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The Hazard Analysis and Critical Control Point System Dr. A. Djazayery Professor of Nutrition, School of Public Health and Institute of Public Health Research Tehran University of Medical Sciences With traditional methods of food control in food processing plants it has been usual to take a sample of the final product leaving the factory and perform laboratory analyses on this sample. When a bacterial contamination was detect- ed, there was no way to know its source or pinpoint exactly where in the process- ing line it had occurred. Observation, experience, and controlled research showed that contamination could occur at any stage; from the point at which raw materi- als entered to the final point of the product leaving the processing plant, includ- ing outside exposures to contaminants. The source(s) of contamination in the plant could potentially be raw materials, machinery, equipment, or personnel. Thus, food processors and control experts adopted the Hazard Analysis and Critical Control Point (HACCP) system, which has had wide application and success in other industries. In this system it is possible to detect contamination at its origin (biological, chemical, or physical) and take appropriate remedial ac- tion. The HACCP system is different from traditional control methods and can play an effective role in promoting food safety and consequently in food security (i.e., access to sufficient, safe food by the community).1 1According to the U.S. Department of Agriculture (USDA), âHazard Analysis and Critical Con- trol Points (HACCP) is a production control system for the food industry. It is a process used to determine the potential danger points in food production and define a strict management system to monitor and manage the system ensuring safe food products for consumers. HACCP is designed to prevent the potential hazards, including: microbiological, chemical, and physical. Juice, meat and poultry, and seafood are regulated at the federal level. Meat and Poultry HACCP systems are regulat- ed by the USDA, and juice and seafood systems are regulated by the FDA.â More information about the HACCP is available at http://www.nal.usda.gov/fsrio/topics/tphaccp.htm and http://vm.cfsan. fda.gov/~lrd/haccp.html. 94
THE HAZARD ANALYSIS AND CRITICAL CONTROL POINT SYSTEM 95 The HACCP system is based on the following well-known principles: 1. Analyzing hazards. Identification of potential hazards associated with a food and of measures to control those hazards. 2. Identifying critical control points. These are points in a foodâs produc- tion (from its raw state through processing and shipping to consumption by the consumer) at which the potential hazard can be controlled or eliminated. 3. Establishing preventive measures with critical limits for each control point. For a cooked food, for example, this could include setting the minimum cooking temperature and the time required to ensure the elimination of any harm- ful microorganisms. 4. Establishing procedures to monitor the critical control points. Such pro- cedures could include determining how and by whom cooking time and temper- ature should be monitored. 5. Establishing corrective actions to be taken when monitoring shows that a critical limit has not been met. Examples include reprocessing or disposing of food if the minimum cooking temperature is not met. 6. Establishing procedures to verify that the system is working properly. Examples include testing time-and-temperature-recording devices to verify that a cooking unit is working properly. 7. Establishing effective record keeping for documentation of the HACCP system. This could include records of hazards and their control methods, of the monitoring of safety requirements and the action taken to correct potential problems. Today the HACCP system is being used in many food processing plants worldwide. Over the last decade or so, action has been taken in Iran to introduce the system to food processors (requiring or at least encouraging them to adopt it) as well as to the relevant authorities and personnel in the health, agriculture, and industry sectors, to food standard authorities, and to food legislators. In the development of an HACCP plan, five preliminary tasks need to be accomplished before an HACCP plan can be developed which include assem- bling the HACCP team, describing the food and its distribution, describing the intended use, developing a flow diagram that describes the process, and verify- ing the flow diagram. The development of an HACCP plan involves 12 phases as follows: 1. Assembling the HACCP team. HACCP teams consist of individuals who have specific knowledge and expertise appropriate to the product and process. It is the teamâs responsibility to develop the HACCP plan. 2. Describing the food and its distribution. This consists of a general de- scription of the food, ingredients, and processing methods. The method of distri-
96 FOOD SAFETY AND FOODBORNE DISEASE SURVEILLANCE SYSTEMS bution should be described along with information on whether the food is to be distributed frozen, refrigerated, or at ambient temperature. 3. Describing the intended use and consumers of the food. Describe the normally expected use of the food. The intended consumers may be the general public or a particular group of the population (e.g., infants, immunocompro- mized individuals, the elderly). 4. Developing a flow diagram that describes the process. The purpose of a flow diagram is to provide a clear, simple outline of the steps involved in the process. 5. Verifying the flow diagram. The HACCP team should perform an on-site review of the operation to verify the accuracy and completeness of the flow diagram. After these five preliminary tasks have been completed, the seven prin- ciples of HACCP are applied. The next seven phases are application of the seven principles described above. The last phase (Phase 12, Principle 7), as described above, is to establish a record-keeping and documentation system. Generally, the records maintained for an HACCP system should include the following: 1. A summary of hazard analysis; 2. HACCP Plan that lists the HACCP team and assigned responsibilities, description of the food, its distribution, intended use and consumer, verified flow diagram, and the HACCP plan summary table. The table should include infor- mation on steps in the process that are critical control points, the hazard(s) of concern, critical limits, monitoring, corrective actions, verification procedures and schedule, and record-keeping procedure; 3. Support documentation, such as validation records; and 4. Records that are generated during the operation of the plan. Four basic steps in establishing an HACCP system in food industry in a country are as follows: 1. Preparation of relevant national standards by the food standard agency (general guidelines for HACCP-system establishment in the food industry, plus standards for specific food or food group); 2. Introduction of the HACCP system to food processors and the relevant government authorities and personnel through short training courses, seminars, and workshops; 3. Development of an HACCP plan in a food processing unit as a pilot; this involves the 12 phases (see above); and 4. Implementation, expansion of the system throughout the province or country.