Preparatory Stage A: Prerequisite food hygiene requirements

• The title of the document. For example “Policy for glass and plastic management.”
• A brief statement on the purpose of the prerequisite measure. For example “To prevent contamination of products from glass or plastic from the factory environment.”
• What measures are necessary to achieve the desired outcome. For example, ”No glass containers to be taken into production area.”
• Who will be responsible for ensuring that the requirements are met. For example, “Production supervisors must ensure that no glass containers are taken onto the production floor.”
• The nature and frequency of any checks that are to be made and by whom. For example, “Production supervisors must check the production area for any glass containers prior to commencing production each day.”
• What should happen if something goes wrong. For example, “Glass bottle found in production area. All staff provided with refresher training on glass policy to prevent recurrence.”
• How, where and by whom these checks are recorded. For example, “Production supervisors must record each pre-production glass check on form X1.”
• When and by whom the procedure must be reviewed for example, “This policy to be reviewed every 12 months by the Operations Manager.”

Operational Prerequisites

Most prerequisites are general in nature and their purpose is to ensure the general hygiene conditions of the food business. However, some prerequisites may be identified through the HACCP study as being critical to food safety to control a specific hazard. These are referred to as “Operational Prerequisites” or “OPR” and they should be carefully identified and managed. 

Find out more about Operational Prerequisites.

References

1. Codex alimentarius food hygiene (basic texts) Fourth edition
2. Canadian Food Inspection Agency: Guide to prerequisite control
3. Appropriate Industry guides

Preparatory Stage B: Obtain Management Commitment

The preparation and effective implementation of a HACCP system requires both time and effort not just on the part of the HACCP development team but also by everyone who is involved in the preparation and handling of your food. As such, there should be a clear statement by management which commits their support to the process. The MyHACCP tool will ask you to provide evidence that such management commitment has been obtained.

It is best for the commitment to be made in the form of a clear written statement of management support for the HACCP process which gives authority to the HACCP team and can be referred to in staff briefings and training sessions. It would also be helpful to include details of the resources that will be made available for the process.

You might prefer to include the commitment to HACCP within a broader food safety policy that you make available to both staff and customers, for example on your website, to demonstrate your determination to develop and implement an effective food safety management. Smaller food businesses in particular may choose to simply make such a declaration.

The key elements of a declaration of management commitment might include:

• Allocation of sufficient staff resources to complete the HACCP study and implement the HACCP system.
• Recruitment of any specialist staff needed to support the HACCP team.
• Raising awareness of the HACCP process with all staff and provide sufficient training to those directly involved in the study.
• Involvement of members of the management team as necessary.
• A commitment to provide timely management decisions as required by the HACCP team to facilitate the development and implementation of the HACCP.
• Purchase of additional equipment as required to ensure the effective operation of the HACCP system.

Preparatory Stage C: Define scope of the study

• selecting an appropriate plan
• briefly describing the product
• identifying the start point and end of the study 
• considering the likely hazards to be encountered

1. Type of HACCP plan

Linear plan

1. Picking of fruit
2. Transport
3. Reception
4. Storage
5. Juice extraction
6. Clarification
7. Juice production
8. Packaging
9. Despatch

Modular plan

• Module 1: Fruit reception
• Module 5: Juice extraction

1. Unload
2. Prewash
3. Pregrade
4. Sampling
5. Storage
6. Final wash
7. Final grading

2. Type of product and how it is packed

3. Start and end points of study

4. What hazards will the HACCP plan cover?

• Physical hazards are specifically associated with a food, for example bones in fish or stones in fruit, or where a residual risk exists once appropriate pre-requisite controls have been put in place. For example, glass contamination in areas where products are packed in glass containers.
• Chemical hazards might include, for example, detergent residues from cleaning or chemical residues from farming practices such as antibiotic residues in milk.
• Microbiological hazards will include relevant bacteria, such as Salmonella, viruses such as norovirus and parasites such as nematodes. In most cases microbiological hazards should be specifically identified rather than merely classifying them by type such as “bacteria” or “viruses”. This is because different microorganisms will have different growth, death and survival characteristics which must be addressed separately in the HACCP plan.
• Food allergens: There are many foods which may cause allergies or intolerances to susceptible consumers but for the purposes of HACCP only the 14 allergens listed in Annex II of Regulation (EU) 1169/2011 need to be considered. These are: 

