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HACCP Hazard Analysis Critical Control Point Training
Level 1: Awareness January 2017 Morning/afternoon Introduce self (and other trainer if relevant) Start with housekeeping – fire exits, catering arrangements, toilet facilities and mobile phone ‘rules’ Ask delegates to say briefly The company you are from What the products are What you would like to get out of the course – (delegates should have thought about this because the ‘joining’ letter asked them to come with their personal requirements) What level of food safety training have you done before? This course has been developed because it has been acknowledged that when a small to medium sized company (especially) wants to increase their understanding or implement HACCP they go on a course – a generic course not particularly related to their products – they then return to their company and they still are not sure where to start. Also that jargon confuses people. Our aims therefore are to work with you to ensure that you leave at the end of the day feeling confident that you understand HACCP, how it’s applied and with the skeleton or part of a HACCP Plan for your business. We’ll undertake to To avoid jargon wherever possible – sorry the first slide has two acronyms!!!! I have put the full words up for you. READ OUT Explain any words or concepts that you do not understand so please tell us if you’d like further explanation To explain the necessary jargon so that we are all speaking the same language. We have to use some terminology because it is included in legislation and therefore may be used by enforcement personnel or customer auditors but we want you to feel comfortable with it. 3) To show you that the people who work on the products are the best (only) people to write the HACCP plan for a company and give you the confidence to defend your plan against any challenges from those who do not know as much about your business as you do!.
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Today’s session will include:
Food Safety What it is and why it is important How a company can achieve a system that produces safe food The structure of a food safety system including HACCP What is involved in implementing HACCP The roles for personnel within a food business in producing safe food Our plan for the day is to go back to basics and look at food safety as a topic We’ll look at food safety systems and what’s involved - it’s more than just HACCP. We’ll look at applying HACCP and what it entails so that you can see the level of thought that needs to go into doing HACCP and to enable you to maybe contribute as time goes on The reason we have to start by looking at food safety is because producing any food involves some risk – it something goes wrong you could kill somebody or at least make them very ill. The consequences of the food safety system going wrong can be disastrous – for all concerned and we’ll consider this during the course. Taking a logical and thorough approach can help prevent problems – which is what this is all about as prevention is always better than cure!
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Learning Outcomes for this course
1. Know the purpose of a HACCP system 2. Know the features of a HACCP system 3. Know how hazards are controlled 4. Know how to manage a Critical Control Point
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Why is Food Safety Important?
Discussion Why is Food Safety Important? So – Why is food safety important? Trainer – Use flipchart to collect ideas from the group and then sort them under the following categories: Protecting the Consumer Protecting your Business Compliance with legislation Use the next slide to summarise Tell us what you think!
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Why is Food Safety Important?
To protect the consumer To protect your business To comply with the law So who is responsible for Food Safety in YOUR business? Summarise and ask who is responsible for food safety within a business? Confirm on the next slide the answer is ‘Everyone’ but in different respects – discuss with the group the different roles of various personnel – owners/managers, supervisors, operatives
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Why is Food Safety Important?
To protect the consumer To protect your business To comply with the law So who is responsible for Food Safety in YOUR business? EVERYONE!
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What are the Laws? There are two main pieces of law covering food safety – one is the Act of Parliament for the UK and the other are the European Regulations on the Hygiene of Foodstuffs What does the law say? Trainer use flipchart to collect ideas to provide details, then summarise: See next slide
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What are the Laws? EC 852/2004 Regulation on the Hygiene of Foodstuffs
The Food Safety Act 1990 EC 852/2004 Regulation on the Hygiene of Foodstuffs Apply principles of HACCP to hazards specific to business and process Based on risk assessment The Food Safety Act 1990 details main offences – To sell food that is injurious to health To sell food that is unfit or so contaminated that is would be unreasonable to expect it to be eaten To sell food that is not of the nature, substance or quality demanded by the customer EC 852/2004 (European Regulations) requires food businesses to Apply the principles of HACCP to identify and manage food safety issues within their process using a tried and internationally accepted technique that was specifically designed for the purpose Allows a business to design a way of managing food safety that is specific to their business and process only and is based on risk assessment so only the issues relevant to the business, their ingredients, their process and factory, their workforce and their finished products need to be very tightly managed over and above standard industry good practices. EC 852/2004 also describes the specific requirements for food businesses in terms of design of premises, design and finishes in food rooms, equipment requirements, cleaning, pest control, maintenance, personal hygiene etc and applies to all food businesses
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What Does the Law Require? - The Principles of HACCP
Principle 1: Conduct a Hazard Analysis Principle 2: Identify Critical Control Points Principle 3: Establish Critical Limits Principle 4: Establish Monitoring Procedures Principle 5: Establish Corrective Actions Principle 6: Establish Verification Procedures Principle 7: Establish Documentation & Records You CAN do HACCP! The law requires the use of HACCP and this slide shows what is required – quite daunting for small businesses – so where do they start? Although you won’t need to ‘do’ HACCP, it’s always good to have an appreciation of legal requirements and know how it works and what some of the terms mean – we’d love to live in a jargon free world but inevitably the jargon enters the language and we don’t want to get left out!
