Introduction to HACCP Principles

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Introduction to HACCP Principles

• Lynn Knipe
• Animal Sciences 555.02
• The Ohio State University

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Why HACCP Training?

• CFR417.7(b) states individual(developing
  HACCP plans) shall have successfully completed a
  course of instruction of the seven HACCP
  principles to meat or poultry processing

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Why HACCP Training?

• HACCP mandated for large meat poultry plants
  Jan. 98, small plants - Jan. 99, very small
  plants- Jan. 00, under MegaReg.

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Why HACCP Training?

• Seafood HACCP - FDA mandated Dec. 18, 1997
• HACCP recommended for establishments inspected
  under 2003 FDA Food Code.
• Frozen Dairy Processors, ODA Division of Dairy.

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Why HACCP?

• Consumers expecting more from foods.
• New products present new food safety
  challenges.
• Previous meat poultry inspection needed
  updating.

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HACCP Summary

• Preventive system for assuring safe food
  pro- duction, before it is too late.
• Applicable to all phases of food production.
• Control of factors affecting
  ingredients, process product.

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HACCP programs are built upon

• Existing regulations guidelines
• SSOPs
• GMPs
• Employee training

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Pre-HACCP Steps

• Assemble HACCP Team.
• Describe Product.
• First page of handout (also p. 38877)
• Develop List of Ingredients nitrites, peanuts,
  milk proteins
• Develop Flow Chart.
• steps listed in column 1 of Form A (Handout)

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• FSIS HACCP Processing Categories
• slaughter
• raw product-ground
• raw product-not ground
• thermally processed - sterile
• not heat treated - shelf stable
• heat treated - shelf stable
• fully cooked - not shelf stable
• heat treated/not fully cooked/not shelf stable

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HACCP Principle 1Conduct a Hazard Analysis

• to determine the food safety hazardshistorical
  ly have occurredreasonable possibility that it
  will occurin absence of controls.. CFR9 Part
  417.2(a)(1)
• Column 2 of Form A (handout)

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Types of Potential Hazards

• Biological - L. monocytogenes, Salmonella, E.
  coli 0157H7, etc.
• Chemical - cleaners, restricted ingredients,
  allergens, antibiotics
• Physical - glass, metal, bone, needles, shot,
  ear tags

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Determine Likelihood of Hazard Occurrence

• Risk Assessment.
• Chemical physical hazards.
• experience plant history may justify
• Biological hazards need documentation.
• pathogen test results, SSOP records, other
  records, scientific publications.
• not written GMPs!

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Preventive Measures to Control a Hazard

• 1. Prevent contamination
• Letters of guarantee
• 2. Cook or sterilize to destroy pathogens.
• 3. Time/temperature control to prevent
  multiplication of pathogens.

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Preventive Measures (Continued)

• 4. Ferment to prevent multiplication of
  pathogens.
• 5. Airflow to prevent environmental
  contamination.
• 6. Metal detectors.
• 7. Bone removal systems.

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HACCP Principle 2 Identify Critical Control
Points in the Process
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A CCP is

• the last point where control can (or is needed
  to) prevent, reduce or eliminate hazards to
  acceptable levels.
• Last column of Form A.

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CCP Examples

• Raw product temperature
• Cooking
• Chilling of cooked product
• Slaughter - fecal contamination
• Product formula nitrites, allergens
• pH adjustment
• L. monocytogenes control -fully cooked, RTE
• Hot holding

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HACCP Principle 3 Establish Critical Limits
for Preventive (Control) Measures Associated with
Identified CCPs

• critical limits shall ensure thatapplicable
  performance targets estab-lished by FSISare met
  - CFR9 Part 417.2(c)(3)

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• CLs are criterion that must be met for each
  preventive measure.
• If exceeded, or not met, product is considered
  adulterated.
• (Optional) Set targets (operating limits), to
  minimize HACCP deviations.
• Start with applicable regulations or
  guidelines.

