Food processes: HACCP carves a place for safety in each step
HACCP (Hazard Analysis and Critical Control Point) is crucial to keeping your food products safe. It’s a system that focuses on identifying and addressing hazards before they contaminate a food product. HACCP is implemented from the time raw materials are received to when product is shipped to consumers.
Think of a critical control point (CCP) as a step in your food process where problems are most likely to occur. Examples include cooking, cooling, or preventing cross-contamination. You’ll need to examine each CCP to identify any possible biological, chemical, or physical food safety hazards. The analysis zeroes in on the hazards that are “reasonably likely” to contaminate a food product and cause illness or injury to a consumer.
Before a new food product can be made, it must undergo this rigorous examination. You’ll then put food safety measures into place to eliminate or control these hazards.
Covered establishments
Certain types of food processors and establishments must have a HACCP plan. They're required by the:
- Food and Drug Administration (FDA) for seafood (21 CFR 123) and juice processors (21 CFR 120), and
- U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) for meat, poultry, and processed egg product establishments (9 CFR 417).
Getting started
HACCP plans can only be developed by individuals who have completed standardized HACCP training. Before developing and implementing a written HACCP plan, you must:
- Conduct a hazard analysis to identify and evaluate all of the potential biological, chemical, and physical food safety hazards associated with each step in your production process for each product made. Steps include receiving, storage, mixing, cooking, cooling, etc.
- Determine which hazards are likely to cause illness or injury if they’re not properly controlled.
FSIS-covered operations (meat, poultry, and processed egg products) also must create a flow chart that shows each step in how your product moves through the facility, from raw materials to the finished item. This helps everyone see the full process in order. Be sure to describe in the flow chart how the final product will be used and who the intended consumers are.
Drafting the HACCP plan
You could say the HACCP plan, itself, is the “meat and potatoes” of your food safety efforts. Certain plan elements must be included though. At a minimum, your HACCP plan must:
- List the food safety hazards (identified in the hazard analysis) that must be controlled for each process;
- List the CCPs for each of the identified food safety hazards, including, as appropriate, CCPs designed to control food safety hazards that:
- Could be introduced inside your establishment; and
- Are introduced outside your establishment, including those that occur before, during, and after entry into your establishment;
- List the critical limits that must be met at each of the CCPs. At the very least, critical limits must be designed to ensure that applicable targets or performance standards are met;
- List the procedures that will be used to monitor each of the CCPs to ensure compliance with the critical limits, and include the frequency you will perform those procedures;
- Include all corrective actions you’ll follow in response to any deviation from a critical limit at a CCP;
- Provide for a recordkeeping system that documents actual values and observations found during CCP monitoring; and
- List the verification procedures that your establishment will use and the frequency you will perform those procedures.
Your written HACCP plan is not complete unless it’s signed and dated. For FSIS-covered facilities this must be done by a “responsible establishment official.” This is defined under 9 CFR 417 as “the individual with overall authority on-site or a higher level official of the establishment.” The signature indicates that your establishment accepts and will implement the HACCP plan. The plan must be dated and signed:
- Upon initial acceptance,
- Upon any modification, and
- At least annually upon reassessment.
HACCP plans for seafood and juice processors must be signed and dated by "the most responsible individual onsite at the processing facility or by a higher level official of the processor." The plan must be dated and signed:
- Upon initial acceptance,
- Upon any modification, and
- Upon verification and validation in accordance with 21 CFR 120.11.21 (juice processors) and 21 CFR 123.8(a)(1) (seafood processors).
Key to remember: HACCP plans are required for certain food processors. By identifying food safety hazards, controlling them at the right points, and maintaining clear monitoring, corrective action, and verification practices, your food establishment can consistently protect consumers and meet regulatory expectations.
