Introduction
On July 25, 1996, the Food Safety and Inspection Service
(FSIS) of the United States Department of Agriculture (USDA) published
a final rule on Pathogen Reduction; Hazard Analysis and Critical
Control Point (HACCP) Systems (PR/HACCP). The PR/HACCP rule requires
meat and poultry plants under Federal inspection to take responsibility
for, among other things, reducing the contamination of meat and poultry
products with disease-causing (pathogenic) bacteria. Reducing contamination
with pathogenic bacteria is a key factor in reducing the number of deaths
and illnesses linked to meat and poultry products. The Preamble to the
final rule describes an overall system in which preventive and corrective
measures are instituted at each stage of the food production process where
food safety hazards could occur.
The HACCP requirements that plants must meet are set out
in 9 CFR Part 417. HACCP is a scientific system for process control that
has long been used in food production to prevent problems by applying
controls at points in a food production process where hazards could be
controlled, reduced or eliminated. A plant must have an effective HACCP
system to comply with regulatory requirements and prevent adulteration
of product.
The HACCP regulatory requirements become
effective on different dates for plants of differing sizes:
Large plants – those with 500 or
more employees – on January 26, 1998;
Smaller plants – those with fewer than 500 but
at least 10 employees on January 25, 1999; and
Very small plants – those with fewer than 10 employees
or annual sales less than $2.5 million – on January 25, 2000.
Note: This Guidebook and
other FSIS technical assistance materials are designed to assist establishments
subject to the regulatory requirements of 9 CFR Part 417 in complying
with those requirements. Part 417 is reproduced in Appendix A.
These regulatory requirements are slightly different from the various
explanations of HACCP developed by the National Advisory Committee on
Microbiological Criteria for Foods (NACMCF), the most recent version of
which was published in 1997.
Developing a HACCP Plan
FSIS is providing this Guidebook for the Preparation
of HACCP Plans to help plants develop and set up their HACCP
systems. There are other FSIS publications which may be helpful. This
Guidebook is the most basic of the FSIS materials. FSIS
has also developed thirteen generic models that plants can use to see
if their specific plans are generally on target or help them get started.
The generic models are more specific than this Guidebook
and each one has at least one fully developed product example which establishment
HACCP teams can study. However, even though the generic models have more
detailed information, they are not designed to be used “as is.”
A company will still need to tailor the plan to suit the specific circumstances
of its own production process.
Policy Notices
In order to clarify issues, which were raised in conjunction
with the first implementation date, FSIS published a series of Policy
Notices in the Federal Register. Copies are included as Appendix
C. The issues addressed include:
Livestock Carcasses and Poultry Carcasses Contaminated
with Visible Fecal Material (November 28, 1997)
Contents of HACCP Plans; Critical Control Points
(January 30, 1998)
Contents of HACCP Plans (January 30, 1998)
Establishment Review of Product Production Records
(March 6, 1998)
HACCP Plan Requirements and Meat and Poultry Product
Processing Categories; Policy Clarification (April 1, 1998)
Listeria Monocytogenes Contamination of Ready-to-Eat
Products (May 26, 1999)
Establishments may wish to refer to these Policy
Notices if they need further clarification about the aspects
of the regulations that are addressed.
In addition to written materials, FSIS has held a number
of events to assist establishments in meeting regulatory requirements
in a timely manner; these include both implementation conferences and
technical assistance workshops.
Finally, FSIS has developed and put in place resources which
are available to answer specific questions; the FSIS Technical Service
Center operates a HACCP Helpline (1-800-233-3935 ext.2) which provides
answers to technical questions from inspection personnel and establishments.
Also FSIS has organized HACCP contacts in each of the states, to which
establishments can turn for help with their specific problems. The District
Office can provide information on the State HACCP Network.
Advice and assistance on developing HACCP systems can be
obtained from many sources other than FSIS (use the Internet web site:
www.nal.usda.gov/fnic/foodborne/haccp/index.shtml).
FSIS encourages establishment officials to consult and use a variety of
resources as they go about planning, documenting, and validating their
HACCP systems. Also included in this Guidebook is a list
of references that can be used by all HACCP teams that have been included
as Appendix B. However, when HACCP regulations become
effective in an establishment, it is the requirements of Part 417 that
must be met. Establishment employees with a thorough understanding of
HACCP concepts should still review the regulatory requirements of this
part to make sure they achieve compliance. This Guidebook
has been revised to make it easier for users to relate its practical advice
with the need to be in compliance with regulatory requirements.
Preliminary Steps
FSIS and most HACCP experts believe that a company will
do a better job of HACCP plan development if it takes some preliminary
steps before it attempts to apply the seven principles and write
a plan. FSIS believes that a company should take the following steps to
get started:
1. Assemble the HACCP team, including one person (consultant,
employee, or other resource) who is HACCP-trained.
2. Describe the food and its method of production and distribution;
identify the intended use and consumers of the products.
3. Develop and verify process flow diagram(s).
4. Decide whether products can be grouped using the process
categories in 417.2(b)(1).
The first part of this Guidebook discusses
how companies, especially small or very small companies, can go about
taking these preliminary steps. Numbers 2-4 are parts of the regulatory
requirements in §417.2(a).
1. Assemble the HACCP team, including one person
who is HACCP-trained.
Assembling a HACCP team may seem like a daunting task, especially
for the owner of a very small or family-centered company. However, FSIS
strongly encourages companies to have more than one person working on
the development of HACCP system(s). This is because HACCP system development
is one of those tasks that are probably better done by more than one person,
even in a very small company. HACCP is an overall process control system
and we believe it takes a variety of different kinds of knowledge and
experience to develop a good system. If your company has only a few people
in it, they may all need to be on the HACCP team, because they all probably
have multiple roles and responsibilities in the company’s operations.
You should consider including on your HACCP team, some resources
which may be outside your company. You may be able to get help from a
trade association or from a local college, university or extension office
which has people in it who know about HACCP process control systems. It
is possible that companies which supply or receive your products and have
already implemented HACCP may be interested in and willing to provide
assistance. FSIS has offered technical assistance workshops to groups
of plants that came together to a central location and worked through
the process of system development in small steps.
One resource you must include is an individual
who has been trained in HACCP in accordance with the requirements of Sec.
417.7. These requirements are that the individual has successfully completed
a course in applying the seven principles of HACCP to meat or poultry
product processing; the course needs to have included a segment on HACCP
plan development for a specific product and a segment on record review.
This HACCP-trained individual does not need to be a company
employee, but does need to be available to you for plan development and
for certain other functions, like reassessing your HACCP plan(s).
2. Describe the food and its method of production
and distribution; identify the intended use and consumers of the products.
The next preliminary step to take is to have the HACCP team
describe the product(s) and their methods of production and distribution.
If your team includes the people who know how things work in your operations,
they should be able to do this quite easily. The important thing for them
to keep in mind is that they need to include every step in the process.
In order to help you make sure you include all the key information, we
have prepared a form which could be used to accomplish this task. Attachment
1 is this form and like all the forms in this Guidebook,
its use is optional.
Whether you use the form or not, the following questions
should be answered when you describe the product:
1. What is the common name of the product?
2. How is the product to be used?
3. What type of packaging encloses the product?
4. What is the length of shelf life of the product, at what temperature?
5. Where will the product be sold? *Who is the intended consumer and what
is the intended use?
6. What labeling instructions are needed?
7. Is special distribution control needed?
* Regulatory requirement
After your team has described the products in words, they
can move on to the next preliminary step.
3. Develop and verify process flow diagram(s).
A flow diagram is a simple schematic picture of the process
you use in your plant to produce the product. You do not need any fancy
equipment, such as a computer, to produce a flow diagram. However, it
does need to be an accurate, clear sketch of the process used in your
plant to make the product. Attachment 2 is an example
of a simple flow diagram for a relatively simple process; Attachment
3 is a more complex flow diagram for a more complicated process.
Either one would be an adequate flow diagram if it accurately pictured
what was actually happening in the plant.
The best means to make sure your flow diagram is accurate
is to have the HACCP team verify it by walking through the plant and making
sure all the steps in the process you carry out are included in the flow
diagram. Verifying the flow diagram is a step your team should be sure
to do carefully. It is also a common means by which auditors or inspectors
verify that a particular flow diagram is correct and complete.
When you are certain that you have an accurate flow diagram
and your team has verified it, it is time to move to the final preliminary
step.
4. Decide whether products can be grouped using
the process categories in 417.2(b)(1).
