Your guide to a robust HACCP Plan

The current global food system is a complex one. Food goes through a number of steps including processing, shipping, prepping, and more before it reaches the consumers, and the risk of contamination is present at each of these steps.

Hazard Analysis and Critical Control Points (HACCP) is a systematic approach that relies on experience and scientific data to proactively identify biological, chemical or physical hazards, thus reducing or eliminating the likelihood of recalls.

The system can be used at all stages of the food system: from growing, processing, shipping to consumer-end tasks such as distribution or serving. Additionally, HACCP involves developing verifiable control measures, and is increasingly being implemented in the cosmetics and pharmaceuticals industries as well.

This article will talk about the evolution of HACCP, its seven principles as well as training and certifications offered to establish a comprehensive HACCP system in food facilities.

The evolution of HACCP

Origins

The origins of HACCP are traced to 1959, when NASA sought Pillsbury’s assistance in producing crumble- and pathogen-free space food. Since there was no comprehensive hazard analysis and risk assessment system in place at the time, microbiologists and food scientists began examining food items to analyze potential areas of concern and compiled a list of hazards as well as “modes of failure” to document microbiological hazards. Food manufacturers working with NASA were required to maintain robust documentation from the moment raw foods reached the plants and to identify critical control points, thus fundamentally prioritizing prevention.

This formed the skeleton of HACCP that is widely used today. Back then, it consisted of only three principles: conducting a hazard analysis, identifying critical control points, and establishing monitoring procedures.

In the 1960s, although HACCP grew as a hybrid between NASA’s documentation requirements and U.S. Army Natick Research Center’s techniques, it was still inadequate to improve food production itself and was not scalable to commercial food production practices.

HACCP was first officially introduced to the food industry at the National Conference on Food Protection in April 1971 and was later used in low-acid canned food regulations. In 1985, 25 years after HACCP was first developed, an independent report by the National Academy of Sciences (NAS) concluded that random testing of foods was inadequate and embraced HACCP as “an effective and rational approach to the assurance of safety and to the prevention or delay of spoilage in foods.”

Food Safety Modernization Act (FSMA)

In 2011, President Barack Obama signed into law FDA’s Food Safety Modernization Act (FSMA), which has come to be known as the “most sweeping reform” of U.S. food safety laws since the 1938 Federal Food, Drug, and Cosmetic Act. The Act adopted the HACCP principles and expanded them to address new pathogens that emerged in foods as well as because of the modern, global food system. It granted the FDA authority to establish and enforce food safety standards within the U.S. food system, right from farms and manufacturing and processing facilities to shippers and receivers who handle human and animal foods.

The FSMA Final Rule for Preventive Controls for Human Food requires food facilities to establish a food safety plan that includes hazard analysis and risk-based preventive controls to identify, reduce or eliminate food safety hazards.

The Role of Preventive Controls Qualified Individual (PCQI)

FSMA requires all the food and beverage facilities that are regulated by the FDA to have at least one Preventive Controls Qualified Individual (PCQI). A PCQI is a trained, experienced individual who would be responsible to oversee or conduct the development of the facility’s food safety plan, among other tasks. Thus, it is crucial for the PCQI to understand the similarities and differences between HACCP and Food Safety Plan, as well as how to identify appropriate process preventive controls (PCs) and to specify critical limits that will control identified hazards.

To become a PCQI an individual must complete training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA (or have acquired equivalent knowledge through job experience).

IEH Academy offers eLearning, virtual, as well as on-site training for the food safety industry. Their PCQI training is developed by Dr. Peyman Fatemi, Vice President of Technical and Regulatory Services at the Institute for Environmental Health. The course is offered as a virtual, live training spanning 5 days (4 hours per day). The curriculum is based on the guidelines from the Food Safety Preventive Controls Alliance (FSPCA) in conjunction with the FDA. Individuals who complete the course will receive a certificate of completion accredited by FSPCA and AFDO.

HACCP in the Food Industry

HACCP shifted determining safety of food from only finished product testing to incorporate and prioritize pre- and in-process microbiological tests at each step of the process to identify, reduce, and eliminate foodborne pathogens.

In the U.S., HACCP evolved from the initial three principles to seven, and is most prominent in three areas of the food industry. Meat HACCP systems are regulated by the United States Department of Agriculture (USDA) while seafood and juice industries are regulated by the FDA since 1995 and 2001 respectively.

Writing a HACCP plan

Writing a HACCP plan is not easy. The plan is a living document that needs to be updated as processes, equipment and personnel in a facility change. It is also extremely unique to a particular facility’s operations, and needs to reflect the specific process, products and environmental conditions.

Not everyone in a facility needs to be able to write a complete HACCP plan, however, everyone in a food facility should understand the fundamental principles behind the identification of all inputs to a manufacturing process and the hazards that are likely to be introduced, increased, or controlled during the process. A HACCP system is successful only when those involved are educated and trained about the importance of their role in safe food production.

Prerequisite programs

The FDA’s Appendix A lists common prerequisite programs upon which the HACCP system must be built. A few examples include supplier control, cleaning and sanitation, personal hygiene, and traceability and recall.

An IEH Academy course (virtual and on-site) provides in-depth information about these prerequisite programs as well as HACCP training. It also provides insights into the entire food safety program, where critical control points are required in the process as well as the importance of monitoring and record-keeping.

Preliminary Tasks

The seven HACCP principles guide you on a systematic and scientific approach to identifying, controlling and eliminating food safety hazards. Before the application of these principles, the FDA outlines five preliminary tasks to be completed.

Assemble the HACCP Team

The HACCP team is responsible for the development, implementation, and maintenance of an effective HACCP system, and needs to reflect personnel from technical, operational, and administrative departments in the company. It benefits from the presence of food microbiologists, personnel from the sanitation, maintenance, and production departments, as well as one person from higher management to invest in new equipment when necessary. Personnel who have expertise related to the specific product and process are also valuable.

Describe the food and its distribution

The HACCP team outlines the food, including descriptions of the ingredients and processing, and distribution methods used.

Weber Scientific has extensive experience in reviewing HACCP plans to make sure you are using the best products based on your HACCP plan.

Includes specific consumer categories, such as infants, elderly, etc.

Once these steps are completed, the HACCP Team is ready to apply the seven HACCP Principles. Each of the seven steps is explained in detail on the FDA’s website.

HACCP principles

Principle 1: Conduct a hazard analysis

Principle 2: Determine the critical control points (CCPs)

Principle 3: Establish critical limits

Principle 4: Establish monitoring procedures

Principle 5: Establish corrective actions

Principle 6: Establish verification procedures

Principle 7: Establish record-keeping and documentation procedures

A HACCP plan is crucial to control potential food safety hazards. Contact Weber Scientific today for a consultation regarding products needed for your HACCP plan.