Cleaning and Sanitizing Monitoring Log GENERIC
Lessons from Foodborne Illness Cases: What to Do After The Plan is Approved?
The Boars Head incident is still being investigated. There are lessons, however, about what to do differently, what actions are needed, after the HACCP Plan is approved, to make it more effective.
A well designed HACCP Plan will have two basic components: hazards and risks; and actions needed to reduce or eliminate those risks. The first component is based on previous illnesses and scientific research: what risks and hazards have been associated with foods in the past? Second, based on those risks, what actions are needed to reduce or eliminate the risks. The first part is previous fact and science while the second promises future action. The severity of risk linked to a food decides the diligence required, whether action should rely on employee behavior, training and facility design; or whether more stringent actions are needed such as are found in critical control points (CCP).
The Boars Head investigation is ongoing and, for this moment, it is impossible to state any conclusions about cause and fault of this incident. However, there are lessons to be learned, lessons to be adapted to any HACCP Plan.
Acceding to FSIS inspections, the Boars Head management relied on their prerequisite programs (PRP), primarily sanitation measures, combined with Listeria sampling procedures, to reduce the risk to their ready to eat deli meats. There is no reference to critical control points (a more stringent means of risk management) by the FSIS inspector.
Some procedures (changing PPE gear between production lines, for example) were not written into the food safety plan but were assumed, perhaps as a part of employee orientation and training. Inspections implied that, because of Listeria recovered on the food pallet, the bacteria could move throughout the production area., on employees or equipment.
The inspection report does not mention whether or not the facility plan contained critical control points and whether or not supervisors were conducting regular audits to verify their food safety plan’s effectiveness. A clear assumption. However, is that if those items were in the plan, they were not effectively followed.
Here are some lessons to be adapted into any HACCP Plan:
1) Prerequisite programs – pest control,, sanitation, employee training, facility maintenance – while these programs cannot stand on their own, they are still very important. Conduct daily audits to note problems;
2) Employee Training – Employees must be familiar with and skilled to use PRPs and any other food safety programs. Be sure to hold regular meetings to explain the programs, post signs throughout the facility as reminders and, most important, PRACTICE!! It’s said that an individual must be able to practice 7-10 times to be able to perform an activity without prompting. Allow regular practice in the presence of an expert who has modeled the behavior – give positive feedback;
3) Clearly state the requirements to reduce the stated risks (‘critical limits’). Critical limits must be stated in clear measurable language that any employee can understand;
4) Monitoring – how will those critical limits be measured and evaluated? Be sure the measuring equipment is calibrated and approved for its intended use;
5) Correct Problems Now! – Correct problems immediately, explain the problem to employees, conduct a retraining session if needed;
6) Write It Down! – Keep written records of how everything is going
7) Verify – Check your records daily and adjust the plan if needed (remember that too many changes might need your regulatory agency’s prior approval)
While it is time consuming to explain, monitor and verify the HACCP components, especially after explaining it once to the staff, employees will appreciate your attention and concern about making the Plan efficient and effective.