How to implement a HACCP System

How to implement a HACCP System

Introduction

A HACCP System ensures that all food safety hazards, that may reasonably be expected to occur, are identified by this process and are then fully evaluated and significant hazards that have been identified are controlled so that products do not represent a direct or indirect risk to the consumer.

Resultant control measures are implemented through the HACCP (food safety) plan and where applicable Prerequisites/GMPs. Below is the process of establishing an effective HACCP System.

Prerequisite Programs/GMPs

Environmental and operational programs necessary to create an environment suitable to produce safe and legal food products should be established. Good Manufacturing Practices that should be implemented prior to Hazard Analysis include:

  1. Environment controls
  2. Construction and layout of buildings and utilities
  3. Layout of premises, including workspace and employee facilities
  4. Supplies of air, water, energy and other utilities
  5. Supporting services, including waste and sewage disposal
  6. Suitability of equipment
  7. Management of purchased materials
  8. Measures for the prevention of contamination/cross-contamination
  9. Cleaning and sanitizing
  10. Pest control
  11. Personnel hygiene
  12. Control of rework
  13. Product recall procedures
  14. Warehousing
  15. Product information and consumer awareness
  16. Food defense, bio vigilance and bioterrorism
  17. Training and Supervision

HACCP Preliminary Steps

1. Assemble the HACCP team, with at least one team member who is HACCP trained

A core multidisciplinary team should be utilized within the company to develop the Food Safety Management System. This core team should be supplemented by other staff when specific areas or products are being analyzed.

2. Make a description of the product, how it is processed or manufactured and the storage and distribution process

The HACCP team should document the end product characteristics, including legal food safety requirements, for the purpose of conducting the Hazard Analysis.

3. Identify the intended use of the products

The HACCP team should identify all possible users and consumers for each product and process category.
Vulnerable groups of the population may have to be considered. The HACCP team should consider the consumers of the product:

  • Is the product intended for babies or infants, children or adults?
  • Is the product intended for a wide spectrum of the population?
  • Is the product likely to be consumed by high risk groups?

4. Identify consumers of the products

The intended use should be based on the expected uses of the product by the end user or consumer.
Consider the intended use of the product:

  • Is the product intended as an ingredient for further cooking?
  • Is the product ready to eat?

5. Confirm the HACCP Scope

HACCP team should define the scope of the HACCP study. For each different type of product or process the HACCP team should define the scope of each HACCP plan, including the products and processes covered.

6. Consider the process and draw a flow diagram

The HACCP Team should construct flow charts for the products and process categories covered by the scope of the food safety management system. For each step in the flow chart the Food Safety team should describe the step and the control measures.

7.Confirm the flow diagram is correct by following the process

Flow charts should be physically confirmed by the HACCP (Food Safety) Team

HACCP principles

All processes used in the manufacture of food products and product groups should be subject to hazard analysis incorporating the Codex Alimentarius HACCP principles

Principle 1

Prepare a flow diagram of the steps in the process. Conduct a hazard analysis by identifying potential hazards. Assess likelihood of occurrence of these hazards and identify control options.

Principle 2

Identify the Critical Control Points in the process using the decision tree.

Principle 3

PEstablish critical limits, which must be met to ensure each Critical Control Point is under control .

Principle 4

Establish a monitoring system to ensure control of the Critical Control Point by scheduled testing or observations.

Principle 5

Establish the corrective action to be taken when monitoring indicates that a particular Critical Control Point is moving out of control.

Principle 6*

Establish documentation concerning all procedures and records appropriate to these principles and their application.

Principle 7*

Verify that HACCP is working effectively.

* Note that in CODEX Annex Guidelines Principle 6 and Principle 7 are verify then document, from a practical point of view I find it easier to document then establish verification procedures which should also be documented.

The following steps should be implemented in establishing the HACCP System:

 

Hazard Analysis

The HACCP team should conduct a hazard analysis for food safety hazards that are reasonably likely to occur for each product and process category. Taking the confirmed process flow diagram your HACCP team will now need to conduct a Hazard Analysis for each step to identify the threats to human health, which might be introduced into products as they are produced.

