Hazard Analysis Critical Control Points Pre-Harvest Considerations
BQA and HACCP • Should you know about HACCP • Understanding HACCP … • Working with HACCP … • Beef industry’s QACMP ... • (Quality Assurance Critical Management Points)
Hazard Analysis, Critical Control Points (HACCP) • It is a system developed for space flight to prevent problems from happening. • If you can figure out what might go wrong, you can work toward finding ways to prevent the problem. • It included check points along the process. These allow you to know if process is working properly before you get to a finished product. • By definition, HACCP is a food pathogen reduction program ... presently not possible in beef production. • However working with HACCP now will provide us valuable experience with the procedures.
Why should you interested in HACCP … because it may be headed to your operation .. especially FEEDLOTS.
Why HACCP …this 20+ year old system has been sold to the major US trading partners as the standard for food processing (production?) safety.
The selling of HACCP …HACCP, a system, targets 3 items (BCP) defects & is aimed at the avoidance not removal of defects.This has lead to selling the“Farm to Table” approach.
Does “Farm to Table” HACCP Make Sense? …Bacterial ……..? Chemical ……..?Physical ……..?
Will or Can “Farm to Table” HACCP Work? …USDA-FSIS says “it is going to” (Consumers concern over food safety is driving regulations … Presently, HACCP is the best food safety system that has surfaced in the previous 20 years that may be workable) HACCP experts (NFP,etc) “classic HACCP” will not, modifications will make it usefulfor some physical defects, most chemical defects, but limited value for many bacterial defects.
Different HACCPs HACCP (Critical Control Points) Safety Quality Factors (Quality Control Points) Operation Specifications Related to Company & Customer Specs Regulatory Requirements (Regulatory Control Points) Hygiene GMP Adulteration(safe/label)
It no longer matters -- how we deal with it will determine if we survive.
HACCP (Hazard Analysis,Critical Control Points) • A Process Control System: • preventing (finding&monitoring) problems &/or mistakes. • If you can figure out what might go wrong, you can work toward finding ways to prevent the problem. • It included check points along the process… allowing you to know if process is working properly. • By USDA definition, HACCP is a(pathogen reduction program) ... • presently not possible for E.coli O157:H7 & Salmonella sp in beef • QACMP makes no promises to control food born pathogens • QACMP will allow us to learn to work with HACCP. • QACMP is compatible with Cost Effective Management. • … Validate / Justify <==> Monitor / Verify
“Build on what you know” … Road Map to BQA => QACMP(QACMP… Implemented after BQA-GMPs) • Cattlemen, Employees, Veterinarians, Nutritionist, Suppliers & Other Specialist must take a close look at what could go wrong. • Build validated practices that allow checking & verifying. • Design all of the everyday working techniques to avoid having anything go wrong.
What it takes to makeHACCP work • Must make the commitment • Must let everyone get involved • Must be able to document all production steps • There are critical points in BQA • Must be able to monitor … simple / validate
Where Do You Start • Establish GMPs appropriate to operation. • Focus on potential for B-C-P defects. • Develop HACCP plan & HACCP training. • The HACCP startup program will be evaluated by management, employees, & consulting professionals. • Outline (flow chart) steps of production & evaluate methods of verification. • Incorporate into mgmt. objectives & into everyone’s job .. Allow it to grow.
Secret to HACCP THE LOOP Justify Verify Monitor
HACCP: Five Preliminary Steps • Bring together your HACCP resources … assemble the HACCP team. • Describe the product & method of Distribution. • Identify the intended use & consumers of the product. • Develop a process flow diagram .. • Verify the diagram • Meet the requirements for Sanitation SOPs & Good Management Practices (GMPs)
Seven Specific HACCP Steps • Identify potential hazards: B-C-P • Identify critical control points • Establish critical limits for CCPs • Establish CCP monitor procedure • Establish corrective actions • Establish record keeping procedure • Establish verification procedures
Conducting a Hazard Analysis • Assure SSOP and GMPs are in place • Review product production & use • Evaluate all ingredients • Evaluate BCP potential for each step • Could BCP reach product or magnify • Could process cause BCP of product • Are hazards addressed by SSOPs &/or GMPs • Describe and identify each BCP • Assess significance using Sci/Tech info.
