SQF Audit Tip #2 HACCP Plan Development

 

As a food safety consultant, I have had the opportunity to review numerous HACCP plans.   Often, they are not adequately detailed and often miss one or more of the steps needed for proper HACCP plan development.   This was one of the driving forces that motivated me to become certified as a HACCP instructor this year.   The following twelve steps (and seven principles) outline the framework that you must follow when developing a HACCP Plan. There are also one or two elaborative bullet points after each step.

 

The 12 Steps.

  1. Assembling a Team
    • The HACCP team needs a least one certified HACCP member.  Everyone else on the team must also have some level of HACCP Training.
  2. Describe the Product and the Target Customers
    • The significance of a hazard in a ready to eat food is much greater than the same hazard in an ingredient that will be further processed by the consumer.
  3. List all of the Ingredients (Including Packaging)
    • The list must have enough detail so that ingredients with unique food safety characteristics stand out.
  4. Create the Flow Diagram
    • Every step in the processes where hazards are potentially introduced must be broken out in the flow diagram.
    • Make sure that the points where rework is introduced are made clear.
  5. Verify the Accuracy of the Flow Diagram
    • It is hard to conduct a proper hazard analysis without observing and confirming the accuracy of the process.
  6. Analyze Every Potential Hazard at Each Step in the Flow Diagram. (Principle 1)
    • Most students finish HACCP training with the knowledge that the hazards are either PHYSICAL, CHEMICAL, or BIOLOGICAL, but how does that apply to the hazard analysis?  It is recommended that the first step of hazard analysis be that the HACCP team brainstorms every possible hazard that could potentially contaminate the product.  They can consider the likelihood of the hazard occurring during the next step.
  7. Create a HACCP decision Tree to Identify Critical Control Points. (Principle 2)
    • If the team doesn’t consider the hazard to be a critical control point because it is controlled by a prerequisite program, then the team should explain their rational for the decision in the hazard analysis.
  8. Establish Critical Limits (Principle 3)
    • The critical limit must be science based.  For example, Appendix A and B for cooking and chilling of meat.
  9. Establish Monitoring Procedures (Principle 4)
  • The monitoring of ALL HACCP related monitoring must always be documented.
  • Employees conducting the monitoring are often under-trained.  The training of these employees must be is a key prerequisite program supporting the HACCP plan.
  1. Establish Corrective Actions (Principle 5)
    • You must have a documented corrective action process to show what happened every time a critical limit wasn’t met.
  2. Establish Verification Procedures (Principle 6)
    • You must have a responsible HACCP team member verify that the HACCP plan is being followed as written.
  3. Establish Record Keeping (Principle 7)
    • All HACCP related records must be organized and must be used as a tool to track non-conformance’s and can be later used for validation.

The steps listed above are central to a successful HACCP plan, but some of them are often overlooked. I would stress that all of the 12 steps (7 principles) be reviewed during the HACCP meetings so that they are not forgotten during the HACCP plan writing process.

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