HACCP revisited – Hazard Analysis and Critical Control Points quality assurance system

HACCP revisited – Hazard Analysis and Critical Control Points quality assurance system – includes related article

Purnendu Vasavada

Assuring quality requires process analysis from the cow to a product’s consumption

The spirit is willing but effective implementation has been weak.

HACCP (Hazard Analysis and Critical Control Points) is a preventive quality assurance system that has received much attention in the last 20 years. Practical implementation of HACCP in the food industry, however, has been slow–until recently. A flurry of foodborne illness outbreaks and industry-wide recalls of a variety of products has motivated the dairy industry to reconsider the HACCP program.

HACCP in a Nutshell

A HACCP plan covers the entire dairy foods manufacturing process starting with the cow and finishing with the consumption of the final product. Under HACCP, the chemical, physical or microbial hazards associated with the production and distribution of food are identified and minimized by monitoring/controlling the process at carefully selected points known as critical control points (CCPs).

The National Advisory Committee on Microbiological Criteria for Foods (NACMF) details seven HACCP principles.

In instituting a HACCP program, microbial and operational expertise is needed to systematically and scientifically evaluate a product’s process from raw materials through distribution.

Two suggested preliminary steps are to describe a product and to “flowchart” its production and distribution. In determining a food’s risk category (zero being the least “risky” and VI the most), one technique is to rate the food product by the number of hazard characteristics it possesses. These are as follows:

* Hazard A: Non-sterile foods intended for consumption by “at-risk” populations.

* Hazard B: Foods with a sensitive (i.e., potentially contaminated) ingredient. All dairy products possess this hazard since milk is such an ingredient.

* Hazard C: Foods processed without a controlled processing operation such as pasteurization.

* Hazard D: Foods subjected to post-processing contamination before packaging.

* Hazard E: Foods with the potential for abuse during storage, handling and distribution.

* Hazard F: Foods without a terminal heat process after packaging.

In recent years, there has been a trend away from use of risk categories, although others still find it helpful.

A question of control

Numerous steps in a food production flowchart may be identified as control points (CPs). CPs should not be confused with CCPs. Many of these CPs are for quality, statistical process control or regulatory purposes; loss of control in such areas does not increase safety risks.

The probability of a health risk occurring at a given CP may be ascertained from product history, scientific literature, predictive modeling, consumer complaints, incidents of recall, seizures, injunctions, etc.

Occasionally, two types of CCPs are identified: CCP-1, where complete or effective control of a potential hazard is affected (e.g., pasteurization or water activity (Aw) below 0.86.); and CCP-2, where partial control is affected (e.g., sanitation procedures). This two-class CCP system gives the impression that completely eliminating hazards is possible. However, as a HACCP system is implemented, implied absolute safety guarantees must be avoided.

Identifying CCPs is followed by establishing the CCPs’ critical limits so that process deviations or out-of-control situations may be detected promptly and appropriate actions may be taken.

Critical limits should be based on CCPs’ critical criteria (e.g., time, temperature, Aw, pH, etc.) and should be easily measurable, preferably through the use of automated devices and on-line sensors to reduce labor costs.

The best laid plans …

The best HACCP plan will fail if it is not regularly verified. Verification involves review of the HACCP plan as well as the processing system itself to be sure the plan is still valid. CCPs, CCP deviations and product dispositions are also reviewed. The review, or audit, is made by company personnel or outside consultants. A written report certifying that the HACCP plan is being followed must be prepared.

While the frequency of HACCP verification may vary, it should be conducted routinely on an unannounced basis.

As the original HACCP concept is modified to make it more “user friendly” and amendable to universal applications in the dairy industry, HACCP is emerging as a comprehensive, preventive approach that can be used to manage the safety of milk and dairy foods. With the harmonizing of food industry regulations and increasing acceptance of new quality management approaches, HACCP is the key to effective quality assurance of dairy foods from cow to consumers throughout the 1990s and beyond.

Vasavada, Ph.D., is a professor of food science, University of Wisconsin, River Falls, Wis.


1. Analyze Hazards and Assess Risks

* Evaluate the product and process to identify hazard characteristics

* Anticipate abuse/mishandling, from distribution through product consumption

* Emphasize microbiological risks and assign risk categories (if helpful)

2. Determine Critical Control Points (CCPs)

* Evaluate product/processing steps to identify CCPs

* Distinguish between CCPs and CPs (control points)

* Avoid using two classes of CCPs, CCP-1 and CCP-2

* Limit CCPs to manageable numbers, ideally six or less

3. Establish Specifications for CCPs

* Determine methods to monitor each CCP

* Determine limits or tolerances for each CCP

* Keep CCP specification easily measurable

4. Monitor CCPs

* Establish a schedule for monitoring each CCP

* Assign responsibility for monitoring and recording results

5. Establish Corrective Actions for CCP deviations

* Record deviations

* Define and communicate corrective actions

* Assign responsibility for corrective actions

6. Establish a Recordkeeping System

* Maintain records or ingredients, process and product controls, CCP monitoring, deviations and corrective actions

* Standardize recordkeeping forms/formats

* Establish a schedule for regular review of records

* Identify a location for the records and establish a policy for retaining records

7. Verify the System

* Review documents and records

* Conduct spot checks of CCP controls

* Conduct internal or external audits of the HACCP plan

ISO 9000 & HACCP

Total Quality Management (TQM) systems, ISO 9000 (a European-initiated QA documentation system) and HACCP all address QA issues and are compatible but not interchangeable.

Though ISO 9000 is becoming globally accepted, O. Pete Snyder, Hospitality Institute of Technology and Management, St. Paul, Minn., notes several of its weak points.

The ISO 9000 series is written to follow classical quality control methods meant for non-food manufacturing operations, says Snyder. Thus, it does not directly address microbial issues, which are the major food safety concern. Secondly, ISO 9000 leaves out the customer–a key concept in TQM. Also, neither ISO 9000 nor HACCP are structured to incorporate continuous process improvements, which is a cornerstone of TQM.

Though HACCP has been around awhile, new food safety concerns are likely to continue to give it attention. For example, the Centers for Disease Control, Atlanta, now uses two enrichment methods simultaneously to analyze foods for L. monocytogenes since any one method misses positive samples 25 percent of the time. The FDA enrichment method was least efficient for recovering L. monocytogenes in dairy products.

Also of import to dairy processors, researchers–some of which are at the Bureau of Microbial Hazards, Health and Welfare Canada, in Ottawa–report that under certain worst-case scenarios, L. monocytogenes survives minimum HTST pasteurization conditions.

Happy thoughts.

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