EGG PROCESSING SAFETY, QUALITY AND SECURITY
Location: Egg Safety and Quality
Title: The Principles of HACCP
Submitted to: National Egg Quality School Proceedings
Publication Type: Proceedings
Publication Acceptance Date: April 18, 2009
Publication Date: May 28, 2009
Citation: Jones, D.R. 2009. The Principles of HACCP. National Egg Quality School Proceedings. VI:9-12.
HACCP is an acronym for Hazard Analysis and Critical Control Point and was initially developed by the Pillsbury Company and NASA. They utilized this program to enhance the safety of the food for manned space flights. The USDA-FSIS implemented the HACCP approach to food safety in the meat and poultry industries beginning in 1998. An assessment of the program was published by the Office of the Inspector General in June 2000. (http://www.usda.gov/oig/rptsauditsfsis.htm) HACCP is a food safety program. It is not meant to deal with quality issues directly. Quality assurance programs should handle those issues. There are potential changes on the horizon for meat and poultry HACCP. You can stay informed about these changes by visiting: http://www.fsis.usda.gov/Regulations_&_Policies/index.asp.
There are several prerequisite programs associated with HACCP. As previously discussed, Standard Sanitation Operating Procedures (SSOPs) and Good Manufacturing Practices (GMPs) are examples of prerequisite programs. Development of a flow diagram, product descriptions, and product ingredient lists are also examples of prerequisite information needed to successfully develop a HACCP plan. It is important to remember that they are not principles of HACCP.
Before beginning any HACCP process, a flow diagram of the process should be developed. Assessment of hazards can be performed easiest with the aid of a flow diagram. Be sure to include not only where ingredients enter the process, but also packaging materials and product storage. Once the flow chart is complete, it is a good idea to walk through the processing line to review the diagram. It is very easy to overlook a step when it is process you work with everyday. It is also a good idea to have someone else review the flow diagram to ensure that your process is clearly represented. If an inspector or auditor ever needs to refer to the flow diagram, you want to make sure they understand what it says.
The flow diagram does not need to be professionally drawn. It should be clear, concise, and convey the complete process being described. Don’t forget to include shipping and receiving in the flow chart. An example can be seen in Figure 1.
Figure 1. Flow chart example.
There are seven principles of HACCP. They are as follows:
1) Assess hazards
2) Determine critical control points
3) Set critical limits
4) Monitor critical control points
5) Corrective actions
6) Record keeping
Principle 1. Assess hazards.
After designing the flow diagram, you then need to assess each step on the flow diagram for potential hazards. There are three types of identified hazards in HACCP: physical, chemical, and biological. A physical hazard is any item, usually visible, which can cause physical harm to a consumer. An example of a physical hazard would be metal shavings, wood fragments, glass, etc. A chemical hazard is defined as a chemical substance that could cause harm to the consumer or is not declared on the label. Machine oil, pesticides, insecticides, and sanitizer residue are all examples of chemical hazards. A biological hazard is one which could cause the consumer to become ill or promote the growth of pathogens in the product. Examples of biological hazards include: cooked product contacting raw product, inadequate thermal processing, and inadequate storage temperatures.
Principle 2. Identify critical control points.
A critical control point (CCP) is a point in the process where a hazard can and must be controlled to reduce or eliminate a hazard. To determine if an identified hazard is a CCP, you must first rank the risk and severity of the hazard. A “decision tree” can then be utilized to determine, based on the risk and severity, if the hazard is a CCP. There are several sources where example forms for risk and severity, along with decision trees, can be found. It is important to realize that some decision trees are extremely complicated. Others do not necessarily suit all processes. For this reason, find a decision tree that you and your employees can utilize and understand. One source would be:
Principle 3. Establish critical limits.
The critical limit is the allowable range of a hazard for which the product would still be considered safe. Critical limits should ensure the safety of the product, but they should also be at a level you can consistently meet during normal processing. An example would be cooler temperature. You have identified the post-processing cooler as a CCP. You have set your critical limit at 42F, but you have trouble consistently maintaining your cooler at 42F. This would not be a wise limit, because when you exceed your limit, all product produced since the last measurement of the CCP is considered “suspect product.” Furthermore, if you are consistently failing to meet your established critical limit, your plan could be ruled ineffective.
If a regulatory limit exists for your CCP, you can use this level as your critical limit. In the example from above, the regulation for post-processing cooler temperature is 45F. By setting your critical limit at 42F, you have now re-written the regulation for yourself. There are instances when a company may decide to make their own regulations more stringent for quality or marketing purposes. I would stress that you should investigate any potential regulations that exist to ensure that you meet these regulations. You should weigh your own options as to if you should make these requirements more intense.
Principle 4. Monitoring.
At this point, monitoring procedures have to be established for each CCP/critical limit. This is when you determine if a critical limit has been exceeded. It is important for monitoring measurements to be quick and accurate. Using our cooler temperature example, obviously the use of a thermometer would be appropriate. It can be quickly read and fast-read models are able to measure temperature rapidly. The thermometer being used should be calibrated frequently to ensure that recorded temperatures are accurate. Other examples of monitoring devises include pH meters/paper, temperature chart recorders, and metal detectors.
When monitoring a biological hazard, microbial plate counts are not effective because these methods generally take 48 h or longer. All product would have to be held for this time period. If a critical limit was exceeded, an even longer period of time would be required to correct the situation.
It is extremely important to write detailed descriptions of the monitoring activity. In other words, exactly who, what, when, where, and how the monitoring should take place. The written descriptions should allow for anyone to understand the precise monitoring activity. All employees who will be taking monitoring measurements should be properly trained and this should be documented in your records.
Principle 5. Establish corrective actions.
Corrective actions are the actions that should be taken if a critical limit is exceeded. In other words, what are you going to do to make the product safe again? At this point in developing your HACCP plan, you may decide that your critical limit and monitoring technique are not appropriate. That is fine. You will then need to go back and establish acceptable measures. Adding additional detergent to a washer if pH falls below 10 would be an acceptable corrective action. You also need to have plans available to tell employees what to do with the suspect product.
Once you have performed a corrective action, you need to document it. On this document you should include: what critical limit was exceeded, how it was corrected, the date of the activity, the product effected (i.e. lot number(s)), what was done with the suspect product, and how to prevent the act from occurring again. All employees con