Safety, Not Quality

Stephanie Richardson, president of Preventive Environmental Management, Inc., a consulting and assessment firm for the food processing industry, pointed out that HACCP is a process control system, and as such it deals with food safety, not quality.

“Food quality is touchy-feely stuff,” she said. For consumers, “A lot of [food safety] is perception — after all, we’re meat eaters — but HACCP is still needed.”

The regulation’s objectives are to minimize risk and comply with Food Inspection Safety System (FSIS) requirements by being proactive and preventive rather than reactive. “Industry is responsible for implementing the process controls to ensure pathogen reductions,” Richardson said. “FSIS’s responsibility is to oversee and confirm that those process controls are in place.”

As of January 25, 2000, all poultry and red meat processing facilities should have implemented HACCP, regardless of their size and number of employees. Some retailers are even requiring their cold storage facilities to implement HACCP, even though they are not required to do so by law.

The HACCP rule is two-pronged. It addresses implementation of the HACCP system of monitoring and paperwork, in addition to regulations for pathogen reduction, including E. coli and salmonella. If a facility is found to be in violation, it risks being “hit, and hit hard” by fines and penalties, Richardson said. Some facilities have been closed.

A written plan is required for each product a company deals with, that describes:

Planned activities;

Set limits;

The responsible party(ies) for monitoring;

When and how monitoring is provided;

Actions to take following a deviation; and

Strategies to ensure that it’s working.

So, a poultry processor would need to have a separate plan written, acted upon, and audited for chicken nuggets, patties, breasts, whole fryers, parts, etc.

Basic Principles

According to Richardson, HACCP has seven basic principles:

1. Conduct hazard analysis.

2. Establish critical control points (CCPs), such as those within the refrigeration process.

3. Establish critical limits.

4. Establish a monitoring procedure.

5. Establish corrective action.

6. Establish recordkeeping procedures.

7. Establish a verification procedure.

The purpose behind all this is “to determine at what point contamination occurred,” Richardson said. She mentioned the fact that some consumers are quite lax in their own food-handling practices, and do things like leaving the chicken in the car on a hot day while running other errands on the way home from the grocery. However, consumer awareness of food safety is quite high, and industry needs to protect itself.

Principle 1, the hazard analysis, includes walking through the process to determine where risks may occur. In addition to tracking ingredients, creating a process flow diagram, and identifying hazards at each process step, she said direct observation of the process is key. “Use those eyeballs. Don’t just look at it on paper.”

Biological Hazards

Biological hazards are the strongest concern to the refrigeration industry, Richardson said, although there is some risk from chemical hazards (such as refrigeration lubricants on the conveyor belts).

Biological hazards include bacteria, viruses, parasites, protozoans, molds, yeast, spores, and others. This brings us to principle 2, identifying CCPs (those points at which you can control whether contamination may or may not occur).

The first common CCP is chilling, followed by cooking, formulation, processing, and slaughter. To establish a CCP, you document each step previously identified as a food safety hazard. Then you document each food safety hazard indicating the type (physical, biological, etc.). Finally, document each food safety hazard using the decision tree analysis.

The CCP decision tree asks:

Does this step involve a hazard of sufficient risk and severity to warrant its control? If yes,

Does a preventive measure for the hazard exist at this step? If yes,

Is control at this step necessary for safety? If no, then it’s not a CCP. If yes,

Modify the step, process, or product.

“The fewer CCPs you have, the better,” said Richardson.

Principle 3 establishes critical limits for preventive monitoring. Critical limits are expressed as numbers, and include time, temperature, humidity, water activity, pH, salt, and chlorine levels. In addition to setting up monitoring and ensuring its operation, facilities need to file supporting documentation for reference.

Principle 4 also deals with monitoring by setting procedures for using the results of monitoring to adjust the process and maintain control. “You’ve got to monitor,” said Richardson. “It proves that you’re maintaining control.” She added that one level of monitoring isn’t enough; “I would have four backups.”

Principle 5, corrective action, requires that immediate action is taken to adjust the process and hold product for further evaluation. It also requires that employees have the right to stop the production line if they suspect that product is not in compliance.

Principle 6, on recordkeeping, is detailed and minute. Richard-son’s general advice: “Document everything.”

Principle 7, on establishing verification procedures, is meant to ensure that the HACCP is working correctly. “Do an audit,” Richardson advised. “Review monitoring records. Calibrate equipment regularly. Document that you did this.”

Biological Hazards II

After telling her audience to wake up, Richardson stated that “The majority of biological hazards in the meat and poultry industry are bacterial.” These are strongly associated with chilling and refrigeration, which are definitely CCPs. Bacteria come in a number of shapes, they are microscopic in size, and they multiply quickly. They are grouped into categories based on temperatures at which they reproduce: Thermophiles grow at higher temperatures, and are therefore not much of a concern to refrigeration technicians. Mesophiles grow in medium temperatures (like the human body temp), and are still not much of a concern to refrigeration technicians, unless the cooler/freezer isn’t operating properly. Psychotrophs grow at refrigeration temperatures, and can be carried in water and ice. They include common spoilage bacteria, and grow in dark, cool, moist areas, like drains. Listeria is a psychotrophic bacteria (see Table 1). Condensation in general is a concern for bacteria transmission and growth, and this is an area of high interest to refrigeration technicians. “Once Listeria takes over a plant,” said Richardson, “it is a bear to get under control.”

Protect Yourself

Refrigeration specialists can protect themselves and their companies by:

Routinely monitoring temperatures;

Having backup monitoring equipment;

Routinely calibrating thermometers and thermostats;

Documenting monitoring and calibration activities;

Ensuring that all employees understand the importance of HACCP;

Designating an employee for monitoring, and giving that position three more people as backups;

Establishing a system that allows for easy identification of questionable product once it is in your control; and

Documenting everything.

“It’s a lot of paperwork,” said Richardson. “It’s a lot of monitoring.” And although refrigeration contractors may not be particularly interested in it, their clients certainly are.

As one attendee said, “We have to sound like we care when we talk to people” about HACCP.

Publication date: 12/04/2000