For food and beverage brands, nothing is more important than product safety. One recall for a contaminated product could not only jeopardize consumer health, it could lead to legal issues and irreversibly damage your brand’s reputation and your business.
To avoid these kinds of problems, companies rely on Hazard Analysis and Critical Control Point (HACCP) plans to help ensure product safety. HACCP plans have become the international gold standard for food and beverage safety.
But developing, implementing and maintaining a HACCP plan requires your team to follow a strict and methodical process. To ensure product safety at your food and beverage manufacturing facility, here’s everything you need to know about HACCP plans.
According to the FDA, a HACCP plan is “a management system in which food safety is addressed through the analysis and control of biological, chemical and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.” That’s a mouthful, but it essentially means you’re creating a comprehensive plan to address food safety at every level of production.
A HACCP plan is not a substitute for your other health and safety programs, such as Current Good Manufacturing Practices (CGMPs). In fact, it uses those programs as a foundation to further enhance safety protocols. Most HACCP plans are specific to a product or process, but they can also center around unit operations as well. HACCP plans are required by the FDA for certain market segments like meat and juice producers. But they are used by manufacturers across the food and beverage industry.
There are five initial steps for developing a HACCP plan, followed by seven guiding principles. In total, it makes for a 12-part process that’s defined by the FDA as follows:
Step 1: Assemble a HACCP team
Step 2: Describe the product and its distribution
Step 3: Describe the intended use and consumers of the product
Step 4: Develop a flow diagram that describes the process
Step 5: Verify the flow diagram
Step 6: Conduct a hazard analysis
Step 7: Determine critical control points
Step 8: Establish critical limits
Step 9: Establish monitoring procedures
Step 10: Establish corrective actions
Step 11: Establish verification procedures
Step 12: Establish record-keeping and documentation procedures
Let’s take a closer look at each of these steps and why they’re critical for developing a HACCP plan and keeping your food or beverage products safe.
To create a HACCP plan, you need to gather employees from across disciplines and formulate a dedicated HACCP team. This team will be in charge of developing the HACCP plan in detail, so team members need to have functional expertise about your processes and procedures, as well as any equipment used in your operations. Team members will likely come from areas like sanitation, quality assurance, production, engineering, food microbiology and distribution. There will likely be a mix of local and off-site personnel.
It may be necessary to bring in outside experts to help assess some hazards and the HACCP plan overall. However, your company’s employees should form the backbone of the team, as they have the most intimate, hands-on knowledge about your products and processes.
Your team’s first job will be to create a general description of the product as well as the ingredients used and the processing method(s) employed. A description of the distribution method is necessary for all products, whether they need to be distributed frozen, refrigerated, or can be shipped at ambient temperature.
This may seem fairly obvious for ready-to-eat products, but describe the expected use of the product as best you can. For your intended consumers, be sure to identify if your products are geared toward seniors, infants, people with specific dietary restrictions, etc. Or, if your target consumer is simply the general public, indicate that in your description.
Your team’s next step is to create a flow diagram that offers a clear outline of all the steps in the process that are directly controlled by your company. The flow diagram may also include steps that occur before or after (i.e. sourcing, distribution, etc.) the actual processing that happens on-site. It doesn’t need to be as detailed as engineering drawings. Instead, consider a block-type flow diagram that’s descriptive enough to provide a complete picture of the process in question.
Once you’ve created the flow diagram, your HACCP team needs to verify the accuracy of the diagram by conducting an on-site review of the processes in question. If any modifications to the plan are deemed necessary, make those changes and document your process.
Once the preliminary steps are completed, it’s time for your team to start identifying and analyzing potential hazards and the appropriate control measures. The idea is to create a list of all the potential hazards that are reasonably likely to cause either an injury to facility staff or illness in consumers if not properly controlled. If a potential hazard is not “reasonably likely” to cause an injury or illness, it doesn’t need to be included in your plan.
During your hazard analysis, remember that a safety concern is different from a quality concern. Hazards can be biological, chemical or physical, and it’s important to consider not only the ingredients and raw materials used, but also each step in your processing, storage and distribution methods, as well as any potential hazards to the end consumer during use of the product.
After you’ve identified and documented potential hazards, it’s time to identify critical control points (CCPs). These are the steps in your process that can be controlled to prevent or eliminate the hazards you just identified. Examples of a CCP include cooking, chilling, chemical testing for contaminants, and product formulation control. The CCPs identified in your HACCP plan will depend on your facility’s layout, equipment, processes and the ingredients used. Having a complete account of your CCPs is critical for developing an effective HACCP plan. So, if part of your process is used specifically to ensure product safety, it should be included as a CCP.
Not to be confused with operational limits, the FDA defines critical limits as “a maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce” food safety hazards. Essentially, the limit is the line between safe and unsafe operating conditions for each of the CCPs you identified. Critical limits are often based on things like temperature, pH, water activity, salt concentration, time, preservatives or sensory information like smell or appearance. However, it’s important that your critical limits be scientifically based. Often, critical limits have already been defined by regulatory standards and guidelines.
For a real-life example of a hazard analysis, CCP and critical limit, let’s consider a facility that produces cooked beef patties. The potential hazard would be enteric pathogens like E. coli. The CCP would be the cooking process, and the critical limit would be that the patty must maintain an internal temperature of 155°F for at least 16 seconds.
Now that you’ve outlined the potential hazards to food safety and the methods of control used to mitigate those hazards, it’s time to establish effective monitoring to ensure controls are maintained in perpetuity. Your monitoring procedures should consist of a planned sequence of observations or measurements to test whether a CCP is under control. Ideally, monitoring would be continuous, and this is actually possible in many cases thanks to automatic sensors and smart technology. Whatever your method for monitoring CCPs, the process should be clearly defined and documented.
A crucial part of establishing monitoring procedures is deciding who will ultimately be responsible for carrying out the monitoring assignments. Personnel like line workers, supervisors and maintenance specialists must be trained in monitoring techniques and fully understand the importance of their assignment. They also need to be trained on how to implement corrective actions should a deviation in control occur.
Just knowing where hazards are likely to occur wouldn’t be very useful without having a way to reestablish control should something go wrong. Your team will need to define corrective actions in advance for each CCP identified in your HACCP plan. At minimum, you’ll need to establish what needs to be done in the event of a deviation, who’s responsible for implementing that corrective action, and how that process will be recorded. Individuals on the plant floor will likely be in closest proximity to any hazards and in the best position to take corrective actions. So, it’s critical these personnel fully understand what’s expected of them to ensure an effective HACCP plan.
If you’ve implemented an effective HACCP plan, you won’t need to conduct much end-product testing because you would've already ensured food safety was maintained throughout the production process. Instead, you’ll need to regularly verify that your HACCP plan is living up to its intended purpose. This means evaluating every critical control point identified in your plan and analyzing whether proper controls are being maintained. Verification should occur during the development and implementation of your plan, as well as on a regular basis once the plan has been implemented. Verifications can be conducted by company personnel, third-party experts or regulatory agencies.
Having a sound record-keeping process is critical for a successful HACCP plan implementation. Among the records you’ll need are a summary of your hazard analysis, the flow diagram, descriptions of your processes and products, as well as the HACCP plan itself and a list of who is responsible for monitoring, verifying and implementing corrective actions at each CCP. You should also maintain any records that are created during operation of your HACCP plan. By establishing a solid documentation process, you ensure your HACCP plan is effective and all personnel are on the same page in your efforts to keep products as safe as possible.
Want to enhance food safety at your manufacturing facility? Contact Ibberson today. Our team of experts can create and implement design-build solutions to revolutionize your food and beverage business.