HACCP: A Management Responsibility?
In 2006, EU Regulation EC No 852/2004 made HACCP a legal requirement, requiring food business operators to implement its principles. Known as Hazard Analysis and Critical Control Points, HACCP is vital for food safety management. Since 1996, I’ve trained many across Levels 2, 3, and 4. Despite its importance, many in the food industry lack a clear understanding of HACCP, its terminology, principles, and roles. A common misconception is that HACCP is mainly about health and safety, but it actually focuses on food safety by assessing microbiological, physical-chemical, and allergenic hazards.
HACCP, developed in the 1950s by NASA to protect astronauts’ food, shifted from end-product testing to a proactive prevention system. It became a voluntary standard in the early 1990s and later a legal requirement in national food safety laws.
The principles of HACCP were misunderstood in those early years. Although food safety management systems were developed, food preparation was not broken down to identify which controls in the food production process were not essential, because controls later in the process were in place to address potential problems with the product.
Although the regulation became a legal requirement in January 2006, it was published in 2004, giving the industry two years to implement a system by that date. The regulation became mandatory under the EU Hygiene of Foodstuffs regulations.
Contact Workforce Training”“food business operators shall put in place, implement and maintain a permanent procedure based on the HACCP principles”.
Regulation (EC)no 852/2004 0n the hygiene of food stuffs.
What is the Terminology Used in a HACCP Plan?
Understanding the terminology or ‘jargon’ in the HACCP plan is key to working effectively with it. This plan is a vital part of the Food Safety Management System (FSMS), which helps identify, assess, and control hazards that could affect food safety. The FSMS includes policies and procedures like Good Manufacturing Practices (GMP) and Good Hygiene Practices (GHP), along with additional controls and detailed documentation, all designed to ensure that the food products your manufacturing business produces are safe and free from contamination, meeting legal requirements. These are known as prerequisite programmes (PRPs), laying a strong foundation for any HACCP plan. In fact, establishing PRPs first makes developing and implementing the HACCP plan much easier, as they are used daily to manage routine hazards across the site. The HACCP plan—whether written or electronic as required—follows the seven principles of HACCP to ensure that risks are effectively controlled during food production.
“Hazard: Anything which may cause harm to your customers through eating the food you produce” Codex 2020.
Food safety risk is the chance of hazards in food. Risk assessment identifies hazards, their likelihood, severity, and significance. Critical Control Points are where hazards matter. HACCP has eleven steps, including seven principles. Prerequisite Programmes like GHP, GMP, training, and traceability are foundational. HACCP aims to produce safe food and minimize harm but does not address health and safety concerns.
The Implementation of HACCP is a management Responsibility.
Although HACCP is mandated by law, senior management must allocate the necessary resources for its implementation and management. Food product safety is primarily the responsibility of management. As we know, food products produced in manufacturing must be ‘fit for human consumption’. For HACCP to be effective, it should be integrated into the entire production process and made accessible to everyone.
Assembly of a HACCP Team.
A HACCP team is formed to ensure proper implementation of the ‘HACCP plan’, usually made up of experienced, trained members. The team develops and implements a system to control biological, chemical, physical, or allergenic hazards that could harm consumers. The team size varies with the manufacturing process; in smaller organizations, members may have dual roles. Members should know about production, hazards, risk control, monitoring, corrective actions, and process technology. The leader managing HACCP should understand HACCP and the process. Typically, members include a quality assurance officer, engineer, production specialist, packaging/distribution manager, and a scribe for notes.
Training the HACCP Team
For the HACCP plan to be effective, the team and those closely involved with the application should receive training.
As they drive the HACCP plan, the team should complete at least level 3, with the team leader possibly completing
level 4.
Those on the periphery should receive at least level 2 HACCP training.
Expert Training at Workforce Training
I have delivered HACCP training across various food sectors for many years. Workforce Training offers Highfield HACCP courses on-site or through open public courses for individuals or organisations that can’t host training. Courses include the Level 2 Award in HACCP for Catering, Levels 2 and 3 for Manufacturing, Level 3 for Catering, and Level 4 for Manufacturing and Catering, based on Codex Principles. We also offer online HACCP e-learning courses, which provide a certificate endorsed by Highfield upon completion. All courses are developed by Highfield and delivered by Workforce Training, with certificates endorsed by Highfield. Contact Philip Wadsworth on my mobile 07764789450 for more info.
Describe the Products and Processes?
Products must be described with the recipes, ingredients, and sources of the raw materials. Include any potential hazards and risks associated with them. Specify the intended storage, such as refrigeration or freezing, and detailed processing methods, such as cooking or smoking. Clarify how the products will be distributed. Detail the shelf life, including best-before or use-by dates and their formats. Describe the packaging, such as vacuum packaging or food-safe film. The labelling instructions should list ingredients by percentage, with the highest listed first, and allergens in bold. Finally, outline the storage process for the finished product, indicating how long it must be refrigerated after production.
Identify the End Users
The likely consumer should be considered. All groups of end users will have vulnerable groups, such as babies and older people.
The end user’s abuse must be considered, such as leaving the product in the car on a hot day or driving a long distance. The possibility of reheating the product and eating it hot must also be considered. Will it then be reheated again?
