The two most important reasons to spend time and money on a HACCP plan are 1) It’s just the right thing to make sure food served to the public for consumption is safe, and 2) A foodborne illness will destroy a company’s reputation quickly, and might do it permanently.
When putting together a solid HACCP plan, many companies make some of the same, common mistakes. Addressing these issues in the beginning gives food producers a firm foundation that they can build on. Creating a good HACCP plan from the beginning means a greater chance of overall success and safer food for consumers.
A facility’s flow diagram needs complete accuracy and attention to detail. “What a lot of people miss is what I call conveyance items,” says Mike Nolan, technical director for ASI Food Safety. Any time product moves from one piece of equipment or machine to another, it travels on a conveyance item. This could be a conveyor belt, cart or tub, forklift, transfer tube, etc. Many facilities show the major machinery involved with the production, but leave out the conveyance method, Nolan says. This causes a lack of attention when it comes time to assess risk. “If they have a bucket that transfers dough from a blender to a former, they don’t do the risk assessment on the bucket,” Nolan adds.
Along with making a flow diagram accurate and reflective of the entire process path, Nolan stresses the importance of beginning it at the correct point. “The flow diagram should start at receiving because at receiving you have certain risks,” Nolan says. Whether or not your receiving dock is opened or closed, if it’s refrigerated, if you’re getting raw ingredients that need to be frozen, all of these factors and more create potential risks at receiving. “The flow diagram has to be accurate, and it has to reflect the true process of the flow of the product,” Nolan says. “A lot of times when you look at a flow diagram, it will just say ‘storage’ and won’t show where the product goes.” Facilities need to include the eight known allergens at receiving and show where they go, as well.
Another way for facilities to ensure flow diagrams remain accurate throughout is to identify critical control points (CCP) by number. For example, if a facility receives product that need to remain within a certain temperature range, that would represent a CCP and need numbering on the flow diagram. The most logical method of numbering would be to start at the beginning with number one, and then move throughout the flow diagram numbering in sequential order. “Sometimes people get creative,” Nolan says, “but as long as the flow diagram CCP matches the monitoring documents and matches the risk analysis, it doesn’t really matter.”
The final piece of the flow diagram where facilities run into mistakes are pieces used to remove foreign objects. “The other thing they miss is any magnets, metal detectors, sieves, sifters or anything that may mitigate foreign objects,” Nolan says. “So if you’ve got a sifter that’s going to remove objects, x-ray, etc., anything that is used for removing foreign objects should be on there.”
In a normal risk analysis, facilities need to pay attention to three types of risk. They are biological, chemical and physical. Of the three, statistics show that biological risks represent the vast majority of recalls and harm done at around 90 percent with chemical around 6 percent and physical at roughly 2 percent. The main focus should be on biological and it needs to be identified. What Nolan sees on many risk analyses simply says biological or pathogen, but that’s a mistake. “Whatever biological pathogen you’re controlling, you need to identify that pathogen in the risk assessment,” Nolan says.
The three areas that facilities need to analyze are raw ingredients, process steps and packaging. Nolan finds that the process steps are usually done. However, they need to match the flow diagram exactly. “When I do an audit/look at a HACCP plan, I actually take the flow diagram and match it up with the process steps risk assessment to make sure that they match, and they should identically match,” Nolan says. The flow diagram and process steps present facilities with a built in double checking mechanism.
Nolan finds that raw ingredients and packaging often get neglected in a facility’s risk analysis. “I would say probably 40% of the HACCP plans that I’ve reviewed over the years don’t even have raw ingredients on them. That’s a big miss,” Nolan says. And while packaging does not present a high risk, it’s still very important to look at. The risks associated with packaging usually come in the form composition and the elements that packaging is exposed to in the process. “When it’s heated up, will the plastic off gas. If they don’t look at those things then they really haven’t done a very good job on the HACCP plan,” he adds.