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Hello all, I’ve got Joe on the phone with us today and as I promised last week he’s all ready to educate us about HACCP and share a little information about what we might encounter with an OSHA Audit!
How are you doing Joe?
JOE – I’m always doing better when I talk safety Marty, its great to be here.
I know you’ve ran a production facility, a quite large operation before. Did you have any HACCP freight or concerns there?
JOE – Absolutely, I think any business that puts out food grade products must have a HACCP plan in place. It’s sort of a game plan. It would also need to address things like maintenance, sanitation and receiving procedures. I only call it a game plan because at some of the large facilities I was in it involved other department managers who also had roles in it.
I did some digging in my old files and found some information that I’d learned back as a young supervisor. The term HACCP represents Hazard Analysis and Critical Control Points, it’s just a production process monitoring system. Some say it got its early beginnings back in World War 2, something to do with artillery shells not firing properly and a system was needed to track their manufacture and assembly to correct the problem. In the 1960’s NASA asked Pillsbury for foods for space flight and they needed to know every process in its production! In today’s world it’s been recognized internationally as a logical tool for adapting traditional inspection methods to a modern, science based, food safety system. Check out Wikipedia.org
https://en.wikipedia.org/wiki/Hazard_analysis_and_critical_control_points
You can find a pretty good record of its inception and history there!
I think HACCP was built based on 7 principals:
- Conduct a hazard analysis
Plan to determine the safety hazards and identify the preventive measures the plan can apply to control them. A food safety hazard is any biological, chemical, or physical property that may cause a food to be unsafe for human consumption.
- Identify critical control points
A critical control point (CCP) is a point, step, or procedure in a food manufacturing process at which control can be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to an acceptable level. On any given plan there can be 1 or 50 points that need to be identified, every point where an issue can occur needs to be identified and listed!
- Establish critical limits for each critical control point
A critical limit is the maximum or minimum value to which a physical, biological, or chemical hazard must be controlled at a critical control point to prevent, eliminate, or reduce that hazard to an acceptable level. I think temperature could be a good example of critical limits we’d need to identify
- Establish critical control point monitoring requirements
Monitoring activities are necessary to ensure that the process is under control at each critical control point. This could be like documenting the temperature at each of the points we identified above.
- Establish corrective actions
These are actions to be taken when monitoring indicates a deviation from an established critical limit. The final rule requires a plant’s HACCP plan to identify the corrective actions to be taken if a critical limit is not met. Again what we’ve done with the product has to be documented.
- Establish procedures for ensuring the HACCP system is working as intended
Validation ensures that the plants do what they were designed to do; that is, they are successful in ensuring the production of a safe product. Plants will be required to validate their own HACCP plans.
Verification ensures the HACCP plan is adequate, that is, working as intended. Don’t get out of the lines here, if there’s an issue it needs to be corrected immediately and our plan may even need to be rewritten or at least some of our points.
Verification also includes ‘validation’ – the process of finding evidence for the accuracy of the HACCP system (e.g. scientific evidence for critical limitations).
- Establish record keeping procedures
The HACCP regulation requires that all plants maintain certain documents, including its hazard analysis and written HACCP plan, and records documenting the monitoring of critical control points, critical limits, verification activities, and the handling of processing deviations. Implementation involves monitoring, verifying, and validating of the daily work that is compliant with regulatory requirements in all stages all the time. Again, documentation is everything and with what we’re talking about today it’s the law!
I remember when I was first introduced to the process it was primarily for meats and poultry products and today it can include cosmetics and pharmaceuticals
HACCP is focused only on the health safety issues of a product and not the quality of the product, yet HACCP principles are the basis of most food quality and safety assurance systems.
Another really good site to check out is https://www.gpo.gov/fdsys/search/searchresults.action?st=HACCP or the Government Publishing Office.
I had to attend some special training classes, I think the corporation I was with at the time called it HACCP Training and I became HACCP Certified to handle the items we were stocking at the time. I assume you went through the same training and certification process right?
JOE – That’s right, from both outside and internally. Learning the steps then learning YOUR company’s steps are a very involved process that takes time. It was about identifying those CCP’s and know what to do when you find something outside the norm. Sometimes a simple find can lead to kink in the operation, say like with something outside the acceptable temp…
One thing I found out while researching todays topics is, and I guess I’d learned it a long time ago is that CFR, on all our regulatory learnings stands for Code of Federal Regulation, the numbers in front of it is for the title like 21 being Food and Drug or FDA information, Title 10 Dept of Energy and 29 CFR 1910 is for Occupational Safety and Health or OSHA.
And Joe that’s a good Segway into OSHA Audits. Last week I was speaking about 3rd party audits and auditors, trying to answer a couple of our listeners concerns and questions and I threw out that you’d be happy to tell us a little about the process, how it works and how we should handle them. Can you share some thoughts or experiences with our group?
JOE – I have personally handled a few OSHA investigations. Primarily your first contact with OSHA will be to fill in your part of their investigation. You will also receive documentation from the investigating OSHA office, in that paperwork there will be notice of investigation you must publicly display in your place of business, as well as send back to OSHA confirmation that you have posted this document. You will also be asked for the incident investigation report that was performed at the time of the incident. Its always good to have a report that’s easy to read, clear and factual. The next thing OSHA typically wants (and wants it documented) is what you did to abate the hazard, and how. Very important and that’s where prevention for employers is key. Sometimes there is nothing to abate, as in an employee may have injured himself with equipment or didn’t follow a process correctly, its much different than say preventing hazards in your tunnel your building that would require a ton to make safe.
In my personal dealings with Agents I found that clear language, precise reporting and doing good ole fashioned what you are supposed to do and common sense all helped resolved the issues my employers tasked me with and was more than enough to show uncle Sam that we are a business that cares about safety and how we work.
Joe thanks for all that InSite Sir, we appreciate you taking time out of your day to enlighten us here at WAOC.
JOE – As usual it was great to be here and am always willing to answer any questions about our work force.
And as always, I’d like to thank each of you our listeners for checking in. If you have a topic or thought you’d like us to talk about shoot us an email to host@warehouseandoperationsasacareer.com, I love getting mail here at the show. I’d appreciate a quick Like and Follow to our Facebook and Twitter feeds to, we try and continue our discussions through groups and pages there each week too! Both of our topics dealt with Safety today, remember Safety is really a component of everything we do in the workplace. Think Safe & be Safe out there!