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1. INTRODUCTION
1.1
In today's global market, quality and safety have become competitive
edge for the enterprises producing goods and providing services.
With the advent of ISO 9000 series of standards, the concept of
quality has taken a tangible form . These standards have made a
dramatic impact on business around the world. For the first time
there is a broad consensus about quality system's minimum requirements.
This is the reasons why ISO 9000 has unanimously received a world
wide acceptance. This presents a good opportunity for the food industry
for upgrading quality and bringing uniformity and consistency in
their supplies to international market.
1.2
The food industry plays an important role in the national economy.
It has a major share in India's exports. Since the international
market has become demanding in terms of quality, safety and delivery,
installation of quality systems and Hazard Analysis Critical Control
Points(HACCP) in food industry would provide a competitive edge
to food supplies in the international market.
1.3
The Quality System standards seek to accomplish the following three
objectives with regard to quality:
a)
The enterprise should achieve and sustain the quality of the product
or service produced so as to meet contractually the purchaser's
stated or implied needs.
b)
The enterprise should provide confidence to its own management that
the intended quality is being achieved and maintained.
c)The
enterprise should provide confidence to the purchaser that the intended
quality is being or will be achieved in the delivered product or
service provided. When contractually required, this provision of
confidence may involve agreed demonstration of requirements.
1.4
Similarly HACCP system, a well established concept in food safety,
identifies specific hazards and provides preventative measures for
their control to ensure the safety of food. The application of HACCP is compatible with the implementation of ISO
9000 and is the system of choice in the management of food safety.
The pace of progress of HACCP has been accelerated dramatically
mainly due to the following two reasons:
a)
many hitherto unrecognized microbial food borne hazard have come to light since 1960's,
b)
the rapidly increasing global sourcing of raw materials and distribution
of finished products make it imperative that governments cooperate
at the international level to provide assurance of food safety.
1.5
HACCP is a tool to assess hazards and establish control systems
that focus on preventative measures rather than relying mainly on
end-product testing. It is now widely embraced by the food industries
and by the government regulatory agencies around the world as a
most cost-effective means of minimizing the occurrence of identifiable
food borne biological, chemical and physical hazards and maximizing
product safety .It is a system which targets critical areas of processing,
and in doing so reduces the risk of manufacturing and selling unsafe
products.
1.6
HACCP can be applied throughout the food chain from the primary
producer to final consumer. It enhances food safety and other, benefits
include better use of resources and more timely response to problems.
In addition, the application of HACCP systems can aid inspection
by regulatory authorities and promote international trade by increasing
confidence in food safety. The successful application of HACCP requires
the full commitment and involvement of management and the work force
as in case of ISO 9000.The HACCP approach adds value to ISO 9000
Quality Management System and a combined effect would be a safe
and wholesome food to consumers.
2. PRINCIPLES
of HAZARD ANALYSIS CRITICAL CONTROL POINTS(HACCP)
2.1
The HACCP system consists of seven principles.It is a system which
identifies specific hazard(s) and preventative measures for their
control. These principles outline how to establish, implement and maintain HACCP system.
PRINCIPLE 1
Identify
the potential hazard(s) associated with food production at all stages,
from growth, processing, manufacture and distribution, until the
point of consumption. Assess the likelihood of occurrence of the
hazard(s) and identify the preventive measures for their control.
PRINCIPLE 2
Determine
the points/procedures/operational steps that can be controlled to
eliminate the hazard(s) or minimize its likelihood of occurrence
[Critical Control Point (CCP)]. A "step" means any stage
in food production and/or manufacture including raw materials, their
receipt , harvesting, transport, formulation, processing, storage,
etc.
PRINCIPLE 3
Establish
critical limit(s) which must be met to ensure the CCP is under control.
PRINCIPLE 4
Establish
a system to monitor control of the CCP by scheduled testing or observations.
