The implementation of the Food Safety Modernization Act (FSMA) in 2015 has marked a significant evolution of the Hazard Analysis and Critical Control Points guidelines, or HACCP. This guide provides an overview of relevant changes for a Food Processing Equipment buyer or operator. It also provides useful solutions to help you audit HACCP compliance in your operations.
Similar to Six Sigma and other manufacturing methodologies, HACCP is a data-driven approach to systematically evaluating and preventing possible hazards before they have a chance to occur in the Food Processing environment. While HACCP can’t guarantee 100% food safety, the end objective is to make food products as safe as possible and prove that your facility processed those products as safely as possible.
The implementation of FSMA marks a mandatory shift in the focus of the food processing industry to prevention. Food safety programs are no longer voluntary, and with the new FSMA guidelines, you’ll be required to show FDA inspectors in-depth documentation that your facility is in compliance.
FSMA builds on the seven principles of HACCP, so it’s important to understand these principles and how they relate to your facility.
Hazards can be biological, chemical, or physical. Analyze each of your facility’s process steps such as storage, preparation, and cooking. Part of this principle is establishing which preventive measures your facility will take to control an identified food safety hazard. Utilizing the latest hygienic cooking technologies is one example of a preventive measure. Click here to learn more about hygienic cooking technologies that could help your facility.
You already identified potential hazards and preventive measures in step one. Now, determine at what points in your process you need to control for the prevention, elimination, or reduction of a potential hazard.
Critical limits define the maximum or minimum value related to controlling for a particular potential hazard. Many limits have already been determined, and you can find more information on your facility’s critical limits by utilizing regulatory literature, scientific journals, or expert consultation.
The main difference between the six principles of the FSMA and those of HACCP relates to this principle. FSMA replaced “determine the critical control points” and “establish critical limits” with “determine and establish preventive controls.” The new terminology requires a more proactive approach to eliminating hazards. Preventive controls encompass not only the hazards that can be controlled at CCPs, but also preventive systems such as sanitation procedures and environmental monitoring.
Monitoring is essential for HACCP plans. It includes both measurements (like temperature) and observations (like physical appearance) to ensure that a CCP (or preventive control) is maintained within tolerances. You’ll also need to produce accurate documentation to use later in the process.
Determine which corrective action your facility will take if the monitoring procedures show that a CCP (or preventive control) is beyond its critical limit.
Put procedures in place to verify that your food safety program works. This includes reviewing records to make sure your process controls are effective, making sure the corrective actions were taken, and ensuring that a control has been maintained. Verification should include your monitoring records.
Under FSMA, your facility will now be required to show FDA inspectors in-depth documentation that you are in compliance, and you will have to document preventive controls with the same rigorous analysis, control, and documentation as CCPs.
The FDA has indicated that it will develop plans and education to help food processing facilities with implementation. In the meantime, get a jump-start by reviewing each step of your current food safety plan and ensuring that your employees understand the importance of in-depth documentation at every step. If your facility already implements the seven principles of HACCP, you may need to make some changes, but for the most part, you will be on your way toward complying with the new preventive control rules. To learn more about implementing an HACCP plan, click here for the USDA’s in-depth guidebook.