Issues and Concerns in HACCP Development and Implementation for Retail Food Operations.
The Hazard Analysis Critical Control Point (HACCP) system has become the most widely accepted program for controlling food safety. HACCP programs for manufactured foods have focused on eliminating or reducing foodborne hazards by controlling time, temperature, pH, and the water activity of the food, Control of personal hygiene, cleaning, and sanitizing are addressed through prerequisite good manufacturing practices (GMPs).
Implementation of HACCP systems in retail food establishments is a relatively new concept. Successful implementation may require that retail food establishments overcome a variety of barriers. Some examples of barriers are the unique aspects of retail food operations, which may require a HACCP program unlike those traditionally used by food processors; failure to make a HACCP program simple and user friendly; disagreement about the role f regulatory personnel in HACCP programs; the need for complex record keeping; languag or cultural variations; high employee turnover; and the need for product-specific versus rocess-specific HACCP methods. Ultimately, however, retail food establishments must effectively control those factors that contribute to foodborne illness, They can do so by combining the ability of HACCP to prevent time and temperature abuse with standard operating procedures that promote good personal hygiene, control of cross-contamination, and proper sanitation.
Through NEHAs long-standing and excellent relationship with NSF International, NEHA was granted permission by NSF International to share with the Journal's readership various papers that were presented November 16-18, 1998, at the "First NSF International Conference on Food Safety" in Albuquerque, New Mexico. This paper. "Issues and Concerns in HACCP Development and Implementation for Retail Food Operations," is one of them.
It is important to note that these papers were screened by an NSF International/Conference for Food Protection advisory committee prior to their presentation at the conference, but they have not been peer reviewed by NEHA's Journal program for technical accuracy.
Because these papers contain useful and interesting ideas and information that may be either delayed or lost if the papers were sent through the Journal's normal peer review process, NEHA has decided to publish them as presented, with only minor editorial modifications.
We hope you look forward to more of these papers in future issues of the Journal!
The hazard analysis critical control point (HACCP) food safety system was developed in the 1960s to ensure the safety of food used by America's astronauts. Since then, a growing number of food processors have used the HACCP system to ensure the safety and wholesomeness of the foods they produce for consumers everywhere.
HACCP programs for manufactured foods have focused on eliminating or reducing foodborne hazards by controlling time, temperature, pH, and the water activity of the food. Control of personal hygiene, cleaning and sanitizing are addressed through prerequisite good manufacturing practices (GMPs). In combination, these two food safety strategies have enabled food manufacturers to identify and effectively control potential food safety problems before they happen.
The Seven Steps of a HACCP System
A decade ago, the National Advisory Committee for the Microbiological Criteria of Foods (NACMCF) developed seven principles for the HACCP process (NACMCF 1992). These principles have become widely accepted as a foundation for HACCP systems. Each of the seven principles, or steps, is summarized below:
1. Hazard analysis: This, step involves identifying biological, chemical, and physical hazards that may be introduced to food by certain production practices or by the intended use of the product. Hazard analysis starts with a review of the menu or product list that identifies any potentially hazardous foods being prepared and served. During this step, the person in charge also should estimate "risk," which is the probability that a condition will lead to a hazard. Hazards that pose little or no risk or are unlikely to occur need not be addressed by a HACCP system.
2. Identify the critical control points (CCPs) in food preparation: A critical control point is an operation (practice, preparation step, or procedure) in the flow of food preparation that will prevent, eliminate, or reduce hazards to acceptable levels. Critical control points provide a "kill step" that destroys bacteria or a control step that prevents or slows the rate of bacterial growth (McSwane, Rue, and Linton, 1998). The most common critical control points are cooking, cooling, reheating, and hot or cold holding.
