HACCP Have We Lost Our Way With HACCP?
By Greg Scher, A Senior Food Protection Warrant Officer, U.S. Army
As food safety becomes an increasingly important issue, it might be a good idea to take a step back and reexamine your food safety plans. Asking a few key questions, such as “who are my customers?” and “how do my HACCP plans help them?” are a good place to start.
HACCP principles were pioneered by the Department of Defense as a way to assure things that can’t be tested are safe. When you look at things such as bombs and artillery shells, it is obvious that they can’t be tested. To test something like that is to destroy it and anything else in the area. I remember Bugs Bunny in the animated Looney Tunes cartoon Forward March Hare, released in 1953. At the end, Bugs is hitting each artillery shell as it came off an assembly line to see if it was a dud. It was the punchline because it’s a really bad idea to test ammunition that way. The thing with testing food is, much like artillery shells, when you test it, you destroy it.
Then we started putting people in space.
NASA could not have astronauts getting sick from the food they eat. To prevent illness from food in space, the agency asked Pillsbury and the U.S. Army Laboratories to find a way to ensure, to a very-high degree, that any hazards to food are removed during packaging and processing. This collaboration resulted in HACCP. A great timeline for the development of HACCP can be found here.
The USDA’s Food Safety and Inspection Service (FSIS) has made HACCP regulatory since 1996. Yet, we still have contamination and recalls with products the agency regulates. The agency will tell you exactly how your HACCP should be implemented and take no ownership if it fails to reduce a hazard to a safe level. You have to take your HACCP plan back; assume your customers are astronauts and you can’t allow a hazard to reach their food.
Having been in Food Safety and Defense for 25 years, I have seen HACCP go through many cycles; first by the requirement of regulators and then by third-party audit standards, such as GFSI. While most food safety professionals would argue this was a good thing, I would argue that, like most well-intended programs, it turned a producer-led process into a process being pulled by benchmarks and regulators to fit their ideas. I believe this stifles initiative, new ideas, and in many of the plants I have visited, seen it becomes a “check-the-box” mentality where there is no HACCP culture developed. There is a good “dog-and-pony” show for regulators and auditors, but when you peel back that first layer, you can often find that the programs are driven by the requirements of customers and regulators, and not specifically by the hazards.
Avoiding HACCP Pitfalls The most common snare to HACCP plans I see is companies not owning them. “Corporate wrote this plan not us.” If your corporation is so directive-based that you have no say in your facilities HACCP plan, then you need to take ownership and take a stand. Most of these types of violations can be found in prerequisite programs. An example would be a program that requires chlorine bleach spray used on a food contact surface to be tested to be at least 200ppm. When you look at the test strip it is obviously stronger than 200ppm. Federal rules state that if you go over 200ppm you are required to do a fresh water rinse of the surface. If you are just using paper that gets darker with the presence of chlorine why not back off to 150ppm? How can you assure that each time you mix the spray you have not exceeded 200ppm? More is not always better or more effective. By backing chorine to 150 you cut chlorine use by 25% and remove the hazard of going over the 200ppm threshold and avoiding violating 21CFR 178. Here is a link to a good paper on use of bleach.http://ucfoodsafety.ucdavis.edu/files/26437.pdf
Another mistake I see is a lack of HACCP prerequisite programs that make sense. People are smart; when you want a program taken seriously, you need to make sure you are not wasting people’s time, money, or effort.
For instance, we are taught that “hair restraint” is a requirement and hairnets need to be worn. In comes the bald guy. Why is he made to wear a hairnet? Are you making people that are clean shaven wear a restraint for their beards? Programs have to make sense if you want them to be taken seriously and embraced by employees to create a great food safety culture.
I also see poor supervision and leadership. If your company’s supervisors are not knowledgeable and do not enforce the programs, it’s time to find new supervisors. If employees are “breaking” program rules there is a reason. Supervisors need to identify the reason and find the root cause. For example, a door to the back of the building is propped open because it is hot and is held open to cool the area. Supervisors should address the temperature in a way that does not violate food defense and won’t let pests in the building. Managers often tell me the employees set them up; I would argue there is poor supervision.
Make Audits A Two-Way Street If you do your homework and can convince a regulator or an auditor that what you do adequately addresses specific hazards, your HACCP plan will be seen effective in their eyes. You are in the plant every day and you know the ins and outs of your facility; most auditors and regulators are only interested in you putting out a safe product. Make audits and inspections two-way conversations where both parties are made the better.
About The Author Greg Scher is a CW4 in the U.S. Army Veterinary Corps with 25 years of food safety and defense experience. He has a B.S. in Management, and as a Senior Food Protection Warrant Officer, has audited over 500 food producers in 57 countries. He is a member of the Order of Military Medical Merit and has been awarded three Bronze Stars.