haccp & special processes · 2018-12-03 · history of haccp •pioneered by the pillsbury...

September 11, 2017

LAURIE JAHN, MPA, LEHP

SENIOR FOOD PROGRAM SPECIALIST

HACCP &

SPECIAL PROCESSES

Would You Work

for a Month

for a Penny a Day?

What If I Doubled

It Each Day?

If you earn 1¢ on the first day, 2¢ on

the second day, etc. …

Day Wages

1………………………1¢

2………………………2¢

3………………………4¢

4………………………8¢

5……………………..16¢

6……………………..32¢

7……………………..64¢

8…………………...$1.28

9…………………...$2.56

10………………….$5.12

11………………...$10.24

12………………...$20.48

13………………...$40.96

14………………...$81.92

15……………….$163.84

16……………….$327.68

17……………….$655.36

18……………..$1,310.72

Day Wages

19……………$2,621.44

20……………$5,242.88

21…………..$10,485.76

22…………..$20,971.52

23…………..$41,943.04

24…………..$83,886.08

25…………$167,772.16

26…………$335,544.32

27…………$671,088.64

28……….$1,342,177.28

29……….$2,684,354.56

30……….$5,368,709.12

31……...$10,737,418.24

On the last day of the

month you would earn

over 10 million dollars!

What Would Happen

If We Didn’t Control

Bacterial Growth?

If just 1 bacterial cell

in this cheeseburger

doubled every 20 minutes…

Bacteria Can Double

Every 20 Minutes!

Hours:Minutes Bacteria

0:00…………………………1

0:20…………………………2

0:40…………………………4

1:00…………………………8

1:20………………………..16

1:40………………………..32

2:00………………………..64

2:20………………………128

2:40………………………256

3:00………………………512

3:20…………………….1,024

3:40…………………….2,048

4:00…………………….4,096

4:20…………………….8,192

4:40…………………...16,384

5:00…………………...32,768

5:20…………………...65,536

5:40………………….131,072

Hours:Minutes Bacteria

6:00………………….262,144

6:20………………….524,288

6:40………………..1,048,576

7:00………………..2,097,152

7:20………………..4,194,304

7:40………………..8,388,608

8:00………………16,777,216

8:20………………33,554,432

8:40………………67,108,864

9:00……………..134,217,728

9:20……………..268,435,456

9:40……………..536,870,912

10:00………….1,073,741,824

At the end of 10 hours this

cheeseburger would contain

over 1 billion bacteria !

ADVANTAGES OF HACCP

Food and Drug Administration recommends the

implementation of HACCP in food establishments because…

…it is a written system of preventative controls that is the most

effective and efficient way to assure that food products are safe.

HISTORY OF HACCP

• Pioneered by the Pillsbury Company with the cooperation and participation of the:

• National Aeronautic and Space Administration (NASA)

• Natick Laboratories of the U.S. Army

• U.S. Air Force Space Laboratory Project Group

• 1960’s-worked together to create food for U.S. Space Program

• 100% assurance against contamination by bacterial and viral pathogens, toxins, and chemical or physical hazards that could cause illness or injury to astronauts

HACCP FOCUSES ON

• Foods most

likely to cause

illness (TCS)

• Monitoring

foods and

procedures

• Taking

corrective

action

FOOD SAFETY MANAGEMENT SYSTEMS (FSMS)

Provides a system to identify, prevent or correct errors

throughout flow of food

System is designed to prevent to occurrence of potential food

safety problems

Validation = Science

Verification = Checking

Calibration = Accuracy

THE FOUNDATION FOR FSMS

• Proper Facility Design

• Proper Personal Hygiene

• Choose Reliable Supplier

• Proper Cleaning and Sanitation

• Appropriate Equipment Maintenance

HACCP PLAN LOOKS AT:

• Menu

• Equipment

• Processes

• Operations

HACCP PRINCIPLES

Principle 1 – Conduct a food safety Hazard Analysis

Principle 2 – Identify the CCPs

Principle 3 – Establish Critical Limits

Principle 4 – Establish Monitoring Procedures

Principle 5 – Take Corrective Action

Principle 6 – Verify the System Works

Principle 7 – Record Keeping and Documentation

Cooking

HACCP FLOWCHART

Receiving Storage Preparation

CCP

Holding Serving Reheating Cooling

CCP CCP CCP

FOOD DEFENSE

• Protection of food products from intentional

adulteration / contamination

• Why is food defense so important?