3. Establish critical limits for preventive measures: Critical limits are set to make sure that each critical control point effectively controls biological, chemical, and physical hazards. These limits are the thresholds or outer boundaries of food safety. The possibility that a hazard will occur increases significantly when a critical limit is exceeded. Critical limits should be as precise as possible. For example, poultry must be cooked to an internal temperature of 165[degrees] F (74[degrees] C) for 15 seconds. A clear definition of the critical limit makes it easier to determine when the limit has not been met. 4. Establish procedures to monitor CCPs: Monitoring involves making observations and taking measurements to determine if a critical limit has been exceeded at a critical control point. This step also provides written documentation that can be used to verify that the HACCP system is working properly
5. Establish the corrective action to be taken when monitoring shows that a critical limit has been exceeded: Immediate corrective action must be taken when monitoring shows that a critical control point is not being controlled. If monitoring reveals that beef stew on a hot, holding table is below 140[degrees] F (60[degrees] C), it is the responsibility of the food safety team to determine the cause of the problem and correct it as soon as possible. In this example, the food may not be at proper temperature for several reasons. Perhaps the beef stew was not heated sufficiently on the stove before being placed on the steam table. Perhaps the steam table is not working properly, or perhaps a food worker is not stirring the product frequently enough to distribute the heat evenly Corrective action must be taken immediately when a critical limit has been exceeded, because the risk of foodborne illness increases when a critical control point is not met.
6. Establish effective record-keeping systems that document the HACCP system: An effective HACCP system requires the development and maintenance of a written HACCP plan. The plan should provide as much information as possible about the hazards associated with each food or group of foods. The amount of record keeping required will vary from one food establishment to another. The detail of the plan will be determined by the complexity of food production operations. A good rule of thumb is to keep enough records to prove that your system is working properly but at the same time to keep the system simple and user friendly for employees.
7. Establish procedures to verify that the HACCP system is working: The final step in a HACCP system is verifying that the system is working properly Verification is a two-step process. First, verify that the critical limits established for the CCPs will prevent, eliminate, or reduce hazards to acceptable levels. Second, verify that the overall HACCP plan is functioning effectively. The establishment's management team must review and evaluate its HACCP plan at least once a year. The plan must be modified to accommodate changes in clientele, new items added to the menu or product list, and new processes used to prepare potentially hazardous foods.
The HACCP Committee of the Conference for Food Protection has affirmed that the seven principles outlined above are appropriate for HACCP systems in retail food establishments. For the sake of simplicity and uniformity it is important to keep the HACCP methodology and the terminology associated with it as consistent as possible. Thus, when the HACCP system is applied at the retail level, the differences from its application elsewhere do not lie in definitions or basic principles. Rather the differences occur in the practical interpretation or application of the principles.
HACCP Methods in Retail Food Establishments
In the United States, more than one million retail food establishments prepare and serve food on a daily basis. These establishments employ millions of. food workers who prepare billions of meals each year. The size and scope of the retail food industry pose a serious challenge to the government's ability to effectively monitor food safety. This circumstance has made it necessary to shift more of the responsibility for food safety to managers and food workers who produce food in restaurants, retail food stores, institutional feeding programs, and other types of retail food establishments.
Food safety management at the retail level requires a comprehensive approach that will actively control risk factors that contribute to foodborne illness. The Centers for Disease Control and Prevention (CDC) have identified improper cooling, improper holding temperatures, cross-contamination, and poor personal hygiene as common risk factors,
The HACCP system, which has been used effectively by food manufacturers for decades, also can be used by retail food establishments to promote food safety. The method offers many benefits to retail food operators. The most significant of these is the ability to identify and control food safety problems before they happen.
To effectively manage food safety, a retail food establishment should implement a system that combines the basic principles of HACC with in-house standard operating procedures (SOPs). The HACCP system will control risk factors associated with time and temperature. The SOPs will control risk factors associated with personal hygiene, cleaning and sanitizing, and pest management.
Potential Obstacles to HACCP Development and Implementation in Retail Food Establishments
In most instances, retail food establishments will encounter some obstacles as they attempt to implement a HACCP system within their operation. Some of these obstacles are inherent with change, but others are unique to the HACCP food safety system. Some of the more common obstacles encountered by a retail food operator when attempting to implement a HACCP system are discussed below. They are not ranked in order of importance.
