Don't Make the Mistake of Underestimating the Power of HACCP Plan Reassessment
In order for a meat company to grow and prosper they must provide their customers with a quality, consistent product at a fair price that is safe. The tool we use in the meat industry to assure the manufacture of safe products is HACCP (Hazard Analysis and Critical Control Points). It is almost 12 years since the first meat plants implemented HACCP.
Many processors produce products very differently than they did 10 years ago. A HACCP plan that was valid in 2000 might not be effective today. By regulation processors are required to reassess their HACCP plans once each calendar year. As a result, this is time of year when many processors reassess their plans. It is also frequently the busiest time of the year. Consequently, HACCP plan reassessment all too often fails to get the attention it deserves. Reassessment helps you confirm that your plan is functioning the way you intended. It provides you with confidence that you are producing safe products and documentation to support that you have done so. I am confident many companies that have gotten involved with recalls or worse wish they had taken HACCP plan reassessment more seriously.
You should reassess your HACCP plan at least annually or whenever changes occur that alter your plan. Reasons to reassess might include changes in: process flow, equipment, product formulation, packaging or product specifications. Reassessment should also occur if information becomes available that might indicate a possible deficiency in your plan. This includes information such as: multiple deviations from a critical limit, customer complaints, inadequate records, new information becoming available concerning the safety of the product or an ingredient or process.
I like to follow a series of steps to make sure all aspects of the plan are addressed during reassessment.
1. Confirm you have the correct HACCP plans based on your products and processes. Make sure each of your products fit into a plan.
2. Review the product description.
3. Review the list of product ingredients. Confirm all ingredients are listed that are used.
4. Review the process flow diagram. Make sure you can trace each product through the flow diagram.
5. Review the hazard analysis. Make sure all potential hazards in the process have been considered.
6. Review the selection of critical control points (CCPs). Make sure documentation is on file to support selection of CCPs.
7. Review the critical limits. Make sure documentation is on file to support selection of critical limits.
8. Review monitoring records and confirm they are being filled out correctly.
9. Review corrective action records and confirm they are being filled out correctly.
10. Confirm your ongoing verification is being done correctly. Review your documentation that supports verification. Examples include: monitoring observation logs, scale accuracy check logs, thermometer accuracy check logs and internal audits.
11. Document each step of you HACCP plan reassessment. Sign the reassessment and store it in a designated place. Reassessment records provide information on why you chose to make changes.
A thorough HACCP plan reassessment will provide you with assurance you are producing safe products and help prevent you from having major food safety problems. Remember: A man can only be judged by his actions, not by his good intentions.