Why Do We Reassess HACCP Plans?
We reassess HACCP Plans for two reasons. First, it is required by regulation that meat plants reassess their HACCP Plans at least once each calendar year. Second, it is a process that provides assurance that we are producing products in a manner that will yield safe products. Food safety is paramount in the meat industry.
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.
I like to follow these steps when conducting a HACCP reassessment.
Confirm you have the correct HACCP Plan(s) based on your products and processes. You do not need to have a separate HACCP Plan for each product; however, you must have at least one HACCP Plan in each process category in which you produce products.
HACCP PROCESSING CATEGORIES
The HAACP regulations set out 9 processing categories in which finished product can be identified, 9 CFR 417.2(b)(1):
(i) Slaughter—all species
(ii) Raw product—non-intact (ground)
(iii) Raw product—intact (not ground)
(iv) Thermally processed—commercially sterile
(v) Not heat treated—shelf stable
(vi) Heat treated—shelf stable
(vii) Fully cooked—not shelf stable
(viii) Heat treated but not fully cooked—not shelf stable
(ix) Product with secondary inhibitors—not shelf stable.
Excellent information on HACCP Plans can be obtained from the Process Category Introduction Module (3/25/15) which is used in training Inspection Program Personnel (IPP).
The Process Category Introduction Module contains information on how to;
- Distinguish between the different HACCP processing categories.
- Identify common hazards for all raw products.
- Identify common hazards for other product categories.
- Identify the raw product processing categories.
- Identify common meat and poultry slaughter steps.
- Identify common processing steps for intact and non-intact raw product.
- Explain the food safety significance of non-intact product.
- Identify common lethality for ready-to-eat product.
A pdf of this 59 page document can be downloaded at the FSIS website: www.fsis.usda.gov. In the search engine in the upper right corner of the website home page type: HACCP process categories. When you are directed to the next page look for the pdf; Process Category Introduction.
Review the following for each of your HACCP Plans;
- Product description.
- List of product ingredients. Confirm all ingredients are listed that are used.
- Process flow diagram. Make sure you can trace each product through the flow diagram.
- Hazard analysis. Make sure all potential hazards in the process have been considered.
- Selection of critical control points (CCPs). Make sure documentation is on file to support selection of CCPs.
- Critical limits. Make sure documentation is on file to support selection of critical limits.
- Monitoring records and confirm they are being filled out correctly.
- Corrective action records and confirm they are being filled out correctly.
- Confirm your ongoing verification is being done correctly. Review your validation documentation that supports verification.
Document each step of your HACCP Plan reassessment. Sign the reassessment and store it in a designated place. Reassessment records should 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: If the plan doesn’t work, change the plan but never the goal.