1. Named cereals containing gluten
2. Crustaceans
3. Sesame seeds
4. Sulphur dioxide & sulphites
5. Fish
6. Soybeans
7. Mustard
8. Peanuts
9. Celery
10. Eggs
11. Milk
12. Named nuts
13. Molluscs
14. Lupins

5. Details of any documents used in the HACCP plan

• Regulation (EC) 852/2004: General food hygiene requirements (HACCP, structure, training etc)
• Regulation (EC) 178/2002: General food law (Safe food, traceability, product withdrawal etc)
• Regulation (EC) 2073/2005: Microbiological criteria for food
  • Food Standards Agency Guidance
  • Chilled Food Association guidance on microbiological testing and interpretation

Preparatory Stage D: Select the HACCP team

• Members of the team should be drawn from all relevant areas of the business and from all relevant staff levels. There should be, where possible, a healthy mix of management and operators from different parts of the business. 
• The team should possess adequate technical knowledge to identify relevant hazards and appropriate controls. The team should also include members with sufficient practical knowledge of the process to advise on the practicalities of implementing such controls.
• Members of the team should be provided with sufficient training and management support to allow them to participate freely in the HACCP team.

Choosing members of the HACCP team

• the necessary technical expertise
• knowledge of what actually happens in practice during the manufacture of the food 
• knowledge of the practicalities of any controls suggested by the HACCP team

Roles of HACCP team members

• Administrative – Members of the administrative group will be responsible for ensuring that the HACCP process is completed in a logical way and adequately documented. They will typically need a detailed understanding of the HACCP process.
• Technical – Members of this group will have a detailed understanding of food science, technology and hygiene as well as a good knowledge of HACCP.
• Operational – Members of this group should have a detailed knowledge of how the business operates in practice.
• Other – Additional expertise should be recruited into the HACCP team as necessary. 

Preparatory Stage E: Describe the product

• physical and chemical properties of the food
• the food packaging
• conditions of storage and distribution
• required shelf life 
• information to be provided to the consumer regarding appropriate storage, handling and use.

• Intrinsic factors: those found within the product itself such as its structure and composition.
• Extrinsic factors: those which are external to the food such as temperature control, packaging and method of processing.

1. List all the ingredients and the name of the supplier for each one

2. State the physical properties of the product

• Physical state – Is the food a liquid, solid, foam, emulsion etc
• Water activity (a_w) – this is the water that is available to microorganisms in the food. Whilst some foods may appear moist, the presence of sugar or salt in the liquid component of the food may prevent microorganisms from accessing the water thus restricting their growth. This is why the use of sugar, for example in jam making, or salt in the case of smoked salmon can be very effective at controlling the outgrowth of both spoilage and dangerous bacteria. Drying foods has an effect on both the moisture content and the a_w. Pure water has an aw of 1.0 and the addition of salt or sugar will reduce this value closer to 0. Most bacteria require an aw value > 0.92 to successfully grow in food but some moulds may be able to grow below this. The aw value is most easily determined in liquid and homogenous foods where the sugar/salt content is likely to be evenly distributed throughout the food. Difficulties in determining a representative aw value may arise in composite foods which contain different varieties of ingredient distributed in an uneven way through the food, for example a meat stew. This will be a matter for your HACCP team to consider.
• pH – This is the measure of the acidity of a food and many bacteria are unable to grow in acidic conditions. For example, Salmonella species will typically grow well at neutral pH (7.0) but are unable to grow in acid conditions of 4.0 or below. As for aw, care should be taken to ensure that any pH measurements taken are representative of the food. For example, in a ready meal the pH of the curry sauce may be 5.5, which would inhibit the growth of some bacteria, but within clumps of vegetables it might be 7.0 which might permit the outgrowth of dangerous bacteria.
• Salt content – Whilst this affects the aw of the food, salt can also have an inhibitory effect on some bacteria in its own right.