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What do you think are the Consequences of NOT Managing Food Safety?
Discussion What do you think are the Consequences of NOT Managing Food Safety? So -What are the consequences of not managing food safety/complying with the law? Trainer to use flipchart to elicit ideas from trainees about what the consequences of failing to manage food safety Customer/consumer illness or injury Customer complaints Major customer scrutiny Loss of business Environmental Health scrutiny Legally required improvement or prohibition (including business closure, job losses) Prosecution Fines Imprisonment Protecting the business Trainer to ask why it is important to protect the business Reputation of the business and of the industry sector Protection of employee’s jobs and livelihood Impact on other related businesses e.g. Cheesemaking operations on dairy farms Trainer to use next slide to summarise
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Consequences of a Hazard reaching the Consumer
Illness or injury/complaints – DEATH Customer and EHO scrutiny Prosecution, fines/imprisonment Loss of business/customers Loss of jobs as production reduced/ company closed and consequences for the workforce Trainer to explain that the most serious outcome is that consumers are affected – and that some of the outcomes could be devastating for those affected Any hint of a problem and customer and enforcement personnel will focus on the business to try to prevent further issues Enforcement personnel will focus on any business that they feel to be posing a risk – more checks and visits Enforcement personnel have very comprehensive powers to deal with food businesses when they consider that there is potential for a food safety issue – they try to help and educate first but if there is a significant concern or an imminent risk to health, they have a number of legal powers including business closure available to them. Prosecution and penalties may be imposed and will seek to identify and deal with those responsible (may be anyone within the business) Customer scrutiny – more audits, checks, doubts by customer Loss of business – customers look elsewhere when lack of supply – lose confidence which ultimately impacts on those who work within the business and may lose their jobs
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Discussion What Makes Food Safe? Ask delegates what makes food safe
Trainer use flipchart to gather delegate’s thoughts Extract –freedom from various forms of contamination – microbiological, chemical, physical, allergenic and obtain some examples Move to next slide to summarise and explain
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What Makes Food Safe? Microbiological (Pathogens) Physical
Freedom from contamination Microbiological (Pathogens) Physical Chemical (including Allergens Making sure pathogens cannot grow Run through answers and ensure all delegates are comfortable with what each category covers. Move on to the next slide to discuss what needs to be done to make safe food
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What Makes Food Safe? Safe food is obtained by
Correct and careful processing Protecting the food from further contamination Explain that we will now run through how a business can ensure these points are covered
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How can we prevent contamination with microorganisms?
Discussion How can we prevent contamination with microorganisms? So, there are various forms of contamination associated with foods. Most people are quite clear about physical and chemical hazards and also about the allergens that are associated with their ingredients and products because of personal experience and information provided in the trade press and by enforcement personnel but many feel unsure about microbiological hazards so we’re going to do a little refresher because this knowledge is frequently important when applying HACCP and identifying hazards. So how can we prevent contamination with microorganisms? Take any answers and put onto a flipchart see next slide for some examples
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Preventing Contamination
Use of reputable suppliers Effective cleaning Compliance with personal hygiene requirements Correct food storage Mention that not all microorganisms are harmful – some result in spoilage but the controls for the harmful ones can help limit the spoilage organisms too and ensure the product reaches the end of it’s shelf life
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Preventing Growth of Microorganisms
How? By making sure microorganisms (bacteria, moulds, viruses or yeasts) cannot get what they need So what do microorganisms need? So if there are micro-organisms in the ingredients or products, we need to minimise the possibility of them growing. Ask the delegates what microorganisms, particularly bacteria need in order to grow/multiply Use flip chart to record answer to get the list below Food Moisture Warmth Time The right acidity (not too acid not too alkali) This is detailed on the next slide and reinforced by the next activity.
