Meat&Poultry - February 2012 - 74

REASSESSING HACCP

methods or systems; production volume; packaging; finished product distribution systems; or the intended use or consumers of the finished product. As with many other aspects of the HACCP regulation, it seems that the expectations for reassessments have changed over time. Each year we dread our annual reassessment because it is a painful process and one that we question if we are performing correctly.

■ Do we have data or documentation to support removing a hazard? ■ Has our process changed to prevent the hazard from being an issue for this process? ■ Do our pre-requisite programs, including purchase specification programs, still support the decisions that we made in the hazard analysis? ■ Are the CCPs and control measures being used to control the identified hazards appropriate? ■ Have we documented the use of the CCP decision tree? ■ Is the CCP adequately controlling the identified hazard or does it continue to occur in the product? ■ Do we need additional CCPs or controls to prevent, eliminate, or reduce the hazard to an acceptable level (or in the case of E. coli O157:H7, to an undetectable level)? ■ Are the current critical limits adequate? ■ Is the support still appropriate for the selection of the critical limits? ■ Is new support available? ■ Have we had critical limit failures that did not result in unsafe product, and if so, does this mean that our critical limit is not set correctly? ■ Are the critical limits based on food safety or on operational requirements? ■ A re t he monitoring procedures sufficient? Are the frequencies supportable? ■ Are monitoring procedures based on cont i nuous or batch processes? ■ If they are based on continuous processes, are there provisions to ensure that production at the end of shift or end of day are accounted for? ■ How are monitoring activities that occur around the clock (e.g., cold

storage) handled to ensure proper documentation? ■ Do the monitoring frequencies closeout the end of production shift or day to prevent products from the next shift or day from being impacted if the critical limit is not met? ■ Have we had deviations, and were the corrective actions appropriate? ■ Were the actual causes of the deviations identified and eliminated in each case? ■ How were the measures to prevent recurrence handled? How often was “retraining” listed? ■ How was product handled to ensure proper disposition? ■ Are the verification procedures appropriate? ■ What are you learning from the direct observation and record review activities? ■ Are “process-monitoring instruments” (usually thermometers) in calibration or are adjustments or replacements routine? As you can see, reassessment is a major component of a HACCP program and should not just be something that is performed when mandated by FSIS either through a notice or rule. When performed correctly reassessment activities result in continuous improvement of an establishment’s HACCP plan, and, hopefully, greater confidence in meeting customer and regulatory requirements for safe food. ■
Kerri Harris is President/CEO of the International HACCP Alliance and is an Associate Professor in the Dept. of Animal Science at Texas A&M Univ. Jeff Savell is Regents Professor and E.M. “Manny” Rosenthal Chairholder in the Dept. of Animal Science at Texas A&M Univ. We would like to hear from you – to comment on this story or to request reprints, contact us by email at meatpoultry@sosland.com.

As with many other aspects of the HACCP regulation, it seems that the expectations for reassessments have changed over time.
In addition, we are often asked for reassessment tips or to assist other establishments with their reassessments, and now establishments are asking how they should handle the non-O157 STECs. We do not have a tool or a list of tips, but we do encourage establishments to consider the following questions when reassessing their HACCP programs. ■ Are there any additional chemical, physical or biological hazards that should be addressed in the hazard analysis? ■ Have there been any unforeseen hazards? ■ Have there been any recalls, illnesses or outbreaks with this type of product, even though it was not our product? ■ Has FSIS issued any reassessment notices for this type of product? ■ Have changes occurred or is there any new information for the hazard analysis that a previously identified hazard does not need to be addressed in the HACCP plan?

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Meat&Poultry - February 2012

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