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Critical limits must be

• based upon scientifically determined
  parameters.
• quantifiable
• , ºF, pH, defects, minutes, CFUs/gm?
• specific (not ranges)
• What cannot be measured, cannot be
  controlled.

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Critical Limit Examples

• Temperatures and times
• salt
• Water activity, Aw
• pH or acidity
• visual appearance?
• hand washing?
• microbial standards?

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HACCP Principle 4 Establish CCP Monitoring
Procedures

• Planned sequence of observations or
  measurements
• to assess whether or not a CCP is under
  control
• ...and to produce a record to verify process.

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Monitoring Frequency

• Continuous monitoring.
• ideal system
• thermocouple or pH probe w/chart recorder
• Monitoring at established intervals.
• manual check every X hr(s)/shift.
• Frequency How much out of compliance product
  are you able to hold?

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Monitoring Responsibility

• Assign responsibility to management or
  production worker?
• Training needed in monitoring method, purpose
  of monitoring, importance of accuracy.
• Records/documents initialed by person
  monitoring.

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Monitoring Responsibility

• Note unusual circumstances.
• Report deviations immediately.

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Monitoring Options

• Actual product monitoring.
• accuracy
• labor intensity
• cross contamination
• Process monitoring
• monitor ovens, coolers, etc.
• continuous recording charts.

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HACCP Principle 5 Describe Corrective Actions

• to be taken when there is a deviation (out of
  compliance or control) from an established
  critical limit.
• Four parts of 417.3(a) (p. 38870, Federal
  Register)

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Corrective Action Plans to Ensure

• ...cause of deviation I.D.ed eliminated.
• CCPunder control...

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Principle 6 Establish Procedures to Verify
that the HACCP System is Working Correctly
(417.4)

• Verification is to a HACCP plan, what
  monitoring is to a CCP.
• Includes initial validation on-going
  verification.

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Initial Validation

• Demonstrate that your HACCP plan is adequate to
  prevent, reduce or eliminate hazards.
• New establishments or new product categories
  90 day trial period to validate.
• Generate and review records.
• Scientific documentation.

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On-Going Verification

• Demonstrate that your HACCP plan is working as
  you intended.
• Ensure that employees are following your
  established procedures for record keeping
  handling product deviations.

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Verification Must Include

• Review of records generated by the HACCP plan.
• Direct observations of the monitoring and
  corrective actions.
• Calibration of monitoring instruments/equipment.

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Reassessment

• Verify that all significant hazards have a CCP
  
• confirm CLs are appropriate
• establish that corrective actions are in place
  and effective
• Total reassessment 1x/yr.

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HACCP System Reassessment Triggers

• new information concerning product safety
• monitoring results
• product link to outbreak
• system modified -
  formulation, processing, distribution
  consumer use

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Pre-Shipment Review

• Must be completed before product is shipped.
• Do ASAP after monitoring.
• Requires lot numbers on products.
• Requires signature.

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Lot ID could be based upon

• full sanitation to full sanitation (FSIS)
• day, shift, 1/2 day (Julian)
• slaughter, cutting
• common ingredients
• mixer batch, brine batch
• sublot by stuffer, oven, etc.

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Lot Identification

• First, ID your product lots
• Later, tie lot information of received product
  to lot information of products you produce.
• Do mock recalls to test system.

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Verification Summary

• Direct observation record review of
  monitoring corrective actions
• Equipment calibration
• Reassess plan
• Designate position (person) frequency.

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HACCP Principle 7 Establish effective record
keeping procedures

• ...only reference available to trace product
  history
• and actions taken to prevent a problem
• ...assist in case of a recall.

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HACCP Records

• Monitoring records
• Deviation/corrective action records
• Verification/pre-shipment review records

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HACCP Records

• Retention of records
• 1 year for unfrozen
• 2 years for frozen
• Store off site after 6 mos.
• Regulatory access in 24 hr.