33. Hazard Analysis of Critical Control Points (HACCP)

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1 33. Hazard Analysis of Critical Control Points (HACCP) John Thompson Learning objectives This lecture outlines the basis of a HACCP system for controlling potential hazards in the food industry Introduction Hazard Analysis Critical Control Point (HACCP) is a systematic approach to the control of potential hazards in food industry operations. It aims to identify problems before they occur and establish measures for their control at the stages in production that are critical to ensuring safety or quality. Control is proactive because remedial action is taken in advance. Many QA processes are HACCP based. Such processes are a key to attaining good manufacturing practices. HACCP is a preventative system in which safety is designed into food formulation and the production process. It is more effective than conventional QA which often relies on end product testing. HACCP was developed in the 1960s for foods for the US space program. According to HACCP protocols, stringent pathogen-free criteria are not verified solely by end product testing. HACCP is designed to assure the elimination of potential hazards. Hazard analysis based QA procedures are now required in Australian food processing establishments Why put in place a food safety program? Irrespective of how food safety is achieved it is illegal to sell Unsafe Food, therefore the consumer has an ultimate right to buy safe food. Business operators who are found to be selling unsafe food can face very harsh penalties, such as being personally charged with manslaughter, the Garibaldi smallgoods case is a good example of this. [The Supreme Court decision on this case can be read by accessing the Australasian Legal Information Institute database at [Type Garibaldi in as a search term and review the decision handed down on 20 th Dec 1996]. Often, it is purely a business decision which food safety system the operator chooses to be involved in to achieve the aim of safe food. This business decision, is generally made based on the customers requirements i.e.; Export market require an Australian Quarantine and Inspection Service (AQIS) approved program; operating in Victoria may require compliance to the Victorian Meat Authority (VMA) requirements; and a domestic customer may require involvement in their own food safety program such as the Woolworths Vendor Quality Management System or other programs such as Safe Quality Food 2000 (SQF 2000). These programs can often run in parallel with each other. MEAT418/518 Meat Technology

2 33.3 Do I need to put HACCP in place to have a food safety program for a food business? No, not currently. HACCP is a tool that is used to develop a Food Safety program, however this is the most accepted tool, being used in Australia today. With the changes in the Food Standards Code Section 3.2 Food Safety& (3.2.1, 3.2.2, 3.2.3) by the Australia and New Zealand Food Authority (ANZFA), it may mean at some point food businesses will have to implement a HACCP based food safety program. FOOD SAFETY PROGRAM STANDARD Health Ministers also agreed to a new model Food Safety Program and agreed that each Australian State and Territory should be free to decide whether they adopt the new Standard this standard will require food businesses to implement a written food safety program, based on Hazard Analysis and Critical Control Point (HACCP). ANZFA News Dec2000 / Jan 2001 Although it is not currently a requirement in all States and Territories in Australia for food businesses to have a HACCP based Food Safety Program in place, the joint Australia New Zealand Food Standards Code has become less prescriptive (i.e. they don t tell you exactly what to do any more), which means the business has to decide what is appropriate for itself. HACCP is considered a suitable tool to do this. (Some examples of these changes can be reviewed at the following web site When a business develops a HACCP plan, they are required to determine critical limits for Critical Control Points (CCPs) and develop verification activities. Industry Guidelines are a good source of information to assist in determining critical limits and deciding what might be considered acceptable or not acceptable as a verification result. One example of this is the Australian Smallgoods Food Safety Guidelines. Whilst these are not compulsory to implement they are a good source of sound advice to smallgoods manufacturers on what are suitable critical limits and safe microbiological results when used for verification. (There are only a few foods that have microbiological guidelines in the Australian Food Standards Code - this is currently being reviewed by ANZFA). Without these guidelines how, for example, would a smallgoods manufacturer decide what water activity a Metwurst should be when it is fully fermented and what bacteria they should test that Metwurst for to prove that the water activity is producing a safe food? If you work in a Meat processing establishment you will already have HACCP in place because there are Australian Standards, which require this (or variations of these by the relevant state industry authorities e.g the NSW Meat Industry Authority or the Victorian Meat Authority). The Australian Standards are written by the Standing Committee on Agriculture and Resource Management (SCARM) (these can be purchased via the Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ) website operating_environment/armcanz/home.html the most relevant ones are 53,54,55,56,57,58,59, and is A guide to the implementation and auditing of HACCP, which is a valuable reference to anyone who is trying to understand the principles of HACCP) 33.4 How to write an HACCP plan One of the best guidelines to follow is the Codex Alimentarius Commission Food Hygiene basic text. Codex Alimentarius is the International food code. (This can be found at STANDARD/standard.htm pp ). Under the Codex (1997) Guidelines, there are 12 steps and seven principles in developing a HACCP program MEAT418/518 Meat Technology

