The development HACCP plan shall identify and manage the following types of hazard: Biological, Chemical, Physical, Allergens, Quality, and Regulatory.
Hazard Analysis (HA) – HACCP Principle 1
The HA is used to identify potential microbiological, physical, chemical and allergen hazards that may be reasonably expected to occur at each process step. Allergen cross-contamination risk is also included. Regulatory/legal and quality hazards and issues at each step shall also be considered.
The HA includes:
- The likely occurrence of hazards and severity/consequence of their adverse health effects or effect on product quality or regulatory compliance
- Qualitative and/or quantitative evaluation of the presence of hazards
- Survival or multiplication of micro-organisms
- Production, persistence or cross-contamination of toxins, chemicals or physical agents
Control measures, if any, applied for each hazard need to be identified and more than one control measure may be required to control specific hazards.
Determination of CCPs – HACCP Principle 2
All hazards at each process step identified during the HA shall be considered in sequence and categorised giving a Risk Rating. If there are hazards at particular steps that are deemed as significant, then it needs to be determined if the step is a Critical Control Point (CCP), Quality Control Point (QCP) or Regulatory Control Point (RCP). Steps that are not a CCP / QCP or RCP but still need to be controlled are control points (CP) and are to be controlled through the established Food Safety & Quality Program.
CCP Critical Limits – HACCP Principle 3
Critical Limits separate acceptability from unacceptability. CCPs are based on:
- Established food safety principles or published research
- Legislative requirements
CCPs shall be measurable/quantitative. Where possible, Action Limits shall be set that allow sufficient time for corrective actions to be taken before CCP critical limits are breached. The accuracy/precision/tolerance of monitoring equipment shall be taken into account when setting critical limits and action limits.
The effectiveness of the CCP in controlling the hazard shall be validated; e.g. metal detector is able to detect at specified limits, and detect metals of the type used on the plant; e.g. a CCP for reduction or elimination of pathogens / microbial loading is validated with trends of micro testing results.
CCP Monitoring – HACCP Principle 4
Monitoring procedures are the planned sequence of observations or measurements of CCP control measures. Monitoring systems shall be able to detect loss of control at the CCP and shall provide this information in time for corrective action to be taken to regain control of the process, and to identify, segregate and reject product before it is dispatched.
The documented monitoring system for each CCP shall define:
- Responsibility – job title of the individual who will carry out the monitoring
- Frequency – if not continuous then at a frequency sufficient to ensure that the CCP is under control.
- Method – detailed specification or procedure
- Records to be kept – including action limits and critical limits, the results of monitoring activity, the signature of the responsible person and verification countersignature.
Corrective Actions – HACCP Principle 5
As with any control process corrective actions need to be taken when monitoring indicates a trend towards loss of control (action limits breached) or a breach of CCP critical limits. The corrective actions will differ slightly depending on which limit is breached:
Where Action limits are breached corrective actions should include:
- Immediate action to re-establish control before the deviation leads to a CCP breach
- Responsibility for the corrective action
Where Critical limits are breached corrective actions should include:
- Immediate action to re-establish control
- Identification of all product produced since the critical limit was breached (since last in control monitoring result)
- Disposition of affected product
- Responsibility for the corrective action
Comprehensive records of the corrective action taken should be maintained on the CCP monitoring record.
HACCP Plan Verification – HACCP Principle 6
As corrective actions are implemented it is important that they are verified to ensure they are achieving the desired results. Verification to confirm the HACCP system is working effectively shall include:
- Microbiological and chemical testing (where applicable) to confirm CCPs, QCPs and RCPs are in control. The schedule includes the type and frequency of testing which has been determined by the risk nature of the products and processes and covers all finished products.
- Shelf-life validations covering both microbiological and sensory testing (where applicable). The schedule includes the type and frequency of testing.
- Physical assessments of products against specifications. Methods for assessment, responsibilities and frequency of assessment are defined.
- Reviewing internal incidents, non-conforming product records, customer complaints, withdrawals or recalls relating to food safety, quality or legality.
- Internal audits of CCP monitoring and corrective action records
Once again records of all verification testing, assessments, reviews and audits are to be maintained.
Documentation & Record Keeping – HACCP Principle 7
It is important to be able to demonstrate that the principles of HACCP have been correctly applied and this is done through documentation and record keeping. These records should include:
- The HACCP Plan, Objectives, Scope, Regulatory & Customer Requirements
- HACCP Development Team Meeting Minutes
- Finished Product Descriptions
- Process Flow Diagrams
- Hazard Analysis
- CCP Determination and Validation
- Critical Limit / Action Limit Determination
- CCP Monitoring Procedures and Corrective Action Procedures
Documentation should also exist to demonstrate that the HACCP Plan has been effectively managed and implemented. This should include:
- CCP Monitoring Records
- Corrective Action Records
- HACCP Training records and competency assessments for operators, supervisors and managers
- Evidence of HACCP management including:
- Verification Schedule and Records
- Team Meeting Minutes
- Modification records
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