This part of the regulations lists nine process categories
into which meat and poultry production can be grouped; they and some examples
are:
(i) Slaughter--all species: beef, swine, and poultry
(ii) Raw product—ground: ground beef, ground pork,
ground turkey
(iii) Raw product--not ground: boneless cuts, steaks
(iv) Thermally processed--commercially sterile: canned
beef stew, Pasta with meat
(v) Not heat treated--shelf stable: summer sausage,
dry salami
(vi) Heat treated--shelf stable: meat and poultry jerky,
snack sticks
(vii) Fully cooked--not shelf stable: hot dogs, wieners,
roast beef, ham
(viii) Heat treated but not fully cooked--not shelf
stable: partially cooked patties, bacon
(ix) Product with secondary inhibitors--not shelf stable:
corned beef, cured beef tongue
One way to cut down on the paperwork that is a part of HACCP
system is to control all products in the same process category using a
single HACCP plan. This is especially advantageous for very small establishments
which may produce many different products. If those products differ only
in characteristics that would not affect safety, e.g. the amount or kind
of seasoning used (hot vs. mild), they are clearly in the same process
category and may be covered by the same HACCP plan.
FSIS has developed eleven generic HACCP models for the processes
listed above and two more specific processes, Mechanically Separated (Species)/
Mechanically Deboned Poultry and Irradiation (including all forms of approved
irradiation procedures).
Now you have completed the preliminary steps that will prepare
you for HACCP system development. It is time for your team to apply the
seven principles of HACCP and develop your HACCP plan. The next seven
sections (principles) of this Guidebook will take you
through this process.
PRINCIPLE I: CONDUCT A HAZARD ANALYSIS
The first principle of HACCP is to conduct a hazard analysis.
Part 417 contains definitions as well as specific provisions which affect
how your HACCP team must go about conducting its hazard analysis. Before
beginning the process, your team should review the definitions of food
safety hazard and preventive measure, and look
specifically at the requirements of 417.2(a).
A. Conducting a hazard analysis is generally considered
to be a two-step process. The first step is to identify the threats to
human health which might be introduced into meat and poultry products
as those products are produced. These hazards are usually
grouped into three categories: Biological (including microbiological),Chemical,
and Physical.
1 Biological Hazards
Biological hazards are living organisms that can make food
unsafe to eat. Biological hazards may be bacterial, parasitical, or viral.
Biological hazards are frequently associated with the raw materials from
which meat and poultry products are made, including the animals and birds
which are primary components. However, biological hazards may be introduced
during the processing of meat and poultry products: from the people who
are involved in the processing; from the environment in which the foods
are processed; from other ingredients in the products; or from the processes
themselves.
Identifying the biological hazards to which your production
processes might be subjected is clearly a difficult and important task—one
that requires all the expertise that your HACCP team can bring to it.
Currently, there is a great deal of emphasis on microbial hazards associated
with meat and poultry products. Some of the major pathogens that may be
associated with meat and poultry products are: Salmonella, Campylobacter
jejuni, Escherichia coli 0157:H7, Listeria monocytogenes, Clostridium
botulinum, Staphylococcus aureus, and Yersinia enterocolitica. For details,
refer to NACMCF document reference 14 listed in Appendix B.
2. Chemical Hazards
Chemical hazards may be the result of something naturally
occurring in foods or added during the processing of foods. Harmful chemicals
have been associated with both acute cases of foodborne illness and chronic
illness.
Naturally occurring chemical hazards are those that are
natural constituents of foods and not the result of environmental, industrial,
or other contamination. They include aflatoxins, mycotoxins and shellfish
toxins.
Added chemical hazards are those which are intentionally
or sometimes unintentionally added to food during the growing, harvesting,
storage, processing, packaging, or distribution phases of production.
This group of chemical hazards is very broad and might include components
of animal feed or drinking water, animal drugs, pesticides, food ingredients
themselves, or chemicals used in the processing establishment such as
lubricants, cleaners, paints, and coatings.
3. Physical Hazards
A physical hazard is a physical component of a food that
is unexpected and may cause illness or injury to the person consuming
the food. Foreign materials such as glass, metal, or plastic are familiar
physical hazards in meat and poultry products, usually found because a
process or a piece of equipment has not been properly controlled while
the food was being produced.
There are a number of situations that can contribute to
physical hazards in foods; they include:
--Contaminated raw materials;
--Poorly designed or poorly maintained facilities and equipment;
--Contaminated packaging materials; and,
--Inattention to details by employees with key responsibilities.
B. This first step in identifying hazards which might be
associated with your production process might be considered like a “brainstorming”
session. Your HACCP team should use the flow diagram and product description,
which you created in your preliminary steps, and systematically think
about what could occur at each step in the process. Attachment
4 is a checklist of questions which might help your team to be
as thorough as possible in considering the hazards which might be associated
with your process.
C. The second step in performing a hazard analysis is to
identify preventive measures that could be used to control each hazard.
Preventive measures are the physical, chemical, or other means that can
be used to control a food safety hazard. Attachment 5
is a form which you can use to go through your process systematically,
identify the hazards which might occur at each step in the process and
the preventive measures which might be used to prevent, eliminate, or
reduce each hazard to an acceptable level which you can use in conjunction
with the checklist. More than one preventive measure may be needed to
control a food safety hazard and more than one food safety hazard may
be controlled by a specific preventive measure.
D. Attachment 6 is a hazard analysis which
has been completed for a simple raw, ground process. When developing your
hazard analysis, be sure to remember that supporting documentation for
the decisions reached by the team is very important and a regulatory requirement
[§ 417.5(a)(1)]. The supporting documentation can consist of the
regulatory citation if the critical limit is based on a regulation, a
scientific paper, study, or in-plant study. Historical information about
the process can also be used. This information should be summarized as
part of the supporting documentation for the team’s decisions. When
making determinations about whether a hazard is reasonably likely to occur,
it is helpful to list the actual hazard or organism of concern. For example,
metal contamination from equipment, Salmonella, Escherichia coli O157:H7,
Campylobacter jejuni, Listeria monocytogenes or other specific pathogenic
hazards, or a specific residue that is known to occur in a like product.
You will find this information very helpful when yearly reassessment,
a deviation, or an unforeseen hazard occurs.
We cannot overemphasize how important it is to do a good
job on your hazard analysis. This is often a difficult and time-consuming
step, and one that requires all the various technical and scientific resources
you can obtain. You can refer to the NACMCF DRAFT document - “FSIS
Microbiological Hazard Identification Guide for Meat and Poultry Components
of Products Produced by Very Small Plants”, August 1999 (Appendix
B, Reference 14)” We know that doing a good job and taking your
time here is worth the effort. You cannot expect to develop a good HACCP
system if you have not been careful and thorough in your hazard analysis.
PRINCIPLE II: IDENTIFY THE CRITICAL CONTROL POINTS
The second HACCP principle is to identify the critical control
points (CCPs) in the process. A CCP is a point, step, or procedure in
a food process at which control can be applied and, as a result, a food
safety hazard can be prevented, eliminated, or reduced to acceptable levels.
So far, in developing the HACCP plan, your HACCP team has
identified biological, chemical, and physical hazards in the raw materials
and the ingredients you use as well as in the steps of your process. For
each food safety hazard reasonably likely to occur, you have identified
a preventive measure. Your next step is to find the point or points in
the process where these preventive measures should be applied.
Fortunately, a great deal of work has already been done
in identifying points where control can be applied in a process . Many
points are commonly recognized in various food processing and production
systems. Some common points where control can be applied in your process
include:
--Chilling to temperatures that minimize microbial growth;
--Cooking to specific temperatures for exact times in order to destroy
microbial pathogens;
--Product formulations, such as the addition of cultures or adjustment
of pH or water activity;
--Processing procedures such as filling and sealing cans; and,
--Slaughter procedures such as evisceration or antimicrobial interventions.
These are just a few examples of measures that may be CCPs.
There are many more possibilities. Different facilities preparing the
same food can differ in the number and types of CCPs they choose to use.
This is to be expected.
The FSIS generic models, as well as other generic models,
give you some ideas about what CCPs might work in the various process
categories which are discussed. Your team needs to remember that these
are just ideas designed to help get your team thinking creatively and
carefully about your own processes and how you want to control them with
your HACCP system.
