Implementing Hazard Analysis and Critical Control Point (HACCP) is crucial for any food business as it helps to identify weaknesses in the preparation and production of food. It also identifies critical limits in compliance with food law and helps to take preventive and corrective measures.
HACCP is therefore, that management tool that provides a structured, systematic approach to the identification of hazards and methods of control that is not achievable by traditional testing and inspection approaches (quality control). During implementation of HACCP, it is imperative to set controls at each point of the production line at which safety problems (physical, chemical and microbiological) are likely to occur.
A HACCP plan is required to be in place before initiating the HACCP system. A HACCP plan consists of 5 initial steps and 7 major HACCP principles. The requirements for Sanitation Standard Operating Procedures (SSOPs) along with Good Manufacturing Practices (GMPs) & Good Hygiene Practices should be considered as Pre-Requisite for HACCP.
II. APPLICATION OF HACCP SYSTEM
- HACCP Implementation steps
1.1 Assemble HACCP team
The food operation shall ensure that the appropriate product specific knowledge and expertise is available for the development and implementation of an effective HACCP plan. A multidisciplinary team shall be assembled either in-house or if such expertise is not available on-site, expert advice shall be obtained from other sources, such as trade and industry associations, independent experts, regulatory authorities, HACCP plan shall be identified and shall describe which segment of the food chain is involved and the general classes of hazards to be addressed (all or selected classes).
1.2 Describe product
A full description of the product shall be drawn up, including relevant safety information such as composition (including raw materials ingredients, allergens), origin, physical/chemical properties that impact food safety (including Aw, pH, etc.),microbial/static treatments (heat treatment, freezing, brining, smoking etc.), packing, labelling, durability and storage conditions and method of distribution. Within businesses with multiple product for example, catering operations with similar characteristics or processing steps may be grouped for the purpose of development of the HACCP plan.
1.3 Identify intended use
The intended use of the product shall be defined based on the expected uses of the product by the end user or customer. The suitability of the product for vulnerable groups of the population such as pregnant women, infants, and elderly should be considered, as necessary.
1.4 Construct flow diagram
The flow diagram shall be prepared to cover all steps in the operation for each specific product or product category. When applying HACCP to a given operation, consideration shall be given to steps preceding and following the specified operation.
1.5 On-site confirmation of flow diagram
Steps shall be taken to confirm the proceeding operation against the flow diagram during all stages and hours of operation and amend the flow diagram where appropriate. The confirmation of the flow diagram should be performed by a competent person or persons. On-site verification activities shall be carried out whenever there are any changes in the process.
1.6 List of all potential hazards associated with each step
Conduct a hazard analysis, and consider any measures to control identified hazards (SEE PRNCILPLE 1) The HACCP team should list all potential hazards (physical, chemical, biological) that may be reasonably expected to occur at each step according to the scope. It should then conduct a hazard analysis to identify for the HACCP plan which hazards are of such a nature that their elimination or reduction to acceptable levels is essential to the production of safe food.
In conducting the hazard analysis, the following should be included as appropriate:
- The likely occurrence of hazard and severity of their adverse health effects
- The qualitative and/ or quantitative evaluation of the presence of hazards
- Survival or multiplication of micro-organisms of concern
- Production of persistence of foods of toxins, chemicals or physical agents
- Conditions leading to the above.
For selection of control measures, consideration shall be given to what control measures, if any, can be applied to each hazard.
More than one control measure may be required to control a specific hazard and more than one hazard may be controlled by a specified control, measure. Where elimination of hazard is not practical, justification for acceptable levels of the hazard in the finished product shall be determined and documented.
1.7 Determine Critical Control Points (SEE PRINCIPLE 2)
For each hazard that requires control, control measures shall be identified. The control measures shall be reviewed to identify those that need to be addressed through the HACCP plan and for which CCPs shall be identified. There may be more than one CCP at which control is applied to address the same hazard or there may be cases where there is no CCP identified. The CCP in the HACCP system shall be determined and this may be facilitated by a logic reasoning approach such as the application of a decision tree. The application of a decision tree should be flexible. This example of a decision tree may not be applicable to all situations and alternative approaches may be used.
If a hazard has been identified at a step where control is necessary for safety, and no control measure exists at that step, or any other, then the product or process should be modified at that step, or at any earlier or later stage, to include a control measure.
