Oct. 16, 2012
by Kerri Harris and Jeffrey Savell
In the Seven Principles of HACCP (Hazard Analysis & Critical Control Points), all principles are important, but one principle really has the opportunity to provide key learnings about a process, and that is Principle 5: “Establish Corrective Actions.” Corrective actions are to be used when there is a deviation from a critical limit at a critical control point (CCP) or when there is an unforeseen food safety hazard. A deviation from a critical limit is a place where something goes wrong in the process and typically both the products and processes have to be corrected so that manufacturing of safe food can continue.
At least in the US and over the past several decades, the National Advisory Committee on Microbiological Criteria for Foods has been the group that has taken responsibility for the development of the HACCP principles and their guidelines for application. The most recent scientific article on this was published in the Journal of Food Protection based on the principles and guidelines adopted by the committee on Aug. 14, 1997. Among the key points the committee made about Corrective Actions was that the goal of HACCP is to prevent, eliminate, or reduce the occurrence of health hazards in foods. Also, that sometimes ideal circumstances do not always prevail resulting in deviations.
A major purpose of corrective actions is to prevent hazardous foods from reaching the consumer.
The committee stated that corrective actions should include the following elements: (a) determine and correct the cause of noncompliance; (b) determine the disposition of noncompliant product; and (c) record the corrective actions that have been taken. The committee also stated that “the HACCP plan should specify what is done when a deviation occurs, who is responsible for implementing the corrective actions, and that a record of the actions taken will be developed and maintained.” When we were first taught HACCP early in our careers and then began teaching it in the 1990s, we spent considerable time working to develop specific corrective actions for a wide variety of possible deviations that may occur. We called it the “what if” game, and we tried to predict all of the possible deviations and responses. Several years after the release of the HACCP regulation, we were still urging those who we taught to develop very specific corrective actions for possible deviations until we worked more closely with agency officials who kept reminding both us and the establishment personnel that it was not necessary to have this predetermined set of corrective actions ready for a deviation to occur.
So, what was different about corrective actions between the two documents, the National Advisory Committee’s principles and guidelines and the HACCP regulation? By now, those who work closely with HACCP in meat and poultry establishments know that CFR 9, §417.3(a) requires four specific actions: “(1) the cause of the deviation is identified and eliminated, (2) the CCP will be brought under control when the corrective action is taken, (3) measures to prevent recurrence are established, and (4) no product that is injurious or otherwise adulterated as a result of this deviation enters commerce.” What the regulation required was a response to these four parts – statements to how the establishment handled these four areas – not pre-described responses to all possible reasons that corrective actions needed to be taken. Teaching corrective actions became very easy: just learn the four parts of §417.3(a) and develop a form to respond to them and be done with it on the oft occasion that there was a deviation. While this approach is correct and will meet the necessary regulatory requirements, meat and poultry establishments may not have benefitted from the key learnings that can arise when corrective actions have to be taken.
So, what are the opportunities to learn from corrective actions? If nothing else, there are two areas that warrant deeper thoughts rather than filling out a form and getting production back up and running. One area for more in-depth learning is the “cause of the deviation” rather than the deviation itself. Some causes are easily determined and can be corrected readily; however, some causes are more difficult to discover and require deeper and more thought-provoking analysis. The second area is the “measures to prevent recurrence.” For some deviations, especially those in continuous processes, mechanical failure is often the cause of the deviation and some form of prescribed maintenance may serve as the measure to prevent the recurrence. Where it gets interesting is in batch processes where human error often is the cause of the deviation and “retraining” is listed as the measure to prevent recurrence. If you have been a HACCP coordinator for any time, you have most likely used the “Thesaurus approach” to figure a better word for “retraining,” especially after it has been used for the 15th time for the same problem.
How can you learn about your process with corrective actions? For these two areas, “causes” and “preventing recurrence,” there is a wealth of information that one should use to ensure control by improving processes and procedures. How often does the HACCP team sit down and really study the corrective actions taken? How often does the team study what really caused the deviations? For many, taking corrective actions becomes a necessary response to a deviation at a critical limit to fulfill regulatory obligations without using this opportunity to learn, improve, and refine processes. The old adages that we learn from our mistakes should apply. Learning from corrective actions may be one of the best educational opportunities we can receive, even though during the moment of battle, we had rather not be in this class at school!