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Preventing Growth of Microorganisms
How? By making sure microorganisms (bacteria, moulds, viruses or yeasts) cannot get what they need So what do microorganisms need? Time Food Warmth The Right Acidity Moisture
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ACTIVITY Handout 1 Introduce ACTIVITY 1
Provide the delegates with Activity 1 worksheet and ask them to fill in what they think is happening to the bacteria under various conditions – they can use rapid growth, slow growth, dead or dormant so they need to fill in the thought bubbles for temperature and approximations for moisture and acidity. Trainer to reproduce each scale on the flipchart and take answers from the delegates, explaining the ‘correct’ answers for each and asking for examples of foods that fit the moisture and acidity ‘scales’ This activity is designed to remind delegates of the factors affecting bacterial growth and also to encourage thinking about why different types of products are less prone to support bacterial growth than others - do not cover in too much detail as this is in preparation for a further activity Introduce the concept that understanding these features enables us to preserve foods and also allows us to prevent food safety problems Handout 1
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Back to the Beginning….. As soon as we harvest food, it starts to deteriorate….. So why might we need to preserve food? Explain food in it’s natural state will start to break down as soon as it’s harvested/killed. This caused problems for our forefathers as they needed to have a supply of food throughout the year for seasonal crops and also, if they killed a large animal, to keep it in edible condition until they were able to consume the whole kill. The deterioration in food as it ‘broke down’ is caused by chemicals naturally present in the food and/or the action of bacteria and other micro-organisms from the soil and surrounding environment. So how did they manage to keep the food? Ask for examples of foods that have been around a long time and have a long shelf life - dried meats – Biltong, Cheese, Cured meats These foods are preserved in different ways i.e. they can be kept for longer. Understanding food preservation is important as we use many of these techniques today in various forms and we rely on getting these techniques right to ensure the food will not only last but will also be safe for consumption Example – home canning of vegetables in the southern states of the US without understanding the important aspects of the process resulted in botulism being relatively common in the 19th century. Paste of Wild Duck at Loch Maree in Scotland in 1922 – all 8 people affected died – also Clostridium botulinum
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Common Preservation Techniques
Heating Drying Use of Chemicals Chilling/Freezing Acidity Manipulation of gases around the product Many of these preservation techniques are based on stopping chemical changes in the food and killing or slowing down the growth of micro-organisms/pathogens. The main techniques – Trainer to explain each and the way that these work Heating – killing the growing microorganism – breaks up the bacterial cell - refer to the ‘answers’ from Activity 1 chart to confirm Chilling/Freezing – slowing down or preventing growth (though not killing) – refer to the ‘answers’ from Activity 1 chart to confirm Use of Acidity/Pickling – taking away growth conditions/destroying cells – refer to the ‘answers’ from Activity 1 chart to confirm Manipulation of Moisture - Drying – removing enough moisture so no growth -refer to the ‘answers’ from Activity 1 chart to confirm Use of Other Ingredients - Use of Salt, Use of Sugar (and effect on moisture within food), nitrites. Change environment away from that pathogens preferred Manipulation of Gaseous Environment – Vacuum Packing, Gas Modification. Change environment away from that which most pathogens prefer (air composition) Usually, it will be a combination of these that makes the food safe and gives the food it’s shelf life e.g. Cheddar cheese - chilling of milk, pasteurisation/heating, use of a starter culture to develop acidity, addition of salt and possibly vacuum packing to prevent mould growth during retailing. ACTIVITY 2: Two options: If delegates have brought examples of their products, go through them one at a time while retaining this slide on the screen and ask which of the above techniques have been employed and discuss the answers given. If not possible ask the delegates to tell you what products they produce and as above discuss which techniques have been used. Summarise by commenting that it is often a combination of techniques that make the food safe and each needs careful control if the food is going to remain safe
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The Food Chain So what do we do?.......... Primary Processing
Secondary Processing Retailing/ Catering Agriculture Consumer In the majority of cases, however, there are many ‘links’ in the food chain. Although a gross simplification with no storage and transportation steps, ask delegates where they are on this processing ‘continuum’ Explain that many food products start in agriculture and are processed through initial stages (e.g. flour milling, sugar beet processing, milk/cream pasteurising) before being sold for further processing (e.g. cake manufacture, ice cream) prior to going to the retailer or caterer for sale to the consumer. Or beef burger – Farm → Slaughter →Cut into joints → Remove meat → Mince & Mix – Form burgers → Pack → Cook and serve → Eat So what do we do?