1.8 Establish Critical Limits for each CCP (SEE PRINCIPLE 3)
Critical Limits shall be specified and validated for each CCP. In some cases, more than one critical limit may be elaborated at a particular step.
These critical limits shall be measurable, Critical Limits based on subjective data (such as visual inspection of product, process, handling) shall be supported by instructions or specifications and / or education and training.
1.9 Establish a monitoring system for each CCP (SEE PRINCIPLE 4)
A monitoring system shall be established for each CCP to demonstrate that the CCP is under control. The monitoring shall be able to detect loss of control at the CCP and in time to make adjustments to regain control of the process and prevent violation of the critical limits. Where possible, process adjustments should be made when the results of monitoring indicate a trend towards loss of control at a CCP. The adjustment should be taken before a deviation occurs.
Data derived from monitoring shall be evaluated by a designated person with knowledge and
authority to carry out corrective actions when indicated. If monitoring is not continuous, then the amount or frequency of monitoring shall be sufficient to ensure that the CCP is under control. The monitoring system shall cover the following:
- Measurements or observations that provide results within an adequate time frame;
- Monitoring device used
- Applicable calibration method
- Monitoring frequency
- Responsibility and authority related to monitoring and evaluation of monitoring results
- Records.
All records and documents associated with monitoring CCPs shall be signed by the person(s) doing the monitoring and by the responsible reviewing official(s) of the company.
The monitoring methods and frequency shall be capable of determining when the critical limits have been exceeded in time for the product to be isolated before it is used or consumed.
1.10 Establish corrective actions (SEE PRINCIPLE 5)
Specific planned corrective actions shall be developed for each CCP in the HACCP system in order to deal with deviations when they occur and to prevent their recurrence. This may require identification of the causes of deviation.
The action shall ensure that the CCP has been brought under control. Actions taken shall also include proper disposition of the affected product. Deviation and product disposition procedures shall be documented. Records of deviations and disposition shall be maintained.
1.11 Establish Verification Procedures (SEE PRINCIPLE 6)
The verification procedures consist of two activities, verification activities and validation activities.
The food business operator shall have in place a system to verify the HACCP plan at a set frequency. Procedures for verification shall be established. The frequency of verification should be sufficient to confirm that the HACCP system is working effectively.
Verification should be carried out by someone other than the person who is responsible for performing the monitoring and corrective actions. Where certain verification activities cannot be performed in-house, verification should be performed on behalf of the business by external experts or qualified third parties.
The HACCP system, including the HACCP plan, shall be reviewed (at least once in a year) and necessary changes made when any modification is made in the product, process, or any step.
Verification activities shall include:
- Self-evaluation
- Review of the HACCP system and plan and its records
- Review of deviation and product dispositions
- Confirmation that CCPs are kept under control.
The results of verification shall be maintained and communicated to the HACCP team/ relevant staff.
The food business operator shall periodically validate the HACCP plan and necessarily before its implementation and after any changes are made. The objective of the validation process is to ensure that identified hazards are complete, correct and effectively controlled under the HACCP plan. Validation activities should include actions to confirm the efficacy of the HACCP system. Records of validation shall be maintained. An annual review of the complete HACCP system shall be carried out.
Verification and validation activities are also important for maintenance of the system as well as continual improvements.
1.12 Establish Documentation and Record Keeping (SEE PRINCIPLE 7)
HACCP procedures shall be documented. Documentation and record keeping shall be appropriate to the nature and size of the operation and sufficient to assist the business to verify that the HACCP controls are in place and being maintained.
Documentation shall include (as a minimum) the following:
- HACCP team composition
- Product description
- Intended use
- Flow chart
- Hazard analysis
- CCP determination
- Critical limit determination
- Validation process
- HACCP plan
The HACCP plan shall include the following information for each identified CCP:
- Food safety hazard(s) to be controlled at the CCP
- Control measure(s)
- Critical limit(s)
- Monitoring procedure(s)
- Corrections and corrective action(s) to be taken if critical limits are exceeded
- Responsibilities and authorities for monitoring, corrective action and verification; – Record(s) of monitoring.
Records to include
- CCP monitoring activities
- Deviations and associated corrective actions
- Disposition of non-conforming products
- Verification procedures performed
- Modifications to the HACCP plan
- Validation record
- Product release records
- Testing records.
Source: FSSAI
Anju Chauhan says
VERY WELL EXPLAINED THANKYOU