3. Describe how the product is processed and/or other preservation methods used

• Heat treatment – Microorganisms can be affected by heat in different ways. Some, such as Salmonella and Campylobacter, will be easily killed by normal cooking temperatures (70°C for 2 minutes) whereas others, such as Clostridium botulinum and Bacillus cereus, will survive such temperatures by forming spores
• Hot smoking – Typically used for fish and meat products at temperatures of approximately 70°C – 80°C and often used in combination with brining
• Brining – Can involve the immersion of food into salt water or the direct application of salt crystals to the outside of the food
• Drying – used for a range of products including milk, egg, herbs, fish and meat products
• Fermentation – the production of alcohol and/or acids in foods, used in the production of meats such as salami as well as in bakery and brewing products

4. Describe how the product is packed and the packaging materials

5. How is the product going to be stored and distributed?

• ambient
• chilled
• frozen

6. What is the shelf life of the product?

Durability date

7. State what your advice is to the purchaser for storing, handling and preparing the product

• Storage instructions prior to opening packaging
  • “Store in a cool dry place”
  • “Keep refrigerated”
  • “Keep frozen”
• Storage instructions once packaging has been opened
  • “once opened, keep refrigerated and use within 3 days”
• Cooking instructions
  • “Cook at 200°C for 30 minutes. Check that food is piping hot before serving”

Preparatory Stage F: Identify intended use of the product

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Statement

The HACCP team need to have a thorough understanding of the intended use of the product(s) included in the HACCP study so that they may undertake an accurate hazard evaluation as part of the Hazard Analysis.

How is this stage achieved?

There are two key factors which are relevant here:

1. The nature of the intended customer.

2. The extent of any further processing of the food prior to consumption.

 Note this list is not exhaustive

Again, the HACCP team should consider the likely abuse/unintended use of the product by the customer or final consumer (See guidance on this under Preparatory Stage E).  You should consider if the product you produce could result in it being sold to a market other than that intended.

2. The extent of any further processing of the food prior to consumption.

Different microbiological criteria will apply depending on whether the food product is supplied raw, processed or ready to eat to the final consumer. The HACCP team will need to clearly define which of these categories applies to the food and what, if any, instructions will need to be provided to the customer to assure the safe consumption of the food.

For example, if the product is supplied to the customer as a ready to eat food, this should be clearly stated on the labelling. Most importantly, however, the HACCP team will need to ensure that any decisions made during the hazard analysis element of the HACCP study takes into account the fact that the food will receive no further processing prior to consumption. Critical control points identified by the HACCP team in the production of such foods will need to “prevent or eliminate” hazards arising from the presence of pathogens such as Salmonella and E.coli o157.

For other types of food, clear information, typically on the food label, should be provided to the consumer where steps are required to be taken prior to the consumption of food to make it safe. For example, a product containing raw poultry should be clearly labelled as such and include clear, validated cooking instructions. It may be that the identified critical control points for a raw or processed food are sufficient to reduce a hazard, such as Salmonella, to an “acceptable level” rather than total elimination because the food will be subjected to further processing by the customer.

Preparatory Stage G: Construct a flow diagram

A process flow diagram shows all the steps involved in the process outlined in the scope of the study. The scope is defined in Preparatory Stage C. 

Making a process flow diagram

The HACCP team or the person leading the development of the HACCP study should construct a flow diagram.  Whatever format you choose, all steps in the process outlined in the scope of the study should be included.

You may wish to use a schematic layout of the factory to help you. Knowledge of what actually occurs in your processes is essential.

Listing the steps in the process

List each step in the process or module. You should consider what happens all the way from receiving the raw materials, through to at least the point of despatch or up to the point of final consumption of the product. 

Think about:

• Preparation
• Packing
• Storage
• Distribution
• You could also consider the following:
• Raw material addition (including water)
• Services (air, water, steam)
• Any temporary product storage or hold periods (particularly during peak production times)
• Recycle or rework loops
• Process delays

You can use a linear or modular format for your process flow diagrams. This might depend on how complex your processes are, and whether parts of a process are the same for several products. 

