The hazard analysis and critical control points (HACCP) system was established in 1959 by NASA to protect food for astronauts in space. It is a science-based systematic approach and risk assessment tool designed to identify and assess specific hazards, including chemical, microbiological, physical, and, now, often radiological hazards. Its focus is on control and prevention throughout the food production process, instead of reliance on finished product testing only.
As a result of its initial success, the process was soon adapted to include not only “space food,” but also traditional food production. Given the fact that HACCP was first developed more than 60 years ago, is this method now an outdated risk assessment tool?
Over the years, the approach to HACCP use has changed slightly. In the past, a large number of critical control points (CCPs) were often identified and defined in food facilities. Now, the tendency is to limit these CCPs and ensure that they are each continuously under control.
To conduct a HACCP assessment, the Codex Alimentarius suggests 12 steps:
- Assemble a multidisciplinary team;
- Describe the product;
- Identify the indented use, including consumer groups and vulnerable groups such as infants;
- Construct a flow diagram;
- Perform an on-site verification of the flow diagram;
- Conduct a hazard analysis;
- Determine the CCPs;
- Establish critical limits;
- Establish a system to monitor and control the CCPs;
- Establish corrective action for any case in which the CCP is not under control;
- Establish a verification procedure to confirm that the system is working effectively; and
- Establish documentation concerning all procedures and records appropriate to these steps.
Based on the questions most often asked by manufacturers, a number of these steps warrant additional consideration and clarification in the development of your HACCP plan.
How do I conduct the hazard analysis? As defined by the Codex Alimentarius, the analysis needs to be conducted by a multi-disciplinary team. The team approach is important to bring different experiences, knowledge, and backgrounds to the process. Involving a technical manager will provide different experience and areas of focus than that of a production manager. A quality manager can then include points from literature and scientific information, which are necessary in a HACCP study to demonstrate that more than just site knowledge is used to inform the process. This diverse team approach supports completion of a well-rounded analysis.
To ensure a good understanding of the basics of the HACCP philosophy, training is also key. The first group in need of training is the core HACCP team, as they will need a detailed understanding of the hazard analysis process and each step of the assessment. The next training group will be those responsible for conducting CCP controls, as they need to know why they are conducting the check and how to best do so. They will also need to know the consequences of improperly completing the check, which may lead to severe health issues for consumers. It is also crucial for this group to understand that if there is any problem or issue related to a CCP, they may need to withhold or recall products from distribution and also then work with their teams to adequately address the problem. To fully implement your HACCP plan, all production employees will need to have completed basic HACCP training so that they understand why such a risk assessment is done and the consequences if it is not properly executed.
Is it sufficient to check only for the intended use of the product? While the intended use should be the focus of your plan, unintended uses should also be taken into consideration. This does not mean that you’ll need to check every bizarre idea about the potential use or misuse of the product. You will, however, need to consider those that are likely to occur. A good example of a likely unintended use is marshmallows. These fluffy treats are not only directly consumed; they can also be heated by microwave or grill, and recipes are published regarding this use. The hazard analysis process should take this unintended use into consideration. If there could be a risk from this heating process, the formula may need to be changed or a warning will need to be published on the product label, stating that the product is not intended for heat treatment.
How do I identify a CCP? The determination of CCPs can be done with the help of a decision tree. This process will guide the HACCP team through a series of questions to help define whether the step is a CCP or not and whether there is a further process step that can prevent, eliminate, or reduce the risk to an acceptable level. This important question helps focus the process on the critical production steps.
Are there rules for the monitoring of CCPs? For the monitoring and control system, a continuous control is often requested. This could involve a process such as permanent temperature control, including pasteurisation and sterilisation. However, controls such as strainers can also be regarded as permanently controlled units if they are checked prior to production and are also in good condition after the production run. This means that, throughout the duration of the production shift, the strainer was in place and all product was properly strained. However, to properly manage it as a CCP, the controls of that strainer need to be completed during the shift, before the product is released, and while it is still the responsibility of the facility. If the product is released automatically 24 hours after production, but the strainer is only checked at the end of the week, it is not an adequate and allowed control of a CCP. In this case, it would be required for the strainer to be checked following each shift, or daily, before the product is released.
Do corrective actions need to be predefined? Prior to any incident, it is mandatory for the HACCP team to clearly define the corrective actions that would be taken in case of a non-compliant CCP. The team will need to discuss and define the possibilities for either the retreatment or destruction of the product in question. For example, milk that isn’t properly pasteurized could be sent back through the process to be pasteurized again, but only after the equipment is cleaned and working properly. Other products, such as one that passes through a free-fall metal detector and is packed in a metallized packaging material and cannot be unpacked and repacked again, will have to be destroyed, as there is no retreatment possible for that product. In a case where a rework is possible and not too costly, the control frequency of the metal detector should be much more frequent, as it should ultimately save product and resources. The advantage of defining these corrective actions prior to an incident is that it can be done in a calm environment, rather than the “panic” mode of an incident or crisis situation. Making senior management aware of this process will gain their support for the consequences of a failed CCP and the defined corrective actions.
What do the verification procedures include? The first verification check is the responsibility of a supervisor or other trained and identified individual or individuals on the team. These controls need to be completed as defined in the HACCP plan. This includes verification by set timelines, whether hourly, by shift, or otherwise as predetermined in your plan. The next level of verification is the control that the calibration of the equipment used is done in the defined frequency, such as the temperature probe calibration for a pasteurizer or the proper calibration of test probes for the metal detector.
The last level of verification/validation is the analysis of complaints that should have been eliminated by the defined CCP controls. For example, if the company has defined 2.5 mm as the critical limit for the metal detector check and there are no metal complaints larger than 2.5 mm, that means the system is working properly. However, if there are several complaints of metal parts between 1.0 and 2.5 mm, the HACCP team should further analyze whether the critical limit of 2.5 mm is an adequate limit to control the risk. For many companies, this verification/validation step is completed, but not necessarily to the required level to control the risk. This step is crucial to finish the cycle of the risk assessment and adequately define further control steps or other limits as needed.
Even though the HACCP method was first established more than 60 years ago, this science-based, systematic approach and risk assessment tool continues to provide a valuable process for manufacturers. By effectively identifying and controlling risks through the production process, the method can help ensure that food is safe. It also helps companies reduce the risk of product recalls and damage to their brands, saving them those costs and ensuring consumer trust in today’s food supply chain.