• Leaving the kitchen door open for a period of time

• Unusual behavior from customer or co-worker

• Do not check deliveries to assure they are safe and intact

• Salad bar is not monitored

• Chemicals are stored near the food and not labeled

• Unknown people have been found in your facility

FOOD DEFENSE SELF-ASSESSMENT CHECKLIST

• Facility Security

• Inspected, Well Lit, Locked, Restricted Access?

• Facility Employees

• Employee Verification, Personal Items Restricted, Trained?

• Receiving Supplies

• Reputable suppliers, Deliveries Inspected, Matched, Moved?

• Food Preparation/Holding/Customer Service

• SOPs, Food Training, No bare hand contact, Salad Bars/Buffets?

• Cleaning

• Chemicals used properly, Sanitizer checked?

FOOD DEFENSE STRATEGIES

• Manager’s Responsibilities

• Be alert and aware

• Encourage employees to report suspicious activities

• Decrease vulnerabilities

• Recall strategy and train staff

• Decrease availability of potential contaminants

• Secure storage areas and label all chemicals

• Identify possible inside threats

• Constant supervision

"Variance" means a written document issued by the

REGULATORY AUTHORITY that authorizes a modification or

waiver of one or more requirements of this Code if, in the opinion

of the REGULATORY AUTHORITY, a health HAZARD or

nuisance will not result from the modification or waiver.

"HACCP plan" means a written document that delineates the

formal procedures for following the HAZARD Analysis and

CRITICAL CONTROL POINT principles developed by The

National Advisory Committee on Microbiological Criteria for

Foods.

VARIANCE VS HACCP PLAN

3-502.11 Variance Requirement

A FOOD ESTABLISHMENT shall obtain a VARIANCE

from the REGULATORY AUTHORITY before:

(A) Smoking FOOD as a method of FOOD preservation

rather than as a method of flavor enhancement

Hold?

Cold?

Liquid?

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.11 Variance Requirement

A FOOD ESTABLISHMENT shall obtain a VARIANCE

from the REGULATORY AUTHORITY before:

(B) Curing FOOD

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.11 Variance Requirement

A FOOD ESTABLISHMENT shall obtain a VARIANCE

from the REGULATORY AUTHORITY before:

(C) Using FOOD ADDITIVES or adding components such

as vinegar:

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

(1) As a method of FOOD preservation rather

than as a method of flavor enhancement, or

(1) To render a FOOD so that it is not

TIME/TEMPERATURE CONTROL OF

SAFETY FOOD

3-502.11 Variance Requirement (continued)

(D) Packaging TIME/TEMPERATURE CONTROL FOR

SAFETY FOOD using a REDUCED OXYGEN

PACKAGING method except where the growth of and toxin

formation by Clostridium botulinum and the growth of Listeria

monocytogenes are controlled

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

Reduced Oxygen Packaging (ROP) includes

methods that may be referred to as:

• modified atmosphere (MAP)

• vacuum packaging

• controlled atmosphere (CAP)

• cook chill

• sous vide (cooking under vacuum)

Ask during inspections if they vacuum pack &

review menu for anything new

Look for vacuum packaged food in the coolers

or freezers – ask if they packaged it themselves

Look for machines/equipment (in prep area)

Finding ROP in Food Establishments

3-502.11 Variance Requirement (continued)

(E) Operating a MOLLUSCAN SHELLFISH (oysters, clams,

mussels and scallops) life-support system display tank used to store or

display shellfish that are offered for human consumption

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.11 Variance Requirement (continued)

(F) Custom processing animals that are for personal use

(i.e. dressing a deer) as FOOD and not for sale or service

in a FOOD ESTABLISHMENT

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.11 Variance Requirement (continued)

(G) Preparing FOOD by another method that is

determined by the REGULATORY AUTHORITY to

require a VARIANCE

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.11 Variance Requirement (continued)

(H) Sprouting seeds or beans.

# 29 SPECIALIZED PROCESSING METHODS (CONFORMANCE WITH APPROVED PROCEDURES)

3-502.12 Reduced Oxygen Packaging Without a

Variance, Criteria

(A) A FOOD ESTABLISHMENT that PACKAGES

TIME/TEMPERATURE CONTROL FOR SAFETY

FOOD using a REDUCED OXYGEN PACKAGING method

shall control the growth and toxin formation of Clostridium

botulinum and the growth of Listeria monocytogenes.