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Potential contaminants/ hazards in the food chain
Discussion Potential contaminants/ hazards in the food chain DISCUSSION Redraw the slide details on a flipchart Refer to earlier slide and consideration of contamination or hazards that may be in the food, ask trainees for examples of contaminants/hazards that may affect products at various stages in the overall food chain. Capture examples given on the flipchart, showing where the contamination may occur and add some examples to supplement where the delegates do not provide sufficient examples in other parts of the food chain e.g. pesticides in cereal production in agriculture. e.g. Agriculture – Pests, Pesticides, herbicides, chemicals from ground water, disease, bacteria from soil or guts, GM, dirt and debris, contamination of milk from teats, soil, mastitis (Staphs), people Primary processing – Contamination by guts during slaughter/cutting, soil/dust, contamination from other batches during transport (milk, cream) or processing (fruit), pieces of machinery, growth of microorganisms if stored Secondary processing – Contamination from other ingredients, work surfaces, people, cross contamination via work surfaces, utensils, growth of microorganisms if stored Retailing/catering – if food not covered contamination/cross contamination as above. If covered and prepared correctly – poor storage could lead to growth of microorganisms, damage to packaging prevent adequate control of growth. Consumer – If not covered and stored correctly any of above Next slide outlines why it is important that we appreciate the various contaminants possible so we can be informed about how this might affect our ingredients and what we might do to deal with these contaminants e.g. a cheesemaker might buy in raw milk; they may then pasteurise/heat treat it before making cheese because they may not know what might be present in terms of food poisoning bacteria. If they produce the milk themselves and have full knowledge of it’s microbiological quality, they may decide to make a raw milk cheese because they are confident the raw milk is free from pathogens
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The Approach to Food Safety Management
All ‘links’ in the food chain are responsible for food safety in their own operations Confidence and trust in suppliers is vital Traceability is needed in case there are any problems Design food safety systems to prevent problems rather than rely on end product testing Food companies need a good ‘food safety system’ Trainer to use this summary slide to highlight that all the links in the food chain are responsible for making sure the food they handle and produce is safe. We use good practices to make sure everything that needs to be in place is in place and working correctly. We make sure we have the right process controls and manage these at all times
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A Food Safety ‘Culture’
The attitude to food safety in a food business is very important for the production of safe food so we’re now going to talk about what needs to be in place for food safety. Trainer note: This slide is part of a sequence of slides to create animation
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Discussion What do you think needs to be in place so a food business can demonstrate food safety is a priority and is effectively managed? Ask the Delegates the question. Write their answers on a blank flip chart but group them without using titles according to whether their answer relates to Management commitment Good Practices/Pre-Requisites HACCP related/process control activities From the answers given, put a heading to each group and then use the analogy of a building – explain that, in this case, it will be a Greek Temple. Ask the group what they would want to start with if they were building a Greek Temple that needed to stand for thousands of years They should say ‘good foundations’ . Trainer to ask which of the three groups on the flipchart would constitute ‘good foundations’ – they should say ‘Management Commitment’. This is discussed on the next slide.
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The ‘Foundations’ - Having a Food Safety Culture
What does a Food Safety Culture involve for the people involved in the Company? Trainer – explain to delegates that each of the elements are important so each needs to be explored a little more. Ask the delegates what they think ‘having a food safety culture’ involves? Trainer to take answers and put on the flipchart Next slide will show summary of the key points Take the answers and paraphrase – bring up bullet points and reinforce
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The ‘Foundations’ - Having a Food Safety Culture
Clear Commitment to Food Safety from Management Knowledge and Skills to Manage Food Safety Ensure Levels of Supervision are in Place and Right for the Business Members of Staff given Responsibility and Authority So we have our foundations. The trainer can use the next slide to bring up the ‘foundations’ on the slide.
