The food safety management system known as HACCP has come a long way since its development for the American space program. It has become an integral part of the country’s entire food safety system. “HACCP has had the biggest impact on ensuring the safety of food ever since it was implemented,” says Jenny Scott, senior advisor to the director of the Food and Drug Administration’s Center for Food Safety and Applied Nutrition. HACCPpicUSDA_406The acronym stands for Hazard Analysis and Critical Control Points and refers to the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. Scott puts it more simply: “Let’s figure out what could go wrong first, figure out what we need to control to prevent these things from going wrong, and then we’re going to have much better assurance that the foods we’re producing are safe.” In the late 1950s, the National Aeronautics and Space Administration (NASA) took on the critical control points system used by munitions factories and developed it with the help of Pillsbury to ensure the safety of the food they were sending into space. Sickening an astronaut with a foodborne pathogen was not an option. HACCP is in widespread use today. It’s almost a necessity for doing business with food, Scott says. In the 1990s, HACCP became a requirement for seafood and juice producers, as well as meat and poultry slaughter and processing establishments. In addition to requiring meat processors to have a HACCP plan in place, the Department of Agriculture’s Food Safety and Inspection Service has been working on an inspection system based on HACCP. Last summer, FSIS released the New Poultry Inspection System based on the HACCP-Based Inspection Models Project (HIMP), which requires facility personnel to conduct carcass-sorting before agency inspectors conduct online carcass inspection. PAR_sidebarJohn Munsell, who ran his family’s meatpacking plant for three decades, criticizes HACCP by saying that it transfers too much of the meat inspector’s authority to the plant owners and was never intended to be used for raw food. “HACCP is no longer primarily involved in a pathogen chase, but a paper chase,” Munsell has written. On the FDA side of things, finalization of the Food Safety Modernization Act rules will lead to what some call an “institutionalizing” of HACCP. The way Scott explains it, FSMA puts in place a broader set of preventive controls, of which HACCP is a part. HACCP can’t cover everything; there are some foundational principles that are managed differently. “You don’t want sick employees handling food, but you don’t deal with that as if it’s a critical control point in a HACCP plan. It’s a basic foundational element,” Scott says. “You’ve got to have a plant you can clean, and you have to have good sanitation practices.” Along the Food Chain When thinking about farm-to-fork, HACCP is not as commonly used by farmers or chefs in restaurant kitchens. HACCP principles don’t work as well in restaurants, Scott says, so they’ve come up with a different approach that focuses more on operations such as cooking, cooling and holding instead of addressing particular food types. “The HACCP system is more geared towards manufacturers,” she says. “That being said, the HACCP principles can be applied fairly broadly.” Roy Costa, founder and owner of the consulting firm Environ Health Associates, argues that restaurants should employ HACCP. “Unfortunately, the restaurant industry has been stuck in what I call ‘compliance culture,’” he says. “They only do what the inspector tells them to do. They don’t take initiative on their own or go beyond the minimum requirements.” Costa adds that, “in order to do HACCP, you have to take the responsibility on yourself.” Expanding Principles There are seven principles to HACCP laid out by the U.S. National Advisory Committee on Microbiological Criteria for Food (NACMCF) when it developed, updated and approved a standardized HACCP system in 1997. They are:

  • Principle 1: Conduct a hazard analysis.
  • Principle 2: Determine the critical control points (CCPs).
  • Principle 3: Establish critical limits.
  • Principle 4: Establish monitoring procedures.
  • Principle 5: Establish corrective actions.
  • Principle 6: Establish verification procedures.
  • Principle 7: Establish record-keeping and documentation procedures.

Separate from her role at FDA, Scott is the U.S. delegate to the Codex Committee on Food Hygiene. That committee is now looking at whether it needs to revise its HACCP annex, which she says is very similar to the NACMCF document. As HACCP has been implemented over the years, there have been some areas of confusion, and the Codex committee is now asking whether there are areas that should be changed or clarified. “A particular area of concern has been the issue of verification and validation,” Scott says. Validation has previously been considered a component of verification — it’s all part of making sure that the system is controlling the hazards. But people have started thinking of “validation” as the scientific basis for the entire plan — what is it capable of controlling instead of verifying it’s being implemented. Scott says Codex is discussing whether verification and validation should be separated into individual principles or simply clarified within the verification principle. The General Principles of Food Hygiene (where the HACCP annex is located) may also be updated more broadly to incorporate HACCP principles. “We’ll have to see how it evolves, but I don’t think HACCP is going away,” Scott says.