View ‘Process flow diagrams’ for some examples of linear and modular diagrams and when you would use them.

Draw a rough paper sketch of the product flow.  Consider how the process is managed and what could realistically happen while it’s in progress. For example, consider optional and intermittent activities.

Including technical data

The inclusion of relevant technical data will depend on the complexity of the operation. This data is useful at the Critical Control Points that you will identify later.  

Technical data could include:

• Time for process or process element (e.g. fry for 2 minutes at 190°C or cool to <5°C in 4 hours)
• Temperature at different parts of the process (e.g. fry at 190°C for 2 minutes or cool to <5°C in four hours)
• Line speed
• Floor plan, equipment and services layout
• Segregation of low/high risk operations
• Personnel routes
• Flow conditions for liquids and solids (psi=pounds per square inch or temperature in °C)
• Waste flows
• Movement routes for raw materials/ingredients

A piece of equipment may have several functions (e.g. a bottle filling machine including rinsing, volumetric/gravity/vacuum/hot fill and capping functions).  All functions should either be included in the description at the process step OR each function entered as a different process step.

Preparatory Stage H: On-site confirmation of flow diagram

Statement

The flow diagram must be checked to verify that it is correct and shows all steps involved in the process as outlined in the Scope of the study (Preparatory Stage C).

How is this stage achieved?

The flow diagram should be confirmed as being correct. It is recommended that this is carried out by someone not familiar with the process in addition to members of the HACCP team. The advantage of having someone not familiar with the process to check the diagram is that “they are a fresh pair of eyes”, and may identify a step that has been overlooked.

You may wish to consider the following:-

• Ensure it is a current and accurate representation of the process/module
• Ascertain if practices are the same for all shift patterns, differing staff levels, seasonal variations, all production patterns (e.g. high and low production volumes)

Documentation and Records

1. Record that the flow diagram has been confirmed as being correct
2. Record the date it was confirmed as correct
3. Record who confirmed the flow diagram as being correct

Records of out-of-date flow diagrams must be kept.

Review

The flow diagram shall be subject to review and should be current and accurate at all times. Amend the flow diagram as the process changes.

Principle 1.1: Identify and list potential hazards

What does this mean?

How is this stage achieved?

• The likely presence of the hazard in raw materials
• Whether the hazard may be introduced during a process step
• Potential for the survival, multiplication or increase in frequency of a hazard at a process step

What will be the result?

Principle 1.2: Conduct a hazard analysis

What does this mean?

How is this stage achieved?

1.   Write a hazard description for each hazard

Presence:

• Presence of Salmonella in raw chicken pieces
• Presence of E.coli o157 in raw beef mince
• Presence of stones in sacks of chick peas
• Presence of bones in fish

Introduction:

• Introduction of E.coli o157 by cross-contamination from utensils
• Introduction of glass from broken light fittings
• Introduction of Listeria from condensate dripping into open food

Growth:

• Growth of Salmonella during ageing process
• Growth of Clostridium perfringens during cooling
• Growth of moulds during maturing process

Survival:

• Survival of Clostridium botulinum spores
• Survival of Trichenella parasites
• Survival of spoilage spore-forming bacteria

2.   Provide a severity score for each hazard

Score 1: Low severity

• Taints in food where there is no actual chemical contamination;  for example, exposure to diesel exhaust fumes or taints from packaging
• Discolouration of food
• Use of wrong ingredient (except if this introduces an undeclared allergen)
• Incorrect “Best before date” applied

Score 2: Medium severity

• Foreign objects which are unlikely to be ingested or to present a choking hazard
• Residual detergent in process equipment
• Enteric viruses such as Norovirus 
• Pathogenic bacteria such as Campylobacter, Bacillus cereus and Staphylococcus aureus which rarely cause serious illness
• Pesticide or heavy metal residues in food

Score 3: High severity

• Pathogenic bacteria or their toxins which cause serious illness or may kill such as E.coli o157 and other VTEC, Salmonella, Clostridium botulinum.
• Protozoa such as Cryptospiridium
• Sharp glass or metal fragments which might be ingested
• Food allergens