3 The seven principles are outlined below. Principle 1. Conduct a hazard analysis This is kind of like undertaking the management tool of Brainstorming. Everything that could possibly go wrong at a particular step in production that could make the food unsafe is identified and written down, irrespective of how important it may seem at the time. This will include three main types of food safety hazards; Chemical, Microbiological and Physical. Some examples of these include; microbiological growth due to poor temperature control, chemical contamination from residual cleaning chemicals, physical contamination from a broken glass light etc. These are then individually analysed for the likelihood of their occurrence, how severe they might be if they did occur and where they may have originated. Often control measures are considered at this step. There are a number of different tools that can be used to analyse hazards. One example is to use a matrix. An example of a matrix is contained in the following website. This matrix is designed for mainly occupational health and safety hazards not for food hazards, however the matrix concept could easily be adopted for food hazards (chemical, microbiological and physical). Double click on the free talk The Use of a Ranking Matrix and Recommendations Prioritisation System for Process Hazard Analysis Studies Analysis-talks.htm-Talks and Papers. It is a good idea to record your working, research and though processes associated with developing you hazard analysis so as HACCP teams change over time, the current HACCP team will always understand why you decided on something. You may need to explain your reasoning to an external auditor if they feel that it is not appropriate. Principle 2. Determine the critical control points A Critical Control Point (CCP) is a step in the production, that control at this point is essential to Prevent, Eliminate or Reduce a food safety hazard to an acceptable limit. To assist in determining if this step is a CCP there are a number of techniques which can be of assistance. One method is to use a CCP decision tree. (Please see (pp for a copy of the CCP decision tree), another useful CCP decision tree is contained in the US Food and Drug Administration website or try the interactive version at Texas A&M ). A CCP may not be the point at which the hazard originates, for example a Market Agent selling Fruit and Vegetables may have identified that Agricultural chemical residues could be a hazard in the produce he/she buys in. Whilst the hazard originates on farm, it will be controlled by the agent at receival to his/her stand. i.e. The control measure they adopt may be that they won t accept produce from farmers who do not have suitable quality assurance practices on farm. (They will be on the Agents Approved Supplier List). The matrix used in conducting a hazard analysis could also be used in aiding this process. The lower the number the more likely it is to be a CCP. Principal 3. Establish critical limits for each CCP. This is the limit that the operator is checking at the CCP in the process to determine if it considered OK or not.these limits are clearly defined and need to be able to be monitored. In the example of the Market Agent, the Critical Limit is clear, the person must be on the Approved Suppliers List. If they aren t then this is considered outside the critical limits. Another example is the washing of shredded lettuce. When the lettuce is fed through the wash bath it needs to be exposed to Free Available Chlorine (FAC) levels of parts per million (ppm) in that bath with that volume of water which runs through at that set rate. The lower limit (30ppm) may have been determined because if the FAC was any lower the product may not have been adequately sanitised. (Determining this limit is called Validation a number of microbiological trials would have been run at different levels of FAC to determine an effective level). The upper limit (50ppm) protects the product from damage from the chlorine. MEAT418/518 Meat Technology