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A Food Safety ‘Culture’
The trainer can then ask what should be built next for our temple (the delegates should say ‘walls’) and the trainer can bring up the next slide showing a series of pillars Food Safety Culture & Management Commitment
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A Food Safety ‘Culture’
Trainer to ask delegates what they think from the remaining two groups on the flipchart represent the walls/pillars. Once the correct answer is given the trainer can bring the next slide up. Food Safety Culture and Management Commitment
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The ‘Walls’ – Making sure that Good Practices (or Pre-Requisite Programmes) are in Place
Ask the delegates what they would consider to be ‘good practices’ or Pre-requisites or Good Manufacturing or Good Catering practices These are the practices which need to be in place for food safety. These practices prevent hazards but do so in a general way so the hazards are managed as a ‘subject’ for the whole processing area rather than at a specific point in the process. Use the flipchart to gather their answers and then bring up the answers on the next slide
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The ‘Walls’ Making sure that Good Practices (or Pre-Requisite Programmes) are in Place
Hygiene & Housekeeping Planned Maintenance of Buildings and Equipment Pest Control Waste Control Supplier Controls Personal Hygiene Training Control of allergens Trainer to explain that this is not an exhaustive list, there may be others e.g. wood and glass controls ACTIVITY: Trainer - divide the group into pairs and allocate a topic to each pair . Give each pair a piece of flipchart paper and marker pens. Ask the pairs to prepare a poster detailing what they would expect a food business to have in place for the topic they have been given and what they know is done to control any contamination that might arise from these not being well managed. Ask each pair to explain what they came up with and refer to the SALSA standard and the requirements, reinforcing the fact that food businesses have a responsibility to ensure these ‘Good Practices’ are in place Trainer to constantly encourage and reinforce and to get delegates to think about importance of their role in ensuring standards are set appropriately and well managed daily
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Good Practices or Pre-requisites
Manage hazards not specific to a particular process or product Support and underpin HACCP Allow HACCP to focus on what are the most significant hazards for a particular product or process Trainer: use this slide to summarise how pre-requisites and HACCP fit together and highlight the importance of pre-requisites being managed well so they can be relied upon. HACCP can then be used to identify and manage the food safety concerns associated with the process Trainer to highlight that physical and chemical (including allergens) hazards are often controlled by pre-requisites
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A Food Safety ‘Culture’
Calibration Planned Maintenance Pest Control Hygiene & Housekeeping Personal Hygiene Training Supplier Controls So the pillars/walls represent Good Practices or ‘Pre-requisites’ – these are the basic requirements that any food business should have in place – these are the things that need to be in place before HACCP is used – making sure the fundamentals are in place and working – we’ll come back to these later. So we have foundations and walls. The final element is the roof – bring up the next slide Food Safety Culture and Management Commitment
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A Food Safety ‘Culture’
HACCP The Process Hygiene & Housekeeping Pest Control Planned Maintenance Training Supplier Controls Personal Hygiene Calibration Finally the trainer can explain that this represents the production process which is where we need to ‘do’ HACCP. We apply the principles of HACCP to examine the processes to identify the hazards that may result if things go wrong and, where we find parts of the process that need very tight day to day control for producing a safe product, then focus attention to ensure those hazards are well controlled - these are Critical Control Points. These will need to be monitored whenever we produce to be sure that the process is in control or, if there is a problem, we know exactly what needs to be done to restore control, capture any product that may be unsafe and deal with these products so we protect the consumer. This is the essence of the HACCP system Using the building analogy, the trainer should challenge the delegates with questions So what would happen to our building if the roof leaked or blew off? What would happen if the walls cracked or one of the pillars crumbled? What would happen if the foundations were not strong enough? All the answers should be similar – the building will/may fall down and it’s integrity has been damaged – in food terms, this means potentially unsafe food. The trainer can then indicate that all the components are needed and each of these component parts needs further examination…. bring up each heading in turn explaining that we need all these components to give us a robust way of managing food safety during day to day working Food Safety Culture and Management Commitment
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The ‘Roof’: ‘Doing’ HACCP
Preparation Grouping products & processes to decide on the different HACCP Plans required Makes applying HACCP efficient & effective Saves time and complexity Trainer to make sure it’s clear that HACCP principles are intended to be applied to the process; this is because the pre-requisites or good practices are used to make sure the food production environment is suitable for the production of safe food. Before HACCP is applied, the company needs to work out how to make sure all food processes have HACCP principles applied to them. This is usually done by grouping products that are processed in the same way and doing HACCP for each group.