CLOSTRIDIUM BOTULINUM AND LISTERIA

MONOCYTOGENES CONTROLS

Clostridium botulinum Listeria monocytogenes

3-502.12 Reduced Oxygen Packaging Without a

Variance, Criteria (continued)

(B) A FOOD ESTABLISHMENT that PACKAGES

TIME/TEMPERATURE CONTROL FOR SAFETY

FOOD using a REDUCED OXYGEN PACKAGING

method shall implement a HACCP PLAN

CLOSTRIDIUM BOTULINUM AND LISTERIA

MONOCYTOGENES CONTROLS

FISH

3-502.12 Reduced Oxygen Packaging Without a Variance, Criteria (continued) (C) Except for FISH that is frozen before, during, and after PACKAGING, a FOOD ESTABLISHMENT may not PACKAGE FISH using a REDUCED OXYGEN PACKAGING method.

Note: Fish must be removed

from ROP before thawing

COOK-CHILL OR SOUS VIDE

3-502.12 Reduced Oxygen Packaging Without a

Variance, Criteria (continued)

(D) A FOOD ESTABLISHMENT that PACKAGES

TIME/TEMPERATURE CONTROL FOR SAFETY

FOOD using a cook-chill or sous vide process shall:

(1) Provide a HACCP PLAN

(2) Ensure the FOOD is handled, cooked and cooled

properly

(3) Maintain records

(4) Implement written operational procedures and a

training program

CHEESE

3-502.12 Reduced Oxygen Packaging Without a

Variance, Criteria (continued)

(E) A FOOD ESTABLISHMENT that PACKAGES cheese using a REDUCED

OXYGEN PACKAGING method shall:

(1) Limit the cheeses PACKAGED to those that are commercially manufactured

in a FOOD PROCESSING PLANT with no ingredients added in the FOOD

ESTABLISHMENT

(2) Have a HACCP PLAN

(3) Labels the PACKAGE (use/sell by 30 days)

(4) Discards if not sold within 30 calendar days

HACCP PLAN

NO HACCP PLAN – ROP IF…

3-502.12 Reduced Oxygen Packaging Without a

Variance, Criteria (continued)

(F) A HACCP Plan is not required when a FOOD ESTABLISHMENT uses a

REDUCED OXYGEN PACKAGING method to PACKAGE

TIME/TEMPERATURE CONTROL FOR SAFETY FOOD that is always:

(1) Labeled with the production time and date

(2) Held at 41°F or less during refrigerated storage

(3) Removed from its PACKAGE in the FOOD ESTABLISHMENT within 48 hours

after PACKAGING.

WHEN A HACCP PLAN IS REQUIRED

8-201.13

(A) Before engaging in an activity that requires a HACCP

PLAN, a PERMIT applicant or PERMIT HOLDER shall

submit to the REGULATORY AUTHORITY for

approval a properly prepared HACCP PLAN.

(B) Before engaging in REDUCED OXYGEN

PACKAGING without a VARIANCE, a PERMIT

applicant or PERMIT HOLDER shall submit a properly

prepared HACCP PLAN to the REGULATORY

AUTHORITY.

CONTENTS OF A HACCP PLAN

8-201.14

For a FOOD ESTABLISHMENT that is required to have a

HACCP PLAN, the plan and specifications shall indicate:

(A) A categorization of the types of TIME/TEMPERATURE

CONTROL FOR SAFETY FOODS that are specified in

the menu such as soups and sauces, salads, and bulk, solid

FOODS such as MEAT roasts, or of other FOODS that

are specified by the REGULATORY AUTHORITY

CONTENTS OF A HACCP PLAN

8-201.14 (Continued)

(B) A flow diagram by specific FOOD or category type

identifying CRITICAL CONTROL POINTS and

providing information on the following:

(1) Ingredients, materials, and EQUIPMENT used in the

preparation of that FOOD, and

(2) Formulations or recipes that delineate methods and

procedural control measures that address the FOOD

safety concerns involved

CONTENTS OF A HACCP PLAN

8-201.14 (Continued)

(C) FOOD EMPLOYEE and supervisory training plan that

addresses the FOOD safety issues of concern

(E) Additional scientific data or other information, as

required by the REGULATORY AUTHORITY,

supporting the determination that FOOD safety is not

compromised by the proposal.

CONTENTS OF A HACCP PLAN

8-201.14 (Continued)

(D) A statement of standard operating procedures for the plan under

consideration including clearly identifying:

