Shawna Wagner, DNV GL
FST Soapbox

Did You Write “NONE” for Biological, Chemical and Physical Hazards in Your HACCP Plan?

By Shawna Wagner
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Shawna Wagner, DNV GL

Industry has changed, approaches to food safety have changed, and your HACCP plan should have evolved.

Ok, ok I know what you are thinking, another article about HACCP. You have been HACCP certified since 1999 and doing this for years—why read this article? That golden sticker on your certificate does not last forever. Industry has changed, approaches to food safety have changed, and your HACCP plan should have evolved. Did it?

Biological, chemical, physical, biological, chemical, and physical hazards. If you are any part of the quality assurance or HACCP team, you can recite this in your sleep. Do you recite economical and radiological hazards? These are one of the most commonly missed items in a plant’s HACCP plan that I have witnessed when auditing. This, of course, applies only to plants that must comply with FSMA, but does it truly hurt to think about including it in all plants? I mean, we are all in this for food safety, right?!

In speaking about radiological hazards, most of the time I will have site management tell me that I am not by a power plant so there are not hazards to my operations. If you are a producer of vegetables and fruits, or a plant receiving these kinds of ingredients, water and even soil can be a home to radioactive hazards! Radioactive minerals are naturally occurring and unless you know where to start, items such as Cadmium may sneak up on you in unacceptable levels. Economical hazards are, in my opinion, a bit easier to research. When looking at economical hazards, we are basically trying to prevent intentional contamination to gain or profit. In more common terms, this is often referred to as food fraud. Olive oil, fish, and even spices have been known to be the victims of food fraud. There are plenty of informational sites out there to help get you started on writing your hazard analysis for food fraud, however some I have found you do have to pay for.

Another common non-conformance that I see missing in HACCP audits is what I would call inputs and outputs to the HACCP flow chart. Inputs are: Water, compressed air, ice and even steam. Outputs are: Waste, animal feed or by-products. This is not an all-inclusive list, but certainly these examples could bring a new level of hazards to your facility, especially if you did not include them in your hazard analysis. Even worse, if you did include them but decided to write in your hazard analysis that word…dare I even say it… “NONE”: You wrote “none” for biological, chemical, and physical hazards. More than likely you have a pre-requisite program, letter of guarantee, or something that controls these hazards, and you absolutely want to include these in your HACCP plan. Give yourself credit! Auditors and customers alike truly want to see that you have documented and given thought to each of your processing steps. Make sure you take that HACCP flow chart and walk around your facility to ensure you have captured the needed information that will give you the best chance of catching items that can be missed. The plan is only as strong as the time you put into it, which leads me to my next point: Your HACCP or Food Safety Team.

The notorious HACCP team. You have one, the head of the team is the QA manager, and you have team members to cover the multi-disciplinary basis. So, what’s the problem? Well, maybe none, but remember the comment about the golden sticker on your certificate? It’s the same thought process here. Your team must be continually updated and educated to keep up with the ever-changing world of food. That 1999 HACCP certificate is no longer valid in the eyes of some customers. I have seen many customers requiring that HACCP be retrained every five years. For the sites that must follow FSMA rules and regulations, have you completed your Preventative Controls Qualified Individual training? You should have, and who is their backup? It takes much planning and money to make this happen, but it is all a crucial step in maintaining food safety and your HACCP plan.

We all know that our programs and processes are not good for forever and that change is inevitable. There are always avenues for gathering information and accessing it. You must be willing to go out and get the resources that will place an upgrade on your food safety management system, as waiting for it can sometimes cause gaps and non-conformities. The big question is: Did you put in the hours?

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Shawna Wagner, DNV GL

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