Ensuring Safe Food — A HACCP-Based Plan for Ensuring Food Safety in Retail Establishments

Bulletin 901

Chapter 6 — The Seven HACCP Principles

The regulation defines a food safety hazard as “any biological, chemical, or physical property that may cause a food to be unsafe for human consumption.”

The hazard analysis shall include ONLY food safety hazards.

The regulation defines a food safety hazard as “any biological, chemical, or physical property that may cause a food to be unsafe for human consumption.”

The hazard analysis shall include ONLY food safety hazards.

• A Critical Control Point (CCP) is defined as “a point, step, or procedure in a food process at which control can be applied and, as a result, a food-safety hazard can be prevented, eliminated, or reduced to acceptable levels.”
• For every significant hazard identified, there must be at least one corresponding CCP to control the hazard, although more than one hazard may be controlled at a CCP.
• Is this step a Critical Control Point (CCP)? The Critical Control Point may be at the point where the hazard occurs or at a later step.

The regulation defines critical limit as “the maximum or minimum value to which a physical, biological, or chemical hazard must be controlled at a Critical Control Point to prevent, eliminate, or reduce to an acceptable level the occurrence of the identified food safety hazard.”

Critical limits are expressed as numbers or specific parameters based on visual observation, such as:

• Temperature — 155°F
• Time — 20 minutes

Monitoring is a planned sequence of observations or measurements to assess whether a CCP is under control and to produce an accurate record for future use in verification.

Monitoring will go much more smoothly if management:

• Monitors Critical Limits Values for What, How, Frequency, and Who.
• Identifies clearly the employee positions responsible for monitoring.
• Trains employees monitoring the CCP in the testing procedures, the critical limits established, the methods of recording test results, and the actions to be taken when critical limits are exceeded.
• Ensures that the employees understand the purpose and the importance of monitoring.

The regulation defines corrective action as “procedures to be followed when a deviation occurs.” A deviation is a failure to meet a critical limit.

HACCP is a preventive system to correct problems before they affect the safety of the food.

The corrective actions are to ensure that:

• The cause of the deviation is identified and eliminated.
• The CCP will be under control after the corrective action is taken.
• Measures to prevent recurrence are established.
• No product that is injurious to health or otherwise adulterated as a result of the deviation is distributed for human consumption.

The Corrective Actions may be included in forms that are created to address:

• The cause of the deviation so that it can be identified and eliminated.
• The CCP so it will be under control after the corrective action is taken.
• The establishment of appropriate measures so that a recurrence may be avoided.
• The affected food so that no product that would be injurious to health or otherwise adulterated as a result of the deviation is allowed to enter commerce.

• Simply stated, the HACCP team needs to verify that the HACCP system is working the way it is expected to work.
• By doing these verifications, the establishment will initially evaluate the operation of the HACCP system and then maintain an updated and effective HACCP system.
• Verification may be broken down into three categories:
  
  1. Validation
  2. Verification
  3. Reassessment

  Validation — Test that the process with the Critical Limits prevent, eliminate, or reduce the hazard to an acceptable level. If a hot deli serving table is to maintain food above 140ºF, then validate that it does.

  Verification — Assure that all required information is written down and documented. If cleaning of equipment is stated in the Hazard Analysis, then check that cleaning is done. Do what you say and say what you do. Verify the written statements.

  Reassessment —
  
  • Do at least annually.
  • Consider potential new hazards.
  • Examine changes in the preparation, raw materials or raw ingredients, personnel, packaging of the finished product, or any other changes that could affect the hazard analysis.

Maintaining proper HACCP records is an essential part of the HACCP system. Good HACCP records — meaning that the records are accurate and complete — can be very helpful because:

• Records serve as written documentation of the establishment’s compliance with its HACCP plan.
• Records allow the retail facility to trace the history of an ingredient, in-process operations, or a finished product should problems arise.
• Records help identify trends in a particular operation that could result in a deviation if not corrected.
• Records could help identify and narrow the scope of a recall in the event a product recall becomes necessary.
• Records that are well-maintained are good evidence in potential legal actions against an establishment.
• There may be new HACCP team members and the rationale for certain decisions is forgotten.

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