Every food processor and food distributor doing business in the United States is required to have a Food Safety Program that is compliant with FDA regulations, as described in the Food Safety Modernization Act (FSMA). A Food Safety Program is comprised of a preventive controls and metrics that are put in place to ensure compliance with FSMA. There are various “third party schemes” such as SQF, BRC, or FSSC22000 that provide the structure & standards for a food safety program to help to guide a company to be in compliance. Obtaining a certification for one of the schemes is a good foundation for a food company to assure themselves and their customers that they are food safe. However, a third party certification alone does not ensure you are in full compliance with FSMA. Adroit’s Food Safety experts can assess where there are gaps between your certification and the FSMA rules. HACCP must be part of every food safety program.

HACCP stands for Hazard Analysis and Critical Control Point. HACCP is an effective means of ensuring food safety from harvest to consumption. Preventing problems from occurring is the key goal of any HACCP plan. HACCP plans employ seven principles including hazard analysis, Critical Control Point identification, establishing critical limits, monitoring procedures, corrective actions, verification procedures, and record-keeping & documentation. ERP solutions, such as Aptean F&B ERP JustFood edition, are an effective tool to build a HACCP plan with a proper preventative approach to ensure that food related processes remain under control.

Before implementing a HACCP plan, a company needs to establish cGMPs or Current Good Manufacturing Practices. These require basic environmental and operating conditions that are necessary to produce safe food. Examples include good facility design, product specifications, sanitary production equipment, cleaning and sanitation procedures, personal hygiene, and training, etc.

The FDA fully describes HACCP on their website. The development of a HACCP plan consists of:

Preliminary work:

1. Form the team – It should be cross functional and include employees from areas such as engineering, production, sanitation, quality assurance, and food microbiology. HACCP plans may vary from one location to the next due to variability. Be sure to include local resources that are familiar with the operation.
2. Describe the food and its distribution.
3. Describe the intended use and consumers of the food.
4. Develop a flow diagram which describes the process.
5. Verify the flow diagram.

The documentation should be accessible to those implementing the plan and change controlled. The best way to do that is to store and manage the documentation electronically. We recommend at a minimum using a document control system such as Microsoft Sharepoint but ideally look at a range of GRC (Governance, Regulatory, Compliance) software solutions to effectively manage the documentation and employee to supply chain partner communication.

Apply HACCP principles:

1. Conduct a hazard analysis.
   • Hazard analysis is a food safety risk assessment methodology. The hazard analysis is a list of hazards which are of such significance that they are reasonably likely to cause injury or illness if not effectively controlled. It is important to consider in the hazard analysis the ingredients and raw materials, each step in the process, product storage and distribution, and final preparation and use by the consumer. This is about food safety – not quality. There is a lot to the analysis, and we suggest getting help from a Food Safety Professional such as Adroit North America to conduct a proper analysis.
2. Determine critical control points (CCPs).
   • A critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Hazards include those things that have a probability to cause illness or injury unless properly controlled. Critical control points are located at any step where hazards can be either prevented, eliminated, or reduced to acceptable levels. Examples of CCPs can include things such as testing for metal, chemicals, and temperature, etc. CCPs must be carefully developed and documented. In addition, they must be used only for purposes of food safety. For example, a specified heat process, at a given time and temperature designed to destroy a specific microbiological pathogen, could be a CCP. Through Aptean’s F&B ERP, critical control points can be defined. The CCP is described and associated with the product workflow. For example, CCPs associated with receiving are automatically referenced when a purchase order receipt is created. To process the receipt, the operator would need to confirm or input the values associated with the CCP. A temperature check at receiving would be triggered by the creation of the purchase order receipt. Until the values are captured, the material lot can’t be released for use.
3. Establish critical limits.
   • For each CCP define one or measures with an acceptable value range or result. Results outside of the value range for the measure are considered unsafe. Defining the acceptable value ranges must be scientifically based. Aptean’s JustFood edition sets the acceptable values. As described in section 2, steps in the process trigger the capture of the values for the CCP measures. When the results are outside control limits workflows then trigger notifications for the creation of a deviation report and corrective action. Until the deviation is resolved the lot is put on hold.
4. Establish monitoring procedures & establish corrective actions.
   • Monitoring is essential to food safety management in that it facilitates tracking of the operation. Ongoing monitoring enables the indication of control trends. If the trend is moving outside of acceptable limits, then action can be taken to bring the process back into control. If the monitoring identifies a loss of control, then the deviation can be flagged and the appropriate corrective action taken. The monitoring records are then used in verification. Per the FDA, “All records and documents associated with CCP monitoring should be dated and signed or initialed by the person doing the monitoring.” Within Aptean F&B ERP, JustFood edition the values associated with the control points are captured and associated with the user-id of the person doing the monitoring. Deviations trigger workflows that notify the HACCP team and require input on the specific corrective actions taken. All inputs are security controlled and associated with the user-id and meet the documentation requirements.
5. Establish verification procedures.
   • Verification is defined as those activities, other than monitoring, that determine the validity of the HACCP plan and that the system is operating according to the plan. Adroit’s Food Safety team can assist with the validations as an independent expert to ensure the HACCP plan is being correctly followed and that the plan is still valid and operating according to the plan. The verification of the food safety plan may be captured into the ERP similar to the ongoing monitoring results.
6. Establish record-keeping and documentation procedures.
   • We encourage the use of a document control system such as a GRC system or Microsoft Sharepoint to describe the plan. Utilize a food-oriented ERP system such as Aptean F&B ERP, JustFood edition to implement the Critical Control Points and associated measures and critical limits. Use the ERP system to capture the ongoing monitoring results, verifications, deviations, and corrective actions. Leverage the reporting capabilities, such as Aptean BI to demonstrate ongoing monitoring.

     

The successful implementation of a HACCP plan requires full organizational commitment, proper process and systems design, and rigorous employee training. Through the proper implementation of HACCP via a food-oriented ERP, your organization will take a significant step towards an integrated Food Safety Culture while reducing your ongoing investment in record keeping and reporting.

Reference:

www.fda.gov – hazard-analysis-critical-control-point-haccp/haccp-principles-application-guidelines