4 Principal 4. Establish a monitoring system for each CCP As you can see in the examples above, the critical limits are related to control of the hazard. Monitoring is of the measure used to control the hazard.the monitoring needs to be clearly defined in the HACCP plan. What needs to be monitored, what method is used, how often, and who is responsible. For the lettuce example above these may be; WHAT Free Available Chlorine HOW Using a Free Available Chlorine dip strip. WHEN Once per hour WHERE In the running water in the wash bath. WHO Wash bath operator. Principle 5. Establish corrective actions This is where you decide what you do, if the monitoring you have done shows that you are outside the critical limits. For the lettuce example it may be to re dose the wash bath with chlorine so it is within the critical limits and then re washes all lettuce that was processed since the last test. This way you have addressed the process and the product that may have been affected. Principle 6. Establish verification procedures. This is where you determine if your HACCP plan actually works. Often rather than reviewing the control measure you put in place at the CCP, you test for the hazard you originally identified, however sometimes you may include a review of records to ensure they are being filled out correctly. In the lettuce example, you might decide to conduct a microbiological test on the product one a month to ensure that the system is working effectively. Principle 7. Establish documentation. Documentation is developed for the HACCP plan. This may include a copy of the hazard analysis that was undertaken, a copy of the CCP, Critical limits and corrective actions determined (Often called a HACCP Audit table). It might be the records or forms that will be used to record monitoring of the critical limits or verification activities. Following is an example of a of HACCP audit table. This is an example only and critical limits are not to be used as a reference. Table 33.1 HACCP Audit table for the Step of washing in a Shredded lettuce. Source: Codex Alimentarius Commission, (1997). Step Hazard Control measure CCP/CP Critical limits Monitoring Washing Pathogens from dirty lettuce staying on product Washing with sanitiser CCP Free availabl e chlorine (FAC) 3050pp m. Corrective Action What FAC levels Stop washing How FAC Re dose and dipstrip ensure FAC When and Hourly in is within where the Critical limits running If< 30ppm water in rewash all the wash lettuce bath. washed since last test Who Wash bath If >50ppm. operator Evaluate Product DISPOSE or DOWNGRAD E where necessary Records Washing FAC log. (R.004) 33-4 MEAT418/518 Meat Technology

5 Examples of HACCP plans (For meat specific information work through the boxed meat example at au/-go to the HACCP guide),, other (American) guides can be found at the following Texas A&M website Keep in mind that some aspects of these plans do not apply to Australian domestic processors (some trim and acid washes)). Keep in mind that any reference material you use should only be used as a resource to guide you not as a specific example. HACCP plans can not be developed for a site effectively if the information in it isn t customized specifically for that site. Reviewing a number of formats will be useful in developing your paperwork. Readings There are no readings for this topic Activities Multi-Choice Questions Useful Web Links Assignment Questions Available on WebCT Submit answers via WebCT Available on WebCT Choose ONE question from ONE of the topics as your assignment. Short answer questions appear on WebCT. Submit your answer via WebCt Summary Summary Slides are available on CD Summary Slides are available on CD HACCP is a preventative system in which safety is an integral part of food formulation and production process. It is more effective than conventional QA, which generally relies solely on end product testing. HACCP program are not compulsory but are becoming more common in the food industry where the emphasis is on self management and the company having to decide the appropriate means of maintaining food safety standards The CODEX guide sets out 7 principle steps in writing a HACCP plan 1. conduct a Hazard analysis 2. determine the critical control points 3. establish the critical limits for each CCP 4. establish a monitoring system for each CCP 5. establish corrective action 6. establish verification procedures 7. establish documentation References ANZFA News Dec 2000/Jan 2001, Issue 25. The monthly newsletter of the Australia New Zealand Food Authority. Codex Alimentarius Commission 1997 Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application. Annex to CAC/RCP, Rev. 3. MEAT418/518 Meat Technology

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