Conducting a Hazard AnalysisContinued • Observe the actual operating practices • Be sure it is the usual process or practice • Evaluate ingredients and product for possible cross contamination • Review past BCP contamination incidents • Evaluate the likelihood & severity of occurrence of each BCP hazard • Can preventive measures be built into the process?
Identify CCPs • "A point, step or procedure at which control can be applied and as a result a hazard can be prevented, eliminated or reduced to acceptable level." • Criteria supported by research. • Criteria specific, quantifiable, provide Y/N • Technique available at reasonable cost • Monitoring is continuous & auto-adjustable • Favorable history of control … • preventing or eliminating a potential BCP hazard.
Steps to Identify CCPs • Q1: Do preventive measures exist for BCP? • if yes go to Q2, if no, is required of safety • if no = not CCP, (if yes modify process) . • Q2: Does this step eliminate/reduce the likely occurrence of BCP hazard to an acceptable level? • if yes = CCP if no go to Q3 . • Q3: Could unacceptable BCP contamination occur? • if yes go to Q4 if no = not CCP • (go to the next step in production). • Q4: Will subsequent step eliminate BCP hazard? • if yes = not CCP if no = CCP • (go to the next step in production)
Establish CCP Critical Limits • "The maximum or minimum value that must be controlled for each BCP hazard at each CCP • Some CLs are regulated by USDA/FDA/EPA…(OSHA) • Some CLs are important to the operation • Some CLs may be differ for different situations • Document/file the CL for each BCP hazard
Establish CCP Monitoring Procedures • Who - What - When - How • Planned sequence of observations/measurement • Clearly identify people responsible for monitoring • Train monitoring people: Why, How, Correction • Document & sign all records • Record on CCP Monitoring Summary Review Sheet
Establish Corrective Procedures • Training to know corrective procedures@CCPs. • How is the ingredient or product handled if BCP contamination occurs at a CCP? • Correcting the cause of "non-compliance" to prevent recurrence at a CCP. • Demonstrating the CCP is again under control. • Document corrective actions. • Record corrective procedures on the Summary Review Sheet.
Establish Record Keeping Procedures • Review current records and determine which ones adequately address CCPs • Develop records/forms for identified CCPs • Develop records/forms for corrective actions • ID & train people to work with records • Documents should be dated and signed • List records for CCP on the Summary Review Sheet
Establish Verification Procedures • Verification must be ongoing • AND is in addition to monitoring activities. • Verification is a double check • How can the CCP control/monitoring be verified? • How often should CCP control monitoring be verified? • Document verification procedures, date & sign • List verifications on Summary Review Sheet
Validate the HACCP Plan • "Validation is the scientific & technical basis for determining the CCP and CL are adequate to control BCP hazard" • Validation should include a third party review • Validation should be done regularly (yearly?) • Reassess potential new BCP hazards • Evaluate all new ingredients, suppliers, production procedures, equipment, and distribution systems
Remember the Basics • BQA will help control the little mistakes that decrease animal performance. • It’s the little mistakes that cost us consumer confidence… they buy what they trust. • There NO Most Valuable Players • BQA is everyone's job.
In the world of food => a force driving consumers purchases • WHAT • THEY • TRUST
... get involved As Will Rogers put it ... "The world is run by the people who show up"
Program Acknowledgments & Funding* • Nebraska Cattlemen* • NCFB Task Force • University of Nebraska Cooperative Extension* • Nebraska Veterinary Medical Association* • National Cattlemen’s Beef Association • Nebraska Beef Council* • USDA - CSREES - EFSQ - Grants* • (Nebraska 96-EFSQ-1-4178 & 98-EFSQ-1-4178)