How to effectively conduct the annual HACCP evaluation?

The HACCP plan should be a living document that continuously and accurately reflects the current operations. This ensures that the company's food safety system remains up to date.

1. Why do it?

The purpose of the assessment is to ensure that the HACCP plan is sufficient to control food safety hazards that are reasonably likely to occur.

The FDA's related requirements specify that the assessment must be conducted by personnel who meet the training requirements described in part 123.10. China's GBT 22000, GBT 27341, and the Global Food Safety Initiative (GFSI) have related requirements for enterprises certified by authorized SQF, BRC, FSSC 22000, or IFS.

BRC Issue 8 (2.14.1 HACCP Plan Review): The HACCP food safety team should review the HACCP plan and prerequisite programs that may affect product safety at least once a year and before any changes occur. Appropriate changes resulting from the review should be incorporated into the HACCP plan and/or prerequisite programs, fully documented, and verification recorded.

GBT 22000 (7.7 Corrective Actions for Critical Limit Deviations): When monitoring results of a critical limit repeatedly deviate or the cause of deviation involves the control capability of the corresponding control measures, the HACCP team should reassess the effectiveness and suitability of the related control measures, improve and update them if necessary.

2. When to do it?

The HACCP plan should be evaluated at least once a year, and also whenever changes occur that affect the hazard analysis or HACCP plan.

Including:

1) Change or add new ingredients

2) Modify the formula

3) New equipment

4) New packaging

5) New production process

6) Change in the intended consumer group

3. What to do?

The annual evaluation of the HACCP plan should include a comprehensive review of the food safety system to verify whether the factory's HACCP plan and prerequisite programs comply with the written requirements. An accurate evaluation plan should be prepared in advance, which is a key part of the HACCP system verification process.

Changes to the HACCP system during the year should be recorded on the evaluation worksheet. When recording, it is necessary to assess whether these changes have any impact on product description, flow diagrams, hazard analysis, or the HACCP plan.

Understand new regulatory requirements and changes in scientific literature published in peer-reviewed journals. These changes may affect identified hazards or limits, thereby impacting the determination of critical control points. Therefore, ensure these changes are correctly incorporated into your HACCP plan and supporting documents.

4. How to do it?

Document Review

Review all written HACCP plans, SSOPs, and related prerequisite programs to verify and check accuracy. All records must be reviewed to ensure they meet the plan's requirements.

Carefully read each plan and confirm whether these plans accurately summarize the company's current operations and practices. It is also important to ensure that all created flow diagrams are related to hazard analysis.

The process flow diagram represents the entire production process from receiving raw materials to finished product shipment. Care must be taken not to overlook any part of the process, such as rework, product returns, or auxiliary inputs like water, ice, and air.

On-site Inspection

Factory audits are required to verify strict compliance with the HACCP plan and accurate record-keeping.

When conducting factory audits, be sure to include:

1) Flow diagram verification, i.e., walkthrough of the production process.

2) CCP monitoring review

3) CCP verification requirements

4) Monitoring of critical operational parameters

Record Review

Thoroughly review CCP records, SSOP records, PRP records, and corrective action records. Verify whether the written plans and records comply.

Review all product test results, including microbiological tests, food contact surface tests, and environmental tests, as part of the verification process. These test results demonstrate whether hazards are effectively controlled.

Supporting Documents

Complete all decision documents for CCPs and critical operational parameters. These documents are part of the HACCP plan's supporting documentation.

Decision documents capture the relevant thought processes, including those used to identify hazards, CCPs, and critical or target limits used to maintain control. Relevant scientific or monitoring support documents should also be outlined in the decision documents for verification purposes.

Reassessment Report

Effective HACCP reassessment also requires reviewing documents and preparing an evaluation report, which should include a summary of the process and reassessment of any subsequent changes.

At minimum, it should include an overview of the scientific principles supporting the plan and in-plant verification data. Additionally, completing the reassessment checklist also demonstrates the content of the factory evaluation.

Ensure the verification worksheet summarizes the CCPs, including critical limits and operational parameters, as well as the factory's specific objectives.

5. Who should do it?

The assessment can be completed by internal personnel; however, it is best for the company to have a third party conduct a HACCP plan assessment at an appropriate time. This helps ensure all steps are accurately completed and documented.

Different perspectives may identify important issues. This practice may help the company prevent foodborne illness outbreaks, major recalls, and regulatory non-compliance.

6. Final words

Food companies should conduct HACCP assessments at appropriate times to help effectively self-inspect and improve, preventing catastrophic situations that could cause the entire company to collapse.