Food Safety and Foodborne Disease Surveillance Systems: Proceedings of an Iranian-American Workshop (2006)

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Implementing and Auditing Hazard Analysis and Critical Control Point Systems and Difficulties in Iran Sassan Rezaie Assistant Professor of Microbiology Tehran University of Medical Sciences As is well known to this audience, the Hazard Analysis and Critical Control Point (HACCP) system is used for food safety and for controlling food process- ing. I will review the basic aspects of the system that have been widely docu- mented in the scientific literature. I will not attempt to cite the many references that I am sure are well known to our American guests.1 HACCP is usually referred to as a preventive, documented, and verifiable system. It is preventive because it focuses basically on the entire process and not merely on the final product. It is documented because there are procedure manu- als as well as work instructions for implementing HACCP and there is also a record-keeping system for control. Finally, HACCP is verifiable because its ef- fectiveness can be checked and verified by such methods as internal audits and final product examination. This preventive, documented, and verifiable system will control food hazards by identifying and characterizing all food hazards from farm to fork, followed by determining critical control points at which a monitor- ing system for detecting the hazards triggers corrective action. To implement 1According to the U.S. Department of Agriculture (USDA), “Hazard 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.” 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. 97 

98 FOOD SAFETY AND FOODBORNE DISEASE SURVEILLANCE SYSTEMS and also audit HACCP systems in food processing industries we have three basic requirements as follows: • It begins with management requirements that are usually referred to as management responsibilities. The first management requirement is setting a hy- giene policy. This is done by top management. This policy will give the organi- zation a hygienic direction. The second management responsibility is the deter- mination of the HACCP system’s scope; this locates the implemented HACCP system in the big picture of “from farm to fork.” The third management respon- sibility is designating the HACCP team, which is usually selected from the com- pany’s middle managers following the implementation of the HACCP system. • The second group of responsibilities concerns the operational pre- requisites. These prerequisites are referred to as good manufacturing practice principles as well as hygiene training. The basic aspects involved include the following: 1. Operating conditions for the equipment used in food processing. 2. Rooms in operating facilities should be indicated as clean and unclean areas in food processing and include any cold rooms. Old infrastructures in many companies usually do not meet the requirements for this aspect of the operation and money should be spent on infrastructure renovation in order to separate the clean from the unclean areas. 3. Cleaning and disinfection procedures in processing areas for the general environment as well as for the machinery. 4. Sanitary services and facilities. 5. Drainage. 6. Lighting. 7. Ventilation. 8. Pest control, particularly in geographic areas with warm climates like Iran. This is an important operational prerequisite in HACCP. There are three strategies in pest control: preventing the entrance of pests into the operations area, preventing the nesting and growth of any entered pests in the operations area, and finally killing the insects and pests. 9. Waste disposal. 10. Water supply: in HACCP we always need detailed and precise water analysis data to control the waterborne pathogens and contamination in food processing. 11. Personal hygiene: all workers and operators should have been tested and certified by the Ministry of Health in Iran. In addition, their protective clothes in clean areas should be prescribed by HACCP documents. 12. Hygiene training is a basic requirement in implementing HACCP. To be effective, hygiene training must change or improve hygienic attitude and behavior. 

IMPLEMENTING AND AUDITNG HACCP SYSTEMS 99 • Other operational steps and requirements for implementing HACCP are as follows: 1. Operational requirements originate from product specifications. The in- gredients of food as well as its formulation and all additives with their amount should be determined here. 2. The second step is the process description, drawing a flow diagram and finally confirming it at the operation site. 3. The third step is the first principle of a HACCP system. All potential hazards—biological, chemical, and/or physical—should be classified in three groups: hazards due to raw materials, hazards caused by cross-contamination, and hazards that are resistant to the elimination process during the operation. 4. The fourth step is the second principle of an HACCP system. A critical control point (CCP) is a stage in the process that can be controlled, and control- ling it can decrease or eliminate a determined hazard. 5. The fifth step is the third principle of an HACCP system. For each CCP we should have at least one critical limit. 6. The sixth step is installation of monitoring systems for the critical limits at CCPs that will monitor hazards. 7. The seventh step is corrective actions that must be performed when monitoring indicates a deviation from the critical limit of a CCP. 8. The eighth step is verification: this means internal audits plus microbio- logical, chemical, and/or physical tests of the final product, as well as investiga- tions of customer complaints regarding the product. 9. The ninth step is documentation; documentation should cover all proce- dures and work instructions in use as well as the recording system. 10. The final step is revision and updating of the HACCP system; this should happen at least once a year and focus on all possible problems that could affect the system.