HACCP Terminology Can Be Confusing
The basic steps in the HACCP process are fairly straightforward. Food establishment managers and food workers often, however, find terminology a bit confusing. For the sake of uniformity it is important to keep the basic HACCP steps and concepts consistent, regardless of the type of retail food operation. It is equally important to make the HACCP system user friendly for retail food operators and their staffs. This goal can best be achieved with a simple system that focuses on controlling the risk factors of foodborne illness through proper temperature control, good personal-hygiene procedures, and cross-contamination control.
There has been an ongoing debate about whether good personal-hygiene practices and cross-contamination control are critical control points or standard operating procedures. The more important issue, however, is the creation of a comprehensive food safety system that uses CCPs and SOPs effectively to control risk factors.
To be successful, the HACCP food safety system must be functional and flexible. It must be tailored to the needs of the individual retail food operation. For example, if an operator believes that the only CCP he or she could apply to a food item (such as fresh produce) is related to personal hygiene, then HACCP principles should not discourage giving handwashing a CCP designation.
If a regulator, consultant, or trainer were to take too rigid a view of what qualifies as a CCP and were to disallow behaviors commonly thought of as SOPs or prerequisites, it could dissuade operators from "fitting" HACCP to their needs. Ultimately, this could jeopardize the goal of reducing risk factors that contribute to foodborne illness.
Fitting the Needs, Resources, and Constraints of the Food Establishment
Industry, regulatory, and academic professionals must understand that with HACCP one size does not fit all. Each HACCP food safety program must be tailored to the needs of the individual retail food operation. It also must fit the resources and constraints of the establishment that is implementing it.
Unlike food-processing plants, which handle one product at a time, retail food operations prepare many different types of food products simultaneously, using a variety of ingredients and production techniques. Therefore, the Food and Drug Administration (FDA) recommends that retail food establishments use a "process approach" when conducting the hazard analysis (Food and Drug Administration, 1998). FDA's process-oriented approach divides retail food flow into the following three process categories:
2. receive--prepare--cook--hold and serve, and
3. receive--prepare--cook--cool--reheat--hot hold--serve.
According to the FDA HACCP Principles Guide, the HACCP system must provide food safety controls for all hazards within each of the three process categories. FDA maintains that controlling the hazards within each of these categories is equivalent to preparing a HACCP plan for each individual product (Food and Drug Administration, 1998).
Regulatory Agencies Use the Traditional 44-Item Checklist During Routine Inspections
Many regulatory agencies have not converted to a HACCP-based system for routine food safety inspections. Retail food managers are reluctant to implement a HACCP program when they fear it might put them in conflict with the regulatory agency in their jurisdiction. Therefore, regulators and operators must understand how HACCP works and the benefits it offers. Efforts to implement HACCP programs should be viewed as a partnership between industry and regulatory agencies. This creates a win-win situation for both groups.
Will Compliance Assessment Be Based on the Internal HACCP Plan?
An important issue is whether local regulators will determine compliance on the basis of an establishment's internal HACCP plan or on the basis of the food safety regulations of the local jurisdiction. For example, a company's internal HACCP plan may set the critical limit for cooking ground beef at 160[degrees] F (71[degrees] C). The food regulation in the local jurisdiction may require ground beef to be cooked to an internal temperature of 155[degrees] F (68[degrees] C). Would the establishment be considered in compliance if the internal temperature of the ground beef was 158[degrees] F (70[degrees] C) when measured by a sanitarian or environmental health specialist during a routine inspection? In this case, the product is being safely cooked according to local health code requirements, but it deviates from the internal HACCP plan, which shows that the process is not under control. Thus, retail food establishment operators fear they could be penalized for not meeting the provisions of their HACCP plan, even when they are in compliance with local health code requirements.
Availability of HACCP Education and Training for Food Managers and Workers
Education and training are key to the successful implementation of a HACCP program. The high rate of employee turnover in most food establishments makes it necessary to offer education and training programs on an ongoing basis. Regulatory agencies, trade associations of the retail food industry, private consultants, and educational institutions all are sources of HACCP training programs. Nevertheless, training programs often are not available in all jurisdictions and may not be offered with the frequency needed to keep pace with turnover. In addition, HACCP training can be very expensive. Cost may cause food managers to delay the start of much-needed educational programs.
