HACCP questions answered by inspection service
commonly posed questions it receives on hazard analysis and
critical control point (HACCP) procedures in a bid to help smaller
companies stay on the right side of the law.
HACCP is an international standard for food safety procedures in processing plants. The FDAembodied the in law in 1995 and it came into effect in January 1998. HACCP is a science based andsystematic method of identifying specific hazards and measures for their control to ensure thesafety of food.
The principles are used by processors as a tool to assess safety hazards and establish controlsystems that focus on prevention rather than relying mainly on end-product testing.
In the guide the Food Safety and Inspection Service (FSIS) confirms that companies need to listthe frequency with which they plan to conduct direct observation verification of monitoring activitiesin their mandatory HACCP plan.
In response to another commonly posed question the FSIS said companies that handle pass through productsare not required to perform pre-shipment reviews. This is because pass through product is not prepared orprocessed at the distribution site, and so no HACCP plan is required.
"Thus, there are no records associated with the production of the product for the plant to perform a pre-shipment review,"the FSIS stated.
The FSIS also confirms that the selection of critical control points (CCPs) for risk reduction is the establishment's responsibility. The CCPs should be selected based on the decisions made during the hazard analysis.
HACCP regulations also require the establishment to have decision-making documents associated with the selection and development of CCPs.FSIS inspectors may raise questions about the decision-making documents and, accordingly, establishment's decisions on whether a hazard is reasonably likely to occur.
The FSIS may also publish an official notice asking all establishments to reassess their HACCP plans for a particular hazard if FSIS becomes aware of new information.
The FSIS confirmed as well that HACCP training certificates do not expire and there are no regulatory requirements inthe regulations addressing the issue of whether continuing education is required..
In relation to questions from processors in the refrigerated ready-to-eat segment, the FSISconfirmed that companies are required to keep HACCP records for at least one year under theregulation. HACCP records for ready-to-eat frozen, preserved, or shelf-stable products are required to be retained for at least two years.
Other answers deal with commonly asked auestions from small and very small plants on how HACCP procedures apply to their operations. Another HACCP information notice deals with the corrective actions they should take in relation to food safety problems.
Failure to follow HACCP procedures can lead to a civil suit from the Food and Drug Administration(FDA) as at least one food firm has found out.
In what is believed to be one of the first attempts to shut down a company due to a failure tofollow HACCP laws, the FDA filed suit earlier this month in Minnesota's federal court, asking ajudge to shut down Worldwide Fish & Seafood due to HACCP breaches.
In its docket the FDA alleges that seven inspections of the company over the past six yearsrevealed it had failed to establish and implement adequate HACCP plans, as required. The FDA said itfiled the suit after settlement talks with the company failed to produce results.
When contacted FoodProductionDaily-USA.com, the company said it was still trading and woulddefend itself against the allegations.
