| Script:
Designing a HACCP Plan – Part 10 |
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Intro:
Welcome to USDA’s Food Safety and Inspection Service podcast. Each episode
will bring you cutting edge news and information about how FSIS is working to ensure public
health protection through food safety. While we’re on the job, you can rest assured that
your meat, poultry, and processed egg products are safe, wholesome, properly labeled,
and packaged correctly. So turn up your volume and listen in.
Host:
Hello and welcome! This is Sheila Johnson and Dr. Ron Jones from the Food Safety and
Inspection Service. Today we’re wrapping up the ten part series on how meat and
poultry plants go about Designing a HACCP Plan. We’ve already covered a general
overview of HACCP, the preliminary steps to design a plan and the seven HACCP
principles, which are: Conducting a Hazard Analysis; Identifying Critical Control
Points; Establishing Critical Limits; Establishing Monitoring Procedures; Establishing
Corrective Actions; Establishing Recordkeeping Procedures and Establishing
Verification Procedures. Today we will end our series with common pitfalls, how to
overcome them and sources for more information.
O.K. Ron, tell us about one of the common pitfalls you see in HACCP Plans?
Guest:
Sure, one of the common pitfalls I’ve seen often occurs in the hazard analysis. Plants
will miss a hazard that is reasonably likely to occur for a process. We discussed
conducting a hazard analysis in part three of this podcast series. If a hazard that is
reasonably likely to occur is NOT identified it can result in the potential for
contaminated product entering our food supply. This can happen for a number of
reasons, but to avoid missed hazards be sure to review the FSIS
generic
HACCP plans and the FSIS “Microbiological
Hazard Identification Guide For Meat and Poultry Components of Products produced by
Very Small Plants”. Both of these publications are available on the FSIS Web site
at www.fsis.usda.gov under the Business and Partners Audience page.
Host:
Are there other resources available?
Guest:
You may also find HACCP resources available on the International HACCP Alliance Web
site and University Extension Service’s Websites’ like Kansas State University, Ohio
State University, and University of Wisconsin. These sites often have specific
information available that can help you identify potential hazards.
Host:
Who could we talk to, to get help identifying the right hazards in our hazard
analysis?
Guest:
You could call your State HACCP Contacts and Coordinators. They provide technical
advice, assistance, resources and conduct activities to support HACCP implementation
in small and very small plants. A listing of each State’s HACCP Contacts and
Coordinators is available on the FSIS Web site. Also, folks can call FSIS at (800)
233-3935 for technical assistance.
Host:
Thanks for those resources. Can plants use the documents and information they find
from the Web sites and HACCP Contacts and Coordinators as supporting documentation?
Guest:
Absolutely. I’m glad you brought that up because another common pitfall is having
insufficient documentation to support the hazard analysis. Owners and operators must
take the information provided and mold it to appropriately apply it to their
operation.
Host:
What’s another common pitfall?
Guest:
I commonly see where a hazard analysis cites history as the justification for why a
hazard is not reasonably likely to occur, but then there is no supporting
documentation to support that hazard analysis decision. This can easily be resolved by
documenting that your process has been the same for many years with no hazards or by
monitoring for the potential hazard and recording the results over a period of time to
demonstrate that the hazard is not reasonably likely to occur.
Host:
Okay, that takes care of the history and record keeping elements.
Guest:
Exactly.
Host:
What’s another example of a common pitfall, like maybe something dealing with critical
control points?
Guest:
Sometimes the critical control point’s critical limit for a microbial intervention
does not reflect the key factors that impacted the antimicrobial’s effectiveness that
the plant used from published research articles it gathered. In these cases, carefully
review the methods of the research article to determine the key parameters. You must
ensure that the proper concentration of the antimicrobial, temperature of the
antimicrobial, and the amount of the antimicrobial is applied to a given product’s
surface area. When in doubt, contact the article’s author for correspondence about
what the key parameters are and how they should be reflected in the critical control
point’s critical limit.
Host:
Sounds like a good idea. What are the other common pitfalls in the verification
activities?
Guest:
At times the HACCP plan does not contain all three ongoing verification activities. We
discussed the ongoing verification activities last week in part nine of this podcast
series. If any of the three required verification activities are not performed at a
particular critical control point then the plant should be able to support the
decision. In other words, the plant should not just arbitrarily decide which
activities to perform at each critical control point. The plant should use a rational
thought process.
Host:
Thanks Ron for all the great advice and tips.
Guest:
Glad I could help. Also there is a lot of information on HACCP on the FSIS web site.
Visit www.fsis.usda.gov. Then click on
“Science” in the left column under “Browse by Subject.” Under the “Science” heading
there is a lot of additional information available on HACCP.
We also have HACCP and food safety materials in printed form. Our food safety
resources brochure is a list of guidance and resource materials that are offered to
the public free of charge. Most resource materials are offered in both English and
Spanish.
Host:
How can a small plant owner or operator get one of these brochures?
Guest:
They can order the brochure by calling (202) 720-9113 or visit our web site.
Host:
Well Ron, thank you again for joining us in this 10 part series on Designing a HACCP
plan. You have provided us with a lot of good information that will make it easier for
small and very small plants with their HACCP plan. Thanks as well to all of you out
there listening.
Outro:
Well, that’s all for this episode. We’d like your feedback on our podcast. Or if you
have ideas for future podcasts, send us an e-mail at podcast@fsis.usda.gov. To learn more
about food safety, try our web site at www.fsis.usda.gov.
Thanks for tuning in.
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