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 severe strains such as Ebola virus and Marburg virus.

Continue reading “CGMPs and HACCP: The Dukes of Hazards”

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

Pink Leads the Charge

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.