Note: Identifying CCPs is one area in which
there are differences between the regulatory requirements of Part 417
and the NACMCF guidance materials (reference 13). The latter include the
use of a Decision Tree; the Decision Tree approach is not necessary for
you to meet regulatory requirements; however, the thought process may
be helpful. You must make sure that your HACCP system meets regulatory
requirements.
PRINCIPLE III: ESTABLISH CRITICAL LIMITS FOR EACH
CRITICAL CONTROL POINT
HACCP principle three instructs your team to establish critical
limits for each preventive measure you will carry out at each CCP. This
step involves establishing a criterion that must be met for each preventive
measure associated with a CCP. Part 417 defines a critical limit as: the
maximum or minimum value to which a physical, biological, or chemical
hazard must be controlled at a critical control point to prevent, eliminate,
or reduce to an acceptable level the occurrence of the identified food
safety hazard.
Critical limits are the boundaries of safety for preventive
measures put in place at CCPs. A critical limit will usually be a reading
or observation such as a temperature, a time, a product property such
as water activity, or a chemical property such as available chlorine,
salt concentration, or pH. Critical limits need to be exact and specific;
HACCP plans should not include ranges as critical limits.
Many critical limits for identified CCPs have been established,
either through regulatory requirements or through the technical and scientific
literature, which are the bases of production processes. Your HACCP team
will probably be familiar with many of these established critical limits
such as: the minimum internal temperature to which products must be cooked;
the time which may elapse while product is being cooled to a specific
temperature; the maximum dimensions of any metal fragments which could
be found in products. These critical limits must be met
if product safety is to be maintained.
When deciding what your critical limits should be, there
are several sources to consider. First and foremost are the regulatory
requirements which apply to your processes. These must be met.
For example, if you produce cooked beef products, you must have critical
limits that meet the current FSIS regulatory requirements for those products.
There may be other sources of critical limits, such as the times and temperatures
that you use in making the products you produce. These may be based on
scientific and technical information from studies or food processing textbooks
or they may be based on family recipes that have been passed down from
one generation to the next and have scientifically been shown to produce
safe product. Critical limits may be drawn from specific challenge studies
or from recognized experts. In any case, you need to establish a critical
limit for each preventive measure you intend to apply at your CCPs.
There are two types of critical limits. A critical limit
can be an upper limit where a set amount or level cannot be exceeded.
A critical limit can also be a lower limit where a minimum amount
is required to produce the safe effect. To address the hazard in ground
product of metal fragments from the grinding equipment, the upper
critical limit for the preventive measure could be no sharp metal fragments
more than 1/32 inch. A grinding room temperature of 50° F to help
control pathogen growth is another kind of upper critical limit.
An example of a lower critical limit would be the addition of
an acidifier to inhibit bacterial growth.
PRINCIPLE IV: ESTABLISH MONITORING PROCEDURES
To carry out HACCP principle four, your team needs to establish
monitoring procedures. Monitoring procedures are those things which are
done routinely, either by employee or by mechanical means, which measure
the process at a given CCP, and create a record for future use. Some monitoring
procedures are employee observations or checks, such as checking the documentation
accompanying incoming materials. Some monitoring procedures are records
from instruments, such as recording thermometers.
Continuous monitoring is always preferred when it is feasible.
When it is not possible, then your HACCP team will need to decide what
will be their non-continuous monitoring procedures and how frequently
they will be performed. There are several issues to consider when deciding
the frequency of non-continuous monitoring checks; the most important
is that the procedures must be performed sufficiently often to accurately
reflect that the process is under control. Expert advice from people with
knowledge of practical statistics and statistical process control will
be important in making your decisions about frequency.
Another factor that HACCP teams must consider is the capacity
of the plant to take corrective actions when monitoring procedures reveal
that there have been deviations from critical limits. When monitoring
procedures show that there has been a deviation from a critical limit,
corrective actions need to be applied to all the potentially noncomplying
product. This usually includes all the product produced since the time
of the last successful monitoring procedure result. So, if your monitoring
procedure was to perform a physical check on arriving product, and your
team decided to do this only once per shift, a deviation from the critical
limit would mean that you needed to apply corrective actions to all the
product which had arrived during the shift.
Another matter for your HACCP team to consider when they
are deciding on what should be the monitoring procedures and how frequently
they should be performed is the need for rapid, real time feedback. Generally,
physical and chemical procedures are preferred over microbial approaches
for monitoring because they provide more rapid feedback.
Monitoring procedures need to be well planned and effective
because of the potentially serious consequences of loss of control. Employees
monitoring CCPs should be trained in the technique to be used to monitor
each preventive measure or control. They should fully understand the purpose
and importance of monitoring and accurately report monitoring activities
and results. They must have complete access to the CCP being monitored
and to the process-monitoring instruments being used.
The persons performing monitoring must record exact values
where exact values are indicated, not “yes/no” or “OK”
observations. This means that if the critical limit is a minimum internal
temperature of 160° F, the observations on the monitoring record would
be recorded as “162 ?F,” “163?F” rather than “yes”
or “OK.”
Attachment 7 is a simple form which your
team might use to help them decide on monitoring procedures and their
frequency.
PRINCIPLE V: ESTABLISH CORRECTIVE ACTIONS
HACCP principle five says: Establish corrective actions
to be taken when monitoring shows that there is a deviation from a critical
limit. In addition, § 417.3 identifies the four features of corrective
actions that FSIS regulators will be checking; they are:
1. Has the cause of the deviation been identified and eliminated?;
2. Will the CCP be under control after the corrective action has been
taken?;
3. Have measures to prevent recurrence of the deviation been established?;
and,
4. Do the corrective action procedures make sure that no product, which
is injurious to
health or otherwise adulterated because of the deviation enters commerce?
HACCP is a preventive system to correct problems before
they affect the safety of the food products people actually consume. Deviations
from critical limits will occur; therefore, you need to have a plan to
make sure those deviations do not lead to unsafe products. Planned corrective
actions are the way you do this. Your HACCP team needs to understand how
important it is to carefully carry out this principle.
For each CCP, your team needs to devise a standardized set
of actions that company employees will follow when there is a deviation
from a critical limit. These are some questions they might ask in developing
corrective actions:
How will people be informed when the deviation occurs?
If a person is performing the monitoring procedure, who will that person
contact?
Who will be responsible for controlling the product that
may have been affected by the deviation? How should that person decide
how much product needs to be controlled?
Who will be involved in deciding what to do about the
product which might have been affected by the deviation?
How will we decide what was the cause of the deviation?
If we need technical experts outside the company, how do we get them?
Once we have figured out what was the cause of the deviation,
who will be involved in deciding how to get the process back in control
and prevent recurrence of the deviation?
If our HACCP trained individual is not available in the
plant immediately, how can we get HACCP expertise to help decide if
our plan needs to be modified?
Who in the company needs to sign off on any modifications
to our plan?
Who will be responsible for keeping the records of everything
we do in response to a deviation from a critical limit at this CCP?
If any person who has a responsibility in our corrective
action plan is not available, who will be the back-up?
Is this set of corrective actions feasible at all times?
Attachment 8 is a simple form to help your
HACCP team make sure they have developed appropriate corrective actions
for each CCP. Part 417 includes regulatory requirements which must be
followed when a deviation not covered by a specific corrective action
occurs or if an unforeseen hazard occurs. Your team should study §
417.3(b) so that you know what to do when this happens. In many ways,
the actions to be taken will be generally similar to what you plan to
do at any specific CCP—get control of the product, figure out what
was the cause and how to keep it from happening again, decide whether
to modify your HACCP plan, etc. Your team should at least think about
how you want to handle these situations.
PRINCIPLE VI: ESTABLISH RECORDKEEPING PROCEDURES
HACCP principle number 6 is to establish effective recordkeeping
procedures that document the HACCP system. The regulatory recordkeeping
requirements for meat and poultry establishments are found in § 417.5
and are quite comprehensive. Your team should review them carefully.
Even though people often complain about it, recordkeeping
is an essential feature of a HACCP system and must be planned and carried
out as carefully as any other element. This principle requires the development
and maintenance of records about both plan development and the operation
of the system. In a study on HACCP prepared by the Department of Commerce
it was clear that, without recordkeeping, problems were more likely to
recur.
Even though people may grumble about keeping records, the
practice can be made sensible and suitable for the operation in question.
Clearly more sophisticated records will be required for more complex operations.
One way to approach development of the recordkeeping requirements of your
HACCP system is to review the records you already keep and see if they
are suitable, in their present form or with minor modifications, to serve
the purposes of your HACCP system. The best recordkeeping system is usually
the simplest one that can be easily integrated into the existing operation.