3.   Provide a likelihood score for each hazard

• The product description as set out in Preparatory Stage E and in particular any chemical or physical properties of your food which might encourage or inhibit microbial growth
• Any published guidance on the likelihood of the hazard, such as food poisoning statistics or information produced by the Food Standards Agency
• The history of such hazards associated with your food

• Score 1 indicates “Low” likelihood. Here it is unlikely, although still possible, that the event will occur. In other words, it is possible but not probable that the hazard will occur in practice. 
• Score 2 indicates“Medium” likelihood. Here it is reasonably foreseeable that the hazard will occur. It could happen although there may not be any evidence of it having happened before.
• Score 3 indicates “High” likelihood. It is very likely that the hazard will occur.

4.   Determine your significant score

Principle 1.3: Specify the control measures for each hazard

What does this mean?

How is this stage achieved?

Control measure

Any action and/or activity that can be used to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

Monitoring

Conducting planned observations or measurements to assess whether a CCP is under control.

• More than one control measure may be necessary to effectively manage a specific hazard. For example, use of a metal detection system, maintenance of the detection system, and training on using it might all be needed to avoid the hazard of metal pieces in food. 
• One control measure may manage more than one hazard.  For instance, oil temperature and fry time can be an effective control for reducing both numbers of Salmonella and Campylobacter in fried food.
• Control measures are not always carried out at the same Process Step where the hazard arises.  For example a hazard at Process Step 1 may be ‘presence of metal in raw material from supplier’; this may have several controls including the use of only pre-approved suppliers, or supply to an agreed specification.  These controls will appear at Process Step 1, however a control measure at Process Step 15 ‘effective working metal detector and rejection system’ is also a control for this hazard.

Principle 2: Determine the Critical Control Points (CCPs)

What does this mean?

A Critical Control Point (CCP) is a step at which control can be applied and is essential to prevent or eliminate a food safety hazard, or reduce it to an acceptable level.

How is this stage achieved?

The correct determination of CCPs is vital to ensure that there is effective management of food safety. The number of CCPs in a process will depend on the complexity of the process itself and the scope of the study (for example, whether there are just a few types of hazard, or lots of different hazards).

CCPs should be determined through experience and judgement; this may be aided by the use of a decision tree.

If you decide to use a decision tree

There are many different decision trees to choose from.  The MyHACCP tool shows you the Codex decision tree or Campden BRI decision tree, but you are not restricted to using these.   You can use a decision tree of your choice, some businesses devise their own.

• Codex decision tree

• Campden BRI decision tree

Using MyHACCP to work through a decision tree (Codex or Campden BRI’s)

• Q1. Do control preventative measure(s) exist? This refers to control measures.
• Q2. Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?  This refers to the process step (not the controls).
• Q3. Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable levels? Think about this in terms of 'if you lost control'.
• Q4. Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level?  This refers to whether there is another process step further on in the process flow diagram that will eliminate identified hazard(s) or reduce likely occurrence to an acceptable level.

Documentation and Records

Review

Principle 3: Establish the Critical Limits

Critical limits are the values at critical control points (CCPs) that must be achieved to ensure the safety of food. These critical limits must be monitored at CCPs, as explained in Principle 4, and failure to consistently achieve these values must result in appropriate corrective action, as outlined in Principle 5. 

Choosing critical limits

The critical limits that you choose must be suitable to ensure that the control measures that you have selected at the CCPs are adequately controlled. As such, appropriate critical limits should meet the following criteria. They should be:

• Observable: Achievement of and any subsequent changes in the critical limits during processing can be detected.
• Measurable: Achievement of the critical limits can be confirmed by measurement and any deviations quantified.
• Subject to “real time” monitoring: Any observations and measurements must be capable of being made whilst processing is in progress to allow appropriate corrective actions to be made in good time.

