According to the President’s Council on Food Safety, “Delivering safe food to the dinner table is the culmination of the work of many people. Producers, shippers, processors, distributors, handlers, and numerous others perform actions every day that may affect the safety of our food. Everyone's challenge is to perform these individual actions as well as possible, so that the food Americans eat is free from physical hazards and dangerous levels of pathogenic microorganisms and hazardous chemicals.”

How is it done? In a foodservice establishment, the answer is through HACCP, the Hazard Analysis and Critical Control Point system. In HACCP, an operator identifies foodborne hazards and determines which step(s) in the flow of food are most likely to result in unacceptable risks for consumers. The operator applies targeted controls at these steps to ensure that each hazard is adequately controlled to ensure food safety.

According to the Food and Drug Administration (FDA) Food Code (2005), “The designated person in charge who is knowledgeable about foodborne disease prevention, Hazard Analysis and Critical Control Point (HACCP) principles, and Code requirements is prepared to recognize conditions that may contribute to foodborne illness or that otherwise fail to comply with Code requirements and to take appropriate preventive and corrective actions.”

HACCP is mandated in some parts of the world, and is highly recommended by the FDA. It is specified as a standard plan of control for specific types of processes, mandated for segments of the US food processing industry, and endorsed by authoritative food safety leaders such as the National Advisory Committee on Microbiological Criteria for Foods (NACMCF), the US Department of Agriculture (USDA), the National Academy of Sciences (NAS), the Canadian Food Inspection Agency (CFIA), and the FAO/WHO Codex Alimentarius Commission, which sets international standards.

Hazards may be introduced into foods at any stage in the farm-to-fork process. However, a foodservice operation is described by the FDA as the “last line of defense before food reaches the consumer.” This places responsibility on the foodservice industry to develop a HACCP plan, implement HACCP controls, and monitor HACCP data.

The FDA states, “By voluntarily developing and implementing a food safety management system … you can take a proactive role in ensuring that the food served or sold in your establishment is safe. Rather than responding to a foodborne illness when it occurs, you can prevent it by taking active steps to eliminate, prevent, or reduce to an acceptable level food safety hazards that cause someone to be sick or injured.”

HACCP begins with a plan, a written document that delineates the formal procedures for following the Hazard Analysis and Critical Control Point principles. The HACCP plan should address these seven steps:

1. Perform a Hazard Analysis – determine what hazards exist in foods served.

2. Decide on the Critical Control Points (CCPs) – determine which step(s) in the flow of a food product represent an “unacceptable” level of risk if hazards are not controlled, where an error could lead to foodborne illness. Note that HACCP software can track your operation’s product-specific CCPs.

3. Determine the Critical Limits – determine how to measure compliance with controls at designated CCPs.

4. Establish Procedures to Monitor CCPs – specify procedures to alert employees to check data at CCPs to ensure safe food. HACCP PDA technology provides an excellent tool for capturing critical limit data and providing customized feedback to the foodservice team on a real-time basis so that errors can be corrected.

5. Establish Corrective Actions – specify actions to take at any time when critical limits are not met. HACCP PDA technology can provide context-sensitive, product-specific instructions to employees on the spot to help correct errors.

6. Establish Verification Procedures – ensure that the HACCP plan is effectively controlling hazards. Data stored in a HACCP software system becomes a repository for review to support foodservice managers with this step of HACCP.

7. Establish Record-Keeping Systems – create a system for collecting reliable HACCP data on a routine basis. HACCP PDA technologies with automated temperature acquisition are an excellent means of ensuring that this data is captured reliably and consistently. According to the FDA, “Records maintained in a HACCP system serve to document that an ongoing, effective system is in place. Record-keeping should be as simple as possible in order to make it more likely that employees will have the time to keep the records.”

The FDA also states, “While record-keeping is voluntary in most retail and foodservice operations, maintaining documentation of the activities in your food safety management system may be vital to its success. Remember that by keeping records you are going above and beyond what your regulations normally require. Records provide documentation that appropriate corrective actions were taken when critical limits were not met. In the event your establishment is implicated in a foodborne illness, documentation of activities related to monitoring and corrective actions can provide proof that reasonable care was exercised in the operation of your establishment. Records may also show that ongoing verification was conducted on the food safety management system. In many cases, your records can serve a dual purpose of ensuring quality and food safety.”

According to FDA advice, “Like many other quality assurance programs, the principles of HACCP provide a common-sense approach to identifying and controlling risk factors. Consequently, many food safety management systems at the retail level incorporate some, if not all, of the principles of HACCP. While a complete HACCP system is ideal, many different types of food safety management systems may be implemented to control risk factors. It is also important to recognize that HACCP has no single correct application. Variations … are appropriate as long as they are based on sound public health judgment.”

