It is important to communicate early and often with the regulatory personnel who will be overseeing a HACCP plan. What the HACCP committee might have learned about HACCP plan writing and HACCP implementation in a HACCP training course may or may not apply to your specific regulatory situation. It is important to acquaint your inspector(s) with your plan early and not surprise anyone with challenges at the eleventh hour.
Once Critical Control Points (CCP) have been identified, it is important to introduce the HACCP plan to existing employees and to do a mock implementation as far ahead of an implementation deadline as possible. Most companies find that their HACCP plan changes dramatically from what was originally on paper to what is feasible to do in an actual operation. Everything from CCP to monitoring procedures is likely to change in a HACCP plan during a mock implementation.
As with any major change, expect that some employees may be resistant to the HACCP process, and that some of the planned monitoring and verification procedures may be difficult to accomplish with the time that employees have available. Mock implementation will likely lead to even more changes, but it is wise to work through these rough spots before you are expected to comply with a regulatory deadline.
Employee training will be very necessary when implementing a HACCP plan. Employees may have only been told to go do something in the past, without knowing exactly why. With HACCP, employees need to understand how their performance (both processing and CCP monitoring) impacts the safety of the food product that they are working with, and the importance of accuracy and honesty in monitoring CCP.
If you don’t already have a lot identification system established, you may need to develop one before you can operate under HACCP. Lot identification is another process that will likely evolve tremendously during a mock implementation. The requirements for lot identification/coding may be found in Appendix 9 (see page 119).
See Appendix 10: Final HACCP Plan — which contains an outline of the material to be included in a completed HACCP Plan manual.