Critical limits may be chemical, physical or even procedural in nature depending on the type of hazard that is subject to control. Some examples include:

Chemical critical limits

• Water activity (A_w)
• pH
• Salt content
• Mycotoxin levels
• Absence of allergens

Physical critical limits

• Temperature
• Dried weight
• Time
• Absence of metal
• Viscosity
• Moisture content

Procedural critical limits

• “Supply of raw beef from approved slaughterhouses which have specific controls in place to minimise the risk of contamination of meat intended to be eaten raw or lightly cooked.”

• The critical limits for controlling Salmonella in chicken pieces at the cooking step (CCP) could be 70°C for 2 minutes. Both the time and temperature are critical limits and must both be achieved.

MyHACCP tool requirements

Documentation and Records 

Review 

A review of this principle should be scheduled and triggered if there are changes within the company or new information becomes available (e.g. legislation, emergence of a new hazard), as outlined in Principle 6.

Principle 4: Establish a Monitoring System

Monitoring is a planned sequence of measurements or observations at critical control points to ensure that the critical limits are continuously achieved.

How is this stage achieved?

• Nature of monitoring: Monitoring can be made by taking appropriate measurements or by making observations. For example temperature measurement or observation of colour change in a food.
• Method of monitoring: Monitoring procedures may involve either in-line or off-line systems. 
  • In-line systems involve the taking of measurements during the process and may be either continuous, such as using an in-line thermometer or non-continuous for example by inserting a temperature probe into food. 
  • Off-line systems may involve the taking of samples for rapid testing for example to determine pH or A_w using calibrated meters.
  • All monitoring equipment must be calibrated and working correctly.
• Frequency of monitoring: The frequency of monitoring will depend on a number of factors:
  • Nature of the product. The frequency of monitoring may be reduced if the products are all of a uniform size.  
  • Nature of the process for example monitoring may be reduced for automated processes compared with manual ones.
  • Nature of production Monitoring may be carried out per batch and hence the size and number of batches produced during a day may influence the frequency of monitoring. 
  • History of previous checks: Once an initial frequency of monitoring is established it will be possible to either increase or reduce down the frequency depending on the results obtained. 

1. What monitoring activities are going to take place at this CCP?

2. Specify how frequently the monitoring activities are to be carried out

3. Define how the monitoring activities are carried out

4. Who is responsible for monitoring actions at this CCP?

5. Please state the name and job title of the deputy, if applicable

6. Where are the results of monitoring recorded?

7. Will the monitoring records be checked and signed off by anyone?

Documentation and records

Review

A review of this principle should be scheduled and triggered if there are changes within the business, as outlined in Principle 6.

Principle 5: Establish a Corrective Action Plan

How is this stage achieved?

• Corrective actions intended to prevent loss of control at a CCP: This may become apparent when monitoring at a critical control point identifies a failure to achieve target values but the critical limits have not yet been breached. Appropriate responses to this type of event may be an adjustment of the process to prevent loss of control and an investigation into why the target values were not achieved. 
• Corrective actions to be taken when loss of control at a CCP has been identified. This will be the case when monitoring has identified that a critical limit has not been achieved and will require the following response:
  • Restore control to the system
  • Identify and place under control any affected product
  • Investigate the cause of the loss of control

1. What are you going to do straight away? Think about the need to stop the process; quarantine the product; and make quick adjustments to relevant equipment or the process for example by increasing the process temperature or extending the process time.   
2. What are you going to do about affected product that has been produced since the last good check? (This may be in storage/despatch.)  This does not include recalling the product, because monitoring should be sufficient to capture the issue before the product has left site. Think about the need to quarantine the product from the last good check i.e. product manufactured during out-of-control conditions, disposal of the product.
3. What are you going to do to in the future? Think about reworking the product if this is appropriate, carrying out an investigation (review cause and correction to prevent recurrence), disposal of the product.
4. Allocate clear responsibility for the above, for instance who is authorised to dispose/rework the product or take the appropriate corrective action.
5. Are all personnel trained and competent for performing the activities stated? Think about training and competency of personnel involved with any of the above.

Documentation and Records

Review

Principle 6: Verification

How is this stage achieved?

