Food safety in the brewery (with notes)

Food Safety in the Brewery

HACCP

Outline • What is HACCP? • Why HACCP? • 7 Principles • 12 Steps

Terminology • HACCP: Hazard Analysis Critical Control Points • HACCP plan: The written document describing the

procedures to be used for controlling food hazards using the HACCP method

• GMPs: Good Manufacturing Practices - One of the foundations for food safety and required by the FDA

• Critical Control Point (CCP): A point during the food manufacturing process where a food safety hazard has to be controlled or the risk of injury becomes unacceptably high.

• Critical Limit: This is the tolerance allowed before a risk becomes unacceptable. May be regulatory or self-determined tolerances.

What is HACCP? HACCP was developed in the 1960’s by Pillsbury in conjunction with NASA for the space program. The current methods of food inspection were not adequate to ensure that astronauts would not get sick in space with no medical help. HACCP is a science based process model for the identification and prevention of food safety hazards during manufacture. Although HACCP is designed only for safety, the same risk based analysis is used as the basis for many quality systems. HACCP is required for certain industries under FDA and USDA regulations. Breweries are not currently under a regulatory HACCP requirement.

Food Safety Hazards • Biological

• Viruses • Bacteria • Parasites

• Chemical • Agricultural • Sanitation • Allergens • Lubricants

• Physical • Wood • Metal • Glass

• Radiological • Required under FSMA • Sources can include equipment and well water

Why HACCP? • FDA – While breweries are not required to have a

HACCP plan, they are required as food manufacturers to produce safe food under CFR 21

• FSMA requires a written food safety plan • Customers expect food they consume to be safe • Recalls are costly and often result in businesses being

forced to close • Reprocessing and repacking are extremely costly and

wasteful • Due diligence – In the case of a lawsuit, a well written

and appropriate plan that is followed can reduce liability

Designing a HACCP Plan There are 5 preliminary steps to be completed before actually developing a HACCP plan. 1. Assemble a HACCP team – should be as cross-

functional as possible 2. Describe your product 3. Identify the intended use – also include uses that

you can reasonably foresee consumers doing 4. Construct a process flow diagram 5. Verify the flow diagram by actually walking through

the process.

Designing a HACCP Plan There are 7 principles to a HACCP plan. 1. Conduct a hazard analysis – determine hazards and

identify preventive measures 2. Identify Critical Control Points (CCP) 3. Establish critical limits for each CCP identified 4. Establish CCP monitoring methods 5. Establish corrective actions 6. Establish record keeping procedures 7. Establish verification methods

Principle 1 Conduct a hazard analysis for each step in your process. Be sure to consider the 4 sources of potential contamination and how they are controlled. Example: Malt receiving. What possible contamination can occur here? Some of the hazards will be different if you are receiving it by railcar vs pallet. How do you verify chemical hazards such as pesticide residue? How about physical such as wood or metal? Example: Bottling. The most obvious is physical and that is glass inclusions.

Principle 2 Identify critical control points. Depending upon your brewery setup, you may have only one or two CCPs. If you have identified many CCPs, then the monitoring, verification, and corrective action process can be overwhelming. There is no “right” number of CCPs to have in any plant but if you seem to have a high number, you may wish to reevaluate the hazard analysis to see if the hazard is controlled by a pre-requisite program or if it is controlled further downstream.

Principle 3 Establish Critical Limits. Each CCP must have a critical limit associated with it. A critical limit is either a minimum or maximum value that is acceptable for preventing an identified hazard. These limits can be based on experience, scientific literature, or industry and governmental guidelines. Just be sure to document your reasoning.

Principle 4 Establish CCP Monitoring Methods. Monitoring can be done either automatically or manually by an operator. If a non-continuous method is used, the sampling program must be statistically valid. A written SOP for the monitoring method must be developed and maintained. All employees responsible for HACCP checks should be given training and that training needs to be documented

Principle 5 Establish Corrective Actions. Now that you have your CCPs and monitoring taken care of, what do you do if you fail your CCP limits? You must have documented procedures for corrective actions each time there is a deviation from your HACCP limits. These corrective action records must be complete and maintained for a designated time period. A HACCP deviation log lets you easily track and trend failures of the system for evaluation in the future.

Principle 6 Establish Record Keeping Procedures. A written policy or SOP defining how you will maintain your records is required. These records include the HACCP plan itself, risk assessments if separate from the plan, CCP monitoring records, deviation records and verification records along with anything else associated with the plan.

Principle 7 Establish Verification Procedures. A written plan on the methods use to verify and validate the HACCP plan is required. Verification is the process used to ensure the HACCP plan is working as intended. For example – are records complete, including monitoring and corrective action documents? Validation is the process to make sure the plan does what it is supposed to do i.e. make safe food.

Prerequisite Programs HACCP is a strong tool but it cannot work effectively by itself. A strong HACCP program also requires effective pre-requisite programs and management commitment. Without all three components, a food safety system will fail. Pre-requisite programs typically control hazards early in the process and minimize the possibility of contamination so that the HACCP plan can focus on those things that can’t be controlled prior to product release. Management commitment is required to maintain these programs and supply the resources necessary.

Prerequisite Programs Pre-requisite programs include items such as material receiving, chemical control, allergen control, GMPs, audits, pest control, preventive maintenance, and traceability. This is not an all inclusive list and each plant has to make its own decisions on what programs are needed and how to implement and maintain them. That however is another lesson.

Information provided by:

Anthony McCollum LinkedIn: Profile

[email protected]

2014

Notes for Food Safety in the Brewery

Slide 7: Designing a HACCP Plan

1.In a small brewery, you may only be able to have 2 people on your team. Large breweries can supply more but an ideal team size should in most cases be limited to 5-7 people 2.Don’t just say beer. You have an alcoholic beverage made from malt and hops with an alcohol range from 4-12% perhaps. Do you use fruit or flavorings in your product? Be thorough 3.Beer is not just for drinking you know. Consumers sometimes do things you do not reasonably expect but that does not mean you need to address all of them. As an example, a certain national brand of aerosol whipped cream gets a large influx of questions every year in February asking if it is safe to use their product in an intimate manner. This is not to be expected but people do cook with beer. 4.You can do this at the table 5.Walk the process and note any equipment such as pumps, filters, etc that were not included in your table top construction of the flow diagram.

Slide 9: Principle 1

Some possible preventive measures at receiving may be temperature if you are dealing with a sensitive material or a COA or letter of guarantee from a supplier that the malt is free of pesticide residue. There are many possible measures for each step along the process flow diagram and there is no need to list every single one as long as what you list is adequate.

Slide 12: Principle 4

Examples of continuous monitoring include temperature recorders, flow rate or pressure recorders, etc. Manual sampling may be recording regulated substances onto a batch sheet or sampling 30 cans an hour or similar.

Slide 13: Principle 5

State or Federal regulations that pertain to your business may determine how long you are legally required to maintain these records. In the absence of those regulations, a quick attorney consultation will give you an idea of best practices.

Slide 15: Principle 7

Verification methods may include audits of records, periodic record review by management, and review/revision of the HACCP plan itself. Validating the plan can be done by challenging the system such as using test cans with foreign material to see if rinsers will remove it. Validation overlaps to a degree with verification because if the record review and data trends indicate multiple failures, your plan probably is not stringent enough and needs better control before the CCPs