A Layman’s Guide to HACCP at the Retail Level – What is Working and What is Not? Gary R. Acuff Professor, Food Microbiology Head, Department of Animal.

A Layman’s Guide to HACCP at the Retail Level – What is Working and What is Not?

Gary R. AcuffProfessor, Food Microbiology

Head, Department of Animal ScienceTexas A&M University, College Station, Texas

President, International Association for Food Protection

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Responsibility for Food Safety

Production Processing Distribution Retail Consumer

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Hazard Analysis andCritical Control Point System

Seven Principles Hazard Analysis Critical Control Points Critical Limits Monitoring Corrective Action Verification Recordkeeping

Has worked well for processing sector.

Application to retail operations more

difficult.

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http://www.cfsan.fda.gov

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Active Managerial Control

Incorporation of specific actions or procedures by management to focus control over foodborne illness risk factors identified by CDC. Food from Unsafe Sources Inadequate Cooking Improper Holding Temperatures Contaminated Equipment Poor Personal Hygiene

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Active Managerial Control

Preventive Elements of effective food safety

management may include: Certified food protection managers

Employee training

Standard operating procedures (SOPs) Recipe cards (with critical limits) Purchase specifications Equipment and facility design and maintenance

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Active Managerial Control

Preventive Elements of effective food safety

management may include: On-going quality control and assurance Employee health policy Specific goal-oriented plans

Risk Control Plans (RCPs) outlining procedures for control of specific foodborne illness risk factors

Voluntary HACCP implementation

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Ideal Progression for Retail HACCP Implementation (FDA)

Step 1 (Develop Prerequisite Programs) Step 2 (Group Menu Items/Products) Step 3 (Conduct Hazard Analysis) Step 4 (Implement Control Measures and Establish

Critical Limits) Step 5 (Establish Monitoring Procedures) Step 6 (Develop Corrective Actions) Step 7 (Conduct Ongoing Verification) Step 8 (Keep Records) Step 9 (Conduct Periodic Validation)

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Variable Products and Processes

“Textbook HACCP” not practical… Focus on identified high-risk foods (cross-

contamination by raw chicken) Risk factors likely to be managed without

the use of formal recordkeeping. Monitoring extremely important (but may

be by indirect measurement).

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Process Approach to HACCP

Establish control of food preparation processes rather than individual food items.

Divide into 3 food preparation processes Process 1: Food Preparation with No Cook Step Process 2: Preparation for Same Day Service Process 3: Complex Food Preparation

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Process Approach to HACCP

Control measures will generally be the same, based on the number of times the food passes through the temperature “danger zone.”

From FDA Regulator’s Manual

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Process Approach to HACCP

Baked Chicken vs. Meatloaf (Example from FDA Regulator Manual) Unique hazards, but grouped together in the “Same Day

Service” category (Process 2). Salmonella, Campylobacter, Bacillus cereus, Clostridium

perfringens all hazards in chicken. Salmonella, Escherichia coli O157:H7, B. cereus, C.

perfringens hazards in meatloaf. Different hazards, but same control measure (cook to

proper temperature). Proper hot holding or time control for sporeformers.

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Prerequisite Programs

Good Retail Practices (GRPs) Vendor certification programs Training programs Allergen management Buyer specifications Recipe/process instructions First-In-First-Out (FIFO) procedures Other Standard Operating Procedures (SOPs)

Prevent temperature abuse

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Overall Keys to Success

Know food source (suppliers) Control in-house operations

Critical limits from FDA Food Code

Demonstrate support by management Maximize employee training Utilize a process approach Consumer education

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What Is Expected of Consumers?

First time in the food safety chain that consumers become involved.

Display of retail market program information influences perception of retailer’s concern for food safety May influence consumers to also handle

food safely

Provide consumer education information

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Example - “Be Food Safe”

Partnership for Food Safety Education and USDA

Consumer education campaign based on “Clean, Separate, Cook and Chill”

Platform developed for retailers to display

Consistent, simple food safety message

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Retail Market Interviews

HACCP voluntary in most cases Implemented to protect consumer Implemented to protect company

Wide range of implementation of HACCP Some follow full 7 principles

Employ a HACCP Coordinator

Some implement as an “overlaying system”

Most common weakness in system Employee turnover Loss of training investment

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Success

Relies heavily on employees A variety of training is provided (some in-

house, most not) General HACCP training Online training “University” for specific area

Cheese, meat Interactive workgroups

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Success

Relies heavily on employees Must work on existing mindset, from

Corporate to bottom level. Change way of thinking “Food safety takes pictures of us.”

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Monitoring and Recordkeeping

From simple to complex Depends on process, employee

Some keep logs, others do not Very important in case of illness, however Experience with foodborne illness – keep logs

Recordkeeping most difficult part Innovative methods Seek employee input Some not sure of accuracy (seeking automation)

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Corrective Action

Varies significantly Who to call What to do

Specific items and processes

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Verification

Difficult to communicate need to employees Aversion to redundancy

May use third-party groups Need to maintain anonymity Employees may change behavior

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What Does Not Work?

Employee turnover Intensive recordkeeping Complex process Difficult equipment Too much guesswork

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What Works?

Get basics right (gmps), then implement HACCP-like program

Employees Convince employees of importance

Partnership – employees, management, customers, health department

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What Works?

Employees Provide a varied education program

Frequent updates Keep it simple and focused

Total support from corporate and upper management (“Top Down”)

Personalize the customer (incentive)

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What Works?

Employees Make the job easier but make sure the

employee understands why it is important. Meet the needs of employees to meet the

needs of customers Must feel a part of the company and the plan

Customers Make sure customers see implementation

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Favorite Quote

Creative people may try new and different things to be more exciting. Sometimes that throws the system off. So you can’t “cookie cutter” everything. We hate to harness the creativity, but we want the system to work.

Requires a delicate balance of allowing creativity and controlling risky behavior.

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