PRINCIPLE 5
Establish
the corrective action to be taken when monitoring indicates that
a particular CCP is under control.
PRINCIPLE 6
Establish
procedures for verification which include supplementary tests and
procedures to conform that the HACCP system is working effectively.
PRINCIPLE 7
Establish
documentation concerning all procedures and records appropriate
to these and their application.
2.2
These principles are closely related to the 20 elements of ISO 9000
(See Fig.1) . This shows how the two systems could be intertwined
to be more effective.
3. APPLICATION
OF THE PRINCIPLES OF HACCP
3.1
When conducting the hazard analysis, consideration must be given
to the impact of raw materials, ingredients, manufacturing practices,
role of manufacturing processes to control hazards, likely end-use
of the product, consumer populations at risk and epidemological
evidence relative to food safety. The intent of the HACCP system
is to focus control at CCPs. HACCP should be applied to each specific
operation separately. For identification of CCPs all aspects of
food chain need to be examined. The HACCP application should be
reviewed and necessary changes made when any modification is made
in the product, process, or any step. It is important when applying
HACCP to be flexible given the context of the application.
3.2
Steps Involved in Implementation of HACCP-The implementation of
HACCP principles requires the following tasks as identified in Fig.2
Logic Sequence for Implementation of HACCP.
3.2.1 Constitute
HACCP team
The
HACCP is carried out by people. If the people are not properly trained
and experienced then the HACCP system is likely to be ineffective.
It should be a multidisciplinary team that has specific knowledge
and expertise appropriate to the product for example agronomists
or veterinarians, production personnel, microbiologists, medical
experts, public health specialists, food technologists, chemists
and engineers according to the particular study. Where such expertise
is not available on site, expert advice should be obtained from
other sources.
3.2.2 Describe
the product and its intended use
It
should be noted what the product actually is and how/by whom it
will be used. A full description of the product should be drawn
up, including information on composition and method of distribution.
The intended use should be based on the expected uses of the product
by the end user or consumer. In specific cases, vulnerable groups
of the population, for example institutional feeding, may have to
be considered.
3.2.3 Construct a process flow diagram
The
process flow diagram is used as the basis of the hazard analysis
and should therefore contain sufficient technical detail for the
study to progress. It should be constructed by the HACCP team. Each
step within the specified area of operation should be analyzed for
the particular part of the operation under consideration to produce
the flow diagram. When applying HACCP to a given operation, consideration
should be given to steps preceding and following the specified operation.
When the process flow diagram is complete, it should be verified
by The HACCP team. It should confirm the processing operation against
the flow diagram during all stages and hours of operation and amend
the flow diagram where appropriate.
3.2.4 Identify
all hazards
When
the process flow diagram is completed and verified, the HACCP team
should list all the biological, chemical and physical hazards(See
Principle1) that may be reasonably expected to occur at each step
and describe the preventative measures that can be used to control
these hazards. For inclusion in the list, hazards must be of a nature
such that their elimination or reduction to acceptable levels is
essential to the production of a safe food. The team must then consider
what preventative measures, if any, exist which can be applied for
each hazard. Preventative measures are those actions and activities
that are required to eliminate hazards or reduce their impact or
occurrence to acceptable levels. More than one preventative measure
may be required to control a specific hazard(s) and more than one
hazard may be controlled by a specified preventative measure.
3.2.5 Identify
the Critical Control Points
A
critical control point is a point/step/procedure where a food safety
hazard can be prevented, eliminated or reduced to an acceptable
levels. The identification of a CCP(See Principle 2) in the HACCP
system is facilitated by the application of a decision tree(See
Figure 3). All hazards that may be reasonably expected to occur,
or be introduced at each step, should be considered. Training in
the application of the decision tree may be required. If a hazard
has been identified at a step where control is necessary for safety,
and no preventative measure exists at that step, or any other, then
the product or process should be modified at that step, or at any
earlier or later stage, to include a preventative measure. Application
of the decision tree determines whether the step is a CCP for the
identified hazard. Application of the decision tree should be flexible,
whether the operation is for production, processing, storage, distribution
or other.
