FSMA is here. This means food processors and manufacturers will be under increased scrutiny to ensure the safety of their products.
For many food companies, FSMA requires switching to a new risk-based hazard analysis system. However, USDA-regulated facilities (e.g., those that handle and process meat and poultry products) will still operate under the Hazard Analysis and Critical Control Points (HACCP) system. In any case, the FDA has promised more inspections and stricter enforcement.
To help you prepare for what’s to come, we’ve put together this list of the five most common HACCP violations in food facilities, based on the FDA’s Inspectional Observation Summaries for fiscal year 2015.
FDA inspectors recorded nearly 200 instances where facilities had a documented HACCP plan, but failed to implement the monitoring, recordkeeping, and/or verification procedures detailed within it.
HACCP plans don’t do any good if they’re just on paper. They must be implemented to help processors avoid food safety problems and their consequences. If it’s been a while since your last internal HACCP audit, it’s time to get one on the schedule.
The specific citation refers to fish and fishery products, but it speaks to a larger issue that food processors and manufacturers now face.
Under FSMA, the same rules that apply to U.S. producers also apply to all foreign suppliers. The onus for ensuring that imported foods comply with U.S. standards lies with the importer. So, if you have any concerns about the products you import, take the time to verify your supply chain before the inspectors arrive.
The third principle of HACCP is establishing critical limits. These limits are values that indicate whether food safety hazards are being controlled to an acceptable level.
The FDA gives the example of cooking beef patties.
To ensure beef patties are free of pathogens like E. coli, an HACCP team decides that beef patties must retain an internal temperature of 155°F for 16 seconds.
In this example, the temperature (155°F) and the time (16 seconds) are critical limits.
This violation comes in two varieties:
Your best plan for ensuring your critical limits meet the regulatory requirements is to properly training your HACCP team.
In facilities where this observation was made, an HACCP plan was in place, but that plan didn’t include “the food safety hazards that are reasonably likely to occur.”
The main goal of HACCP is to control food safety hazards. That effort starts with identifying them. Again, training will help you avoid this type of citation.
In this violation, the HACCP plan identifies the likely food safety hazards, but not how those hazards can be controlled.
A critical control point (CCP) is a specific step during food processing where a control can be applied to reduce food hazards by bringing them within the critical limits. As illustrated by the beef patty example above, the most common CCP is cooking.
Your HACCP plan is your best defense against food safety hazards — and against citations from FDA inspectors. For more information about compliance, view our other food safety articles. If you’d like to know where you stand on food safety, request a plant safety audit.