May 23, 2012
by Kerri Harris and Jeffrey Savell
In 1994, as the US Dept. of Agriculture’s Food Safety and Inspection Service personnel discussed plans for mandating Hazard Analysis and Critical Control Point systems for meat and poultry establishments, industry representatives and educators discussed the need for industry training. The founding members of the International HACCP Alliance were proactive and recognized the need for standardizing HACCP training. They developed a process for accrediting training programs and approving lead instructors.
To date, more than 60,000 names are listed in the registry of individuals who have completed an Alliance-accredited training program and the number continues to increase. Because HACCP is a dynamic system, it is important to look back at training to see how it has evolved, as well as to think about future training needs.
Although the industry started training before the Final Rule on Pathogen Reduction and Hazard Analysis and Critical Control Point Systems was released on July 25, 1996, the rule did provide specific training requirements.
According to 9 CFR §417.7 Training:
a) Only an individual who has met the requirements of paragraph (b) of this section, but who need not be an employee of the establishment, shall be permitted to perform the following functions:
1) Development of the HACCP plan, in accordance with §417.2(b) of this part, which could include adapting a generic model that is appropriate for the specific product; and
2) Reassessment and modification of the HACCP plan, in accordance with §417.3 of this part.
(b) The individual performing the functions listed iN paragraph (a) of this section shall have successfully completed a course of instruction in the application of the seven HACCP principles to meat or poultry product processing, including a segment on the development of a HACCP plan for a specific product and on record review.
Some companies chose to train at least one employee, while others decided to work with consultants or other individuals who met the training requirements. Either way, a “trained” individual should have been responsible for developing, reassessing and modifying the HACCP programs. The initial demand for HACCP training was tremendous, and most of the two-and-a-half to three-day training programs were taught for specific process categories (i.e., beef slaughter; poultry slaughter; or raw, not ground).
Today, the majority of “public” HACCP courses are no longer restricted to a specific-process category, and the number of “company-specific” HACCP courses has increased, allowing participants to more openly discuss plant-specific issues.
Although the number of people trained per year has fluctuated, the demand for training still continues. Since the HACCP principles have not changed, some people have questioned why HACCP training is still needed.
We believe there are several reasons HACCP training has and should continue. One of the primary reasons is employee turnover. We have taught classes for many years, and for some companies we train a new HACCP person every year or two due to changes in job duties within the company or people leaving the company.
New hires due to growth and expansion is another reason companies continue to send people to training. Although there is no regulatory requirement for continuing education, we do get a significant number of repeat participants. These individuals re-take the course every few years to fulfill audit requirements, to refresh their knowledge or to find out if anything has changed from the last time they took a course.
Most courses cover the same basic topics that were covered in the mid-1990s, but as our understanding of developing and implementing HACCP has changed, the examples and stories of what has and what has not worked have changed.
Instructors typically have a better understanding of how to help establishments design scientifically supportable HACCP/food-safety programs that will comply with current regulatory requirements and expectations, which have evolved.
Courses are now offered that cover more than the seven principles and basic steps required to develop a HACCP program. Today, individuals can take “advanced” HACCP courses. Some of these courses focus specifically on verification and validation, while others address reassessing the HACCP programs and supporting decisions made during initial development. Other courses are designed to address specific biological hazards, such as dealing with Listeria monocytogenes in post-lethality exposed, ready-to-eat products or with E. coli O157:H7 in non-intact beef products.
Years ago, we started offering a course called “Beyond Basics: HACCP Plan Improvement.” All participants must bring at least one HACCP plan with them, and we walk through all aspects of their food-safety system. This class is designed for a few people at a time so that individual attention can be paid to each participant. The goal of the course is to ensure that participants are able to support and defend their programs. Most attendees of this class say they wished they had taken it before they had a Food Safety Assessment or third-party audit of their food-safety system.
Over the years, we have faced many challenges in training people in HACCP. Some of the challenges seem simple – like are weekdays or weekends best for industry personnel? Management often wants the training on weekends to ensure employees do not have to miss work. However, employees who are forced to give up their free time to participate in training over a weekend often are frustrated and end up being more focused on when the class will end rather than learning the material.
For companies with multiple shifts, it is also a challenge to teach individuals who have worked the late shift and come straight to class. Also, educational background varies widely among participants so using teaching methods that are appropriate for everyone can be a struggle at times. Some participants have only worked in the food industry for a short time, so they are overwhelmed with the terminology and the acronyms so easily thrown out by us.
Language can also be a barrier in instruction. A simple solution might be to offer the separate trainings, but it is often difficult to assemble a large enough class that would warrant instruction in a specific language.
Sometimes having individuals from different companies in the same class is challenging because they do not want to openly share in the discussion. But having multiple people from the same company in a HACCP course may limit discussions and the opportunity for some to ask questions because they may worry about being scrutinized by their co-workers.
Finally, having supervisors and employees together in the same class may lead to a similar discomfort where people may feel intimidated to really open up and participate during the lectures and breakout session.
As we think about the future, we expect that some courses will be offered on-line rather than in the traditional classroom. These may include dissemination via web-only methods or the use of videoconferencing technologies to create a “virtual” classroom. As educators, our job is to ensure training is designed to meet the participants’ needs; otherwise we are wasting their time and our time.
Giving employees the best opportunity to excel in the workplace begins with providing the best tools to succeed. This usually begins with the Introductory HACCP course, which is designed to introduce the Seven Principles and explain the basic steps in developing a HACCP system.
This may not be like basic training in the military, but it has been a rite of passage for thousands of food-safety professionals for nearly two decades.