HACCP principles and applications It is regulatory not voluntary. FDA -Title 21 CFR 123 Fish and Fishery Products Two parts -8 Sanitation conditions HACCP principles HACCP IS a food safety management tool & is designed to minimize the risk of foodsafety hazards: biological, chemical and physical ,preventive NOT reactive.,maximize product and consumer safety. Hazards in HACCP : Condition or contaminant in food that can cause illness or injury. Does NOT refer to undesirables such as: Insects ,Bones,Hair
,Filth,Spoilage
Economic Fraud,Violations of regulatory food standards not directly related to safety.
Introduction to Food Safety Hazards Biological- Bacteria ,Viruses, Parasites Chemical- Allergens,Pesticides,Sanitizers,Antibiotics,Additives,Naturally occurring chem. Physical- Glass,Plastic,Metal Biological Hazards: Pathogenic Bacteria Most spoiled foods DO NOT present a health risk Not all food APPEARING normal is safe to eat Need to control microorganism GROWTH (infective doses) – Differ with different organisms. Can be 10, can be 1000’s. Food infection - live pathogens are swallowed that grow in the body (dose)(e.g., Listeria, Salmonella, Vibrio) Food Intoxication - pre-formed toxins are swallowed (e.g., botulism and staphtoxins) Bacteria Bacteria (other than viruses) need: Food,Water,Proper temperature,Air, no air, minimal air,Proper acidity,Time to grow Pathogenic Bacteria- Bacillus cereus,Campylobacter jejuni Clostridium perfringens ,Clostridium botulinum (Type E) Pathogenic E. coli (E. coli O157H:7),Listeria monocytogenes Salmonella spp. (S. typhimurium, S. enteriditis),Shigella spp. (S. dysinteriae) Staphylococcus aureus ,Vibrio parahaemolyticus Vibrio vulnificus ,Yersinia enterocolitica
Parasites- Roundworm, Tapeworm, Anisakis simplex.In seafood, parasitic worms in fish consumed RAW are a food safety hazard, otherwise considered filth .Controlled by freezing (-4F @ 7 days; 31F @ 15 h; -31F until solid, then store ≤ –4F @ 24 h) Controlled by cooking Viruses –Need suitable host in which to grow Do not require food, air, water to survive Spread via poor hygiene - fecal/oral Infect living cells, species specific, reproduce inside host cell Do not cause spoilage Survive in human intestines, water or food for months Heat resistant Examples: Hepatitis A, Norovirus – Eating raw, steamed clams, oyster products, sewage, and unapproved waters Chemical Hazards Naturally Occurring Scombrotoxin/Histamine,Ciguatera toxin (tropical/subtropical)toxic algae (barracuda, amberjack, horseeye jack, king mackerel, groupers and snappers Shellfish toxins/Marine biotoxins- toxic algae Paralytic shellfish poisoning (PSP) Diarrhetic shellfish poisoning (DSP) Neurotoxic shellfish poisoning (NSP) Amnesic shellfish poisoning (ASP)/Domoic Acid •
Intentionally Added •
Food Additives Direct (allowable limits under GMPs)
Preservatives (e.g., nitrites & sulfiting agents) Nutritional additives (e.g., niacin) Color additives (e.g., FD&C Yellow #5) •
Unintentional Additives Agricultural chemicals (e.g., pesticides, fungicides, antibiotics/drug residues and growth hormones)
herbicides,
fertilizers,
Cross-contaminating food allergens from inadequately cleaned shared processing equipment Physical Hazards Any potentially harmful extraneous matter not normally found in food Glass,Wood,Stones,Metal,Plastic
Haccp is not a stand alone program GMP’s vs. SSOP’s GMP’s define the measures used to keep food sanitary and defines general hygienemeasures. (CFR TITLE 21, PART 110),Proper practices for safe and sanitary handling of foods.Applicable to any food industry.Basis for sanitation part of the Seafood Regulation.SSOP’s or SCP’s describes procedures used to accomplish sanitary food handling and general hygiene practices..Monitoring and corrective action records required
Differentiating HACCP and Sanitation Control Procedures
Hazard
Control
Type of Control
Control Program
Histamine
Time & temperature of scrombroid fish
Product specific
CCP
Pathogen Survival
Time & temperature for smoking fish
Processing step
CCP
Contamination with pathogens
Wash hands before touching product
Personnel
Sanitation
Contamination with pathogens
Limit employee movement between raw and cooked areas
Personnel
Sanitation
Contamination with pathogens
Clean and sanitize food contact surfaces
Plant environment
Sanitation
Chemical contamination
Use only food-grade grease
Plant environment
Sanitation 26
Those issues that can be part of the SSOP system do NOT have to part of the HACCP Plan. All safety issues that are associated with the SPECIES or PROCESS must be in the HACCP PLAN 8 Key Conditions of Sanitation 1. Safety of water (source and in-plant; includes ice). 2. Condition and cleanliness of food-contact surfaces (gloves, garments etc). 3. Prevention of cross-contamination (employee practices/handling; separation of raw and “cooked” product; plant design – movement of product and people; handwashing) 4. Maintenance of hand-washing, hand- sanitizing and toilet facilities. 5. Protection from adulterants. 6. Labeling, storage and proper use of toxic compounds. 7. Employee health conditions. 8. Exclusion of pests.
