comes down to managers and owners. Creating an environment where safety comes first starts with using the right tools for the job, and color coding can help with that.

What you need to know about FSMA: Part 1

If you are in the food industry and have had your eyes and ears open, then most likely you have heard the word FSMA being thrown around… a lot. However, some people might find themselves unfamiliar with the term or have limited knowledge of it, so in this entry we are going to cover some general information regarding FSMA and in upcoming blogs we will go into further detail about each proposed rule issued by the FDA that supports this legislation.

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The people, pathogens and food of today are not those of the past. Our population is living longer and with problems that make them more susceptible to foodborne illness complications. Pathogens are evolving and becoming more adaptable and harder to kill. Our food is traveling more than it ever has. For example, the FDA states that 15% of food we eat is imported. A total 75% of our seafood, 20% of our vegetables, and 50% of our fruit is imported. However, one thing has not changed and that is the threat that foodborne illness presents to the food industry and its consumers. Continue reading What you need to know about FSMA: Part 1

Using Color-Coding for Food Safety and Organization

Lately, I’ve been doing a lot of consulting with food processors to build and improve color-coding systems in their facilities. Color-coding can be approached in a variety of ways, and works well with a number of related programs. One such program is a lean manufacturing practice called 5S, which I encountered often in a previous position working in the steel industry.

I’m starting to see 5S used more often in food processing. Although I am not an expert in this system developed by the Japanese, I do know that the 5 S’s are Sort, Set in Order, Shine, Standardize, and Sustain. The aim is to eliminate waste, keep workspaces organized, and develop procedures that are consistently easy to follow. I can see why this set of guidelines is appealing to food processors. An organized processing facility is agreeable with inspection authorities, because it demonstrates that a food safety procedure is defined and in practice.

Color-coding for food safety

Color-coding is also commonly applied in conjunction with written food safety plans and HACCP programs to further enhance food safety. The purpose of HACCP and the CGMP regulations laid out in 21 CFR 110 is to identify and control hazards that could potentially impact the safety of food. Cleaning and food contact tools can potentially transfer hazards like pathogens and allergens throughout the facility, so it may be important to keep certain tools in designated areas. Color-coding supports this objective by clearly identifying where tools belong or what task they are designated to perform.

food safety color coding for controlled areas and tasks

Color-coding best supports food safety efforts when it is applied with simplicity. A best practice to keep in mind is that the way to create the most effective color-coding program is to implement tools in one solid color. Otherwise the program may become diluted and can introduce more confusion for employees.

Organizing tools with color

When food safety is a concern, it should take precedence over organizational efforts when building a color-coding program. A system like 5S is excellent in supporting a food safety program such as HACCP. However, colors should primarily be determined by the food safety program prior to defining organization principles related to 5S.

Fitting all of these programs together can be challenging, but it is possible and most definitely beneficial to food safety efforts. Anytime you need guidance or advice on building or revising a color-coding system in your food facility, you can call on Remco for support.

CGMPs and HACCP: The Dukes of Hazards

In the past couple of blog entries, we’ve covered CGMPs or Current food Good Manufacturing Practices. These are procedures and standards set forth by the FDA to help assure safe, quality, consumable food.

salmonella biohazard food safety riskIn this article, we’ll be covering the different types of hazards that can occur in food processing, and also the controls that can be put in place to reduce the risk of those hazards. Many CGMPs exist to control these hazards, so naturally CGMPs can be used to support a HACCP plan.

So what constitutes a hazard? There are basically three types: biological, physical and chemical.

Let’s start with biological hazards. The Centers for Disease Control (CDC) has determined four levels of biohazards starting with Level One which includes bacteria and other microorganisms that can transmit from one person to another via contact or through the air like E. Coli. Each level is more hazardous than the previous, leading to Level Four which includes the most sever strains such as Ebola virus and Marburg virus.

Physical hazards are perhaps the easiest to understand. These include any extraneous objects or foreign matter that could cause illness or injury to a person consuming a food product. Bone chips, injection needles, wood fragments, pieces of packaging, insects or filth are just several of the items possible. Glass fragments physical food safety hazardSources of contamination can be from raw materials, improper production procedures or badly maintained facilities. Harken back to our blog article that referenced Upton Sinclair’s The Jungle and how it revealed the filth and unsafe practices of the meat packing industry in the early 1900s, and one could understand how such a list may have first been developed. CGMPs and other food safety regulations have advanced today’s food processing practices; however it is important to be mindful of how even the most minor change might introduce an opportunity for new physical hazards.

Finally, there are chemical hazards. Some of these, unfortunately, are unavoidable such as pesticides, herbicides, growth hormones and antibiotics, additives and processing aids, and lubricants. Sometimes, improper storage or usage of chemicals like cleaning compounds contributes to contamination of food. Allergens fall in the chemical hazard category, too. The top eight known food allergens reported by the FDA are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat and soybeans. Thus, the FDA has established tolerance levels to keep chemical hazards in food at a minimum.