When you are setting up your recordkeeping system, think
about who will be in the best position to make the record entry, who will
need to review the record prior to shipping, plus, when and where will
be the best place to keep the records. Think about making simple understandable
forms that will work well in your situation. Make sure your employees
know exactly what is expected if they are responsible for making a record
entry. It is extremely important that they sign and date the records at
the time the specific event occurs.
Records do not need to be in any particular format. Often
HACCP plans are presented in a tabular form. Attachment 9
is an example of a blank HACCP Plan form in a typical format. Attachment
10 is a list of some typical records of a HACCP system in operation.
The PR/HACCP regulation also includes a requirement for preshipment review
in § 417.5(c). This step can provide you added assurance that you
have done everything in your HACCP plan before you ship the product. There
are examples in each of the generic models on how this can be accomplished.
PRINCIPLE VII: ESTABLISH VERIFICATION PROCEDURES
HACCP principle seven is to establish verification procedures
to make sure the plan is working correctly.
Your team needs to decide on what procedures the plant will
perform to verify that the HACCP system is working effectively and
how often these actions will be performed. Verification uses methods,
procedures, or tests in addition to those used in monitoring to see whether
the HACCP system is in compliance with the HACCP plan or whether the HACCP
plan needs modification. There are three types of verification.
Validation is the initial phase in which
the plan is tested and reviewed. The choices made while working through
the preliminary steps and HACCP principles must be repeatedly tested and
shown to prevent or control identified hazards in the “real world”.
In this phase, microbial or residue testing can be used effectively to
verify that the process is in control and is producing acceptable product.
Such testing provides clear evidence that the techniques and methods adopted
by the plant to control hazards are not just effective in theory but will
work in this specific plant.
Ongoing verification ensures that the HACCP
plan is working effectively on a day-to-day basis. This type of verification
includes such tasks as calibrating monitoring instruments, observing monitoring
activities and corrective actions, and reviewing HACCP records to see
that they are being made and kept according to the plan.
Reassessment is an overall review of the
plan that must be performed at least annually, or whenever any changes
occur that could affect the hazard analysis or alter the HACCP plan. Reassessment
is similar to validation in that it considers whether the plan is adequate
in general rather than focusing on the plan's daily operations. It is
also similar to validation in that it must be done by a HACCP-trained
person.
ATTACHMENTS
Attachment 1 - PRODUCT DESCRIPTION
| PROCESS CATEGORY: SLAUGHTER
PRODUCT: BEEF |
| 1. COMMON NAME? |
BEEF; BEEF VARIETY MEATS |
| 2. HOW IS IT TO BE USED? |
CARCASSES; VARIETY MEATS |
| 3. TYPE OF PACKAGE? |
CARCASSES – NONE; VARIETY MEATS – 50
POUND BOXES |
| 4. LENGTH OF SHELF LIFE, AT WHAT TEMPERATURE? |
7 DAYS AT 40° F |
| 5. WHERE WILL IT BE SOLD?
CONSUMERS?
INTENDED USE? |
WHOLESALE TO DISTRIBUTORS ONLY |
| 6. LABELING INSTRUCTIONS? |
KEEP REFRIGERATED |
| 7. IS SPECIAL DISTRIBUTION CONTROL NEEDED? |
KEEP REFRIGERATED |
Attachment 2 - PROCESS FLOW DIAGRAM

Attachment 3 - PROCESS FLOW DIAGRAM

Attachment 4 - Checklist of Questions (Hazard Analysis
Process)
This point in hazard analysis consists of asking a series
of questions that are appropriate to each step in the flow diagram. The
hazard analysis should question the effect of a variety of factors on
the safety of the food.
1. Ingredients
Does the food contain any sensitive ingredients that are likely
to present microbiological hazards (e.g. Salmonella. Staphylococcus aureus),
chemical hazards (e.g., aflatoxin, antibiotic, or pesticide residues)
or physical hazards (stones, glass, bone, metal)?
2. Intrinsic factors of food
Physical characteristics and composition (e.g., pH, type of acids, fermentable
carbohydrates, water activity, preservatives) of the food during and after
preparation which can cause or prevent a hazard.
Which intrinsic factors of the food must be controlled in
order to ensure food safety?
Does the food permit survival or multiplication of pathogens
and/or toxin formation before or during preparation?
Will the food permit survival or multiplication of pathogens
and/or toxin formation during subsequent steps of preparation, storage,
or consumer possession?
Are there other similar products in the market place? What
has been the safety record for these products?
3. Procedures used for preparation/processing
Does the preparation procedure or process include a controllable step
that destroys pathogens or their toxins? Consider both vegetative cells
and spores.
Is the product subject to recontamination between the preparation
step (e.g., cooking) and packaging?
4. Microbial content of the food
Is the food commercially sterile (i.e., low acid canned food)?
Is it likely that the food will contain viable sporeforming
or nonsporeforming pathogens?
What is the normal microbial content of the food stored
under proper conditions?
Does the microbial population change during the time the
food is stored before consumption?
Does that change in microbial population alter the safety
of the food?
5. Facility design
Does the layout of the facility provide an adequate separation of raw
materials from ready-to-eat foods?
Is positive air pressure maintained in product packaging
areas? Is this essential for product safety?
Is the traffic pattern for people and moving equipment a
potential source of contamination?
6. Equipment design
Will the equipment provide the time/temperature control that is necessary
to meet critical limits?
Is the equipment properly sized for the volume of food that
will be prepared?
Can the equipment be controlled so that the variation in
performance will be within the tolerances required to produce a safe food?
Is the equipment reliable or is it prone to frequent breakdowns?
Is the equipment designed so that it can be cleaned and
sanitized?
Is product contamination with hazardous substances, e.g.,
glass, likely to occur?
What product safety devices such as time/temperature integrators
are used to enhance consumer safety?
7. Packaging
Does the method of packaging affect the multiplication of microbial pathogens
and/or the formation of toxins?
Is the packaging material resistant to damage, thereby preventing
the entrance of microbial contamination?
Is the package clearly labeled “Keep Refrigerated”
if this is required for safety?
Does the package include instructions for the safe handling
and preparation of the food by the consumer?
Are tamper-evident packaging features used?
Is each package legibly and accurately coded to indicate
production lot?
Does each package contain the proper label?
8. Sanitation
Can the sanitation practices that are employed impact upon the safety
of the food that is being prepared?
Can the facility be cleaned and sanitized to permit the
safe handling of foods?
Is it possible to provide sanitary conditions consistently
and adequately to ensure safe foods?
9. Employee health, hygiene, and education
Can employee health or personal hygiene practices impact the safety of
the food being prepared?
Do the employees understand the food preparation process
and the factors they must control to ensure safe foods?
Will the employees inform management of a problem which
could impact food safety?
10. Conditions of storage between packaging and
the consumer
What is the likelihood that the food will be improperly stored
at the wrong temperature?
Would storage at improper temperature lead to a microbiologically
unsafe food?
11. Intended use
Will the food be heated by the consumer?
Will there likely be leftovers?
12. Intended consumer
Is the food intended for the general public, i.e., a population that does
not have an increased risk of becoming ill?
Is the food intended for consumption by a population with
increased susceptibility to illness (e.g., infants, the elderly, the infirm,
and immunocompromised individuals)?