Constructing a Process Flow Diagram
This diagram, created by the HACCP team who initially draw it across the table, can omit critical manufacturing steps, leading to their exclusion from the risk assessment. It follows the sequence of production, with each member ensuring accuracy, detailing all steps from raw material arrival and storage to preparation, processing, and packaging removal, including reworked products and external packaging. Key details like storage times, cooking, blast-chilling durations, and temperatures should be recorded. The team should verify the diagram by walking through it to identify missed steps and update as needed. Repeated walkthroughs, especially during night shifts, help ensure accuracy across all shifts, maximizing the diagram’s and HACCP plan’s effectiveness.
The 7 Principles of HACCP
HACCP is a set of seven principles that provide a framework for conducting a risk assessment and identifying critical control points (CCPs) where controlling a hazard is essential. These CCPs can then be monitored to minimise risk and enable immediate action if a hazard arises. When implementing HACCP, there are seven principles to follow to make the system effective and efficient.
Conduct a Hazard Analysis (Principle 1)
The first step in HACCP is to identify food safety hazards during processing, starting with selecting raw materials and ensuring safety standards. This includes observing the process flow and activities around the main line, like wearing blue gloves and beard snoods. Knowledge and judgment help anticipate potential issues. HACCP addresses physical, biological, and chemical hazards, mainly focusing on biological hazards such as foodborne illnesses, cleaning products, and physical contaminants.
Determine the Critical Control Points (CCPs) (Principle 2)
The critical control points (CCPs) are the steps in the process where
‘Control measures are essential to eliminate or reduce the hazard to an acceptable level.
Failure to apply control measures effectively may harm or injure the end consumer. A ‘decision tree’ is used to determine each CCP, drawing on the HACCP team’s expertise. It’s a diagram of questions to assess if a step is a control or critical control point—relying on the team’s knowledge. For example, meat preparation is a control point. When meat is cooked, the decision tree identifies it as a CCP, also determining if it’s cooked and for how long. Training and supervision are recommended at each CCP, such as during shifts. It’s good practice to record each CCP’s justification. This helps produce justified CCPs for monitoring, corrective actions, and verification procedures within the FSMS.
Establish Validated Critical Limits for Each CCP (principle 3)
When establishing CCPS, the HACCP team must set validated critical limits specific to each CCP, which should be measurable and aligned with control measures such as temperature, time, and physical parameters. Bacteriological sampling is avoided due to delayed results. A tolerance around the limit helps detect breaches early. For example, high-risk food stored at 8 °c for 4 hours must be destroyed if exceeded, or corrected proactively. Monitoring ensures the process remains under control, involving observation or measurement like temperature, with quick results. If deviations occur, causes are addressed. Corrective actions involve dealing with affected products and restoring control, with procedures specifying actions, responsible persons, and reporting. When a limit is breached, products may be quarantined, tested, reprocessed, or destroyed if unsafe. Supervisors and management review breaches, prevent recurrence, and decide on product release or recall, ensuring labels are clear for traceability. Recalls are costly and can lead to compensation demands.
Validate the HACCP Plan and Establish Verification Procedures (Principle 6)
The key principle is to verify that the HACCP plan effectively controls hazards, often through a trial validation period validating CCPS and PRPs. For example, maintaining a minimum temperature of 75 degrees during meat cooking, with timing varying based on the meat type, is essential. Verification involves ensuring personnel follow monitoring procedures and meet food safety standards, with frequency based on monitoring records. This process confirms the plan’s effectiveness and the product’s safety.
Establish Documentation and Record Keeping (Principle 7)
Documentation for HACCP should match the food process’s size and complexity. Complete it timely with signature and date for completeness. Properly completed documentation supports a due-diligence defence in court. Management uses records to investigate complaints, during inspections, or audits. HACCP and prerequisite documents should be stored in hard copy or electronic formats, preferably both. Include in each document the title, developer’s name, version, and date. Completed evidence shows that food safety is properly managed.
Reviewing the HACCP Plan
The HACCP plan should be reviewed regularly, but at least once a year. It should not be developed and then placed in a manual, only to be left on a high shelf and forgotten until needed. The HACCP plan should be consistently reviewed and updated, functioning almost like a living documented system.
There are several reasons to review the HACCP plan: the introduction of a new product or a change to the existing process; the introduction of new machinery or new scientific information, such as a computer-operated oven; or a change to a recipe that uses raw materials from a new supplier, like sugar or salt, which should be removed or reduced.
It is vital to thoroughly document the verification of the HACCP plan, especially any changes made—specifying who made them and on what date. This helps ensure that the plan is correctly implemented, reduces the risk of contaminated food products, and keeps the document functioning effectively.
Summary
Food hazards can pop up during production, but the HACCP system is here to help us cut down risks and keep things safe. It encourages a caring safety culture by getting everyone involved. When used the right way, HACCP not only lowers business risks but also boosts customer trust and makes sure our products are safe. Its proactive approach allows us to fix issues right on the spot during production, saving money on testing, rework, waste, complaints, and recalls. Plus, HACCP helps us follow legal rules, showing we’re doing our best to be responsible. Making sure we implement it properly is key to enjoying these benefits. Luckily, there are handy guides available, like the free food hygiene guide for the Catering Industry, to help us stay compliant.
