ESTABLISH CORRECTIVE ACTION PROCEDURES FOR EACH CCP

ESTABLISH CORRECTIVE ACTION PROCEDURES FOR EACH CCP (HACCP PRINCIPLE 5)

During the development of the HACCP plan, the HACCP team must establish procedures to be followed if and when the monitoring of a CCP reveals that the critical limits are not respected (i.e., a deviation occurs), and therefore there is a loss of control of the hazard at the CCP. A product that is obtained at a process step where the CCPs are not respected is a nonconforming product and is likely to be unsafe if consumed. The procedures that are established to prevent unsafe product from reaching the consumer are the corrective action procedures or deviation procedures. This HACCP principle recognizes that in spite of the fact that a CCP is operating in a process, it is possible that there could be loss of control at the CCP and this loss of control will be detected during the monitoring procedure.

The following points must be addressed in the corrective action procedures:

• The specific, immediate action to be taken when it is discovered that the critical limits at a CCP are not respected, and therefore there is a deviation from the critical limits

• Identification of the cause of the deviation from the critical limits at the CCP

• The actions to be taken to correct the cause of the deviation so that the deviation does not recur

• Determination of the period of time for which the deviation occurred and the quantity of nonconforming product that was prepared during this time

• The actions to be taken with respect to the nonconforming product to ensure that it does not reach the consumer

• The importance of keeping records of all the actions taken to address the deviation and the nonconforming product

For all of the points listed here, the corrective action procedure must identify the personnel who are responsible for the actions to be taken when there is a deviation from the critical limits at a CCP.

In the event that a deviation from the critical limits at a CCP is discovered only after the non-conforming product has been shipped from the establishment to the customer, then the HACCP prerequisite program Traceability and Recall (Chapter 4) must be used to address this situation.

 ESTABLISH VERIFICATION PROCEDURES FOR EACH CCP AND FOR THE ENTIRE HACCP PLAN (HACCP PRINCIPLE 6)

 

This HACCP principle requires that the HACCP team develop measures that will evaluate (a) the effectiveness of the HACCP plan that has been developed and (b) the effectiveness of the HACCP system on an ongoing basis after its implementation.

• Verification of initial HACCP plan: The verification of the initial HACCP plan involves validation to ensure that the critical limits, the monitoring procedures and the corrective action procedures (HACCP

Principles 3–5, Steps 8–10) established at each CCP are indeed capable of controlling the hazard that is required to be controlled. This validation must be conducted during the development of the HACCP plan; it is therefore an essential part of the HACCP plan development.

The verification activity must also demonstrate that every aspect of the HACCP plan that has been developed must be fully and correctly implemented.

• Verification of the HACCP plan on a continuous basis: The HACCP plan that has been developed must include activities that will demonstrate the following:

The measures (monitoring procedures, corrective action procedures, record-keeping procedures) which have been implemented at each CCP, must continue to be effective and must operate as required by the HACCP plan. The most common form of verification is ongoing review of the required records of monitoring and corrective actions by personnel other than those who were responsible for the monitoring activity or the corrective action.

Supervisory personnel should carry out this type of verification.

Verification activities could also include periodic sampling and analysis to verify the effectiveness of the CCP to control a hazard.

Table 5.5 gives examples of verification activities for some CCPs.

Every aspect of the entire HACCP plan that has been implemented must continue to function as  originally intended; this type of verification is typical of a system audit, and includes an independent review of the entire HACCP plan at a predetermined frequency. In the event this verification activity discovers that there are deficiencies in the HACCP plan, these deficiencies must be corrected immediately.

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