Whether your USDA plant operates under HACCP principles or you’re an FDA plant preparing to implement a food safety plan under FSMA, avoiding food safety pitfalls should always be a top priority. By maintaining control over major food risks, the industry assures consumers that food products are as safe as current science, technology, and regulatory environments allow.
However, no matter how careful we are, mistakes can and do happen. To help minimize risk, I’ve highlighted five deficiencies auditors frequently encounter when reviewing HACCP plan reassessments.
1. Inaccurate Flow Diagrams
All manufacturing process steps must coincide with the written flow diagram. Remember to consider the product re-work flow and addition points, product repacking, and contact points in the process where water and/or gasses such as CO2 and N2 are added. As a best practice, I recommend verifying the flow diagram among team members to be sure all the process steps are represented.
2. Incomplete Hazard Analysis
Some hazard analyses are simply cookie-cutter versions declaring “no hazards identified” or just listing "pathogens" as a hazard. When performing your hazard analysis, make sure to consider the appropriate raw material hazards and identify the specific pathogen of concern. When assessing any potential hazards in your manufacturing process, be sure to review your hold/foreign material log and maintenance logs when trying to determine your level of risk.
3. Inadequate Decision Making Documents and Scientific Data
Facilities must justify the frequency of their monitoring procedures if the product is not being monitored 100% of the time. You will need to justify your frequencies as written in the HACCP plan.
Best practices include:
- Increased sampling during the first 90 days
- Following up with a statistical process control (SPC) analysis of your data in order to determine a reasonable frequency
- Some food companies also use military sampling plans such as acceptable quality limits (AQL) to determine frequencies.
Be sure scientific references used as supporting documentation in validation of your plant’s HACCP Plan are relevant to the products being produced. Reference your scientific/technical documents within the body of your Hazard Analysis, or include footnotes.
4. Inadequate Direct Observation
It's important to conduct direct observations of employees performing each monitoring procedure. Observations can quickly identify any procedural issues and key training opportunities. Direct observation of monitoring activities is a verification procedure listed in 9 CFR 417.4(a) (2), and find they are often overlooked or are not completed with the frequency outlined in the HACCP plan.
5. Ineffective Corrective Actions
Often we run across training and retraining as a corrective action, but if you have to retrain the same person 3 to 4 times on a task, you may want to look at putting a more accountable person in that position. Corrective actions should include a thorough root cause analysis performed by productive, knowledgeable, and contributing team members with the goal of solving the problem the first time.
By diligently seeking to address these five areas and eliminating them as possible deficiencies, you’ll help to ensure that auditors will be that much less likely to find fault with your HACCP plan reassessments.