What is the 4th HACCP principle?

Definition and Purpose

A monitoring system for each CCP is necessary to demonstrate it is operating within a defined critical limit, which significantly reduces the risk of unsafe product reaching the consumer.  Codex describes monitoring as “the act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control”1. Monitoring operational limits creates an opportunity to act before a deviation occurs at a critical limit. Recorded observations and measurements also provide documented evidence to support verification activities and legal compliance.

Measurements and Observations

Monitoring must provide rapid, accurate and repeatable results that relate back to critical and operational (target) limits. There are generally two ways to monitor a critical control point: measurement and observation. Measurements usually include temperature, time, pH, Aw, etc. Whereas observations may focus on colour change in food, visually checking operation of a metal detector, inspecting the integrity of a sieve, etc.

Methods of Monitoring

Monitoring procedures are dependent on three factors: critical limits, capability of the chosen method or device to detect a deviation and process throughput. Observations and measurements can be performed on-line or off-line. On-line systems may take measurements continuously or at intervals during the process1,2. Continuously monitoring systems may also require additional manual checks to verify accuracy. Off-line systems take samples for rapid testing elsewhere, using instruments such as calibrated pH or Aw meters1,2. Observational systems also check if a critical limit can be detected and control mechanisms in place for a CCP are working as expected.

Equipment used to monitor operational and critical limits must be maintained and calibrated to provide reliable results1,2.

Monitoring Frequency

The frequency of discontinuous monitoring should be enough to provide acceptable assurance that a CCP is under control1. It can be time based (e.g. hourly) or production based (e.g. each batch). The rate of frequency must permit enough time to regain control over the process and deal with affected product. This is determined by sound historical knowledge of the product and process. Factors to consider include:

• level of tolerance between operating limit and critical limit1
• amount of product at risk if a deviation should occur at a CCP1
• variations in process and product1,2
• automated or manual processes2
• history of previous checks2

A corrective action may also temporarily increase frequency of monitoring.

Monitoring Personnel

Consideration should be given in assigning responsibility for monitoring activities1. CCP monitoring is often associated with production personnel because they are familiar with the process. Production supervisors or managers and quality assurance personnel will usually verify the monitoring activity. Personnel assigned to monitoring CCP’s must be trained and demonstrate competency in relevant procedures. Records of training and competency assessment should be maintained2.

Documentation and Records

The monitoring system must be documented and outline the following:

• specify what control parameter(s) will be monitored
• state the frequency of measurements and/or observations
• specify who is responsible for performing and overseeing the monitoring activity
• define or refer to a procedure in how to conduct the monitoring activity, including details of equipment to be used2
• detail where the results of monitoring are recorded with specific reference to documents and/or online systems2
• List any supporting, procedures, work instructions and specifications2.

Accurate monitoring records show the process was under control or appropriate corrective action was taken. A record must state the date, time and result of the monitoring activity. All monitoring records must be signed by the person conducting the monitoring activity and countersigned by the person responsible for checking records, such as a supervisor or manager.

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References

Food Standards Agency (2020). Principle 5: Establish a Corrective Action Plan. [online]. Available at:  https://myhaccp.food.gov.uk/help/guidance/principle-5-establish-a-corrective-action-plan%20Accessed%20on%2001/11/20#help-31  Accessed on 01/1120

Food and Agriculture Organisation of the United Nations (unknown). Section 3 – THE HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM [online]. Available at: http://www.fao.org/3/w8088e/w8088e05.htm#module%2010%20%20%20establish%20corrective%20actions%20%20%20task%2010principle%205  Accessed on 01/1120

HACCP (Hazard Analysis Critical Control Point) is defined as a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. The goal of HACCP is to prevent and reduce the occurrence of food safety hazards. 

It is based on the application of scientific principles to food processing and production. The University of Nebraska has been providing educational programs and assistance to food processing and food production professionals since 1993.

HACCP training is for meat and poultry processors, food processors, and food service operators. UNL provides introductory HACCP workshops that are accredited by the International HACCP Alliance. For more information about upcoming HACCP trainings, contact Dr. Byron Chaves.