 

Hazards are predominantly grouped into three categories:

  • Biological (including microbiological)
  • Chemical
  • Physical

 

Allergens and radiological hazards may also need to be considered.

The next step in performing a hazard analysis is for the HACCP team to consider the list all of the hazards that may be reasonably expected to occur at each step.

This first step in identifying hazards which might be associated with your production process might be considered a “brainstorming” session.

 

For each Food Safety Hazard Identified, the acceptable level of the hazard in the end product is determined taking into account:

  • Regulatory requirements
  • Customer food safety requirements
  • Historic information
  • Scientific literature
  • Professional experience
  • Intended use by the customer

 

This hazard list is referred to as a Preliminary Hazard List and covers all hazards that could potentially occur in the product.

 

In conducting the hazard analysis, wherever possible the following should be considered:

  • The probability of hazards occurring
  • The severity of hazards by their adverse health effects
  • The qualitative/quantitative evaluation of the presence of hazards
  • Survival or multiplication of microorganisms of concern
  • Production or persistence of toxins, chemicals or physical agents
  • Conditions leading to the above
  • Customer complaints and previous internal non-conformances
  • Prerequisite programs that create hygienic and safe conditions

 

The HACCP team must then consider what control measures, if any, exist which can be applied for each hazard.

 

Each potential food safety hazard should now be risk assessed by the Food Safety Team to determine whether its elimination or reduction to acceptable levels is required to produce a safe product and also any controls required to achieve the acceptable levels.

 

Hazard Assessment

Each potential food safety hazard is risk assessed to determine whether its elimination or reduction to acceptable levels is required to produce a safe product and also any controls required to achieve the acceptable levels.

For each step grades of impact (severity of adverse health effects) and probability (likelihood of a food safety hazard occurring) need to be allotted and the combined matrix used to judge the significance and priority for elimination or minimization of the hazard.

 

First the Food Safety Team assess the probability of the hazard occurring and enter:

1 for Highly Unlikely

2 for Possible

3 for Likely

 

Then the Food Safety Team assesses the severity of the hazard and enters:

1 for Not Severe

2 for Could possibly cause illness

3 for Severe (Could be fatal)

 

Probability and Severity are Multiplied to give a Significance Score for the Hazard.

 

All of the food safety hazards that score a 9 are regarded as significant and form the Significant Food Safety Hazard List

 

Critical Control Points

HACCP Principle 2 is to identify the critical control points in the process. A CCP is a step in a food process at which control can be applied to prevent, eliminate, or reduce to acceptable levels a food safety hazard. Critical Control Points are established using the decision tree as the latest step in the flow path where controls can be effectively administered for a particular Significant Food Safety Hazards.

Note: You should still ensure that your control measure or prerequisite programs adequately control significant hazards even if not identified as controlled at CCPs. Each hazard on the Significant Food Safety Hazard list must be controlled by a control measure (or combination of control measures) that prevent, eliminate or reduce the hazard to the defined acceptable levels.

Critical Limits for each CCP

For each CCP, the appropriate critical limits are defined. A critical limit is 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 exact and specify the limits required for food safety using the preventive measures put in place at CCPs.

A critical limit can be an upper limit where a set amount or level cannot be exceeded.

A critical limit can also be a lower limit where a minimum amount is required to produce the safe effect.

 

Validation of Control Measures

The HACCP team should confirm that the control measures (or combination of control measures) are capable of achieving the defined acceptable levels for each food safety hazard by validation activities.

 

Supporting validation documentation can consist of information from:

  • Regulatory limits or Industry Code of Practice Guidelines
  • Scientific journals
  • Documented challenge studies
  • In-house data

 

The HACCP documentation must identify:

  • The hazard or pathogen, including the level of hazard prevention or pathogen reduction to be achieved
  • The processing steps that will achieve the specified reduction or prevention

 

Establishing a Monitoring System for each CCP

A monitoring procedure should be established for each CCP to ensure compliance with critical limits.