Attachment 5 - HAZARD IDENTIFICATION/PREVENTIVE
MEASURES
| HAZARD IDENTIFICATION/PREVENTIVE
MEASURES |
| PROCESS CATEGORY: |
| PRODUCT: |
| PROCESS STEP |
FOOD SAFETY HAZARD |
PREVENTIVE MEASURE(S) |
| |
|
|
APPROVED BY:_________________________________________ Date:____________
Attachment 6 - HAZARD ANALYSIS – RAW PRODUCT,
GROUND – Fresh Pork Sausage
| Process
Step |
Food
Safety Hazard |
Reasonably
Likely to Occur? |
Basis |
If
Yes in Column 3, What Measures Could be Applied to Prevent, Eliminate,
or Reduce the Hazard to an Acceptable Level? |
Critical
Control Point |
| Receiving - Meat |
Biological: Pathogens
-microbial (Salmonella, Escherichia coli 0157:H7) |
Yes |
Either pathogen may be present
on incoming raw product. |
Letters of guaranty that supplier
meets base line criteria or in process control of room temperature
or storage temperature to prevent growth |
1B |
| Chemical –
None |
|
|
|
|
| Physical –
Foreign materials |
No |
Plant records
show that there has been no incidence of foreign materials in products
received into the plant. |
|
|
| Receiving – Nonmeat
Ingredients/Packaging Materials |
Biological –
None |
|
|
|
|
| Chemical – Not acceptable
for intended use |
No |
Letters of guaranty are received
from all suppliers of nonmeat ingredients and packaging materials. |
|
|
| Physical – Foreign
materials |
No |
Plant records demonstrate that
foreign material contamination has not occurred during the past
several years. |
|
|
| Storage (Cold) - Meat |
Biological –
Pathogens (List those specific to the product) |
Yes |
Pathogens are reasonably likely
to grow in this product if temperature is not maintained at or below
a level sufficient to preclude the growth. |
Maintain product temperature at
or below a level sufficient to preclude pathogen growth. |
2B |
| Chemical – None |
|
|
|
|
| Physical – None |
|
|
|
|
| Storage – Nonmeat
Ingredients/Packaging Materials |
Biological –
None |
|
|
|
|
| Chemical – None |
|
|
|
|
| Physical – None |
|
|
|
|
| Assemble/Pre-weigh Nonmeat
Ingredients |
Biological –
None |
|
|
|
|
| Chemical – None |
|
|
|
|
| Physical – None |
|
|
|
|
| Assemble/Weigh Meat |
Biological –
None |
|
|
|
|
| Chemical – None |
|
|
|
|
| Physical – None |
|
|
|
|
| Grind/Blend |
Biological - None |
|
|
|
|
| Chemical – None |
|
|
|
|
| Physical – Metal
contamination |
Yes |
Plant records show that during
the grinding process metal contamination is likely to occur. |
In-line magnets are installed on
the stuffing lines. |
3P |
| Sausage Stuffer |
Biological –
None |
|
|
|
|
| Chemical – None |
|
|
|
|
| Physical – None |
|
|
|
|
| Rework |
Biological –
Pathogens |
Yes |
Rework can be a source of continuing
inoculation with pathogens. |
Rework is condemned or used in
a cooked product at the plant. If it will not be used that day or
is coded and not mixed so that the identity and total time in plant
or process can be determined. |
4B |
| Chemical- None |
|
|
|
|
| Physical – None |
|
|
|
|
| Packaging/Labeling |
Biological: Pathogens
– parasitic (Trichina) |
Yes |
Trichina has historically occurred
in raw pork products. |
Labels that clearly indicate this
is a raw product, along with cooking instructions, and the safe
food handling statement. |
5B |
| Chemical – None |
|
|
|
|
| Physical – Metal
contamination |
Yes |
Metal contamination that may have
come into the establishment or is contaminated during the grinding
process must be removed. |
Functional metal detector is on-line
in the packaging/labeling area to remove metal contamination. |
6P |
| Finished Product Storage
(Cold) |
Biological –
Pathogens |
Yes |
Pathogens are reasonably likely
to grow in this product if temperature is not maintained at or below
a level sufficient to preclude their growth. |
Maintain product temperature at
or below a level sufficient to preclude pathogen growth. |
7B |
| Chemical – None |
|
|
|
|
| Physical - None |
|
|
|
|
| Shipping |
Biological –
None |
|
|
|
|
| Chemical- None |
|
|
|
|
| Physical – None |
|
|
|
|
Attachment 7 - HACCP PLAN DEVELOPMENT FORM: MONITORING
PROCEDURES AND FREQUENCY
| HACCP PLAN DEVELOPMENT FORM:
MONITORING PROCEDURES AND FREQUENCY |
| PROCESS CATEGORY: |
| PRODUCT: |
| PROCESS STEP/CCP |
CRITICAL LIMITS |
MONITORING PROCEDURES *(WHO/WHAT/WHEN/HOW) |
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
* 417.5(b), 417.2(6), 417.2(4)- Who refers to the requirement
that records must be initialed; When – to the time the specific
event occurs; What – the measurement to determine compliance at
the CCP; and How - the method used to monitor the CCP.
Attachment 8 - HACCP PLAN DEVELOPMENT FORM: CORRECTIVE
ACTIONS
| HACCP PLAN DEVELOPMENT FORM:
CORRECTIVE ACTIONS |
| PROCESS CATEGORY: |
| PRODUCT: |
| PROCESS STEP/CCP |
CRITICAL LIMITS |
MONITORING PROCEDURES (WHO/WHAT/WHEN/HOW) |
*CORRECTIVE ACTIONS |
| |
|
|
|
| |
|
|
|
| |
|
|
|
| |
|
|
|
| |
|
|
|
| |
|
|
|
| |
|
|
|
| |
|
|
|
*Be sure to include your planned actions to address all
parts of § 417.3.
Attachment 9 - HACCP PLAN
| HACCP PLAN |
| PROCESS CATEGORY: ________________________________ |
| PRODUCT EXAMPLE: _____________________________________________ |
| CCP# and Location |
Critical Limits |
Monitoring Procedures and Frequency |
HACCP Records |
Verification Procedures and Frequency |
Corrective Actions |
| |
|
|
|
|
|
Signature: __________________________________
Date: ______________________________________
Attachment 10 - List of Some Typical Records of
a HACCP System in Operation
1. Ingredients
-
Records from all monitored CCPs
-
Supplier certification documenting compliance with establishment’s
specifications.
-
Establishment’s audit records verifying supplier
compliance.
-
Storage temperature record for temperature-sensitive
ingredients.
-
Storage time records of limited shelf-life ingredients.
2. Preparation
3. Packaging
4. Finished product
-
Sufficient data and records to establish the efficacy
of barriers in maintaining product safety.
-
Sufficient data and records to establish the safe shelf-life
of the product if age of product can affect safety.
-
Documentation of the adequacy of the HACCP procedures
from an authority knowledgeable of the hazards involved and necessary
controls.
5. Storage and distribution
6. Deviation and corrective action
-
Records of all actions taken following deviations at
a CCP.
-
Reassessment records and modifications to the HACCP
plan indicating approved revisions and changes in ingredients, formulations,
preparation, packaging, and distribution control, as needed.
7. Employee training
APPENDIX A
PART 417--HAZARD ANALYSIS AND CRITICAL CONTROL POINT
(HACCP) SYSTEMS
§ 417.1 Definitions.
For purposes of this part, the following definitions shall
apply:
Corrective action. Procedures to be followed when
a deviation occurs.
Critical control point. A point, step, or procedure
in a food process at which control can be applied and, as a result, a
food safety hazard can be prevented, eliminated, or reduced to acceptable
levels.
Critical limit. The maximum or minimum value to which
a physical, biological, or chemical hazard must be controlled at a critical
control point to prevent, eliminate, or reduce to an acceptable level
the occurrence of the identified food safety hazard.
Food safety hazard. Any biological, chemical, or
physical property that may cause a food to be unsafe for human consumption.
HACCP System. The HACCP plan in operation, including
the HACCP plan itself.
Hazard. SEE Food Safety Hazard.
Preventive measure. Physical, chemical, or other
means that can be used to control an identified food safety hazard.
Process-monitoring instrument. An instrument or device
used to indicate conditions during processing at a critical control point.
Responsible establishment official. The individual
with overall authority on-site or a higher level official of the establishment.
§ 417.2 Hazard Analysis and HACCP Plan.
(a) Hazard analysis. (1) Every official establishment
shall conduct, or have conducted for it, a hazard analysis to determine
the food safety hazards reasonably likely to occur in the production process
and identify the preventive measures the establishment can apply to control
those hazards. The hazard analysis shall include food safety hazards that
can occur before, during, and after entry into the establishment. A food
safety hazard that is reasonably likely to occur is one for which a prudent
establishment would establish controls because it historically has occurred,
or because there is a reasonable possibility that it will occur in the
particular type of product being processed, in the absence of those controls.
(2) A flow chart describing the steps of each process and
product flow in the establishment shall be prepared, and the intended
use or consumers of the finished product shall be identified.
(3) Food safety hazards might be expected to arise from
the following:
(i) Natural toxins;
(ii) Microbiological contamination;
(iii) Chemical contamination;
(iv) Pesticides;
(v) Drug residues;
(vi) Zoonotic diseases;
(vii) Decomposition;
(viii) Parasites;
(ix) Unapproved use of direct or indirect food or color
additives; and
(x) Physical hazards.