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HACCP Awareness HACCP is based on some principles that were defined about 20 years ago by an international group of experts. These were shown earlier/briefly and there’s plenty of information available - If you are interested, please ask the trainer As you saw earlier, there are 7 principles of HACCP and we’ll go through these so you can get a feel for what’s involved in applying them
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(Hazard Analysis and Critical Control Points)
What is HACCP? (Hazard Analysis and Critical Control Points) It’s a technique for making sure that All the relevant food safety concerns are identified A practical and sensible plan is designed to prevent or control these food safety hazards during production by focusing attention on ‘Critical Control Points’ (CCPs) …………………Simple!
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How does HACCP work? The ‘Good Practices’ or ‘Pre-requisites’ are introduced and confirmed as being in place and working The business writes HACCP Plans to cover all the products made HACCP Plans are implemented by ensuring ‘Critical Control Points’ (CCP) are closely monitored during production If a problem is found at a ‘CCP’, defined actions are taken to resolve the problem. This makes sure the affected products don’t reach the consumer
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ACTIVITY What is a HAZARD? Handout 2
What is a hazard? Ask delegates what they understand by the term ‘hazard’. Trainer to discuss with delegates using Handout 2 – Food Safety Hazards – Test Your Knowledge!
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Hazard Analysis Undertaken by a group of people within the company who
Draw a diagram of the steps/stages in the process being examined Take each step in the process and consider any hazards that may occur and the cause Decide which of the identified hazards are genuinely likely to occur Decide what measures can/should be taken to prevent or control each of these hazards – these are ‘CONTROL MEASURES’ The legislation refers to hazard analysis. This simply means that a structured approach is used to identify hazards and where they might occur. This allows us to see where they need to be controlled. Example: there will be pathogens in meat, which might be a hazard, but if we are then cooking it that is the point in the process where that hazard will be controlled. Once we have completed the hazard identification, we decide if the hazard needs to be controlled i.e can it really happen and can it really cause illness and then we need to make sure effective controls are in place Tutor to explain control measures and provide some examples relevant to the group being trained
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What are Critical Control Points (CCPs)?
Points in the process where it is Critical to Control the hazards identified by hazard analysis Each CCP must be under control during processing/manufacturing to make sure safe food is produced - otherwise the consumer may be harmed
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How do we make sure Critical Control Points (CCPs) are under control?
Use agreed and valid limits (called CRITICAL LIMITS) e.g. cooking to a minimum core temperature of 82°C MONITOR the control measure at an agreed frequency e.g. take core temperatures of the product to ensure the Critical Limit has been met, every batch Follow CORRECTIVE ACTIONS defined in the HACCP Plan to protect the consumer The Critical Limits for each CCP will highlight when the control measure at the CCP isn’t working correctly e.g. cooking to a minimum core temperature of 82°C We monitor the control measure at an agreed frequency so the HACCP plan will define how to monitor and how often you do it e.g. take core product temperatures to ensure the Critical Limit has been met, every batch If the critical limit is not met then the HACCP plan will have specific Corrective Actions defined to make sure the problem with the process control is resolved, the affected product is found and dealt with and therefore the consumer is protected – see next slide for discussion of corrective actions.
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Corrective Action Must include:
What to do with the possibly unsafe food How to restore control at the Critical Control Point Examples include: Stopping production of any more product Finding products produced since the last ‘good’ check Fixing the problem that caused loss of control Calling the supervisor/manager Corrective action is very important. When things have gone wrong, people tend to ‘flap’ and do what comes into their heads, which may not be the right course of action. In HACCP, we define exactly what needs to be done when the monitoring shows us that there is a problem with not achieving the Critical Limit at the CCP. The main requirements are detailed on the slide and examples are as shown. It is important that the person operating the equipment can take the right initial action as this means no more unsafe food is produced and that any potentially unsafe products are being found and segregated. Calling the supervisor is secondary as the operator should have the authority to take initial corrective action to minimise the impact of the problem and then decisions on what to do with the potentially defective product can be made later.
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Reassurance! HACCP does not mean more work – just different, targeted work that is more effective for food safety Most businesses only have a few Critical Control Points Controlling and monitoring a Critical Control Point is usually done by the person responsible for operating that part of the process HACCP needs to be clear ‘who does what’ and what needs to happen in the event of a problem
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What does HACCP look like in practice?