Many Food Establishments Lack the Resources to Implement a HAACP Program
Many food establishments, especially small, independent operations, do not have the time, money, or professional staff needed to create and implement a HACCP program. True; implementation of a HACCP program can be viewed as an investment in the future. Many operators, however, can start such a program only by diverting resources from some other equally worthwhile program or activity
Managers of retail food establishments should expect some obstacles to arise as they develop and implement HACCP programs. Those managers who anticipate the obstacles and take steps to address them are most likely to succeed.
Food managers and supervisors must know how to develop, implement, and maintain the HACCP program. This knowledge begins with an understanding of the factors that affect food safety. Food workers must be skilled in performing the specific tasks (monitoring and recording) required by the HACCP plan. Each establishment should conduct education and training programs that provide employees an overview of the HACCP system and how it works to ensure food safety. These training programs should include in-depth examination of the critical control points, critical limits, and monitoring activities required by the HACCP program. Training also can motivate food workers by stressing the importance of their tasks in the ultimate success of the overall HACCP program. Because of the high rate of employee turnover in most food establishments, HACCP training must be an ongoing activity.
A HACCP plan must be compatible with the menu, personnel, production methods, and facilities. What works for one establishment may not work for another. The needs of a small operation with a limited menu and limited number of food-processing methods will differ greatly from those of a large facility or group of facilities with extensive menus and food production activities. Regardless of the size and complexity of the operation, food managers are encouraged to "Keep It Simple." The simpler and more straightforward a HACCP program is, the easier it will be to implement and maintain.
Successful implementation of a HACCP system requires open, ongoing communication between regulators and industry personnel. As discussed earlier in this paper, regulators and operators must understand how the HACCP method works, and implementation should be viewed as a partnership between industry and regulatory agencies. An effective way to build trust and rapport is to offer joint HACCP training for food managers and regulatory officials. Joint education offers many benefits. First, managers and regulators will learn the same information about the HACCP system and how it can ensure food safety. Second, they will have an opportunity to exchange ideas and share concerns. Third, they can negotiate issues such as whether HACCP should be process or product specific, which behaviors are CCPs and which are SOPs, and how compliance will be determined. Finally educational programs provide both parties an opportunity to interact informally outside the workplace. This will help managers and regulators develop the rap port they will need as they embark upon implementing HACCP programs in retail food establishments.
The HACCP system is a prevention-based safety program that identifies and monitors hazards associated with food production before they happen. This system has been used successfully by food processors for decades. It is now finding its way into more and more retail food establishments.
When combined with proper equipment and facilities, a knowledgeable workforce, and sound SOPs, the HACCP approach can provide retail food establishments with a comprehensive food safety system. Food managers can use the HACCP system to estimate the relative risks of hazards and to determine where control procedures are needed most. When properly applied, a HACCP system enables a food establishment effectively to control any food flow point at which a hazardous situation could occur. Because the HACCP method focuses on the actual safety of the food item, it will protect public health far better than traditional methods that focus on sanitation and safety. Although the development and implementation of a HACCP system requires time, money, and effort, food operators will do well to view the understanding as an investment in food safety and the ultimate success of their establishments.
(Adapted with permission from Proceedings of the First NSF International Conference on Food Safety, Albuquerque, New Mexico, November 16--18, 1998.)
Corresponding Author: Dr. David McSwane H.S.D., Associate Professor, Indiana University--Purdue University at Indianapolis, School of Public and Environmental Affairs.
Food and Drug Administration Managing Food Safety: A HACCP Principles Guide for Operators of Food Service, Retail Food Stores, and Other Food Establishments at the Retail Level, 69 pp., April 15, 1998.
McSwane, David, Rue, Nancy and Richard Linton, Essentials of Food Safety and Sanitation, Prentice Hall, Upper Saddle River, NJ, .373 pp., 1998.
National Advisory Committee on Microbiological Criteria for Foods, "Hazard Analysis and Critical Control Point System," International Journal of Food Microbiology, Vol. 16, No. 1, pp. 1-23, May, 1992.
(*.) Editor's note: Because this paper was originally published in the Proceedings of the First NSF International Conference on Food Safety, the references are not consistent with the Journal of Environmental Health's normal style format.
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