(b) The HACCP plan. (1) Every establishment shall
develop and implement a written HACCP plan covering each product produced
by that establishment whenever a hazard analysis reveals one or more food
safety hazards that are reasonably likely to occur, based on the hazard
analysis conducted in accordance with paragraph (a) of this section, including
products in the following processing categories:
(i) Slaughter--all species.
(ii) Raw product--ground.
(iii) Raw product--not ground.
(iv) Thermally processed--commercially sterile.
(v) Not heat treated--shelf stable.
(vi) Heat treated--shelf stable.
(vii) Fully cooked--not shelf stable.
(viii) Heat treated but not fully cooked--not shelf stable.
(ix) Product with secondary inhibitors--not shelf stable.
(2) A single HACCP plan may encompass multiple products
within a single processing category identified in this paragraph, if the
food safety hazards, critical control points, critical limits, and procedures
required to be identified and performed in paragraph (c) of this section
are essentially the same, provided that any required features of the plan
that are unique to a specific product are clearly delineated in the plan
and are observed in practice.
(3) HACCP plans for thermally processed/commercially sterile
products do not have to address the food safety hazards associated with
microbiological contamination if the product is produced in accordance
with the requirements of part 318, subpart G, or part 381, subpart X,
of this chapter.
(c) The contents of the HACCP plan. The HACCP plan shall,
at a minimum:
(1) List the food safety hazards identified in accordance
with paragraph (a) of this section, which must be controlled for each
process.
(2) List the critical control points for each of the identified
food safety hazards, including, as appropriate:
(i) Critical control points designed to control food safety
hazards that could be introduced in the establishment, and
(ii) Critical control points designed to control food safety
hazards introduced outside the establishment, including food safety hazards
that occur before, during, and after entry into the establishment;
(3) List the critical limits that must be met at each of
the critical control points. Critical limits shall, at a minimum, be designed
to ensure that applicable targets or performance standards established
by FSIS, and any other requirement set forth in this chapter pertaining
to the specific process or product, are met;
(4) List the procedures, and the frequency with which those
procedures will be performed, that will be used to monitor each of the
critical control points to ensure compliance with the critical limits;
(5) Include all corrective actions that have been developed
in accordance with § 417.3(a) of this part, to be followed in response
to any deviation from a critical limit at a critical control point; and
(6) Provide for a recordkeeping system that documents the
monitoring of the critical control points. The records shall contain the
actual values and observations obtained during monitoring.
(7) List the verification procedures, and the frequency
with which those procedures will be performed, that the establishment
will use in accordance with § 417.4 of this part.
(d) Signing and dating the HACCP plan. (1) The HACCP plan
shall be signed and dated by the responsible establishment individual.
This signature shall signify that the establishment accepts and will implement
the HACCP plan.
(2) The HACCP plan shall be dated and signed:
(i) Upon initial acceptance;
(ii) Upon any modification; and
(iii) At least annually, upon reassessment, as required
under § 417.4(a)(3) of this part.
(e) Pursuant to 21 U.S.C. 456, 463, 608, and 621, the failure
of an establishment to develop and implement a HACCP plan that complies
with this section, or to operate in accordance with the requirements of
this part, may render the products produced under those conditions adulterated.
§ 417.3 Corrective actions.
(a) The written HACCP plan shall identify the corrective
action to be followed in response to a deviation from a critical limit.
The HACCP plan shall describe the corrective action to be taken, and assign
responsibility for taking corrective action, to ensure:
(1) The cause of the deviation is identified and eliminated;
(2) The CCP will be under control after the corrective action
is taken;
(3) Measures to prevent recurrence are established; and
(4) No product that is injurious to health or otherwise
adulterated as a result of the deviation enters commerce.
(b) If a deviation not covered by a specified corrective
action occurs, or if another unforeseen hazard arises, the establishment
shall:
(1) Segregate and hold the affected product, at least until
the requirements of paragraphs (b)(2) and (b)(3) of this section are met;
(2) Perform a review to determine the acceptability of the
affected product for distribution;
(3) Take action, when necessary, with respect to the affected
product to ensure that no product that is injurious to health or otherwise
adulterated, as a result of the deviation, enters commerce;
(4) Perform or obtain reassessment by an individual trained
in accordance with § 417.7 of this part, to determine whether the
newly identified deviation or other unforeseen hazard should be incorporated
into the HACCP plan.
(c) All corrective actions taken in accordance with this
section shall be documented in records that are subject to verification
in accordance with § 417.4(a)(2)(iii) and the recordkeeping requirements
of § 417.5 of this part.
§ 417.4 Validation, Verification, Reassessment.
(a) Every establishment shall validate the HACCP plan's
adequacy in controlling the food safety hazards identified during the
hazard analysis, and shall verify that the plan is being effectively implemented.
(1) Initial validation. Upon completion of the hazard analysis
and development of the HACCP plan, the establishment shall conduct activities
designed to determine that the HACCP plan is functioning as intended.
During this HACCP plan validation period, the establishment shall repeatedly
test the adequacy of the CCP's, critical limits, monitoring and recordkeeping
procedures, and corrective actions set forth in the HACCP plan. Validation
also encompasses reviews of the records themselves, routinely generated
by the HACCP system, in the context of other validation activities.
(2) Ongoing verification activities. Ongoing verification
activities include, but are not limited to:
(i) The calibration of process-monitoring instruments;
(ii) Direct observations of monitoring activities and corrective
actions; and
(iii) The review of records generated and maintained in
accordance with § 417.5(a)(3) of this part.
(3) Reassessment of the HACCP plan. Every establishment
shall reassess the adequacy of the HACCP plan at least annually and whenever
any changes occur that could affect the hazard analysis or alter the HACCP
plan. Such changes may include, but are not limited to, changes in: raw
materials or source of raw materials; product formulation; slaughter or
processing methods or systems; production volume; personnel; packaging;
finished product distribution systems; or, the intended use or consumers
of the finished product. The reassessment shall be performed by an individual
trained in accordance with § 417.7 of this part. The HACCP plan shall
be modified immediately whenever a reassessment reveals that the plan
no longer meets the requirements of § 417.2(c) of this part.
(b) Reassessment of the hazard analysis. Any establishment
that does not have a HACCP plan because a hazard analysis has revealed
no food safety hazards that are reasonably likely to occur shall reassess
the adequacy of the hazard analysis whenever a change occurs that could
reasonably affect whether a food safety hazard exists. Such changes may
include, but are not limited to, changes in: raw materials or source of
raw materials; product formulation; slaughter or processing methods or
systems; production volume; packaging; finished product distribution systems;
or, the intended use or consumers of the finished product.
§ 417.5 Records.
(a) The establishment shall maintain the following records
documenting the establishment's HACCP plan:
(1) The written hazard analysis prescribed in § 417.2(a)
of this part, including all supporting documentation;
(2) The written HACCP plan, including decisionmaking documents
associated with the selection and development of CCP's and critical limits,
and documents supporting both the monitoring and verification procedures
selected and the frequency of those procedures.
(3) Records documenting the monitoring of CCP's and their
critical limits, including the recording of actual times, temperatures,
or other quantifiable values, as prescribed in the establishment's HACCP
plan; the calibration of process-monitoring instruments; corrective actions,
including all actions taken in response to a deviation; verification procedures
and results; product code(s), product name or identity, or slaughter production
lot. Each of these records shall include the date the record was made.
(b) Each entry on a record maintained under the HACCP plan
shall be made at the time the specific event occurs and include the date
and time recorded, and shall be signed or initialed by the establishment
employee making the entry.
(c) Prior to shipping product, the establishment shall review
the records associated with the production of that product, documented
in accordance with this section, to ensure completeness, including the
determination that all critical limits were met and, if appropriate, corrective
actions were taken, including the proper disposition of product. Where
practicable, this review shall be conducted, dated, and signed by an individual
who did not produce the record(s), preferably by someone trained in accordance
with § 417.7 of this part, or the responsible establishment official.
(d) Records maintained on computers. The use of records
maintained on computers is acceptable, provided that appropriate controls
are implemented to ensure the integrity of the electronic data and signatures.
(e) Record retention. (1) Establishments shall retain all
records required by paragraph (a)(3) of this section as follows: for slaughter
activities for at least one year; for refrigerated product, for at least
one year; for frozen, preserved, or shelf-stable products, for at least
two years.
(2) Off-site storage of records required by paragraph (a)(3)
of this section is permitted after six months, if such records can be
retrieved and provided, on-site, within 24 hours of an FSIS employee's
request.
