Meat&Poultry - February 2012 - 72

Meat Perspectives

Reassessing HACCP
Ongoing evaluation of prerequisite programs should be a priority
BY KERRI HARRIS AND JEFF SAVELL
meatpoultry@sosland.com

T

he Food Safety and Inspection Service’s proposed rule entitled ia coli in Certain Raw Beef Products,” which was released on Sept. 20, 2011, states that establishments should reassess their Hazard Analysis and Critical Control Point plans, Sanitation Standard Operating Procedures, or other prerequisite programs when they have a first-stage screen positive (stx and eae) because they may not be adequately controlling a reasonably likely to-occur food-safety hazard. Simply stated, reassessment is the process of reviewing and evaluating the

ard and Critical Control Point System (9 CFR 417) includes the following statements for reassessment: ■ 417.2(d)(2) – The HACCP plan shall be dated and signed: (iii) At least annually, upon reassessment, as required under § 417.4(a)(3) of this part. ■ 417.3 (b) – If a deviation not covered by a specified corrective action occurs, or if another unforeseen hazard arises, the establishment shall (4) Perform or obtain reassessment by an individual trained in accordance with § 417.7 of this part, to determine whether the newly identified deviation or other unforeseen hazard should be incorporated into the HACCP plan. ■ 417.4 (a)(3) – Reassessment of the HACCP plan. Every establishment shall reassess the adequacy of the HACCP plan at least annually and whenever any changes occur that could affect the hazard analysis or alter the HACCP plan. Such changes may include, but are not limited to, changes in: raw materials or source of raw materi-

als; product formulation; slaughter or processing methods or systems; production volume; personnel; packaging; fi nished product distribution systems; or the intended use or consumers of the fi nished product. The reassessment shall be performed by an individual trained in accordance with § 417.7 of this part. The HACCP plan shall be modified immediately whenever a reassessment reveals that the plan no longer meets the requirements of 417.2(c) of this part. ■ 417.4 (b) – Reassessment of the hazard analysis. Any establishment that does not have a HACCP plan because a hazard analysis has revealed no food-safety hazards that are reasonably likely to occur shall reassess the adequacy of the hazard analysis whenever a change occurs that could reasonably affect whether a food-safety hazard exists. Such changes may include, but are not limited to, changes in: raw materials or source of raw materials; product formulation; slaughter or processing

“Shiga Toxin-Producing Escherich-

Harris

Savell

HACCP plan and related programs to ensure they are effective and implemented correctly. However, proper reassessment is not as simple as it sounds. Reassessment is not a new requirement. The Pathogen Reduction; Haz-

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Meat&Poultry - February 2012

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