HACCP Plan Implementation
And
Record
Management
HACCP Plan
Implementation
and
Record Management
Lynn Knipe,
Ph.D.
Extension
Meats Specialist
The Ohio State
University
2029 Fyffe
Road
Columbus, OH 43210
Funded by the
Presidents
Food Safety Initiative
Washington, DC
December, 1999
Table
of Contents
Introduction
.1
Fully-Cooked, Not Shelf
Stable Process
1
Figure 1. Partial Flow
Chart.
.2
Figure 2. HACCP Form B, CCP-1
...4
Figure 3. HACCP Form B, CCP-2
..5
Figure 4.
Monitoring Form
..6
Figure 5.
Monitoring Form, Pre-shipment Review
.10
Figure 6. HACCP Form C
.10
Raw Ground
Process
11
Figure 7. Flow Chart
...12
Figure 8. HACCP Form B
..13
Figure 9. Monitoring Form
14
Figure 10. HACCP
Form C
...16
Slaughter Process
...17
Figure 11. Flow Chart
.18
Figure 12. HACCP Form B
19
Figure 13.
Monitoring Form
.20
Appendix
.21
Fully Cooked Process, Cook and Chill Monitoring Form
...21
Corrective
Action Log
.22
Jerky Monitoring Form
..23
Temperature Regulations and Guidelines
24
Lot Identification of the Products That You
Produce
.25
Introduction
This manual accompanies the HACCP Plan
Implementation and Record Management video.
The total package is designed to provide you, the very small meat
processor, with some examples of Critical Control Points (CCPs), plus how to do
process verification, pre-shipment review, as well as how to manage the records
that will be generated from the CCPs.
Neither the manual or the video will discuss HACCP plan writing, and it
is assumed that you have written your plan before you read through the manual
or watch the video.
Not all CCPs shown in the video will apply to your
operation, and not all of every companys CCPs may be shown in the video. Only your hazard analysis can determine what
is needed for your HACCP plan.
Additional examples of monitoring forms for CCPs of other processes are
shown in the appendix of this manual.
Heat Treated, Fully Cooked Product
Critical Control Points
Through hazard analysis of its process (See Figure 1),
Schad Meats, Inc., has identified several processing steps as CCPs in their
HACCP plan, such as:
CCP-1
Cooking/Smoking
CCP-2 Listeria monocytogenes control during
packaging
Note in Figure 1, that not all of the flow chart would fit
onto one page, so only the portion of the flow chart that includes the CCPs is
shown. Schad Meats has additional CCPs
in its plan, that are not demonstrated in this video. Also, a CCP for cooling of cooked products is not demonstrated in
the video, but an example of a monitoring form for cooked product cooling is
presented in the appendix (p. 21).
Figure 1. Partial
Flow Chart for Fully Cooked, Not Shelf Stable Process
Critical Limits
The
critical limits for each CCP, in the video, seen in the second column of Form B
(Figure 2), include:
CCP-1
minimum of 148°F internal ham temperature
CCP-2
minimum of 160°F water temperature in
shrink tank
Monitoring Procedures
Monitoring procedures for CCP-1 include checking final,
internal product temperature in the geometric center of the largest ham, at the
end of the cooking cycle, using two thermometers: a digital recording thermometer and a continuous chart recording
probe (See Figure 2). Monitoring
procedures for CCP-2 involve monitoring the water temperature of the shrink
tank at the beginning and end of the packing process (See Figure 3).
To
monitor CCP-1, the smokehouse operator watches for the digital display on the
front of the house to reach 153°F. At this point the employee compares the digital reading to the
temperature indicated by the chart recorder on the side of the house, and
records the date, time, digital temperature and initials the record all on the
same recording chart paper (See Figure 4).
With
an internal temperature recording chart, it is also possible to monitor the
length of time that the internal temperature was at a selected
temperature. For example, Schad Meats
has set 148°F as its critical limit,
based on processing history, that the interior of each ham has been held at 140°F or higher for at least 30 minutes. This time-temperature combination satisfies
the Salmonella Lethality Performance Standards (FSIS Appendix A, Updated June
1999). Your
critical limit could possibly be the total time that the internal temperature
has exceed 140°F, etc., if you have a
working recording chart. If you do not
have a recording chart, an example of a monitoring form for recording cooking and
cooling temperatures can be found in the appendix (p. 21).