(f) Official review. All records required by this part and
all plans and procedures required by this part shall be available for
official review and copying.
§ 417.6 Inadequate HACCP Systems.
A HACCP system may be found to be inadequate if:
(a) The HACCP plan in operation does not meet the requirements
set forth in this part;
(b) Establishment personnel are not performing tasks specified
in the HACCP plan;
(c) The establishment fails to take corrective actions,
as required by § 417.3 of this part;
(d) HACCP records are not being maintained as required in
§ 417.5 of this part; or
(e) Adulterated product is produced or shipped.
§ 417.7 Training.
(a) Only an individual who has met the requirements of paragraph
(b) of this section, but who need not be an employee of the establishment,
shall be permitted to perform the following functions:
(1) Development of the HACCP plan, in accordance with §
417.2(b) of this part, which could include adapting a generic model that
is appropriate for the specific product; and
(2) Reassessment and modification of the HACCP plan, in
accordance with § 417.3 of this part.
(b) The individual performing the functions listed in paragraph
(a) of this section shall have successfully completed a course of instruction
in the application of the seven HACCP principles to meat or poultry product
processing, including a segment on the development of a HACCP plan for
a specific product and on record review.
§ 417.8 Agency verification.
FSIS will verify the adequacy of the HACCP plan(s) by determining
that each HACCP plan meets the requirements of this part and all other
applicable regulations. Such verification may include:
(a) Reviewing the HACCP plan;
(b) Reviewing the CCP records;
(c) Reviewing and determining the adequacy of corrective
actions taken when a deviation occurs;
(d) Reviewing the critical limits;
(e) Reviewing other records pertaining to the HACCP plan
or system;
(f) Direct observation or measurement at a CCP;
(g) Sample collection and analysis to determine the product
meets all safety standards;
and
(h) On-site observations and record review.
APPENDIX B
References for HACCP Teams
1. Agriculture Canada. Food Safety Enhancement Program
– HACCP Implementation Manual. Camelot Drive, Nepean, Ontario,
Canada, 1996.
2. American Meat Institute Foundation. HACCP: The Hazard
Analysis and Critical Control Point System in the Meat and Poultry Industry.
Washington, D.C., 1994.
Useful sections in particular are:
Chapter 3 – microbiological hazards, pp. 15-26
Chapter 4 – chemical hazards, pp. 27-32
Chapter 5 – physical hazards, pp. 33-35
Appendix A – NACMCF HACCP
Appendix C – Model HACCP plans
3. Baker, D.A. Application of Modeling in HACCP Plan
Development. Int. J. Food Microbiol. 25:251-261, 1995.
4. Corlett, D.A., Jr. and Stier, R.F. Risk Assessment
within the HACCP System. Food Control 2:71-72, 1991.
5. Council for Agriculture Science and Technology. Risks
Associated with Foodborne Pathogens. February 1993.
6. Easter, M.C., et al. The Role of HACCP in the Management
of Food Safety and Quality. J. Soc. Dairy Technol. 47:42-43, 1994.
7. Environmental Protection Agency. Tolerances for Pesticides
in Foods. Title 40, Code of Federal Regulations, Part 185. U.S. Government
Printing Office, Washington, D.C., 1998.
8. Food and Drug Administration. The Food Defect Action
Levels. FDA/CFSAN. Washington, D.C., 1998.
9. Food and Drug Administration. Fish and Fishery Products
Hazards and Control Guide --Get Hooked on Seafood Safety. Office
of Seafood. Washington, D.C., 1994.
10. International Commission on Microbiological Specification
for Foods. HACCP in Microbiological Safety and Quality. Blackwell
Scientific Publications, Oxford, 1988.
Useful sections in particular are:
Chapter 10 – raw meat and poultry, pp. 176-193
Chapter 11 – roast beef, pp. 234-238
Chapter 11 – canned ham, pp. 238-242
11. International Commission on Microbiological Specification
for Foods. Microorganisms in Foods 4. Application of Hazard Analysis
and Critical Control Point (HACCP) Systems to Ensure Microbiological Safety
and Quality. Blackwell Scientific Publications, Boston, 1989.
12. National Advisory Committee on Microbiological Criteria
for Foods. March 20, 1992 -- Hazard Analysis and Critical Control
Point System. Int. J. Food Microbiol. 16: 1-23, 1993.
13. National Advisory Committee on Microbiological Criteria
for Foods. Adopted August 14, 1997-- Hazard Analysis and Critical
Control Point Principles and Application Guidelines. J. Food Protect.
61(9): 1246-1259, 1998.
14. National Advisory Committee on Microbiological Criteria
for Foods. DRAFT document - FSIS Microbiological Hazard Identification
Guide for Meat and Poultry Components of Products Produced by Very Small
Plants. 1-22, August 1999.
15. National Advisory Committee on Microbiological Criteria
for Foods. June 1993 -- Report on Generic HACCP for Raw Beef.
Food Microbiol. 10: 449-488, 1994.
16. National Research Council. An Evaluation of the
Role of Microbiological Criteria for Foods and Food Ingredients.
National Academy Press, Washington, D.C., 1985.
Useful sections in particular are:
Chapter 4 – microbiological hazards, pp. 72-103
Chapter 9 – raw meat, pp. 193-199
Chapter 9 – processed meats, pp. 199-216
17. Notermans, S., et al. The HACCP Concept: Identification
of Potentially Hazardous Microorganisms. Food Microbiol. 11:203-214,
1994.
18. Pierson M.D. and Dutson, T. Editors. HACCP in Meat,
Poultry, and Fish Processing. Blackie Academic & Professional.
Glasgow, 1995.
Useful sections in particular are:
Chapter 4 – meat and poultry slaughter, pp. 58-71
Chapter 5 – processed meats, pp. 72-107
Chapter 7 – risk analysis, pp. 134-154
Chapter 13 – predictive modeling, pp. 330-354
19. Pierson, M.D. and Corlett, D.A., Jr. Editors. HACCP
Principles and Applications. Van Nostrand Reinhold, New York, 1992.
20. Stevenson, K.E. and Bernard, D.T. Editors. HACCP:
Establishing Hazard Analysis Critical Control Point Programs., A Workshop
Manual. The Food Processors Institute, Washington, D.C., 1995.
Useful sections in particular are:
Chapter 11 – forms for hazard analysis, CCPs, critical limits,
HACCP master sheet, example HACCP for breaded chicken
21. Stevenson, K.E. and Bernard, D.T. Editors. HACCP:
A Systematic Approach to Food Safety. 3rd Edition. The Food Processors
Institute, Washington, D.C., 1999.
22. Tompkin, R.B. The Use of HACCP in the Production
of Meat and Poultry Products. J. Food Protect. 53(9): 795-803, 1990.
23. Tompkin, R.B. The Use of HACCP for Producing and
Distributing Processed Meat and Poultry Products. In Advances in
Meat Research. Volume 10. Hazard Analysis Critical Control Point in
Meat, Poultry and Seafoods. Chapman & Hall, 1995.
APPENDIX C
Livestock Carcasses and Poultry Carcasses Contaminated
With Visible Fecal Material
[Federal Register: November 28, 1997 (Volume 62, Number
229)]
[Rules and Regulations]
[Page 63254-63255]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr28no97-2]
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DEPARTMENT OF AGRICULTURE
Food Safety and Inspection Service
9 CFR Parts 301, 307, 308, 310, 318, 381, 416, and 417
[Docket No. 97-067N]
Livestock Carcasses and Poultry Carcasses Contaminated With
Visible Fecal Material
AGENCY: Food Safety and Inspection Service, USDA.
ACTION: Notice on complying with food safety standards under
the HACCP
system regulations.
------------------------------------------------------------------------------------------------------------
SUMMARY: The Food Safety and Inspection Service is publishing
this notice to assure that the owners and operators of federally inspected
slaughter establishments are aware that the Agency views its “zero
tolerance” for visible fecal material as a food safety standard.
Fecal material is a vehicle for microbial pathogens, and microbiological
contamination is a food safety hazard that is reasonably likely to occur
in the slaughter production process. In controlling microbiological contamination,
a hazard analysis and critical control point plan for slaughter must be
designed, among other things, to ensure that, by the point of post-mortem
inspection of livestock carcasses or when poultry carcasses enter the
chilling tank, no visible fecal material is present.