Customized implementation is easy when the versatile HACCP technologies are available behind the scenes to support the HACCP plan. Some of the questions that can help in customization, according to the FDA, include the following:

Identifying hazards:

How will it be served? Immediately? Held on a buffet?

Does this food have a history of being associated with illnesses?

Will this require a great deal of preparation, making preparation time, employee health, and bare hand contact with ready-to-eat food a special concern?

How will employees exhibiting symptoms such as diarrhea or vomiting be handled?

Are you serving food to a population that is known to be highly susceptible to foodborne illness (e.g., residents of health care facilities, persons in child or adult day care facilities, etc.)?

Setting CCPs:

Is this operational step the last step at which a control can be applied to prevent or eliminate a hazard (or reduce it to an acceptable level)? (If yes, then this step is a CCP).

Is there a step later in the process will control the hazards of concern? (If yes, this step is not a CCP; a later step will be.)

Monitoring:

What will you monitor?

How will you monitor?

When and how often will you monitor?

Who will be responsible for monitoring?

Developing Corrective Actions:

What measures do you expect employees to take to correct the problem?

Do your employees understand the corrective action?

Can the corrective action be easily implemented?

Are different options needed for the appropriate corrective actions depending on the process and monitoring frequency?

How will these corrective actions be documented and communicated to management so the system can be modified to prevent the problem from occurring again?

Over recent years, the FDA has been developing HACCP advice geared specifically to the foodservice industry. Unlike the food manufacturing environment, a foodservice operation may have a broad array of menu items, each with unique hazards. The FDA HACCP Manual for Food Service and Retail Establishments, online at www.cfsan.fda.gov/~acrobat/hret2.pdf, offers streamlined HACCP advice for grouping foods by production process:

“Since the early 1980s, retail and foodservice operators and regulators have been exploring the use of HACCP in restaurants, grocery stores, and other retail food establishments. Most of this exploration has centered on the question of how to stay true to the definitions of HACCP yet still make the principles useful to an industry that encompasses a very broad range of conditions. Through this exploration, HACCP principles have been slightly modified to apply to the varied operations found at retail.

“When conducting the hazard analysis, food manufacturers usually use food commodities as an organizational tool and follow the flow of one product. This is a very useful approach for producers or processors since they are usually handling one product at a time. By contrast, in retail and foodservice operations, foods of all types are worked together to produce the final product. This makes a different approach to the hazard analysis necessary. Conducting the hazard analysis by using the food preparation processes common to a specific operation is often more efficient and useful for retail and foodservice operators. This is called the Process Approach to HACCP. The process approach can best be described as dividing the many food flows in an establishment into broad categories based on activities or stages in the flow of food through your establishment, then analyzing the hazards, and placing managerial controls on each grouping.” (FDA)

The three process groups, based on the number of trips a product takes through the danger zone, are:

Process 1: Food Preparation with No Cook Step Example flow: Receive – Store – Prepare – Hold – Serve (no cook step to destroy pathogens)

Process 2: Preparation for Same Day Service Example flow: Receive – Store – Prepare – Cook – Hold – Serve (only one trip through the temperature danger zone)

Process 3: Complex Food Preparation Example flow: Receive – Store – Prepare – Cook – Cool – Reheat – Hot Hold – Serve (two or more complete trips through the temperature danger zone)

The hazards associated with each food on a menu may vary. Yet in customizing the HACCP software and HACCP PDA systems, an operator can choose to groups like foods together for the purposes of automating and documenting HACCP controls.

Centers for Disease Control
www.cdc.gov/ncidod/dbmd/diseaseinfo/foodborneinfections_g.htm

FDA Bad Bug Book
http://vm.cfsan.fda.gov/%7Emow/intro.html

FDA Food Code
www.cfsan.fda.gov/~dms/foodcode.html#intro

FDA HACCP Links
www.cfsan.fda.gov/~lrd/haccp.html

FDA HACCP Manual for Food Service and Retail Establishments
www.cfsan.fda.gov/~acrobat/hret2.pdf

FightBAC!
www.fightbac.org

FoodSafety.gov
www.foodsafety.gov

International HACCP Alliance
www.haccpalliance.org

National Food Safety Education Month
www.foodsafety.gov/%7Efsg/september.html

USDA HACCP Web Page
foodsafety.nal.usda.gov/nal_display/index.php