HACCP STEP-BY-STEP — PART IX
BY CHAR NORTON, RD
Last month we discussed the need to establish the critical limits for each control point selected in a HACCP program. Setting those limits helps verify that the control points are realistic and measurable.
The next step: set up monitoring procedures and identify appropriate corrective actions for when monitoring indicates there has been a failure to meet the established critical limits for a given procedure.
A monitoring procedure must be in place for every identified CCP and all monitoring must be formally documented.This provides ongoing proof that particular actions are completed appropriately and is audited when a HACCP process requires verification.
For example, recording the finished temperature of ground beef is a monitoring procedure associated with a well-known CCP. Further processing or consumption should not proceed unless monitoring shows that the CCP is within specified limits.
In general, continuous monitoring throughout processing is preferable but not always possible. For example, the recorder used on many refrigerators that provides a continuous chart of variations in the unit's interior temperature is an example of continuous monitoring. Such systems will often trigger an early warning system if a process starts to drift out of control.
One of the real benefits of a strong monitoring system is that it can help to reduce product loss if a deviation does occur. If a problem is not detected until a product is ready for sale or service, the cause of the problem may be difficult to determine and product will usually have to be disposed of. On the other hand, if monitoring identifies that a measurements at a particular control point are starting to show unusual variations, corrective action can often be taken before that is necessary.
Monitoring procedures should be spelled out completely in the HACCP plan with the basic what, how, where, who and when of the procedure.
What: Clearly describe the CCP and the limits to be maintained.
How: Describe in detail how the procedure will be implemented.
Where: Note the exact physical location where the measurement must be taken.
Who: Identify the staff members who have access to the CCP and the skills and knowledge to perform monitoring actions. Make clear how the responsibility for monitoring is assigned.
When: Indicate whether monitoring will be continuous or scheduled. If sampling is required, indicate how often this should take place.
In general, there are two types of monitoring: measurement monitoring and observation monitoring.
Many kinds of data collection are used in monitoring procedures. These can include visual observations, lapsed periods of time, measured temperature, measured pH, documentation that particular employee actions have been performed, inspection of records, documentation, etc.
The choice of a measure depends on the nature of the critical limit, the practicality of monitoring methods that may be available, the real-istic time delays specific techniques will require and, significantly, the cost of the monitoring compared to the cost of a potential settlement if a food-borne safety incident occurs.
In contrast, observation monitoring typically involves the use of checklists. A HACCP checklist should contain each item of importance or relevance to the specific CCP and to its critical limit.
Observation monitoring includes sensory and visual checks (sight, smell, touch), visual observations for physical characteristics (presence of foreign materials; package integrity) and checks of sanitary conditions (preoperational and operational sanitation, personnel hygiene practices, etc.).
Observation monitoring is usually done with checklists that are customized for each operational area. When all of the items on a list have been completed, the individual documents its completion by noting time, date and with a signature, and by making any additional notes that are appropriate (see example).
Keep in mind that as you develop your monitoring procedures it's imperative that recorded data be observed as within the boundaries of the specified critical limit. Too often, operators starting the HACCP process simply begin to collect data, as if data for its own sake will make food safety happen.
A similar situation can exist in observation monitoring, where one can easily include observations related to company dress code policies unrelated to personal hygiene, such as noting offensive logos on a uniform rather than limiting the observation only to whether it is clean and changed daily.
While observation monitoring might seem easy, it's often difficult to manage because comparisons to critical limits require interpretation. The person performing the monitoring must be highly trained, skilled and standardized with other observers.
Observers must also be able to make judgment calls . For example, is package damage severe enought to affect food safety?
Measurement monitoring is more exact when applied to quantitative limits like temperature, which can be recorded on data sheets or control charts. These should be designed to be easily interpreted, demonstrate trends, and highlight subtle changes.
The advantage of instrument monitoring is in limiting the need for interpretations, reducing the chance of error. Technology today makes automating many measurements and tracking product from farm to fork possible.
On the other hand, when instrumentation is used to monitor CCPs, equipment reliability must be maintained, with regular testing and calibration as recommended by the manufacturer.
Very sophisticated analytical or microbiological testing is available to monitor the CCPs. However, such methods are not always practical on a continual basis. An operator may want to perform such tests initially to identify potential problem areas, but then rely on more traditional monitoring during ordinary operations. Time delays, practicality and the cost are all valid reasons for choosing other measurement techniques. Again, this is the kind of decision that must be made with a careful weighing of the severity and risk of a potential compromise of the CCP.
Next month we'll look at how to establish procedures to confirm that a HACCP System is working effectively.
Charnette Norton is vice president of Romano Gatland of Texas, foodservice consultants & planners worldwide, in the regional office located in Missouri City, TX. Presently, she is serving on active duty in Bosnia as part of U.S. Operation Enduring Freedom. Char Norton and Ruby Puckett coauthored the book "HACCP, The Future Challenge—Practical Application for the Foodservice Administrator."