FOR FURTHER INFORMATION CONTACT: Patricia F. Stolfa, Assistant
Deputy Administrator, Regulations and Inspection Methods, Food Safety
and Inspection Service, Washington, DC 20250-3700; (202) 205-0699.
SUPPLEMENTARY INFORMATION: The Food Safety and Inspection
Service (FSIS) administers a regulatory program under the Federal Meat
Inspection Act (FMIA) (21 U.S.C. 601 et seq.) and the Poultry Products
Inspection Act (PPIA) (21 U.S.C. 451 et seq.) to protect the health and
welfare of consumers by preventing the distribution of livestock products
and poultry products that are unwholesome, adulterated, or misbranded.
A livestock product or poultry product is adulterated under any of a number
of circumstances, including the following: if it bears or contains any
poisonous or deleterious substance which may render it injurious to health,
unless when the substance is not an added substance, the quantity in or
on the article does not ordinarily render it injurious to health; if it
consists in whole or in part of any filthy, putrid, or decomposed substance
or is for any other reason unsound, unhealthful, unwholesome, or otherwise
[[Page 63255]]
unfit for human food; or if it has been prepared, packed,
or held under unsanitary conditions whereby it may have become contaminated
with filth or whereby it may have been rendered injurious to health (21
U.S.C. 453(g)(1), (g)(3), and (g)(4) and 601(m)(1), (m)(3), and (m)(4)).
Both the FMIA and the PPIA include requirements for government inspection
and prohibit transactions in products required to be inspected unless
they have been ``inspected and passed'' or if they are adulterated (21
U.S.C. 458(a)(2) and 610(c)). FSIS enforces a ``zero tolerance'' standard
for visible fecal material on carcasses and carcass parts at inspected
establishments that slaughter livestock or poultry. This standard is reflected
in the Agency's regulations under the FMIA and the PPIA (9 CFR chapter
III, subchapter A and subchapter C, respectively), which require (among
other things) that establishments handle livestock carcasses and carcass
parts to prevent contamination with fecal material and promptly remove
contamination if it occurs (Sec. 310.18) and that establishments prevent
poultry carcasses contaminated with visible fecal material from entering
the chilling tank (Sec. 381.65(e)). When inspection program personnel
observe fecal material at post-mortem livestock inspection or thereafter
(i.e., at or after the final rail) under the FMIA or when poultry carcasses
are about to enter the chilling tank or thereafter (i.e., at any point
after the final pre-chiller wash) under the PPIA, they condemn affected
carcasses and carcass parts unless the contamination is removed in accordance
with regulatory requirements. The Agency is publishing this notice to
assure that the owners and operators of federally inspected slaughter
establishments are aware that FSIS regards its zero tolerance for visible
fecal material as a food safety standard under both the FMIA and the PPIA.
Reiterating the Agency's position is particularly appropriate now, as
federally inspected establishments prepare to comply with the hazard analysis
and critical control point (HACCP) system regulations (part 417).
\1\ Part 417 requirements, as well as pathogen reduction
performance standards for Salmonella in establishments that slaughter
cattle, swine, chickens, or turkeys, prepare ground beef or fresh pork
sausage, or process ground chicken or turkey (Secs. 310.25(b) and 381.94(b))
will apply as of January 26, 1998, in establishments with 500 or more
employees; January 25, 1999, in establishments with 10 or more but fewer
than 500 employees (unless the establishment has annual sales of less
than $2.5 million); and January 25, 2000, in establishments with fewer
than 10 employees or annual sales of less than $2.5 million.
The essence of FSIS's position is that fecal material is
a vehicle for microbial pathogens, and microbiological contamination is
a food safety hazard that is reasonably likely to occur in the slaughter
production process (Sec. 417.2(a) and (b)). Consequently, HACCP plans
must control for microbiological contamination at slaughter, and to meet
the zero tolerance standard, an establishment's controls must (among other
things) include limits that ensure that no visible fecal material is present
by the point of post-mortem inspection of livestock carcasses or before
poultry carcasses enter the chilling tank (Sec. 417.2(c)).
In the Pathogen Reduction-HACCP Systems final rule (61
FR 38806, July 25, 1996), FSIS explained the reasoning underlying its
position on fecal contamination, and at the beginning of this year, FSIS
addressed the role of its zero tolerance for visible fecal material on
poultry carcasses in the final rule that codified the standard under the
PPIA (62 FR 5139, February 4, 1997). Preparation for implementation of
the HACCP system regulations has not changed the Agency's conclusions
about the appropriateness of this standard, under the FMIA as well as
the PPIA.
As the Agency stated in the Pathogen Reduction-HACCP Systems
final rule (61 FR 38837):
In slaughter establishments, fecal contamination of carcasses
is the primary avenue for contamination by pathogens. Pathogens may reside
in fecal material and ingesta, both within the gastrointestinal tract
and on the exterior surfaces of animals going to slaughter. Therefore,
without care being taken in handling and dressing procedures during slaughter
and processing, the edible portions of the carcass can become contaminated
with bacteria capable of causing illness in humans. Additionally, once
introduced into the establishment environment, the organisms may be spread
from carcass to carcass.
Because the microbial pathogens associated with fecal contamination
are the single most likely source of potential food safety hazard in slaughter
establishments, preventing and removing fecal contamination and associated
bacteria are vital responsibilities of slaughter establishments. Further,
because such contamination is largely preventable, controls to address
it will be a critical part of any slaughter establishment's HACCP plan.
Most slaughter establishments already have in place procedures designed
to prevent and remove visible fecal contamination.
As noted in the zero tolerance final rule and confirmed
today with respect to livestock as well as poultry, establishments that
process animals must adopt controls that they can demonstrate are effective
in reducing the occurrence of microbial pathogens, including controls
that prevent the fecal contamination of carcasses (62 FR 5140). Under
the HACCP system regulations, critical control points to eliminate contamination
with visible fecal material are predictable and essential components of
all slaughter establishments' HACCP plans. Initial validation of a HACCP
plan for slaughter and monitoring thereunder, as verified and documented
in establishment records, must demonstrate the effective operation of
the plan's controls on a continuing basis (Secs. 417.3(a), 417.4, and
417.5).
FSIS personnel will continue to verify compliance with the
zero tolerance standard in slaughter establishments that are subject to
part 417 requirements. The Agency will use visual observations and other
findings by FSIS personnel in evaluating the effectiveness of an establishment's
preventive controls and corrective actions for fecal contamination (Secs.
417.6 and 417.8). The presence of visible fecal contamination on livestock
carcasses presented for post-mortem inspection or poultry carcasses entering
the chilling tank will mean that establishment controls have failed; repeated
failures will evidence that establishment corrective actions have failed
to prevent recurrence and, thus, possible system inadequacy.
In addition to enforcing the zero tolerance for visible
fecal material, FSIS will use the results of establishment testing for
generic E. coli (Escherichia coli Biotype I, as already required by Sec.
310.25(a) or Sec. 381.94(a)) in assessing how well an establishment is
controlling its slaughter and dressing processes to prevent fecal contamination.
The pathogen reduction performance standards for Salmonella (Secs. 310.25(b)
and 381.94(b)), which FSIS will enforce through its own testing program,
will complement the zero tolerance standard and E. coli testing.
Done at Washington, D.C., on November 18, 1997.
Thomas J. Billy,
Administrator.
[FR Doc. 97-31176 Filed 11-26-97; 8:45 am]
BILLING CODE 3410-DM-P
Contents of HACCP Plans: Critical Control Points
[Federal Register: January 30, 1998 (Volume 63, Number 20)]
[Rules and Regulations]
[Page 4560-4562]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr30ja98-2]
-----------------------------------------------------------------------
DEPARTMENT OF AGRICULTURE
Food Safety and Inspection Service
9 CFR Part 417
[Docket No. 97-082N]
Contents of HACCP Plans; Critical Control Points
AGENCY: Food Safety and Inspection Service, USDA.
ACTION: Compliance with the HACCP system regulations.
-----------------------------------------------------------------------
SUMMARY: The Food Safety and Inspection Service (FSIS) is
publishing this document to ensure that the owners and operators of federally
inspected establishments are aware that the identification of appropriate
critical
[[Page 4561]]
control points is crucial to complying with the Agency's
regulations on hazard analysis and critical control point (HACCP) systems.
The HACCP system regulations require that a HACCP plan list critical control
points for each food safety hazard identified as reasonably likely to
occur in the production process. The number of critical control points
will depend upon the production process and the hazard, but a HACCP plan
must specify as critic