Developing HACCP solves

Food companies, including those specializing in food-grade ingredients, food contact materials and packaging as well as service providers, must develop HACCP programs using a “clean-sheet” approach rather than follow the established HACCP templates used for other specific food processor types. This approach should be based on the fit of their operations (e.g., high-risk protein, low-risk protein, liquid or dry ingredient, chemical, packaging or logistics) to existing HACCP models and templates and/or the unique aspects of the operational models and food risks.

Effective and workable approaches to mitigating the above issues should consider designing and customizing HACCP training to include product and unique process flow. To best accomplish this, several issues must be addressed, including the following:

• Training needs to be more open to specific and unique industry and operational needs. It further needs to be “fit for the use” of the related product and process food safety risk. For example, in packaging with high engineering of product, training needs to focus on the ultimate process design and capability developed and maintained by process engineers.

• Content registers must be developed to provide elements and direction for HACCP program design, development and implementation. HACCP teams should work under the direction of a competent and advanced HACCP-trained coordinator to design and establish the content register during development and implementation, in addition to using the established five-step approach and seven HACCP principles per Codex Alimentarius. The content register should address risks and control measures that are unique to operations, finished product and services that impact food safety (e.g., pest control, service contractors, trainings, comanufacturers).

• The HACCP development process needs to be open and channel aspects of the program to the risks associated with nontraditional HACCP food applications (see “New HACCP Applications,”) or service operations.

• In-depth reviews and assessments should be conducted by an appointed HACCP/food safety team and/or outside expert(s) with emphasis in the following areas:

• Food ingredients, including dry, mill, liquid, whole grains, snack foods, etc.

• Potential pathogens unique to raw materials/ingredients, potentially introduced from processing conditions and the environment, water activity, allergen control program, operational product changeover, food contact utensils, maintenance tools, microbial air quality based on air-handling units, process room air quality and pressure, critical equipment necessary for safe food production, environmental monitoring programs, cleaning in-place and cleaning out-of-place, plant construction monitoring program during operation, preventive maintenance program for critical parts and aligned equipment, employee traffic, material and product handling, contact packaging supplier, etc.

• Food contact packaging (i.e., flexible films, lids, paper, converters, rigid plastic, glass, metal), including source and validation of inks and dyes (domestic or imported), compressed air quality, type of lubricants (food-grade versus non-food-grade, soy- or mineral oil-based), physical and chemical properties with reference to ink, migration and permeability, compatibility and reaction of adhesives/inks under various handling conditions by consumers such as heat and cold. These could be mitigated through documented material and ingredient vendor/supplier validation studies or in-house finished product shelf-life studies.

• Service providers (e.g., transport, logistics, uniforms), including airflow and circulation during handling and transportation of refrigerated and frozen foods, approved laundry chemicals, cleaning water temperatures, verification and validation of cleaning uniforms during storage and transportation, and driver and personnel training on critical responsibilities that impact food safety.