Lesson 2 - Quality Assurance and Quality Management

HACCP is a system for managing food safety hazards. In this section we will cover what is required to implement HACCP using the seven HACCP principles. These principles are:

Principle 1 – Conduct a hazard analysis

Principle 2 – Identify the critical control point (CCP)

Principle 3 – Establish critical limits

Principle 4 – Monitor CCPs

Principle 5 – Establish corrective actions

Principle 6 – Verify

Principle 7 – Establish recordkeeping

HACCP is recognised globally and it is the system recommended by the Codex Alimentarius Commission. In most countries it is mandatory for a food business and necessary where a due-diligence defence is used against prosecution after a consumer has been harmed by food. We will now look at what needs to be done to implement an effective HACCP plan and to maintain the system.

For HACCP to work effectively we need to have another set of control measures to ensure food safety. These controls, which sit outside of the HACCP framework but are described in the HACCP documents, are the pre-requisite programmes (PRP). PRPs should reduce/remove food safety hazards; in turn, this will reduce critical control points. If an HACCP system has more than a handful of CCPs it means that the pre-requisite programmes are inadequate.

We now look at what we need for an effective set of pre-requisite programmes.

       1. Food safety policy

We need to have a policy which sets out the brewery’s commitment to managing food safety. It can be a brief summary of the food-safety management activities but it needs to detail the intended actions and outcomes, and how they are achieved. All staff need to be aware of its contents.

       2. Location

The brewery should be located where the beer is not at risk from the environment. For example, you should not operate a brewery in an area of high levels of crime where the plant/beer could be sabotaged, or in a place with neither safe water supplies nor scope for groundwater extraction.  

       3. Categorisation of risk areas

We need to conduct a risk assessment to establish what controls are required in each area of the brewery to prevent product contamination. High risk areas will require tighter controls than low risk areas. Our high risk areas are areas where the product is open, for example the cask-racking or can-filling areas. Low risk areas are areas away from open products or raw materials, like store rooms or plant rooms. Control in high risk areas will involve special workwear and guarding around equipment whereas low risk areas control measures could be limited to not consuming food and drink in the area.

       4. Fabrication and equipment

We need to ensure buildings are fit for their purpose, easy to clean, and well maintained. This is to prevent the fabric of the building entering the beer or pests gaining access to brewery. Our equipment needs to be fit for purpose and easy to clean and should be subject to regular planned, preventative maintenance.

       5. Supplier assurance

Many, if not most, potential food safety hazards originate up the supply chain. As a brewer we must ensure that we are making our beer with safe ingredients. We need to audit suppliers to ensure they are managing food safety effectively. Everything we buy must be purchased on the basis of an agreed specification. The specification should stipulate conformance to food safety legislation and that the supplier has an effective HACCP system in place.

       6. Cleaning and housekeeping

We need to set out and complete a schedule of cleaning for plant and facilities based on a risk assessment. Cleaning should be documented and the effectiveness of removal of the cleaning products by rinsing checked. We also need to have a plan in place to deal with spillages to prevent the spilled chemical entering the beer.  

       7. Staff facilities and hygiene

The personal hygiene of our staff must be controlled by training and monitoring and we need to ensure that rest and washing facilities are sufficient and fit for purpose. Toilet facilities should not open directly into production areas. 

       8. Pest control

We must control the risk of infestation of the brewery by pests down to a minimum. Pest control practitioners must be suitably qualified and competent, and their activities carried out according to an agreed schedule. Any pest control materials at the brewery must be controlled to ensure none enters the beer.  

       9. Brittle materials policy

We need to minimise the use of brittle materials (such as glass or brittle plastic) and, where unavoidable, ensure that it cannot enter the beer. The policy will detail how brittle materials are managed. A register of the locations and uses of brittle materials also needs to be kept along with a procedure for dealing with breakages. Regular audits of the condition of brittle materials need to be completed to identify possible contamination risks from broken items. 

       10. Training

In order to guarantee that food-safety-critical tasks are carried out effectively, we must ensure our procedure details how they are to be done and that brewery staff have been trained and assessed against the procedure.

       11. Quality management system

As we learned earlier, a structured QMS gives us a framework with which to manage quality. Food safety is part of quality as defined by the expectations of the customer so a QMS will also help to manage food safety. The components of a QMS are complementary to the HACCP system.

       12. Product recall and traceability

We need a system by which, if there is a threat to the safety of a consumer, the offending product can be traced and withdrawn from sale. Each individual package of beer should have a lot code which enables traceability back through the brewing process to the raw material supplier. In addition, a record needs to be kept of where the package has been sold to enable effective recall. A plan detailing actions by those responsible for undertaking the recall is also required. A record of customer complaints relating to food safety needs to be kept for at least as long as the use by date for the product.

We can recognise a number of the PRPs from the food GMP we saw earlier. There are some commonalities between PRPs and GMP but it is important to understand they are not the same.