• Validation – "Will the HACCP plan ensure that safe food will be produced?”
• Verification – “Is the HACCP plan working, is it producing safe food?”
• Review - “Is the HACCP plan up to date?”

1. Validation

• Identification of hazards
  • You should reference an authority (journal, guidance, textbook) for each identified hazard or record the reasoning of the HACCP team for the inclusion of each hazard in the HACCP plan. 
• Evaluation of hazards
  • You should include a written justification for the hazard evaluation process used to identify significant hazards in Principle 1.2.
  • An explanation of why a given hazard has been discounted should be included.
• Selection of critical control points
  • You should specify the method used to select  critical control points . For example, use of the Codex Alimentarius decision tree.
• Define critical limits
  • Critical limits can often be validated by reference to relevant literature such as legislation or Industry Guides.
  • If such critical limits are selected then you must demonstrate that your process is capable of operating at the proposed critical limits.
  • If there is no published evidence that proposed critical limits will be sufficient to achieve control at a CCP, it will be necessary to conduct suitable validation exercises such as mathematical and/or microbiological modelling supported by challenge testing or other relevant studies.
• Establish corrective actions
  • Where a corrective action includes an option to rework or reuse a non-conforming product, evidence must be provided to guarantee that such reuse will result in safe food.

• Food Standards Agency guidance on the safety and shelf-life of vacuum and modified atmosphere packed chilled foods with respect to non-proteolytic Clostridium botulinum (2008)
• A code of practice for the manufacture of vacuum and modified atmosphere packaged chilled foods 2nd Ed 2009 (Campden BRI)

2. Verification

• Taking measurements, for example temperatures, at various points along the process to ensure that the system is behaving as expected. 
• Targeted microbiological and/or chemical sampling of intermediate and final products to ensure that the food is meeting expected standards.
• Auditing documents throughout the system to ensure that the correct information is captured, recorded and acted upon in accordance with the HACCP plan.
• External audits on suppliers to verify that raw materials meet expected criteria.
• Staff assessments to ensure that procedures are fully understood and that staff are competent to perform any tasks allocated to them.
• Trend analysis of monitoring data to determine whether process controls are adequate and tolerances realistic.
• Analysis of customer complaints and third party audits to identify any potential gaps in the HACCP plan.
• Analysis of waste and rework figures to ensure that they correspond with records of corrective actions.

3. Review

• Changes in raw materials or product formulation
• Introduction of new product
• Change in raw materials supplier
• Change in processing system
• Change in layout or environment
• Modification to process equipment or new equipment
• Failures in system e.g. corrective action or product recall
• Anticipated change in customer or consumer
• Any report from the market place that indicates a health or spoilage risk associated with the product
• Emergence of a new food-borne pathogen (such as bacteria that can cause illness) with public health significance or other health issue
• Changes in legislation

Documentation and Records

Principle 7: Establish documentation and record keeping

How is this stage achieved?

1. Appropriate to the nature and size of the operation – your local environmental health practitioner will be able to guide you on this requirement.
2. Sufficient to assist the business to verify that the HACCP controls are in place and being maintained.

What to consider regarding documentation

• What records need to be kept?
• How are they to be stored – e.g. hard copy, electronic?
• Where are the documents to be stored?
• How long are the records to be retained for? (what is an appropriate time, think about the shelf-life of the product and possibly how the product may be misused)
• Who is responsible for the records?
• Who needs frequent access to the records?

Examples of documentation

• The HACCP plan
• List of hazards and details of the hazard analysis
• CCP determination
• Critical limit determination
• Training needs analysis
• Procedures – e.g. standard operating procedures, corrective action procedure
• Work Instructions

Examples of records

• CCP monitoring activities
• Deviations and associated corrective actions
• Verification procedures performed
• Modification to the HACCP plan
• Training undertaken
• Daily records (glass and brittle plastic check)
• Visual inspection reports
• Team meeting records
• Processing records

Review

• Does the documentation cover all of the HACCP system operation?
• How is the document controlled with regards to update and issue etc?
• Are all documents accurate and current?
• Are verification procedures documented?
• How is change and version control managed?