(1) Each CRITICAL CONTROL POINT

(2) The CRITICAL LIMITS for each CRITICAL CONTROL POINT

(3) The method and frequency for monitoring and controlling each

CRITICAL CONTROL POINT by the FOOD EMPLOYEE designated

by the PERSON IN CHARGE

(4) The method and frequency for the PERSON IN CHARGE to routinely

verify that the FOOD EMPLOYEE is following standard operating

procedures and monitoring CRITICAL CONTROL POINTS

(5) Action to be taken by the PERSON IN CHARGE if the CRITICAL

LIMITS for each CRITICAL CONTROL POINT are not met

(6) Records to be maintained by the PERSON IN CHARGE to

demonstrate that the HACCP PLAN is properly operated and managed

https://www.fda.gov/Food/GuidanceRegulation/HACCP/ucm2006801.htm

IMPLEMENTATION AND MAINTENANCE OF

THE HACCP PLAN

• Assemble the HACCP Team

• Describe the food and it’s distribution

• Describe the intended use and consumers of the food

• Develop a flow diagram which describes the process

• Verify the flow diagram

EXAMPLES OF COMMON PREREQUISITE

PROGRAMS Facilities

Supplier Control

Specifications

Production Equipment

Cleaning and Sanitation

Personal Hygiene

Training

Chemical Control

Receiving, Storage and Shipping

Traceability and Recall

Pest Control

The hazard analysis consists of asking a series of questions which are

appropriate to the process under consideration. The purpose of the questions is

to assist in identifying potential hazards.

EXAMPLES OF QUESTIONS TO BE CONSIDERED

WHEN CONDUCTING A HAZARD ANALYSIS

A. Ingredients

B. Intrinsic Factors e.g. pH, type of acidulants, fermentable

carbohydrate, water activity, preservatives

C. Procedures used for processing

D. Microbial content of the food

E. Facility design

F. Equipment design and use

G. Packaging

H. Sanitation

I. Employee health, hygiene and

education

J. Conditions of storage

between packaging and the

end user

K. Intended use

L. Intended consumer

1.Does the food contain any sensitive ingredients that may present microbiological hazards (e.g., Salmonella, Staphylococcus aureus); chemical hazards (e.g., aflatoxin, antibiotic or pesticide residues); or physical hazards (stones, glass, metal)?

2.Are potable water, ice and steam used in formulating or in handling the food?

3.What are the sources (e.g., geographical region, specific supplier)

CCP DECISION TREE (FDA SAMPLE)

A.Verification procedures may include:

1. Verification schedules

2. Review of the HACCP plan

3. Review flow diagram

4. Review of the HACCP system

5. Review of CCP monitoring records

6. Validation of critical limits

7. Validation of HACCP plan (on-site)

8. Review of modifications

9. Sampling and testing CCPs

EXAMPLES OF VERIFICATION ACTIVITIES

B. Verification should be conducted:

1. Routinely, or on an unannounced basis, to assure CCPs

are under control.

2. When there are emerging concerns about the safety of

the product.

3. When foods have been implicated as a vehicle of FBI.

4. To confirm that changes have been implemented

correctly after a HACCP plan has been modified.

5. To assess whether a HACCP plan should be modified

due to a change in the process, equipment, ingredients,

etc.

EXAMPLES OF VERIFICATION ACTIVITIES

C. Verification reports may include information on the presence and

adequacy of.

1. The HACCP plan and the person(s) responsible for

administering and updating the HACCP plan

2. The records associated with CCP monitoring

3. Direct recording of monitoring data of the CCP while in

operation

4. Certification that monitoring equipment is properly calibrated

and in working order

5. Corrective actions for deviations

6. Sampling and testing methods used to verify that CCPs are

under control

7. Modifications to the HACCP plan

8. Training and knowledge of individuals responsible for

monitoring CCPs

9. Validation activities

EXAMPLES OF VERIFICATION ACTIVITIES

A. Ingredients for which critical limits have been established

B. Processing, storage and distribution records

C. Deviation and corrective action records

D. Employee training records that are pertinent to CCPs and

the HACCP plan

E. Documentation of the adequacy of the HACCP plan

from a knowledgeable HACCP expert

EXAMPLES OF HACCP RECORDS

Scan in application

1. http://www.wakegov.com/food/healthinspections/resources/Pages/HACCP.aspx

2. http://www.vdacs.virginia.gov/services-forms.shtml

3. https://www.austintexas.gov/sites/.../food_pool_variance-HACCP_appl_1-15-15.pdf

4. https://www.maricopa.gov/DocumentCenter/Home/View/5805

5. www.houstontx.gov/health/Food/Variance%20or%20HACCP.doc

6. https://www.tn.gov/assets/.../GUIDANCE_FOR_REQUESTING_A_VARIANCE.pdf

7. Variance Application Form (pdf)

8. www.orangecountync.gov/departments/health/VARIANCE_APPLICATION.pdf

9. https://www.env.nm.gov/...Program/.../VarianceApplication_04082016FinalRev01.1.pdf

10.www.tetonwyo.org/ph/docs/TCEH-HACCP%20Packet.pdf

SAMPLE REQUEST VARIANCE/HACCP