The most commonly recognised monitoring procedures are from instruments but can be employee checks such as inspecting the documentation accompanying incoming materials.

Continuous monitoring is always preferred when it is available. This is normal when the process is continuous rather than by batch.

Monitoring should ideally provide information in time to make adjustments to ensure control of the process to prevent it exceeding the critical limits.

Ideally adjustments should be taken before a critical limit is breached.

 

Establishing a Corrective Action Plan

The corrective action to be taken when monitored results indicate a failure to meet a control limit is defined including responsibilities.

The corrective action plan needs ensure:

  • the cause of the deviation has been identified and eliminated
  • the CCP reverts to a controlled state after the corrective action has been taken
  • measures to prevent recurrence of the deviation have been established
  • product is quarantined until it is established that it is safe

 

Establishing HACCP Documents and Records

The HACCP team should establish procedures and records to ensure adequate food safety controls are in place. This includes documenting the HACCP plan which summarises all the critical control points, the monitoring procedures, critical limits, corrective actions, records and responsibility and authority.

 

Verification Planning

The HACCP team should define the methods, frequencies and responsibilities for verification activities (the simplest way to do this is by review of product analysis results and/or audit of HACCP documentation).

 

Review of the HACCP Plan

The HACCP team should review the HACCP plan and prerequisite programs at least annually and prior to any changes which may affect food safety.

 

References

“Hazard Analysis and Critical Control Point (HACCP) system and Guidelines for its Application” (Codex Alimentarius Commission, Geneva).

How to Develop a Food Safety Management System

How to Develop a Food Safety Management System

A Food Safety Management System should be planned, established, documented and implemented in order to ensure compliance with company, customer, regulatory and statutory requirements. Senior management need to confirm the scope of the Food Safety Management System including product categories, processes and activities conducted on by the organization.

 

Senior management need to be committed to the food safety management system and establishing and implementing, then fully communicating and supporting company policies, procedures and objectives. Senior management plan, establish, document and implement the food safety management system by:

 

  • Establishing and implementing a Food Safety Policy.
  • Communicating and Maintaining the Food Safety Policy.
  • Establishing and implementing Food Safety Objectives.
  • Communicating and Maintaining the Food Safety Objectives
  • Leading and supporting a food safety culture within the site
  • Conducting regular pro-active management reviews and communicating outputs.
  • Communicating commitment to satisfying customer requirements including food safety, quality and service
  • Supporting and planning the development and operation of the Food Safety Management systems.
  • Ensuring the food safety management system is maintained when changes are planned and implemented.
  • Establishing documentation required for the effective development, implementation and updating of the food safety management system and communicating pertinent information throughout the organization.
  • Providing the human and financial resources, and training, to manage the Policies and Objectives effectively.
  • Providing the infrastructure and work environment to manage the Policies and Objectives effectively.
  • Promoting an ethic of continuous improvement throughout the company.
  • Ensuring the strict observation of all food safety system procedures, the use of correct materials and equipment, recording and reporting of both standard and non-standard events and compliance with the company rules.
  • Providing the resources to audit the Food Safety Management system effectively.
  • Providing the resources necessary for the food safety team to effectively implement a Food Safety HACCP plan.
  • Carrying out regular Management Reviews.
  • Implementing and maintaining Corrective Action, Preventative Action and Continuous Improvement Plans.
  • Communicating effectively throughout the food chain from primary suppliers to end consumers including any relevant food safety information.
  • Providing the resource to ensure the company is kept up to date with all industry codes of practice, legislative, scientific and technical information appropriate to the products in the countries of raw material supply, production and product sales.

 

Due diligence

 

An effective Food Safety Management System demonstrates due diligence of the company in the effective development and implementation of safe food operations. The Food Safety Management System documents are supported by the completion of specified records for the monitoring of planned activities, maintenance and verification of control measures and by taking effective actions when non-conformity is encountered.

