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