It
should also be noted that Schad Meats has set 153°F as its company target for
an endpoint cooking temperature to minimize deviations from their critical
limit.
For CCP-2, the designated employee checks the water
temperature of the shrink tank at the beginning and end of ham packaging, and
records both temperatures on
Thermal Processing
(CCP-1)
PROCESS/STEP
|
CRITICAL LIMIT
|
MONITORING PROCEDURES
|
BY WHOM
|
CORRECTIVE ACTIONS
|
|
Thermal
Processing (Cook/Smoke) CCP1
|
³148° inter-nal ham end- point temperature
|
Measure
temperature in the geometric center of the largest ham in the
lot/batch with two internal ham probes, one which records continuously on the
recording chart and a second one which gives a digital reading. The temperature shall not be less then 148°.
Note: Both readings are
recorded on the chart.
|
|
Meet
criteria of CFR 417.3. If the internal temperature recorder or digital
recorder is less than 148°, the supervisor or person
in charge will:
1.
Determine the reason for not meeting the CL.
2.
Subject the product to additional thermal processing until it exceeds
the required critical limits.
3.
Chill the product until such time as the product can be thermally
processed to meet the CL.
4.
Determine the disposition of product.
Prevent
the potentially adulterated product from entering into commerce.
Take
corrective actions to prevent re-occurrence of same root cause of deviation.
|
Figure 2.
HACCP Form B, Fully Cooked, Not Shelf-Stable Process
Product Surface Heat Treatment (CCP-2)
PROCESS
STEP
|
CRITICAL LIMIT
|
MONITORING PROCEDURES
|
BY WHOM
|
CORRECTIVE ACTIONS
|
|
Product
Surface Heat Treatment
(Packaging)
CCP-2
|
³170° water temperature in shrink tank at
beginning and end of packaging. instantaneously (time/temperature sufficient for inactivating surface
pathogens, based upon the Salmonella Performance Standards)
|
At
the start and finish of each lot/product, the digital read out of the
temperature of the shrink tank shall be recorded. The water temperature will exceed 160°.
|
|
Meet
criteria of CFR 417.3.
If
the digital recorder is less than 160°, the packaging clerk
shall suspend any further processing and notify the supervisor. If any product has been product surface
heat treated at less than 160°, then
1.
The product shall be inspected for vacuum-package integrity.
2.
If packages are intact, then the product will be resubmitted to the
surface heat treatment, until it meets the CL set forth here.
Disposition
of product will determined after all corrective actions have been taken and
plant determines if any food safety issues exist.
|
a label that is added to the recording
chart. While the critical limit is 160°F or higher, Schad
Meats has a company target for water temperature of 190°F.
Worth Noting
For smaller diameter cooked products, the critical limit
for the cooking step would likely need to be higher than 148°F,
and reflect inactivation temperatures of Listeria, such as 160°F,
due to the much shorter cooking times and lower oven temperatures.
Verification
Verification
is to a HACCP plan, what monitoring is to a CCP. The verification process can be summarized by three major
procedures:
1.
Review
of the monitoring record
2.
Review
of the person doing the monitoring, or checking the checker
3.
Verification
of instrumentation accuracy or equipment calibration
Additional
points of verification, which are not demonstrated in the video are:
HACCP
plan reassessment, which needs to be done at least annually, and process
validation. Reassessment involves
verifying that all significant hazards have a CCP, confirming that critical
limits are appropriate, and establishing that corrective actions are in place
and effective, to prevent future food safety hazards from occurring. Things that would trigger a HACCP system
reassessment include: new information concerning product safety, your own
monitoring results, product link to outbreak, your processing system being modified,
such as: changes in formulation, processing, distribution and consumer use.
Process validation involves assembling data
to demonstrate that your HACCP plan works (early, mock implementation of your
plan), product testing for pathogens, metal, etc., and scientific literature
that supports the safety of your HACCP plan.