Preliminary Steps: HACCP = 7 basic principles Preliminary steps are needed for effective HACCP design, implementation and management of HACCP. Steps 1-5 of the Hazards
Receiving Products (Includes seafood, dry ingredients, packaging, etc.)
Processing Steps 1, 2, 3….
Flow Diagram:
Packaging Storage Distribution 30
7 HACCP Principles 1. Conduct hazard analysis and identify prevention or control measures 2. Identify critical control points (CCP) 3. Determine critical limits 4. Monitor each critical control point 5. Establish corrective action with a critical limit deviation 6. Verification of the HACCP plan
7. Recordkeeping for critical control points, corrective action and verification STEP 1: Conduct Hazard Analysis. Identify Prevention or Control Measures •
What are the potential biological, chemical and physical hazards at each processing step that must be prevented, eliminated or reduced to an acceptable level?
•
Can the hazard be controlled, introduced or enhanced at the specific processing step?
•
Is the hazard “reasonably likely to occur,” or significant and present a risk to the consumer?
Step 2: Identify critical control points (CCP) •
A point, step or procedure at which control can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable levels
•
That point in the process that if you lose control a food safety hazard will exist.
•
A hazard in one step may be controlled in another. How?
•
Identify only those CCP’s needed to do the job – not too many. Why?
•
One CCP may control more then one hazard ie.temperature to control bacterial growth and histamine formation
•
A hazard may require control at >1 step ie. fish patty thickness and cook step; brining and smoking
Step 3: Identify Critical Limits (CL) •
Critical limits must be set for EVERY CCP
•
Critical limit: A maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate, or reduce to an acceptable level the occurrence of a food safety hazard
Step 4: Monitoring each (CCP) Four parts: •
What will be monitored?
•
How will the CL of CCP be monitored
•
Who will monitor the CL of the CCP?
•
How often (frequency) will the CL of the CCP be monitored?
Step 5: Establish corrective action Corrective action: procedures at each CCP to be followed when a deviation occurs •
Correct and eliminate the cause of the deviation and restore process control.Identify the product that was produce during the process deviation and determine its disposition.
Step 6: Verification/Validation of HACCP Plan Verification: a check on your HACCP plan and system to make sure it is working properly and followed. Activities, other then monitoring, that determine the validity and verify or prove that the system is operating according to plan.
of
the
HACCP
plan
Validation: Involves scientific evaluation to be sure that the approach is sound before the HACCP plan is implemented. Elements of Verification •
CCP Verification Activities Calibration of monitoring devices Review of calibration records CCP record review
Monitoring Corrective Action Targeted sampling and testing
•
HACCP System Verification Audits – observations/review Microbiological end product testing
•
Regulatory Inspections/Audits
Step 7: Recordkeeping PRELIMINARY STEPS: SSOP monitoring and correction HACCP SYSTEM RECORDS HACCP plan and support documentation CCP monitoring molluscan shellfish)
(molluscan
shellstock;
shucked
Corrective Action Verification/Validation (Importer written verification procedures, importer product specs, importer affirmative step[s]) ALL FORMS REQUIRE SPECIFIC INFORMATION Title, firm name/location, product information, actual observations/ measurements, critical limits, time/date, initials of operator, reviewer signature and date. All HACCP and SCP records should include:: •
Firm name and location
•
Time and date of monitoring observation
•
Operator’s signature or initials
•
Product information (product type, package size,processing line and product code where applicable) •
Actual observations or measurement
•
Critical limits
•
Reviewer’s signature or initials, and date of review (verification)
•
(Form title – not required, but helpful to have)
Record Retention •
One (1) year for refrigerated or perishable products
•
Two (2) years for frozen or shelf stable products
Off site can be transferred but returned for official review upon demand.
