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Hazard
Analysis Critical Control Points/Pathogen Reduction is the government's
response to the President's Safe Food Initiative, developed
as a response to the E. coli 0157H7 outbreak in Washington
State that so captured the public's attention. However, the
system itself had been around for 30-some years as a way to
ensure a safe food supply for America's astronauts. In order
to understand the importance of a safe food supply for humans
in space, imagine, if you will, a bad case of food poisoning
in a space suit - or in a weightless environment.
In
order to forestall such a tragedy, HACCP was born of the efforts
of:
- The
United States Army
- The
National Aeronautics and Space Administration
- The
Pillsbury Company.
The
Food and Drug Administration adopted HACCP in the mid-1990s
for the food processing establishments it regulated, because
of the nature of its regulatory oversight structure. Unlike
the meat and poultry industries, which the Meat Inspection Act
(MIA) of 1906 and the Poultry Products Inspection Act (PPIA)
of 1958 stipulate must be under carcass-by-carcass inspection
by Federal inspectors (Program employees), the FDA
inspects establishments based on their records of compliance
with FDA's regulations and Title 21, Code of Federal Regulations
(CFR).
Under
Title 9 CFR, parts 416 and 417, the USDA's
HACCP program was formalized in Federal law. As the USDA agency
responsible for meat and poultry inspection, the Food
Safety and Inspection Service became the administrator
for HACCP in the meat and poultry industry.
HACCP
is a seven-step process of examining product flow in all meat
and poultry slaughter and processing establishments. The seven
steps are:
- Hazard
Analysis - a formal examination of every step in the food
slaughter/manufacturing process to determine if any biological,
chemical, or physical hazards are potentiallypresent.
The analysis conclusions must be supported by either scientific
knowledge or historical data from the establishment's operations
- Determination
of Critical Control Points (CCP's) - determining where,
in each process, the critical point(s) for process control
exist
- Specification
of Criteria - determining what criteria will indicate that
process control has been achieved, or is in effect
- Implementation
of a Monitoring System - deciding how the criteria defining
the critical control points will be overseen - i.e.,
how and how often must the process controls at the CCP's
be checked
- Corrective
Actions - corrective actions is a four-step process:
- The
cause of the deviation is identified and eliminated
- The
CCP will be under control after the corrective action
is taken
-
Measures to prevent recurrence are established
- No
product that is injurious to health or otherwise adulterated
as a result of the deviation enters commerce
- Verification
- plant management shall verify that the process is under
control prior to allowing the establishment's product(s)
to enter commerce - simply put, the company has to certify
that all CCP's were met and the product is safe for human
consumption before it can be sold
- Documentation
- paperwork, paperwork, paperwork!
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Each
establishment's HACCP plan must be examined by a Program employee
annually to verify that it meets the requirements of the law
and, if any changes are made or processes added, a re-verification
must be completed by a Program employee at that time.
That,
in a nutshell, is HACCP.
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