In
the video, Linda Slover of Schad Meats, Inc., describes how she will review the
records made that morning. First, she
had a couple of rubber stamps made that allow her to stamp verification and
pre-shipment review forms onto her recording chart, wherever she needs, without
interfering with the chart recording.
Again, one stamp allows her to document that she has reviewed the record
itself. The other stamp is for the
pre-shipment review, which they do after all CCPs have been monitored. Stamping the recording chart allows for this
company to do all of the record keeping on one chart. The things that she looks for in her review are:
1)
that
they have met their critical limit,
2)
that
the date and time of the monitoring have been recorded
3)
and
that the employee who made the record have put their initials on the chart.
When
all of these points are found to be adequately completed during the original monitoring,
she signs off by putting her initials, the date and current time on the
reviewed by stamped form. This
reviewed record will be held until the product is packaged. Likewise, she demonstrates how she reviews
the second CCP (water temperature of the shrink tank) for the product that was
cooked the previous day and packaged today.
For that review, she goes to her review stamp on the recording chart and
signs off on the review by initialing and dating a sticker that is applied to
the product label.
In the video, the designated employee verifies the
accuracy of the two internal probes that were used in the original monitoring
by checking the internal temperature with a third, hand-held thermometer, and
she marks V on the recording chart (Figure 4), and records this third
temperature there, to make it obvious that this is a verification step. Thermometers used for heat-treated products,
are also typically calibrated by inserting them into boiling water, and
comparing thermometer temperature to boiling point temperature.
Also, as part of verification, when checking the checker,
this company marks the v (to denote verification), date, and verifiers
initials next to the checkers entry on the recording chart, if this
verification determines that the checker is completing the monitoring task
satisfactorily.
Pre-Shipment Review
The designated employee is able to do the pre-shipment
review, when all of the CCP monitoring records are completed, showing that all
of the critical control points have been met, and corrective actions taken if
necessary. When an employee determines
that the product is ready to release for shipment, the employee records his
initials, that days date, time and quantity of product (pieces, pounds, etc.)
in the lot.
Lot Identification
In
the video example, the lot of fully cooked hams is identified by the numbers
00002, which is the 21st day after packaging or the 2nd
day of the year 2000. January 2nd
is converted to a Julian date and the first two zeros represent the year
2000. This date is used to signal the
last date that this lot of product may be shipped from their plant. Additional information regarding lot
identification is available in the appendix (page 23).
The accuracy of your records is
as important as meeting your critical limits.
By having verifiable and accurate records, you are ensuring that you
have done everything possible to put the safest meat products on the market.
Figure 5. Monitoring Form for CCP-2, in Center of
Product Label
Cooked Ham
HACCP Form C
|
Process
Step/CCP
|
Verification
Activities
|
Recordkeeping
Activities
|
|
CCP-1
Cooking
|
Calibrate
thermometers and house chart recorder - weekly
Daily verification of monitoring
& corrective action records.
Check
the checker weekly.
Pre-shipment review each
batch.
Reassess
plan annually.
Product
sampling - monthly.
|
Monitoring &
Verification (meat temperatures) records
Corrective action records
Pre-shipment review
records
Calibration
records
Microbial sampling records
|
|
CCP-2
Packaging
|
Daily verification of
monitoring & corrective action records.
Check the checker each batch.
Pre-shipment
review each batch.
Reassess
plan annually.
Product
sampling - monthly.
|
Monitoring &
Verification (meat temperatures) records
Corrective action records
Pre-shipment review
records
Calibration
records
Microbial sampling records
|
Figure 6. Form C, Fully Cooked, Not Shelf Stable
Raw Ground Product
Critical Control
Points
Through hazard analysis, this very small establishment,
Carles Bratwurst, has identified the mixing step (after grinding ) as a
critical control point (CCP) for a biological hazard in its raw ground product HACCP
plan (See Figure 7). Checking product
temperature during cutting and packaging would also be a logical CCP for
biological hazards determined likely to occur in a raw, not ground processes.
Critical Limits
Their
critical limits for this CCP, seen in the second column of Form B (Figure 8):
50°F maximum, internal ground meat temperature
Monitoring Procedures
Monitoring procedures for CCP-1 (See Form B, Figure 8),
involve checking ground product temperature once per batch, at the time of
mixing.
