Meat&Poultry - August 2011 - 40

Meat Perspectives

Knowing limitations
HACCP alone is not a food safety silver bullet
BY KERRI HARRIS AND JEFF SAVELL
meatpoultry@sosland.com

M&P is proud to introduce “Meat Perspectives,” a quarterly column focusing on industry issues related to food safety, HACCP programs and meat science. M&P also welcomes Kerri Harris and Jeff Savell (bios at end of article) to its editorial stable of hired hands, enhancing the expertise-rich content readers have come to expect.
n Dec. 29, 1995, the Food Safety and Inspection Service published an advance notice of proposed rulemaking and additional rulemaking proposals describing the agency’s strategy for mandating Hazard Analysis and Critical Control Point (HACCP) systems. The Pathogen Reduction; Hazard Analysis and Critical Control Point Systems; Final Rule was issued on July 25, 1996, and HACCP was implemented in all inspected meat and poultry establishments between January of 1998 and 2000. The HACCP concept depends on using seven principles to identify and control Harris food-safet y hazards throughout a production process. HACCP systems are and should be dynamic to allow for modifications in production and/or changes in the food-safety hazards. So, change should not be a surprise. HowSavell ever, in looking back to 1998, and then thinking about where we are now, it appears the expectations for HACCP may have changed more than the HACCP systems.

A food-safety tool
However, we need to remember that HACCP is a tool that focuses on food safety. It should not be a stand-alone program but rather part of a foodsafety system. Unfortunately, it seems that both the industry and regulatory agencies have tried to force HACCP into being more. Maybe the expectations of HACCP are like the saying that “if the only tool you have is a hammer, then everything starts to look like a nail,” and some people forget they have other tools, such as prerequisite programs, that should be part of their food safety systems. This is not meant to imply that HACCP does not work – it works well. Properly designed HACCP plans in food processing operations that can apply effective controls achieve positive results. Also, technologies, such as irradiation and high-pressure pasteurization, are being used for some

finished raw products. Unfortunately, in raw meat and poultry production, HACCP’s capability to prevent, eliminate or reduce pathogens is questionable due to the inherent risks associated with raw products and the lack of a true critical control point in these processes. When mandatory HACCP was first implemented in raw meat and poultry processes, most people seemed to understand that CCPs were designed to reduce risk (i.e., lower pathogen counts) rather than eliminate the risk altogether. Some processors initially tried to use the term “control points” rather than “critical control points” to distinguish the limitations of the interventions. However, the language in the HACCP regulation did not clearly allow for the incorporation of control measures or other prerequisite programs, and establishments were encouraged to include these process steps in their HACCP plans as CCPs – even though these steps did not truly prevent, eliminate, or reduce the pathogen to an acceptable level. Over time, FSIS began to acknowledge and accept the use of prerequisite programs. For example, the Oct. 7, 2002, Federal Register Notice (Vol. 67, No. 194) on dealing with E. coli O157:H7 contamination of beef products “…grinders that have purchase specifications that require that all of their suppliers have one or more CCPs in their HACCP plans that are validated to eliminate or reduce E. coli O157:H7 below detectable levels and that ensure these specifications are met may determine that no additional steps to address E. coli O157:H7 are necessary in their production process for ground beef. However, given the nature of the pathogen, FSIS strongly

40 • Meat&Poultry • August 2011 • www.MeatPoultry.com

http://www.MeatPoultry.com

Meat&Poultry - August 2011

Table of Contents for the Digital Edition of Meat&Poultry - August 2011