3.2.6 Establish
critical limits for each CCP
Since
the critical control point(See principle 3) define the boundaries
between safe and unsafe products, it is vital that they are set
at the correct level for each criteria. The HACCP team should therefore
fully understand the criteria governing safety at each CCP in order
to set the appropriate critical limits. Critical limits must be
specified for each preventative measure. In some cases more than
one critical limit will be elaborated at a particular step. Criteria
often used include measurements of temperature, time, moisture level,
pH, and available chlorine, and sensory parameters such as visual
appearance and texture.
3.2.7 Establish
a Monitoring System for Each CCP
Monitoring
is one of the most important aspects of any HACCP system. It is
the scheduled measurement or observation of a CCP relative to its
critical limits. The monitoring procedures must be able to detect
loss of control at the CCP (Principle 4). Further, monitoring should
ideally provide this information in time for corrective action to
be taken to regain control of the process before there is a need to reject the product. Data derived
from monitoring must be evaluated by a designated person with knowledge
and authority to carry out corrective actions when indicated. If
monitoring is not continuous, then the amount or frequency of monitoring
must be sufficient to guarantee the CCP is in control. Most monitoring
procedures for CCPs will need to be done rapidly because they relate
to on-line processes and there will not be time for lengthy analytical
testing. Physical and chemical measurements are often preferred
to microbiological testing because they may be done rapidly and
can often indicate the microbiological control of the product. All
records and documents associated with monitoring CCPs must be signed
by the person(s) doing the monitoring and by a responsible reviewing
official(s) of the company.
3.2.8 Establish
Corrective Actions
Specific
corrective actions (See Principle 5) must be developed for each CCP
in the HACCP system in order to deal with deviations when they occur.
The actions must ensure that the CCP has been brought out under
control. Actions taken must also include proper disposition of the
affected product. Deviation and product disposition procedures must
be documented in the HACCP record keeping. Corrective action should
also occur when monitoring results indicate a trend towards loss
of control at a CCP. Action should be taken to bring the process
back into control before the deviation leads to a safety hazard.
3.2.9 Establish
Verification Procedures
The
HACCP system should include verification procedures (Principle 6)
to provide assurance that HACCP system is being complied with on
day-today basis. This can be done most effectively by using audit
method. Establish procedures for verification that the HACCP system
is working correctly. Monitoring and auditing methods, procedures
and tests, including random sampling and analysis, can be used to
determine if the HACCP system is working correctly. The frequency
of verification should be sufficient to validate the HACCP system.
Examples of verification activities include:
*
Review of the HACCP system and its records.
* Review of deviations and product dispositions.
* Operations to determine if CCPs are under control.
* Validation of established critical limits.
3.2.10
Establish Record Keeping and Documentation
Efficient and accurate
record keeping (Principle 7) is essential to the application of
a HACCP system. Records need to be kept of all areas which are critical
to product safety as written evidence that the HACCP system is in
compliance with the documented system. Documentation of HACCP procedures
at all steps should be included and assembled in a manual. Records
are useful in providing a basis for analysis of trends as well as
for internal investigation of any food safety incidents which may
occur.
It
is extremely useful to allocate a unique reference number to each
HACCP record. The types of records that might be retained are as
follows:
*
HACCP plan,
* Amendment to HACCP plan,
* CCP monitoring records,
* Hold/trace/recall records,
* Training records,
* Audit records,
* Meeting records,
* HACCP system procedures.
4. HACCP THROUGH
ISO 9000
4.1
ISO 9000 encompasses all of the activities of a company to ensure
that it meets its quality objectives and HACCP system is directed
towards ensuring safety of food. ISO 9000 and HACCP, concerned with
quality and food safety management system respectively, have much
in common. In fact quality in broader sense includes safety. Therefore,
the best way is to use ISO 9000 route to manage HACCP to ensure
quality and safety of food. Both the systems are quality assurance
systems, designed to provide maximum confidence that a specified
acceptable level of quality and safety are being achieved at an
economic cost.
4.2
The seven principles of HACCP(See clause 2) and 20 elements of 9001,
the most comprehensive model, are closely related (See Figure 1).
Both require documented procedures for their operation. The ISO
9000 requires all activities affecting quality to be documented.
If HACCP requirements are intertwined wit ISO 9000 documented system,
it would be the most cost effective and efficient system to manage
both quality and safety. A more detail comparison of HACCP and ISO
9000 is given in Table 1.
5. CONCLUSIONS
5.1
It may be seen how the two systems-ISO 9000 and HACCP- are vital
for management of quality and safety of food to assure customers
around the world. The regulatory agencies lay more emphasis on safety
while businesses emphasize on both quality and safety as component
of reliable quality. HACCP adds reliability to quality ie food is
not only good at the point of manufacture but also through its shelflife
period.
5.2
It is logical to select ISO 9000 route to implement HACCP as it
is a well known widely practised system around the world with over
150 000 companies already certified. It would be much easier to
induct HACCP in a n already operating ISO 9000 system with a little
tailoring.
Figure
2
LOGIC SEQUENCE
FOR APPLICATION OF HACCP
1.
Assemble the HACCP Team
2.
Describe Product
3.
Identify Intended Use
4.
Construct Flow Diagram
5.
On-Site Verification of Flow Diagram
6.
List All Identified Hazards Associated With Each Step and Consider
Preventative Measures to Control Hazards
7.
Apply HACCP Decision Tree to Each Step With Identified Hazard(s)
(See Figure 3)
8.
Establish Critical Limits for Each CCP
9.
Establish a Monitoring System for Each CCP
10.
Establish Corrective Action for Deviations that May Occur
11.
Establish Verification Procedures
12.
Establish Record Keeping Documentation
FIGURE
3
DECISION
TREE
Q
1
Yes
Do
Preventative Measure(s) Exist?
No
Modify
step, process or product
Is control at this step for safety
YES
NO
Not a CCP STOP(*)
Q
2 Is the Specifically Designed to Eliminate or Reduce the Likely
Yes
Occurrence
of a Hazard to an
Acceptable
Level?
No
Q
3
Could
Contamination With Identified
Hazard(s)
Occur in Excess or
Acceptable
Level(s) or Could These
Increase
to Unacceptable Level(s)?
Yes
No
Not
a CCP Stop(*)
Q
4 Will a Subsequent Step Eliminate
Identified
Hazards(s) or Reduce
Likely
Occurrence to an Acceptable
Level?
Yes
No Critical Control Point
Not
a CCP
STOP(*)
(*)
Proceed to the next identified hazard in the described process
TABLE 1 ISO 9001
AND ITS APPLICATION TO HACCP
4.1
Management-Quality policy may include HACCP and responsibility demonstrate
management commitment.
- Responsibility and authority for HACCP must be defined
- Management review for ISO 9000 should include review of effectiveness
of HACCP operation
4.2
Quality system
-
HACCP specifically considers all activities which could impact on
the safety of the product and ensures that they are consistently
documented, a quality product is also a safe product.
4.3
Contract review
Like
ISO 9000,it considers the relationship between the customer and
supplier meet the requirements. Some raw materials may be CCP and
it will be essential to have tight control over their supply.
4.4
Design control
HACCP
process starts at the product concept stage, i.e. the design, and
control through a Quality Management System .Design control must
include HACCP at the concept stage - has it
been designed safely?
4.5
Document control
Like
ISO 9000, HACCP documents including HACCP Plan, artwork for packaging
need to be controlled and authorized . This will prevent the use
of obsolete documents. Use of uncontrolled copies should be avoided.
Each
HACCP document should bear a unique reference number for cross-referencing
with CCP.
4.6
Purchasing
Everything
purchased from raw material to subcontracted items should be clearly
specified through written specifications.
Control
of subcontractors should be through assessment and records kept.
This
will include calibration, process equipment servicing, hygiene and
pest control.
4.7
Customer-supplied
It
is essential to ensure that ingredients and packing material when
supplied by customer are included in the HACCP assessment. Product
identification HACCP System requires tracebility of cation and batches
of raw material to final traceability products in the event of a
failure at a CCP.
A
documented recall plan should be maintained for being able to trace
and withdraw any defective product.
4.8
Identification and Traceability
4.9
Process control
HACCP
includes the following key areas at all stages in the process:
i)
Building - all facilities from raw material storage areas, through
process and dispatch. Including employee amenities.
ii)
Plant and equipment - process capability, preventative maintenance,
hygienic design and cleaning.
iii)
Personnel - training, health screening, meeting legislation.
iv)
Cross-contamination - at all stages where this could be a risk.
v)
Waste materials - clearly identified and segregated.
vi)
Computer failure - contingency plans should be in place.
vii)
Environmental control - atmosphere, ground water.
4.10
Inspection and Where raw material are CCPs, these testing should
not be used until confirmation of conformance has been received.
Materials
used before being certified as meeting specifications should be
traceable in order to allow a recall at a later stage if necessary.
Finished
products should be held until confirmation of all CCPs having been
met in full has been received.
Records
of all inspection and test results should be maintained.
Personnel
carrying out testing should be trained as being capable for the
job.
4.11
Inspection measuring
All
equipment needed to monitor a CCP should be of known accuracy and
precision and calibrated on a regular basis and status marked.
Equipment
must be maintained and stored correctly in-between calibration in
order to avoid damage.
Records
of calibrations should be kept
4.12
Inspection and test status
There
should be a clearly defined method for identification of the inspection
and test status of any raw material, product, or equipment to prevent
its being used inadvertently.
4.13
Control of non-HACCP should define who is responsible conforming
product for taking corrective action in the event of a deviation.
This must include what to do with product made
while the system was out of control, i.e. to rework, recycle to
reject.
Procedures
must be developed to ensure that all non-conformities at a CCP are
recorded. This will enable trends to be analysed.
4.14
Corrective action
If
a CCP is out of control the underlying cause must be identified
in order for the problem to be permanently resolved and not repeated.
Corrective
actions also include pest control audits and hygiene audits.
The
effectiveness of any corrective action must be verified for confirmation.
All corrective action must be recorded.
4.15
Handling, storage, Hazards may arise from improper packaging and
handling and storage of a product or delivery raw material or use
of unsuitable packaging material - unable to withstand distribution.
Areas for consideration include:
food
contact packaging
control of artwork
storage and distribution temperatures
stock rotation
shelf-life
contamination risks
environment conditions
hygiene and pest control
4.16
Quality records
HACCP
records affecting safety should be controlled and retained for a
specified period based on statutory regulations and product shelf-life
as demonstration of the effective management of food safety.
4.17
Internal Quality
HACCP
System should be a part of internal audit system and audited regularly
by members of the HACCP Team or internal auditors for its continued
suitability and effectiveness paving the way for continued improvement
of the HACCP System. Process Flow Diagrams must be audited as part
of the verification.
4.18
Training
HACCP
relies on the participation of knowledgeable and trained people
across a wide range of disciplines. Areas training should reflect
system changes, emerging food safety issues, new processes and corrective
action skills.
Training
records should be available for all staff and include all types
of training - in-house, external, skills or awareness activities.
4.19
Servicing
This
normally not applicable. But suppliers of vending equipment may
require servicing of such equipment to be documented and controlled
as Such equipment can be source of hazards if not cleaned and maintained
correctly.
4.20
Statistical
For
HACCP Control sampling regimes at each CCP needs to be documented.
Statistical sampling plan may be used decisions of conformance are
being based upon results of sampling and testing. Statistical techniques
may also include process capability assessment and statistical process
control during CCP monitoring.
HACCP
CONTROL CHECK SHEET
Sl.
Process Hazards Preventative CCP Critical Monitoring Corective
No. Steps Measures Limits Actions
original
TABLE
1 ISO 9001 AND ITS APPLICATION TO HACCP
ISO
9000 CLAUSES HACCP APPLICATION
4.1
Management - Quality policy may include HACCP and
responsibility demonstrate management commitment.
- Responsibility and authority for HACCP must be defined
- Management review for ISO 9000 should include review of effectiveness
of HACCP operation
4.2
Quality system
- HACCP itself is a Quality System but this clause specifically
considers all activities which could impact on the `Quality' (safety)
of the product and ensures that they are consistently documented,
a quality product is also a safe product.
4.3
Contract review
Particularly
relevant to Supplier
Quality
Assurance as it considers the relationship between the purchaser
and suppler meet the requirements? Some raw materials may be Critical
Control
Points
and it will be essential to have tight control over their supply.
4.4
Design control
The
design control clause is not included in ISO 9002 - usually the
one that food companies go for. This is a pity because the HACCP
process starts at the product concept stage, i.e. the design, and
control through a Quality
Management
System would be a real benefit. Design control must include a hazard
analysis risk assessment at the concept stage - has it been designed
safely?
4.5
Document control
All
HACCP documents need to be controlled by being reviewed, signed
and dated by authorized personnel.
This
will prevent the use of out of date documents.
Each
HACCP document should bear a unique reference number for cross-referencing
with CCP log sheets for example.
When
changes to the HACCP Plans are made new issues must go to listed
copy-holders and obsolete documents destroyed.
Ad
hoc photocopying of `uncontrolled' copies must be avoided and where
necessary these copies should be clearly marked `Uncontrolled'.
Control
of artwork for a packaging should be reviewed and signed off.
4.6
Purchasing
Purchasing
covers everything from raw materials to subcontractors. Everything
purchased should be clearly specified through written specifications.
Control
of subcontractors should be through assessment and records kept.
This
will include calibration, process equipment servicing, hygiene and
pest control.
4.7
Purchaser-supplied
As
this will apply to ingredients and products packaging materials
which are supplied by the purchaser for processing into his products,
it is essential to ensure that these items are included in the HACCP
assessment and that as much information as is needed is available.
4.8
Product identifi-
Essential
within the HACCP System to cation and be able to trace batches of
raw traceability materials or products in the event of a failure
at a CCP.
A
written recall plan should be maintained in order to minimize the
effect of any failure by being able to trace and withdraw any defective
product.
4.9
Process control
Obviously
highly relevant to HACCP and essential to include the following
key areas at all stages in the process:
i)
Building - all facilities from raw material storage areas, through
process and dispatch. Including employee amenities.
ii)
Plant and equipment - process capability, preventative maintenance,
hygienic design and cleaning.
iii)
Personnel - training, health screening, meeting legislation.
iv)
Cross-contamination - at all stages where this could be a risk.
v)
Waste materials - clearly identified and segregated.
vi)
Computer failure - contingency plans should be in place.
vii)
Environmental control - atmosphere, ground water.
4.10
Inspection and Where raw material are CCPs, these testing should
not be used until confirmation of conformance has been received.
Materials
used before being certified as meeting specifications should be
traceable in order to allow a recall at a later stage if necessary.
Finished
products should be held until confirmation of all CCPs having been
met in full has been received.
Records
of all inspection and test results should be maintained.
Personnel
carrying out testing should be trained and qualified appropriately.
They should also be assessed as being capable for the job.
4.11
Inspection measuring
Effective
control of CCPs relies on test equipment accurate measuring methods
or equipment. All equipment needed to monitor a CCP should be of
known accuracy and precision and calibrated on a regular basis.
All
measuring equipment should be status marked so as to make it clear
to all personnel what is calibrated and what is to be used for general
guidance only.
Equipment
must be maintained and stored correctly in-between calibration in
order to avoid damage.
Records
of calibrations should be kept.
4.12
Inspection and test status
There
should be a clearly defined method for identification of the inspection
and test status of any raw material, product, or equipment to prevent
its being used inadvertently.
4.13
Control of non-The HACCP Control Chart will define conforming product
who is responsible for taking corrective action in the event of
a deviation. This must include what to do with product made while
the system was out of control, i.e. to rework, recycle to reject.
Procedures
must be developed to ensure that all non-conformities at a CCP are
recorded. This will enable trends to be analysed.
Once
any non-conforming product has been brought back into specification
it must be tested again to confirm conformance.
4.14
Corrective action
If a CCP is out of control the underlying cause must be identified
in order for the problem to be permanently resolved and not repeated.
Corrective actions also include pest control audits and hygiene
audits. the corrective action taken in the event of any problem
arising must be the right corrective action - new hazards could
arise if the wrong corrective action is taken. An example of this
is to shroud a piece of equipment in polythene because the roof
above is leaking.
The
effectiveness of any corrective action must be verified for confirmation.
All
corrective action must be recorded.
4.15
Handling, storage, Hazards may arise from improper packaging and
handling and storage of a product or delivery raw material. Also
if the packaging is unsuitable - unable to withstand distribution.
Areas for consideration include:
food
contact packaging
control of artwork (usage instructions, ingredients and nutritional
data)
storage
and distribution temperatures stock rotation shelf-life contamination
risks environment and building fabric hygiene and pest control
4.16
Quality records
HACCP
records will need to be retained in a controlled manner. They may
form part of a due diligence defence or be needed during a regulatory
inspection as demonstration of the effective
management of food safety.
Quality-related
records include product and raw material specifications, the HACCP
Plans, Process Control records including CCP log sheets, calibration
records, minutes of HACCP/food safety meetings, audits.
Retention
time must reflect both statutory regulations and product shelf-life.
Three years as a minimum for those records that demonstrate system
management.
4.17
Internal Quality
Process
Flow Diagrams must be audited
Audits
as part of the verification.
The
HACCP System itself should be regularly audited by members of the
HACCP Team in order to assess whether it is working, correct and
applicable. Internal audits can act as a health check. Documented
non-compliances raised must be corrected, allowing continued improvement
of the HACCP System. The audit will be what makes the HACCP System
live within the company and not remain as documentation on the shelf.
Auditors
must be trained and independent of the department being audited
and records of audit must be kept.
4.18
Training
Effective
HACCP relies on the participation of knowledgeable and trained people
across a wide range of disciplines.
HACCP
and Food Safety Management will continue to develop. It is important
therefore that future training needs are considered on an ongoing
basis. Areas for inclusion may reflect system changes, emerging
food safety issues, new processes and corrective action skills.
Training
records should be available for all members of staff and include
all types of training - in-house, external, skills or awareness
activities.
4.19
Servicing
Often
not considered relevant in manufacturing, but as an example, suppliers
of vending equipment will be particularly aware of this clause as
it required the servicing of such equipment to be documented and
controlled. Such equipment can be a source of hazards if not cleaned
and maintained correctly. This needs to be considered in line with
the servicing frequency.
4.20
Statistical
The construction of the HACCP Control techniques
Chart
requires sampling regimes at each CCP to be documented.
If
decisions of conformance are being based upon results of sampling
and testing then it must be ensured that schemes are mathematically
based i.e. the use of statistical sampling plans.
Other
relevant statistical techniques include process capability assessment
and statistical process control during CCP monitoring.
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