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  • Karl Gunnar Kolb

    The High Sierra Group has written hundreds of HACCP programs for quite a while; first, many do not take HACCP development seriously. Producers need to read CODEX, FDA and USDA information/guidance about HACCP development. Second, the HACCP should be critically reviewed every time there is a major change in the plant or at least once a year. Third, a competent third party needs to review the HACCP and be part of the team. Fourth, when looking for a HACCP class, determine if the instruction or institution presenting the class is fully able to teach the class; education, training and experience. Stronger advice goes to auditors; they have a larger responsibility to know and understand HACCP development.

  • Ollie

    I’m glad Jenny Scott believes HACCP is the best thing since sliced bread. I’ve worked in the food industry for 40 years, before HACCP and since the HACCP inception, seeing no better control of the “hazards” in manufacturing. I have to agree with John Munsell, that HACCP has lead to a paper chase in most food industries, making sure the binders of documents are up to date, but never really addressing the issues or root causes of hazards. Do we really need Scott and her FDA and USDA to add more government regulations to the food industry?

  • JTAK Food Safety

    Unfortunately I agree with the paper chase. Many in the food industry and even regulators are more concerned with the paperwork than how the system is implemented. I completely disagree with the premise that HACCP doesn’t work well in the retail food industry. It takes work to implement, but the principles can be applied to any operation.

  • 9 CFR 417 is a good rule; however, Mr. Munsell has a valid point. 9 CFR 417 emphasizes written plans and documentation, but those plans and documents were never intended to replace hands-on, organoleptic inspection of product. The majority of 9 CFR 417 noncompliance records are for record keeping noncompliance. Too many FSIS inspectors spend too much time in an office looking for clerical errors on documents and not enough time on the production floor. Personally, I do not feel that my health is at risk because an establishment employee wrote 2014 on a document in January 2015. It such an error were truly significant, the IRS would have most of us in jail for making the same mistake on checks.

  • John Munsell

    FSIS described HACCP from day one as “Farm to Fork”. Well, Farms lack a critical control point (CCP), which is defined as a point in the production system where controls can be employed which Prevent (P), Eliminate (E), or Reduce (R) pathogens to a less-than-detectable level in this PER environment. Thus, CCP’s require a lethality treatment, such as fully cooking or irradiation. Live animals at the ranch haven’t been exposed to a lethality treatment; thus, the farm/ranch doesn’t qualify for TRUE HACCP. When meat processing plants produce and sell RAW meat, the meat likewise has not been exposed to a lethality treatment. Such plants totally lack a valid CCP, yet FSIS requires the plants to fabricate a HACCP Plan, concocting as CCP’s treatments which lack the PER criteria. While I fully endorse Pillsbury’s original and valid HACCP protocol, we are living a lie when we claim that raw foods have been produced under the HACCP umbrella. Restaurants which cook food (a lethality treatment) can qualify for true HACCP. So can meat plants which make fully cooked, ready-to-eat jerky, ham, etc. Such plants qualify for deregulation: raw meat does not qualify for deregulation. Organoleptic inspection should be an integral part of a comprehensive food safety portfolio, but FSIS denigrates visual observation as an archaic throwback to pre-Jack In The Box dinosaur days. FSIS claims that even if fecal material is visually observed on the carcasses on the kill floor, all such fecal is guaranteed removed by downstream interventions such as carcass washes. But, I can easily devise a paperwork system (the heart of FSIS HACCP) which proves that all fecal is removed, at least in theory. Grocery stores selling cantaloupe, peanut butter, tomatoes, sprouts etc obviously lack a legitimate CCP. Such stores do not qualify for TRUE HACCP, in spite of FSIS claiming that HACCP is “Farm to Fork”. FSIS claims that the answer to pathogen problems in ground beef at retail meat markets is for the store to maintain a Grinding Log, creating a consumer perception that the mere existence of a Grinding Log will prevent the sale of contaminated meat. A close review of agency statements during the recall at several Hanaford stores in the northeast a few years ago prove that FSIS’ primary focus is paper flow, not pathogens. Consumers must treat all raw food as potentially lethal, in spite of the fact that many such foods were produced at a HACCP Plant. FSIS has intentionally schemed a scenario in which they’ve hoodwinked consumers into thinking that all USDA-Inspected meat is safe, raw or otherwise. We are living a lie. John Munsell

  • crookedstick

    This is a joke when it comes to FSIS inspection of Horses to slaughter. Horses are flighty animals who may take a dozen of captive bolt shots before stunned. shame on USDA, Horses are NOT an “amenable,e” species.