A few sensible ‘rules’ for making the HACCP Plan work The HACCP Plan needs to be written down The HACCP Plan needs to be implemented Records need to be kept to show Critical Control Points are being actively monitored Records need to be kept to show Corrective Actions are taken when the Critical Control Point is not working properly Trainer to highlight that, at this stage, the business now has a HACCP Plan and has done some work to prove that it will work (validation) Trainer to ask delegates Why does the plan need to be written down? Why does the HACCP Plan need to be implemented? Why do we need to keep records?
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Types of Documents & Records
The HACCP Plan Procedures and Work Instructions Records to Show Pre-Requisites are Working Records to Show Food Safety is Being Managed Monitoring & Corrective Action Verification Review HACCP Plan: Once implemented, this may sit on a shelf for most of the time but don’t forget it can have other uses. What might these be? (e.g. as a training aid) Procedures & Work Instructions: What type of procedures/work instructions might be needed? (Refer to SALSA standard and discuss when and why written procedures may be necessary) Ask for examples and write on flipchart (Cleaning Schedules, Procedures for Handling Glass Breakages, Product Recall Instructions, Procedures for Monitoring CCPs) Records of Pre-requisites and their Operation: Ask for examples and write on flipchart (Goods Intake Inspection Records, Ingredient & Packaging Specifications, Pest Control Inspection Reports, Records of Calibration, COSHH sheets, Training Records Records to Show Food Safety is Being Managed : Ask for Examples and write on flipchart (Records of CCP monitoring and corrective actions, records of validation, microbiological testing records (verification), records of internal audits, Records of checks carried out to see if the monitoring records have been filled in correctly, records of changes made to the HACCP Plan, records of reviews of the HACCP Plan)
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Why keep Records? To demonstrate product safety is being managed
For audits Customer Environmental Health SALSA Insurance May be used for employee training Provide history for problem solving Identify potential problems (adverse trends) So, why keep records? Tom Clancy says in the film ‘Debt of Honor’ “If it isn’t written down, it didn’t happen” Trainer to ask delegates to think about the sorts of people who may visit their business. Who has visited in the past year or two? Did they ask to see any records? Were they specific in their requirements or more general?
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Discussion Designing Records for CCPs
What should be included on a Critical Control Point record? Trainer to ask delegates what they would include on a Critical Control Point record and write on a flipchart
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Designing Records for CCPs
Records may include: Details of: The Critical Limit Brief details of the Monitoring procedure & frequency of check Corrective Action requirements Traceability information (e.g. product names/batch codes) Space for Comments eg details of corrective action taken Space for reviewer to sign/ initial and date Records should be formatted to make completion easy Trainer to summarise – here’s some ideas we prepared earlier….. At a minimum, you should make a note of what was made on each day and batch coding information, to allow for traceability. It can be useful to detail some of the requirements for the CCP – reminders about Critical Limits, what the Monitoring method is and what Corrective Actions are required Ask - Why is it a good idea to complete your records while you’re in production? Why do you need to put the time and date of production? Can you think of an example when making a record of time/date might be useful in the future? (example answer – when dealing with a customer complaint) Why should the record be initialled by the employee? If computers are to be used to store record information, what sort of controls might need to be considered?
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Let’s look at a CCP record
ACTIVITY Let’s look at a CCP record Handout 3 ACTIVITY Trainer to work with delegates and pose questions: What extra information would you add to this form? Eg critical limit information, document control etc Or ask questions / discuss How does the person doing the check know what to do each time? How do they know what the check should be? Is it clear from the form this is for a CCP? Where can they record any comments? Should a manager be looking at the form too? Look at the completed example – Does it give you confidence that temperature checks are being carried out at the correct frequency (3 x per day)? Does it give you confidence that the people doing the checks are competent to do this job? Handout 3
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The Role of the CCP Monitor
Controlling the food production process Monitoring Critical Control Points (doing tests and checks) at the right frequency to see if the process is under control Taking Corrective Actions as defined in HACCP Plan Keeping records to show the CCP is well managed Flagging issues/suspicions about the process Suggesting better ways of working at the CCP The CCP Monitor has a key role – managing food safety at the ‘sharp end’
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Remember: These records may be your only proof!
