Expanding HACCP Content and Food Industry Application
October 19, 2015 - Kestrel Food Safety
Hazard Analysis and Critical Control Points (HACCP) was originally developed based on several key program types. The templates were created for specific industries and food risks and, therefore, do not fully address HACCP-level requirements of all food-level risks in the marketplace. For example:
- AIB is focused on the bakery and confection market.
- Codex Alimentarius looks at general food on a global level.
- USDA/FSIS, IHA, NEHA focus on meats, protein, and diary.
Much of the development of a HACCP program is based on training for these segments. Ultimately, foods or industry segments requiring HACCP have followed these established models, even though they do not always align with food risks or operational models. As a result, HACCP plan coordinators outside of these risk categories (e.g., food contact packaging, contract food packaging, food ingredients, pet food, service providers (e.g., transport, warehouse, logistics, uniforms)) have been challenged to make determinations with limited comparable reference.
Unfortunately, facilities like these are often left with ineffective HACCP programs that are deficient in managing operational risks unique to the company’s product or processing environment. This may include a lack of risk assessments, minimal preventive controls and validations, or not being scalable to the changing requirements of the market (i.e., GFSI continuous improvement, science-based findings of risks, FSMA’s Hazard Analysis and Risk Preventative Controls (HARPC)).
Workable HACCP Solutions
Food companies, including food grade ingredients, food contact materials, packaging, and service providers (e.g., transport, warehouse, logistics, uniforms) need to develop HACCP programs using a “clean-sheet” approach rather than following the established HACCP templates used for other specific food processor types. This approach should be based on the fit of their operations (e.g., high risk protein, low risk protein, liquid or dry ingredient, chemical, packaging, or logistics) to existing HACCP models and templates and/or the unique aspects of the operational models and food risks.
Effective and workable approaches to mitigating the above issues should consider designing and customizing HACCP trainings to include product and unique process flow. To best accomplish this, several issues must be addressed, including the following:
- Training needs to be more open to specific and unique industry and operational needs. It further needs to be “fit for the use” of the related product and process food safety risk. For example, in packaging with high engineering of product, training needs to focus on the ultimate process design and capability developed and maintained through process engineers.
- Content registers must be developed to provide elements and direction for HACCP program design, development, and implementation. HACCP teams should work under the direction of a competent and advanced HACCP-trained coordinator to design and establish the content register during development and implementation, in addition to using the established 5 Steps Approach and 7 HACCP Principles per Codex Alimentarius. The content register should address risks and control measures that are unique to operations, finished product, and services that impact food safety (e.g., pest control, service contractors, trainings, co-manufacturers).
- HACCP development process needs to be open and channel aspects of the program to the risks associated with non-traditional HACCP food applications or service operations.
- In-depth reviews and assessments should be conducted by an appointed HACCP/food safety team and/or outside expert with emphasis in the following areas:
- Food ingredients, including dry, mill, liquid, whole grains, snack foods, etc.
- Potential pathogens unique to raw materials/ingredients, potentially introduced from processing conditions and environment, water activity (Aw), allergen control program, operational product changeover, food contact utensils, maintenance tools, microbial air quality based on air handling units, process room air quality and pressure, critical equipment necessary for safe food production, environmental monitoring programs, cleaning in-place (CIP) and cleaning out-of place (COP), plant construction monitoring program during operation, preventive maintenance program for critical parts and aligned equipment, employee traffic, material and product handling, contact packaging supplier, etc.
- Food contact packaging (i.e., flexible films, lids, paper, converters, rigid plastic, glass, metal), including source and validation of inks and dyes (domestic or import), compressed air quality, type of lubricants (food grade vs. non-food grade, soy- or mineral oil-based), physical and chemical properties with reference to ink, migration and permeability, compatibility and reaction of adhesives/inks under various handling conditions by consumers such as heat and cold. These could be mitigated through documented material and ingredient vendor/supplier validation studies or in-house finished product shelf-life studies.
- Service providers (e.g., transport, logistics, uniforms), including air flow and circulation during handling and transportation of refrigerated and frozen foods, approved laundry chemicals, cleaning water temperatures, verification and validation of cleaning uniforms during storage and transportation, driver and personnel training of critical responsibilities that impact food safety.
Operational Processes and Food Risks
HACCP training and programs are typically based on high-risk products to biological contamination, but there are many other product and operational scenarios now requiring HACCP. Companies should compare their operational process and food risks to HACCP model options. This can be achieved through the following:
- Reviewing and assessing available human and financial resources with accountability for deliverables
- Developing high-level, risk-based matrix models
- Aligning definitions for likelihood and severity factors with identified potential and operational risks from biological, physical, chemical, allergen, and radiological perspectives
- Using scientific validations aligned with process and/or product scope
- Conducting documented and statistically scientific in-house verification and validation study
- Further aligning FSMA preventive controls and incorporating them into the various food operational and risk categories
Developing and implementing a HACCP program requires a significant investment of time and effort. Though HACCP continues to evolve, it is up to the individual company to design and customize HACCP programs to make them effective and workable, particularly in foods and industry segments outside of HACCP’s “standard” risk categories. Identifying industry, academic, category, customer, supplier, and established global information can help support plan design, including hazard analysis, preventive controls, and risk rating/ranking.
In addition, there are a number of operational considerations that can help ensure a compliant and value-adding HACCP program:
- Appoint a food safety team with extensive process and product experience, including R&D, product engineering, process engineering, and maintenance
- Conduct effective and customized HACCP team training by a certified lead HACCP trainer with extensive and varied product process experience, including contact packaging, high risk, milling, snack food, etc.
- Establish an approved and verifiable supplier and purchasing program
- Conduct in-depth risk assessment and implement mitigation strategies for critical equipment
- Include and establish critical equipment/equipment during the process hazard analysis risk assessment and development
- Achieve compliance to GFSI scheme of choice as a HACCP plan requirement
- Develop and implement a verifiable change management program that focuses on new product and product development
- Develop a robust in-house training program for critical control points (CCP) and operational prerequisite monitors and verifiers
Submitted by: Regina Tihfon