Editor’s note: This is the fifth of a seven-part series on Hazard Analysis and Critical Control Points sponsored by PAR Technologies. There are seven HACCP principles outlined by the Food and Drug Administration to serve as a guideline for creating a systematic approach in the identification, evaluation and control of food safety hazards.

Once a company falls out of compliance with its HACCP plan, it becomes at risk for having to issue a food recall.

“A HACCP plan outlines things that must be done a certain way to prevent food safety hazards,” explains says Donna Schaffner, HACCP consultant microbiologist and the Associate Director of Food Safety, Quality Assurance and Training for Rutgers Food Innovation Center South.

“In the event of a HACCP deviation which causes a food company to fall out of compliance, the company must be able to justify why the product is still safe, in order to prevent having to issue a recall.”

While some HACCP deviations can cause major food safety hazards, such as cross contamination or not following proper cooking procedures. Others might have no impact on the product but instead could jeopardize a company, such as when employees fail to document that procedures were followed properly.

When reviewing any given deviation, there are a few questions that apply to all food companies:

  • “What was the deviation?”
  • “What critical limit(s) wasn’t met?”
  • “How long have you been out of compliance?”
  • “Who caused the deviation”
  • “How much product was affected?”
  • “Who is going to record and ensure implementation of corrective action?”

“These are all things that need to be investigated when a HACCP deviation occurs, in order to establish the proper corrective action,” explains Schaffner.

“If there are multiple monitoring procedure points along the process line, they might be able to prove if a product is still safe, despite lack of one of those actions being documented according to the correct time-table.”

For example, if a critical limit monitoring procedure requires that temperatures of raw ground beef be taken every hour and the assigned employee misses the time window, any product that missed the temperature check must be segregated. The food company must, at that point, implement proper corrective action, which might be microbiological testing of sample of the ground beef to ensure it is safe before being released for shipment.

Food companies might also have the option to repurpose the product, for example in this case, the raw ground beef produced without the proper temperature records might be immediately diverted for cooking and used as a cooked product.

According to Schaffner, the biggest issue she sees when reviewing deviation reports, is companies failing to take quick action.

“Sometimes companies will just set the product aside, not take action and ship it anyway. Other times a company will put products on hold, but not segregate them properly,” she says. “It is essential that corrective actions are done quickly and effectively to ensure that the food which can’t be proven safe does not get distributed for sale.”

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