So how does a food processor control hazards? A good basic step is to develop a written food safety plan built around the CGMPs outlined by the FDA. These guidelines were created to assist processors in recognizing and controlling hazards. Processors can take due diligence a step further by building a HACCP plan. The first principle of HACCP is conducting a hazard analysis. Following HACCP principles is a thorough and systematic method of approaching quality control. HACCP planning guides processors in identifying and evaluating hazards and critical control points, and establishing a program to monitor, correct, verify and track any potential safety or quality hazards in the food production process. CGMPs can be used on their own or in conjunction with HACCP principles to keep hazards in check.

As the song goes, “we’re only human,” which is exactly why hazards can happen and controls are considered necessary to help minimize the risks of breaches in food safety. Through our experiences with various food producers over the years, we understand food safety is a subject that’s not taken lightly. At the minimum, any company producing food should have someone on staff who understands what constitutes a hazard that requires some effort to control. We continue to want to learn more about how different food producers are minimizing their risks. How does your company control hazards? What’s worked and what hasn’t? We’d appreciate hearing from you. Tell us your thoughts. And for more information on hazards and controls, check out our white paper Understanding GMPs.

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.

Building your HACCP Plan—Part 1

With the advent of the Food Safety and Modernization Act of 2011, many food processors are taking proactive steps to develop a HACCP Plan. As new rules related to FSMA are proposed, many processors are asking the question, “How do we develop a HACCP Plan?”

HACCP quality check in food processing facilityLet’s start with a brief review. HACCP stands for “Hazard Analysis Critical Control Point.” A HACCP Plan includes a series of procedures to control the process and sensitive points in the food chain, with the ultimate goal of producing consumer foods that are safe for consumers’ health.

Through our research on the subject and working with food processors, we’ve observed several suggested steps in developing an effective HACCP Plan. In this blog entry, we’ll cover three tips for developing a successful HACCP Plan. We’ll follow up with another blog to cover a few more helpful suggestions.

1. Understand the seven HACCP principles.

The United States Department of Agriculture provides seven principles for developing a HACCP Plan: 1) Conduct a Hazard Analysis, 2) Identify Critical Control Points (CCPs), 3) Establish Critical Limits for each Critical Control Point, 4) Establish Critical Control Point Monitoring Requirements, 5) Establish Corrective Actions, 6) Establish Record Keeping Procedures, and 7) Establish Procedures for Verifying the HACCP System is Working as Intended.

Realizing that’s a lot to digest right there, we suggest you visit the FSIS website to read in more detail about the seven principles and what’s involved with each one. Basically, your HACCP Plan will start with a Hazard Analysis of each product, then you’ll need to work through each point in the process to determine CCPs, then establish and monitor corrective actions for those CCPs. (See our previous blog article that covers more about CCPs.)

2. Use the power of the team.

In our observations, some of the best HACCP Plans are those developed by a team within a food processing organization. Who should be on your team depends on the structure of your organization, but typical titles included are:

  • HACCP Coordinator
  • Quality Assurance Manager
  • Plant Operations Manager
  • Engineering Manager
  • Maintenance Manager
  • Sanitation Manager and/or Supervisor
  • Shipping & Receiving (Warehouse) Manager and/or Supervisor
  • Line Supervisor and/or Machine Operator

In our experience, the HACCP Coordinator is usually the point person for the HACCP Plan. This person is ultimately responsible for coordinating and maintaining the HACCP Plan. If you don’t have a HACCP Coordinator within your organization, then your Quality Assurance Manager or even CEO may be the appropriate person to have that responsibility.

We appreciate learning more about how companies assign  HACCP responsibilities — what works and what doesn’t. Email us your thoughts on this issue at Sales@remcoproducts.com.

3. Identify the products that will be covered by the HACCP Plan.

Unless you’re a very small food processor, chances are your company produces more than one product. Thus, it’s important to identify every product that will be covered by your HACCP Plan. For each product, your Hazard Analysis should include the product name and description, its ingredients and processing methods, food safety factors involved with processing the product, how it is distributed, the product’s intended use and target consumer.

With these three steps covered, next you’ll get into the heart and soul of your HACCP Plan. For your convenience, we’ll cover more steps in our next blog entry. In the meantime, you may enjoy reading an overview of HACCP planning from the University of Florida IFAS Extension, or our white paper, “HACCP Planning for Food Safety.”

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: Use Complete Implementation

We’ve come to the final post in our series of 10 things to know when starting or revising a color-coding program. You may have already determined that color-coding is the solution for your facility’s food safety needs. If not, take a look at our previous blog posts in this series, and perhaps you will find some things you have not yet considered.

Vikan Hygienic Zone Planner Application for color-codingThe final key to the success of a color-coding program is ensuring that it is completely integrated into the facility. If you have decided to take the plunge and start a color-coding program, or if you think yours needs some tweaking, remember that even a good color-coding program can be problematic if it is not completely applied. Ensuring complete implementation will improve internal adoption.