The Seven Principles of HACCP

HACCP is based on seven principles, which are the most important steps in writing a HACCP plan. The first two steps provide the foundation for the HACCP plan. The remaining five steps are the application steps of the HACCP plan and provide the structure for conducting the workings of the HACCP plan in the processing plant.

Principle 1: Conduct a Hazard Analysis

The application of this principle involves listing the steps in the process and identifying where significant hazards are likely to occur. The HACCP team will focus on hazards that can be prevented, eliminated or controlled by the HACCP plan. A justification for including or excluding the hazard is reported and possible control measures are identified.

Principle 2: Determine Critical Control Points (CCPs)

A critical control point (CCP) is a point, step or procedure at which control can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable levels. The HACCP team will use a CCP decision tree to help identify the critical control points in the process. A critical control point may control more that one food safety hazard or in some cases more than one CCP is needed to control a single hazard. The number of CCP's needed depends on the processing steps and the control needed to assure food safety.

Principle 3: Establish Critical Limits

A critical limit (CL) is the maximum and/or minimum value to which a biological, chemical, or physical parameter must be controlled at a CCP to prevent, eliminate, or reduce to an acceptable level the occurrence of a food safety hazard. The critical limit is usually a measure such as time, temperature, water activity (aw), pH, weight, or some other measure that is based on scientific literature and/or regulatory standards.

Principle 4: Establish Monitoring Procedures

The HACCP team will describe monitoring procedures for the measurement of the critical limit at each critical control point. Monitoring procedures should describe how the measurement will be taken, when the measurement is taken, who is responsible for the measurement and how frequently the measurement is taken during production.

Principle 5: Establish Corrective Actions

Corrective actions are the procedures that are followed when a deviation in a critical limit occurs. The HACCP team will identify the steps that will be taken to prevent potentially hazardous food from entering the food chain and the steps that are needed to correct the process. This usually includes identification of the problems and the steps taken to assure that the problem will not occur again.

Principle 6: Establish Verification Procedures

Those activities, other than monitoring, that determine the validity of the HACCP plan and that the system is operating according to the plan. The HACCP team may identify activities such as auditing of CCP's, record review, prior shipment review, instrument calibration and product testing as part of the verification activities.

Principle 7: Establish Record-keeping and Documentation Procedures

A key component of the HACCP plan is recording information that can be used to prove that the food was produced safely. The records also need to include information about the HACCP plan. Record should include information on the HACCP Team, product description, flow diagrams, the hazard analysis, the CCP's identified, Critical Limits, Monitoring System, Corrective Actions, Recordkeeping Procedures, and Verification Procedures.

“Who is going to measure it?”

“How are they going to do it?”

These are just a few of the questions a Hazard Analysis and Critical Control Points team needs to answer when establishing monitoring procedures for a food safety plan, says Donna Schaffner. The independent HACCP consultant microbiologist and the Associate Director of Food Safety, Quality Assurance and Training for Rutgers Food Innovation Center, Schaffner says keeping an eye on procedures will help keep food companies out of trouble

Monitoring procedures will aide food companies primarily in three ways:

• Control and tracking of critical limits;
• Determining when action needs to be taken when deviation occurs for a critical limit; and
• Provide records that a HACCP plan was kept in compliance.

It is recommended that monitoring procedures be continuous. However, it isn’t always a straightforward process to set a protocol for a time-consuming component like microbiological testing, when compared to physical and chemical protocols. Depending on the product and how it is being processed, monitoring procedures will vary significantly.

However, two things remain the same for every monitoring procedure – attention to detail and personnel training.

To help maintain a structured monitoring protocol, Schaffner advises HACCP teams to create a time interval which includes every detail from when a specific measurement needs to be taken.

Specific methods for taking measurements must also be included. The correct equipment must be selected. Employees must be trained in its proper use and maintenance, including calibration procedures.

“This information needs to be written into the HACCP plan and then followed. If a HACCP team says a measurement needs to be taken every hour, then it has to be taken every hour,” explains Schaffner.

“Most likely, monitoring critical limits won’t be the only task an employee has throughout the day, but if they get side tracked and don’t keep up with set monitoring times and conduct a measurement incorrectly, it can cause a company to fall out of compliance with its HACCP plan, which can put them at risk for a recall. This is why an investment is made into training personnel to do the job properly.”

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