Record Keeping Tips Never pre-record data or use ‘ditto’ Never postpone making entries and rely on your memory Modifications: never “Tipp-Ex” or erase line out and correct; initial any changes Standardise forms Remember: These records may be your only proof! Trainer to highlight some useful tips for record keeping It may seem obvious but don’t write anything down in advance of taking your temperatures etc – don’t assume anything (because ASSUME makes an ASS out of U and ME). Similarly, don’t write ditto or delay making records. Ask delegates why might this cause you problems? It is considered bad practice to use Tipp-Ex or own brand correcting fluid or to erase anything permanently, why is this considered poor practice? Use standardised forms because a familiar theme will help people navigate the paperwork. Think about websites like Amazon and ebay, which ones work and which don’t? Finally, think about why you keep these records. Trainer to discuss the legal concept of due diligence. See next slide for Tudor & Sons story
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Information Sheet Tudor and Sons Handout 4
Finally, think about why you keep these records. Trainer to discuss the legal concept of due diligence. Refer to the Tudor & Sons story with regard to falsifying records HANDOUT 4 – Tudor & Sons Newspaper Article. Handout 4
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Confirming or Verifying that Products are Safe
How do you know your HACCP plan is working? Double check your records Perform internal audits Look at complaints Product testing Verification is the phrase used to describe the process a company goes through to double check that their HACCP plan is working. How could you do this? Well, suggested ways are looking at old records – have CCP limits been exceeded? Why could this be? For example, does your food not always cool as quickly as you would like? Could that be due to the nature of the equipment that you’re using or the way the food is laid out? Internal audits help you take snap shots of the HACCP system to see if all is well. Complaints may have underlying trends which show that all is not well with the HACCP system, like product going mouldy before its best before date or complaints about meat smelling “off” before its use by date. Finally, there’s product testing. Usually micro testing. Small companies often ask their lab to advise what tests are needed and what the acceptable limits are.
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Reviewing Records Review records prior to despatching product to ensure: Have the records been correctly completed? Have the critical limits been met? Has proper corrective action been taken if a critical limit was not met? Trainer to discuss - Why might a company need to review CCP records before product is sent to customers? What might you need to think about if a CCP hasn’t been met? Think about storage temperatures, cooling time / temperatures and ingredients. What sort of corrective action might need to be taken?
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Retention of records Keep for at least 1 year beyond maximum possible shelf life (consider home freezing etc) Keep the records in good condition Keep the records filed to make access or disposal easy Consider different ways of retaining records Once your records have been made, I’m afraid you’ll have to keep hold of them for a while! Why is this? This can be a headache for a lot of businesses – big and small, so give archiving and the nature of your records some thought. How compact could you make your records without them becoming a burden?
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Thinking about changes
Discussion Thinking about changes Ask the delegates: What sort of changes might prompt you to review your HACCP Plan or Pre-requisites? Write the answers on the flipchart Some suitable answers are detailed on the next slide….
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Changes New process flow New ingredient or change to an ingredient
New product Annual review If you change your process flow or make a new product or add a new ingredient, you will probably need to change your HACCP plan. A common example is a butchery that starts to make its own stuffing to put in the birds at Christmas, how might this affect the HACCP plan? (Talk about ingredients, allergens, microbiological risks, process flow, machinery, temperatures). In any event, you should have a look at the HACCP plan every year to make sure that it is still relevant.
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Making it Better and Better!
Do Check Act Plan A HACCP plan isn‘t a static document Remember - Plan, Do, Check, Act – the HACCP team should continually think about making the system better and better. Plan – All the right pre-requisites are in place and a HACCP Plan and associated procedures and records are now ready. Do – The HACCP Plan is in place, colleagues have been trained accordingly Check – The plan is reviewed, does it work? Is it complete? If the forms don’t work – then change them! After all, the company has to live with them every day! Act – Make the necessary improvements.
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In Summary…… Don’t be afraid of the jargon HACCP is simply a tool
HACCP is very logical A HACCP plan helps YOU to make safe food A few final thoughts… You don’t need to be scared of HACCP. It’s making your companies product safe. This course should have shown you why it’s important. Just as importantly you now know that if you’re monitoring/checking a CCP that what you do is key to making HACCP work! When you go back to work think about your role, do you know what the critical limits are? Do you know what to do if your bit of the process isn’t meeting it’s critical limit? The HACCP plan is important but it’s the people who make it work! Once the HACCP plan is in place it becomes a ‘way of life’
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