Doing something halfway is never a good idea, and the same holds true for color-coding. When a color-coding program is implemented in pieces, the chances of success start to deteriorate. On the surface, it might seem easier to slowly bring in color-coding into your facility; but in the long run, it will be better for everyone to roll the program out all at once. Incomplete implementation might seem desirable due to a limited budget, time constraints, or lack of manpower. No matter what the reason, sometimes you just have to bite the bullet and go all the way. Go big, or go home, as they say. Once it is a part of everyday life at the facility, a color-coding program will be one more asset that you have at your disposal.

If you read our last post, you know that communication plays an integral part of starting a color-coding program. Communication and complete implementation of the color-coding program go hand in hand. By communicating with every employee and team member, complete execution of the color-coding system will be that much more successful.

One issue that might prevent a complete roll-out of a color-coding program is budget concerns. This is a valid issue, and one likely to be shared by many operations. However, because a successfully applied color-coding program can help decrease the chance of cross-contamination, and therefore recalls, it could save money in the long-term. Color-coding a food processing facility is an investment. Just like any investment, there are start-up costs—but the end result will be well worth the money put into it.

In addition to any budget concerns, lack of time and manpower can also be issues standing in the way of introducing a color-coding system into your facility. Every food processing facility, from the smallest to the largest outfits, can benefit from a color-coding program. If time is an issue for you, ask us for help. Remco and Vikan have tools that can help you quickly identify zones and plan the entire program for your facility. We’re here to assist you with the process.

10 Things To Know About Color-Coding: Communication is Key

Essential to an effective color-coding system is a well thought-through communication plan. With the proper communication channels in place, your color-coding system has the best chance for successful adoption—in turn helping you to mitigate the risk of cross-contamination. Communication should start at the top of the company, and go down to each and every employee. When all employees are knowledgeable about the new or changed program, the chances of success are even higher.

HACCP Plan for food safetyThe initial employee training communications must be clear and concise to ensure everyone is on the same page. When starting, or even revising, a color-coding system, employees must understand the reason for the change. Dealing with the threat of cross-contamination is serious, and the need to establish barriers to those threats is critical. The better every employee understands this, the more effective the color-coding system will be when put into practice.

Communicating with employees on how color-coding can help with tool storage is also very important. Establishing procedures for storage can help with tool inventory management. If employees are taught the proper procedures for tool storage right out of the gate, this will go a long way in preventing any loss of tools or time. One particular way to help encourage proper storage is to use custom shadow boards that integrate outlines of the tools so that there is no question where tools belong. Some facilities might use the 5S system to maximize organization. The use of color-coding is a great way to enhance the 5S philosophy. 5S is a Japanese workplace organizational system which uses five phases: sort, set in order, systematic cleaning (or shine), standardize and sustain. Along with using shadow boards, 5S helps encourage employees to properly store tools, maximizing their usable life.

Green color-coded wall bracket with rubber clips for sanitation Red color-coded wall bracket with rubber clips for sanitation Blue color-coded wall bracket with rubber clips for sanitation
 Zone 1   Zone 2   Zone 3

Daily communication to employees is essential to the longevity of the program. Daily communication starts with good signage. Clearly written instructions, bilingual if necessary, are essential to providing employees with instructions on the color-coding program. It may even help to include visual or graphic representations on the signage for each zone; for example, a picture of a peanut on the sign designating the color of tools intended for use with peanuts. In addition to written instructions, daily verbal communication is also vital. Any changes or revisions to the color-coding plan must be clearly communicated to all employees, from the top down.

It is a best practice to include your color-coding program in your official regulatory documentation. Many regulatory bodies require documentation of certain procedures, and color-coding can become a great advantage for your operation. While color-coding is not required for compliance with any food safety regulations, it is looked upon with favor by auditors. Including your color-coding plan in the facility’s Preventive Control or Prerequisite Procedures, which includes GMPs, SOPs, CCPs, and Non-CCPs, will go a long way in ensuring company-wide adoption, consistency and compliance of the program. For facilities that must comply with HACCP or HARPC regulations, including color-coding on those plans is, again, not required but, a best practice. HACCP, or Hazard Analysis & Critical Control Points, is a food safety management system which helps to identify and control cross-contamination threats. Similarly, HARPC, also known as Hazard Analysis and Risk-Based Preventive Controls, also requires identification and control of risks in food processing facilities.

Here are some important things to remember:

  • Start at the top and go down
    • Communicate with all levels of employees to ensure complete implementation
  • Have good signage
    • Signs should have written and visual cues to identify the zone and where the tools are approved for use
    • Include a printout that gives details for reordering of tools, such as vendor, item number, manufacturer, etc.
  • Keep up with training
    • Consistent training programs for all employees will improve adoption and ongoing use of the program
  • Include color-coding on regulatory plans
    • Color-coding is looked upon favorably by regulatory bodies