Most of the US food safety programs are risk based to ensure that the public is protected from health risks of unsafe foods. Risk assessment is used in estimating the magnitude of the problem faced, and in determining the appropriate risk management response. This is true for both the inspection process as well as insurance recommendations.
Hazard Analysis Critical Control Point (HACCP)
The Hazard Analysis and Critical Control Point (HACCP) system is a logical, scientific approach to controlling hazards in meat, meat products, poultry and poultry products . HACCP is concerned with food safety. It does not deal directly with facilities, equipment or employees. HACCP is a preventive approach for assuring that safe food products are produced.
Introduction to HACCP
The application of HACCP is based on technical and scientific principles that assure food safety. An ideal application would include all processes from the farm to the table. The principle of HACCP can be applied to production, meat slaughter and processing, shipping and distribution, food service and in home preparation.
Prevention of hazards cannot be accomplished by end product inspection. The most important aspect of HACCP is that it is a preventative system rather than an inspection system of controlling food safety hazards. Controlling the production process with HACCP offers the best approach for many processors.
HACCP is a systematic preventative system that uses common sense application of scientific principles. The application of HACCP is systematic because a plan is structured based on potential hazards identified and preventive measures implemented. The process is common sense in that each processor understands their own operation and is best able to assess how to control the process to ensure food safety. HACCP is also science-based, as the controls that are placed in the process should be based on scientific information.
The HACCP system has two major components. The HA of HACCP represents the logic in the hazard analysis, and is identified with the where and the how of the hazards. The CCP of HACCP represents the critical control point that provide the control of the process and the proof of control.
The end objective of HACCP is to make the product as safe as possible and to be able to prove that the product was processed as safely as possible. This does not mean that HACCP provides 100% assurance of food safety to consumers, but it does mean that a meat processing company is doing the best job possible for safe food production. The assurance of safety comes from the process of identifying the hazards, establishing controls for the identified hazards, monitoring the controls, and periodically verifying that the system works.
The USDA FSIS requires only two tests as part of a HACCP plan to ensure food safety. The first is a generic ecoli test for slaughtered carcasses. The second is a food contact surface test for ready to eat products. All other tests are required by the establishment to ensure the product is safe. All other tests support the establishment’s HACCP plan and are required by plant managers.
Section 310.25 discusses post mortem ecoli testing for livestock and Section 381.94 addresses testing for poultry.
New York no longer provides HACCP assistance at the Geneva Food Venture Center. As the position in New York is vacant, those needing assistance are advised to contact:
Dr. Catherine Nettles Cutter, Ph.D. (Coordinator)
Associate Professor and Food Safety Extension Specialist-Muscle Foods,
Department of Food Science, Pennsylvania State University,
433 Food Science Building
University Park, PA 16802
Phone: (814) 865-8862
Fax: (814) 863-6132
USDA State HACCP Contacts and Coordinators can be found at:http://www.fsis.usda.gov/Contact_Us/State_HACCP_Contacts_&_Coordinators/
HACCP focuses on three types of hazards: biological hazards, chemical hazards and physical hazards. Biological hazards are the type of hazards that receive the most attention in the HACCP system and which also present the greatest risk of severity and occurrence. Biological hazards include hazards from pathogens such as bacterial, viruses, yeast, and molds. Bacteria that receive the greatest attention in the United States include E. Coli 0157:H7, Listeria Monocytogenes, Salmonella, Staphylococus auerus and Campylobacter. Chemical hazards in meat products could result from the misuse of antibiotics in production, contamination with sanitizers or cleaning agents, or environmental contamination from hydraulic fluids. Physical hazards are probably the most recognized by consumers as they usually find this hazard. Glass, metal and plastic are physical hazards that can occur in meat products.
The seven principles of HACCP are:
1. Conduct a Hazard Analysis
2. Identify Critical Control Point (CCP)
3. Establish Critical Limits for CCP
4. Establish Monitoring Procedures
5. Establish Corrective Actions
6. Establish Recordkeeping Procedures
7. Establish Verification Procedures
More information on HACCP is available at: http://www.extension.org/pages/Food_Safety_%2F_HACCP
Standard Operating Procedures (SOP)
Standard Operating Procedures (SOPs) are descriptions of particular tasks undertaken in a food processing operation. A specific SOP should address the following: the purpose and frequency of doing a task, which individual will do the task, a description of the procedure to be performed including all the steps involved, and the corrective actions to be taken if the task is performed incorrectly. USDA mandated Sanitation Standard Operating Procedures (SSOPs) for Meat and Poultry Operations effective January 27, 1997. The rule calls on plant management to develop SSOPs that address daily routine sanitary procedures, before and during operations to prevent direct product contamination or adulteration. Procedures should be specific for each plant and can be as detailed as the plant wants to make them.
Good Manufacturing Practices (GMP)
Good manufacturing practices (GMP) refers to a set of procedures and measures taken by a plant to ensure that the food is not adulterated: In a plant environment, all SOPs should take GMPs into account when being written and as such, SOP’s and GMPs are used in conjunction with each other. FDA mandates GMPs but not SOPs. NYSDAM also has its own set of rules and regulations identifying GMP’s as they relate to Human Foods (1NYCRR, PART 261).
Any operations which manufactures, processes, packs, labels or holds human food is obligated to follow NYSDAM’s GMPs. On farm retail establishments that hold food are required to:
- Keep the grounds about a food plant free from conditions that may result in the contamination of food. This requires proper storage of equipment, litter, waste, refuse, and cutting of weeds and grass within the immediate vicinity of the building or plant. Dusty roads, yards and lost may also constitute a source of contamination as would excessively muddy or inadequately drained areas.
- Design and construct plant buildings and structures to be suitable in size, to facilitate maintenance and sanitary operation and include for proper storage of equipment and supplies.
- Clean and maintain equipment to preclude adulteration of foods.
- Equip plants with sanitary facilities and accommodations including water supply, sewage disposal, plumbing, hand washing facilities, toilets, and rubbish and offal disposal.
Sanitary Operations include planning for general maintenance, animal and vermin control, sanitation of equipment and utensils, and storage and handling of equipment and utensils.
End Product Testing
Prior to the de-regulation of product testing by the Clinton Administration, it was the responsibility of Federal Inspectors to test product for market readiness. The transition to a HACCP based system put the burden of inspection on the plants themselves. It was strongly debated if this would encourage more or less end-product testing. Basing their reputation and livelihoods on product quality, product testing largely continued and expanded as the increased number of recalls would indicate. Eventually corrections and adjustments were made within plants and recall numbers declined in subsequent years.
Bacteria have a specific range of environmental factors in which they can grow and survive. Environmental tests performed include measuring temperature, oxygen levels, water activity (or the water available for microbial growth), acidity, nutrient availability, bacterial levels already present and the presence of competitive microbes.
Today, plants test products for various microbial pathogens such as clostridium botulinum, staphylococcus aureus, listeria monocytogenes, Escherichia coli 0157-H7, and salmonella species. Foreign materials such as spinal cords, bone fragments or other items may also be screened for.