The
designated employee, in this case, the person mixing the bratwurst, monitors
this CCP, which involves temperature measurement, using a dial thermometer and
recording the temperature on the monitoring form (Figure 9).
CCP Deviation and Corrective Actions
On
another day, the designated employee notices that the mixed bratwurst
temperature exceeded the 50°F critical limit, meaning
that a deviation from the critical limits of the HACCP plan had occurred. At this point, the employee refers to the Corrective
Action Log (appendix, p. 22) on the monitoring form (Figure 9, p. 14).
Bratwurst
Flow Chart
Receive
meat
Store fresh meat Store frozen meat
Thaw frozen meat
Weigh and grind meat
Mix bratwurst CCP-1
Package product
Store in freezer
Figure 7. Flow Chart for Raw Ground Process
Bratwurst
HACCP Form B
|
Process
Step/CCP
|
Critical Limits
|
Monitoring Procedures
|
Corrective
Action
|
What
|
How
|
Frequency
|
Who
|
|
CCP-1
Mix meat
|
Raw ground and mixed
bratwurst temperature not to exceed 50°F
|
Ground and mixed bratwurst
temperature
|
Dial thermometer
|
1 reading per batch
|
Mixer operator or
supervisor
|
Follow 417.3:
1. Room
temperature too
warm, because
of processing
room refrigeration
units both
defrosting at the
same time.
2. After problem
fixed, room
temperature
monitored by
recording chart
for 3 days.
3. Plan modified
to include
checking room
and meat
temperature prior
to processing.
4. Entire lot
moved to another
cooler or freezer,
until meat
temperature is less
than 40°F.
|
Figure 8. HACCP
Form B, Raw Ground Process
The Corrective Action Log requires
that the four points of 417.3 of the regulation (See Form B, Figure 8) be
described, such as:
1. Cause of the deviation identified and
eliminated: processing room was
found to be warmer than normal, because both refrigeration units were in the
defrost cycle at the same time.
2. CCP is under control after corrective
action taken, as room temperature is monitored for three days.
3. Measures to prevent recurrence of deviation:
include modifying plan to include checking room temperature and ground meat temperatures
before mixing.
4. Measures to prevent distribution of
adulterated product: Entire batch
moved to another cooler, until meat temperature 40°F or less.
Verification
According
to this plants HACCP plan, verification will occur once per day, and it will
be performed by a second employee.
Verification in this establishment involves both checking the checker
and checking the records for accuracy and completeness (Fig 10). Verification is documented in this operation
on the temperature monitoring form (Fig. 9).
Note that the second employee doing the verification, uses a red ink pen
for verification, which is understood to be used only by that person.
Thermometer Calibration
Calibration
of thermometers used in this HACCP plan must be done and documented at the
bottom of the temperature monitoring form.
For thermometers used in colder temperature ranges, ice water is used
for calibration.
Pre-Shipment Review
Prior to shipment, every lot of product produced under
HACCP must go through a pre-shipment review process. In this operation, designated employee
reviews all records related to this lot of bratwurst, to determine that all
records including monitoring, corrective actions, verification, etc. have been
properly completed, and that no deviations to critical limits have occurred.
Note that the person doing the pre-shipment review is the same person who did
the monitoring, which is not unusual for very small meat plants, with very few
employees.
Lot Identification
This lot of bratwurst is identified by the date of
processing, and sublotted by the order of processing (a,b,c, etc.), so the
first batch made on December 13, 1999 is coded as 91213a. Again, additional information on lot
identification is available in the appendix (p. 23).
Bratwurst
HACCP Form C
|
Process
Step/CCP
|
Verification Activities
|
Recordkeeping Activities
|
|
CCP-1
Mix bratwurst
|
Calibrate
thermometers daily
Daily
verification of monitoring & corrective action records.
Check the
checker weekly.
Pre-shipment
review - each batch.
Reassess
plan annually.
Product sampling - monthly.
|
Monitoring & Verification (meat
temperatures) records
Corrective action records
Pre-shipment review records
Calibration records |
