Hazard Analysis Critical Control Point Systems

The scientific community accepts that HACCP systems, when used properly, will substantially enhance food safety. HACCP is defined as a management system in which food safety is addressed through the analysis and control of physical, chemical, and microbiological hazards from raw material production, procurement, and handling to manufacturing and consumption of finished product. The successful implementation of HACCP requires a firm commitment from top management (27). Bryan (28) provides a historical perspective on HACCP. The principles of HACCP were endorsed in the 1980s by the National Research Council (NRC) (29). NRC has issued a number of reports on meat, poultry, and seafood very supportive of the HACCP concept (30-32). A number of reports have been issued by the National Advisory Committee on Microbiological Criteria for Foods (33-38). The HACCP principles have gained recognition by industry and regulatory agencies. USDA has mandated the use of HACCP in meat and poultry (39), and FDA in seafood (40). Guidelines for fresh fruits and vegetables have been issued by FDA (41).

The FDA Food Code (42) incorporates the principles of HACCP. There have been a number of guidelines, manuals, and generic plans in the literature. The National Advisory Committee on Microbiological Criteria for Foods standardized the hazard principles as follows:

1. Conduct a hazard analysis

2. Determine the critical control points

3. Establish critical limits

4. Establish monitoring procedures

5. Establish corrective actions

6. Establish verification procedures

7. Establish record-keeping and documentation procedures

To facilitate the development of a HACCP plan, certain prerequisite requirements are suggested. The importance of education and training of management and employees cannot be overemphasized. An in-depth discussion on the preparation and implementation of HACCP plans is beyond the scope of this article. The HACCP steps, however, are briefly discussed here:

Conduct a Hazard Analysis. A hazard analysis requires identification of the hazards that might reasonably be expected to occur. The hazards must be critical to assure food safety. Examples include physical hazards (metal, glass), chemical hazards (pesticide residues, undeclared allergenic ingredients), and microbiological hazards (pathogens, parasites). Regulatory agencies have defect action levels such as pits and stems. They do not present a health hazard. Physical hazards have been reviewed.

Determine Critical Control Points (CCPs). Critical control points are defined as the steps that are applied to prevent, eliminate, or reduce a hazard to an acceptable level. Examples would be cooking, metal, or allergen controls.

Establish Critical Limits. Establishing critical limits involves determining the maximum and/or minimum values to which a physical, chemical, or microbiological hazard must be controlled at a determined CCP to prevent, eliminate, or reduce to an acceptable level the occurrence of a food safety hazard. Examples include cooking and cooling time and temperature limits, and metal detection limits.

Establish Monitoring Procedures. Monitoring procedures assess whether CCP is under control. They provide a record for future use in verification.

Establish Corrective Actions. Should deviations occur from the critical limits, then corrective action is needed to bring the critical limits into compliance. The steps include determining the cause and, of course, correcting it; disposing of the noncompliant product; and recording the corrective actions that need to be taken to prevent reoccurrence. These actions should be developed and be a part of the HACCP plan.

Establish Verification Procedures. Verification procedures are developed to determine whether the HACCP plan is valid. A well-designed, functional HACCP plan has enough safeguards built in so that end-product testing should be minimal.

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