BRCGS Food Safety F837: Position Statement: Clause 1.1.2

BRCGS Food Safety F837: Position Statement: Clause 1.1.2

BRCGS Food Safety F837: Position Statement: Clause 1.1.2 Define and maintain a clear plan for the development and continuing improvement of food safety culture

 

BRCGS has issued a position statement to ensure expectations relating to compliance with clause 1.1.2; its consistent application at certificated sites, and assessment during audits are understood.

In summary, the clause requires sites to: Define and maintain a clear plan for the development and continuing improvement of food safety culture.

This plan must include:

Clearly defined activities that will be completed

Involve all sections of the site that have an impact of product safety (whilst specific activities may be relevant to certain departments or roles, overall the plan must ensure that all relevant section/roles are covered)

An action plan indicating how the identified activities will be undertaken/completed

Measurement of the activities (i.e. where they completed, where the correct people involved, were activities successful, any other learnings)

Intended timescales for the completion of the activities

A review of the effectiveness of completed activities

 

Where sites are non-compliant, the non-conformities will be graded as follows:

 

Major Non-conformity

Where the site does not have a documented plan for food safety and quality culture. In this context a plan is more than a short statement of intent, but documentation incorporating the requirements of the clause (as summarised above).

 

Minor Non-conformity

Where a documented plan exists, but is: of poor quality (e.g. insufficiently detailed, for example missing timescales for completion or absence of clear action plans), does not cover all the relevant areas or staff and is not fully implemented (e.g. some activities not implemented or not completed to predefined schedule).

 

Site review of the effectiveness of completed activities

The third bullet point in the clause requires sites to undertake a review of the effectiveness of completed activities.  As audits to the Standard only commenced in February 2019 it is possible that this review of the success of the programme, would not always be implemented in year 1 and therefore non-compliance with this bullet point is not considered a nonconformity until the site’s second audit to Issue 8.

 

Grading

The non-conformance shall be included in the calculation of the site grade.

Effective date: 1st June 2019

 

Source BRCGS News here: https://www.brcgs.com/media/1495789/f837-position-statements-for-issue-8-v2-03092019.pdf

 

How our Implementation Packages Assist in Compliance

 

Our Implementation Packages include tools and procedures to assist in complying with all the clauses of the BRCGS standard. As an example, for planning and developing a food safety culture we provide a template for Senior Management to use, below are some extracts and examples:

 

Food Safety Culture

 

The company recognises that a successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of the food safety management system. The site’s senior management plan for the development and continuing improvement of food safety culture.

 

Senior management are responsible for delivering a “It is how we do things here” food safety culture by:

Leadership – starting from the top

Demonstrating visible commitment

Effective communication of company philosophy and policy

Ensuring there is accountability from the top of the organisation to the bottom

Developing employee confidence and mutual trust

Developing reward schemes including ‘Employee of the Month’ award

Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity

Developing an action plan for the development and continuing improvement of food safety culture

 

Monitoring Food Safety Culture

 

Senior management monitor and measure through individual reposts and trend analysis the degree of development of the food safety culture by analysing information including KPIs from:

 

Hygiene & Housekeeping Audits

Internal Audits

External Audits

Non-conforming products

Environmental monitoring

Review of implementation plan and numbers trained

Employee reviews

Staff surveys on values and culture

Customer Complaints

Staff Turnover

Staff Exit Interviews

 

Results of monitoring are shared throughout the organisation.

 

Responsibilities

 

Senior management are responsible for reviewing the effectiveness of completed activities at the monthly Management Review meeting

 

Individual Food Safety Culture Development Table

 

All employees will undergo the following briefings and stages:

 

Food Safety Policy

Food Safety Objectives

Food Safety Management System Overview

Job Descriptions

Job Training

Employee Briefing

Individual Objectives

CCP Controls – Training Procedures & Record Completion

PRP Controls – Training Procedures & Record Completion

Employee Review

 

Reference

 

QM 1.1.2 Food Safety Culture Planning: