Saturday, January 31, 2009

Hazard Anaysis of Critical Control Points

Reading this material on hazard analysis reminded me of when I worked in the food production industry. I had to have special training from the Food Processors Institute (FPI) on Hazard Analysis and Critical Control Points (HACCP) the tenets and process of HACCP and those we are learning here on risk assessment are quite similar.
HACCP process has several steps. The seven principles are: (1) hazard analysis, (2) critical control point identification, (3) establishment of critical limits, (4) monitoring procedures, (5) corrective actions, (6) record keeping, and (7) verification procedures. From http://www.fsis.usda.gov/OA/background/keyhaccp.htm more on these points in a bit.
While HACCP is primarily concerned with human health and not so much the environment, I thought the two approaches were quite similar. I worked in both the fruit juice concentrate plants and also in sun dried foods, each had its own complications but the HACCP teams I put together were made up of the same types of individuals. Just as we are learing, I had a representative from every aspect of production, even those who were not directly involved in production. HACCP is not a worker safety program, but one to protect the public from hazards in your product.


As such I had mechanics, secretaries, managers, fork lift drivers, cookers, and farmers on my teams.
HACCP is relatively new to the food industry, you think we have food scares and recalls now, you should look back in history. A forerunner to HACCP was developed in the form of production process monitoring during World War II because traditional "end of the pipe" testing wasn't an efficient way to ferret out artillery shells that would not explode. Sound familiar? That same thing could be said about any industrial pollution, not just in food.

Let me tell you a bit more about HACCP-
from http://en.wikipedia.org/wiki/Hazard_Analysis_and_Critical_Control_Points

Hazard Analysis and Critical Control Points (HACCP) is a systematic preventive approach to food and pharmaceutical safety that addresses physical,chemical, and biological hazards so that key actions, known as Critical Control Points (CCP's) can be taken to reduce or eliminate the risk of the hazards being realized.
Based on risk-assessment, HACCP plans allow both industry and government to allocate their resources efficiently
In the US, HACCP compliance is regulated by 21 CFR part 120 and 123. instaid of 40 CFR which contains RCRA, 29 CFR which regulates HAZWOPER remediation workers. Or 49 CFR which contains rules for transporting hazardous materials

As I said before there are seven principles in the HACCP process:
Principle 1: Conduct a hazard analysis. Determine hazards and identify the preventive measures that can be applied to control these hazards. For HACCP purposes a hazard is any biological, chemical, or physical property that could endanger human life or health.
Principle 2: Identify critical control points. A Critical Control Point (CCP) is a point, step, or procedure at which control can be applied and, as a result, hazard can be prevented, eliminated, or reduced to an acceptable level.
Principle 3: Establish critical limits for each critical control point. A critical limit is the maximum or minimum value to which a physical, biological, or chemical hazard must be controlled at a critical control point to prevent, eliminate, or reduce to an acceptable level.
Principle 4: Establish critical control point monitoring requirements. Monitoring activities are necessary to ensure that the process is under control at each critical control point.
Principle 5: Establish corrective actions. These are actions to be taken when monitoring indicates a deviation from an established critical limit. The final rule requires a plant's HACCP plan to identify the corrective actions to be taken if a critical limit is not met.
Principle 6: Establish record keeping procedures. The HACCP regulation requires that all plants maintain certain documents, including its hazard analysis and written HACCP plan, and records documenting the monitoring of critical control points, critical limits, verification activities, and the handling of processing deviations.
Principle 7: Establish procedures for ensuring the HACCP system is working as intended. Validation ensures that the plants do what they were designed to do; that is, they are successful in ensuring the production of safe product. Plants will be required to validate their own HACCP plans
Taken from http://www.cfsan.fda.gov/~lrd/bghaccp.html

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