HACCP and more

by Kerri Harris and Jeffery Savell
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It often seems like the further we go with Hazard Analysis and Critical Control Point (HACCP) and food-safety programs, the farther away from the basic HACCP principles we get and the less confident we are in our programs. We are often asked what are the top things an establishment should consider when developing or reassessing their food-safety and HACCP programs.

1) Understand your process- No one should know more about your process than you do. It is your responsibility to know what is and is not working. You must understand that a successful food-safety program is more than just a HACCP plan; it is a total system. It includes pre-requisite programs that address the facility, the employee practices and the overall operation.

During introductory HACCP training, we tell participants they need to have well-defined-and-implemented pre-requisite programs before they try to develop and implement a HACCP plan. Without a solid foundation, the HACCP system will fail. This means the facility and equipment must be maintained in a manner that prevents the development of insanitary conditions. It means that employees must be properly trained and clearly understand their roles in the food-safety system. Employee practices are critical to the success of any program. It means the overall operation – production practices, pest control, supplier approvals, employee training, preventive maintenance and other programs – should strengthen the food-safety program rather than detract from it.

HACCP is facility- and product/process-specific. When developed correctly, it is a systematic and preventive approach to food safety that is adaptive, dynamic and flexible. But HACCP is only as good as the science behind it and the information that we use to support our decisions. HACCP is not, and should not be, a stand-alone program. HACCP is not a tool to manage the entire facility. And, having a HACCP plan is not a guarantee of food safety.

Therefore, it is imperative to know the entire process and how all of the programs are integrated to ensure the most solid approach possible. Each process has its own set of unique characteristics, so the food-safety system must also have its own set of unique characteristics. Food safety is not a “one-size-fits-all” approach.

2) Know regulations, policies and agency expectations- HACCP regulations have not changed since introduced in July 1996. However, there is still confusion or lack of understanding over certain parts of it like the definition of a reasonably likely to occur food-safety hazard, or the requirements for initial validation or which decisions require supporting documents.

This confusion or lack of understanding is not limited to industry personnel, but it is also an issue for agency personnel or third-party auditors. We believe that everyone should understand the actual meaning of the HACCP regulation not just be able to recite the various sections.

In addition, other regulations have been released since then as well as policy changes over the last several years. For example, the agency expanded its policy for classifying E. coli O157:H7 as an adulterant in ground beef to include all non-intact beef products, and then it recently included six additional Shiga-toxin producing E. coli as adulterants in raw, non-intact beef products. It also released information about sampling and testing expectations. So, while the HACCP regulation has not changed, each establishment must be able to keep up with new regulations, policy changes and agency expectations or their food-safety programs will be lagging behind.

Another twist is the unique set of food-safety requirements expected by your customers or by third-party auditing bodies. These requirements may go above and beyond agency requirements, and in some instances they may differ from agency requirements. It is easy for an establishment to lose ownership of its food-safety programs, and for agency personnel and/or auditors to take control and tell the establishment what should be included in their HACCP/food safety program. Unfortunately, the establishment is often “between a rock and a hard place” because they must be able to make both the agency and the auditors happy, while trying to maintain some control over their programs.

3) Communicate with your suppliers and understand their food-safety programs- Technology has made the sharing of information easier than ever. You can communicate with your supplier the old-fashioned ways such as face-to-face or via telephone or fax, or you can use more modern techniques, like the Internet and email, or even tools, like texting, Twitter, Instagram or even snap-chat and vine.

Regardless of the method, communication with your suppliers is important. If you do not communicate with them on a regular basis, then you could possibly make inaccurate assumptions or incorrect decisions based your understanding of their programs. These faulty decisions could jeopardize your food-safety program.

From the beginning, our industry has been willing to openly share and discuss food-safety programs and decisions because a food-safety failure in one establishment often has a detrimental impact on the entire industry. Therefore, the industry has worked together to enhance food safety. So, look at the information provided by many suppliers on their websites, and if you are not able to find the information do not hesitate to contact them about their food-safety programs. You can also ask them about what works and does not work for specific processes.

4) Communicate with your customers and understand the intended use of products you are supplying to them- Just as it is important for you to know what your suppliers are doing, it is equally important for you to communicate with your customers and to understand how the products will be used. Large companies typically have only a few processes (e.g., slaughter; raw, not ground; raw, ground) in a single facility. However, smaller operations often have multiple processes (e.g., slaughter; raw, not ground; raw, ground; heat treated, not fully cooked; fully cooked, not shelf-stable; fully cooked, shelf-stable). Therefore, these further processors may be using a single raw material across multiple process categories.

Your initial thought might be it is not your concern how they use your products, but we challenge you to think differently. The manner in which they use the products that you supply to them could potentially impact your operation. If you have an understanding of how they are using the raw materials, then you may be able to offer suggestions on how to purchase and or lot product to minimize the risk of implicating products across multiple process categories.

5) Ensure your “hold-and-test” and recall programs are effective- In today’s environment, raw materials and/or finished products are being tested at multiple levels – the supplier may test trim; the grinder may test finished products; or the cook operator may test raw materials and finished products. Regardless of the location in the chain, the establishment should have a hold-and-test program in place. Notice, “hold” comes first. This means that you should never take a sample – or allow the agency to take a sample – if you are not able to hold all products that would be impacted by a positive test result. Identifying the impacted product is often a complicated process. It requires the establishment to have a complete understanding of all raw materials coming in and finished products going out.

Defining a “test lot” that would be implicated by a positive test is often different than defining a “production lot.” So, if you are uncertain how to determine the raw materials and finished products that would be implicated, we encourage you to ask for help now rather than waiting until you have a positive test and find out you did not hold the correct products.

We also encourage you to think of every sample as positive and treat/hold the associated raw materials and finished products accordingly, until you receive a negative test result. This recommendation is consistent with FSIS’ regulation that requires producers to hold shipments of non-intact raw beef and all ready-to-eat products containing meat and poultry until they pass agency testing for foodborne adulterants. Along with proper hold-and-test procedures, it is important for your company to have an effective recall program. This means that you should develop the program and conduct mock recalls to ensure that it works. Make sure you consider all ingredients, packaging and other items. As of May 8, 2013, all establishments, including small and very small establishments, should have a written recall procedure.

While there are many other important aspects of a HACCP/food-safety program, these are ones that we believe top the list based on our experiences. Following these five key areas will help your company be successful in producing safe food and being in compliance with all existing food- safety regulations.

Kerri Harris is president/CEO of the International HACCP Alliance and is an associate professor in the Dept. of Animal Science at Texas A&M Univ. Jeff Savell is Regents Professor and E.M. “Manny” Rosenthal Chairholder in the Dept. of Animal Science at Texas A&M Univ.
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