Lesson 2 - Quality Assurance and Quality Management

Stage 7. Establish monitoring at each CCP (HACCP Principle 4)

Next, we need to set out how and when we will monitor our CCP, who will do the monitoring, and how it will be recorded. Monitoring can be off line, in line, or on line. Our monitoring must be sufficient to ensure we can catch a process operating outside the critical limits before any product affected can leave the process. For this reason, continuous automated systems are preferred over manual systems involving timed checks. Automated systems will either set off an alarm or act to shut the process down if the critical limit is reached. They will also be fitted with a failsafe where the system will go into the alarm condition if monitoring stops. As an example, we can consider a system measuring the differential pressure (dP) across a plate heat exchanger being used to chill beer using glycol. Maintaining a positive dP between the beer and glycol ensures the glycol cannot leak into the beer. If the dP dropped below the critical limit, the pressure sensor would register this and the PLC would shut down the chilling process and the alarm would be triggered. Our means of monitoring must be documented and will cover equipment, method, and responsibilities.

Maintenance activities on the equipment monitoring the CCP (like calibration checks on pressure sensors and thermometers) are also set out here. Documenting these activities commits the brewery to this action. Failing to maintain elements of monitoring destroys the due-diligence defence to prosecution. Data from monitoring must be reviewed and documented to demonstrate control of the hazard.     

You should have been trained in HACCP to at least the point of awareness. When you are next in the brewery find the HACCP documentation, find your CCPs, and use the decision tree to work out why they have been established as a CCP. Be sure to tell the HACCP lead if you don’t agree!

Stage 8. Establish corrective action (HACCP Principle 5)

Next we must establish the corrective actions required if the control of our CCP fails and critical limits are reached. Corrective actions need to ensure that the process returns to operating within critical limits and must also cover what to do with any product affected when the critical limits were reached. In the case of our glycol heat exchanger the corrective actions would be: to quarantine any beer which was being chilled by the heat exchanger at the time of the issue, for testing for the presence of glycol; and to investigate the drop in dP and repair the cause of the problem. As with critical limits, our corrective actions also need to be validated to ensure they prevent the hazard reaching the customer.

Stage 9. Establish verification procedures (HACCP Principle 6)

We must prove (verify) that we are operating our system according to the plan and effectively controlling our hazards. Verifying activities will include: 

• Additional analyses of attributes relating to the hazards we are aiming to control

• Reviewing customer feedback on products

• Carrying out audits to ensure corrective actions are being completed

• Auditing of the pre-requisite programmes to verify compliance

• Analysis of CCP data and deviations from critical limits

At this stage we set out what we will need to do to undertake this verification as a set of procedures and records.

Stage 10. Establish documentation and records (HACCP Principle 7)

The outcome of the last six steps of our HACCP implementation will be: our process flow diagram, a set of hazards which have been assessed, a plan of what we do to control them, and a plan of what needs to be done if the control fails. This, along with the means by which we verify the system, forms the bulk of the required HACCP documentation and provides the information for our procedures, training, and records for operating HACCP in the brewery.

Stage 11. Implement the HACCP plan

Now that we have our plan the next step is to implement it. We train those operating the processes in question on how we control the CCP and how to complete the necessary records. CCP signage is displayed at the point where the CCP is measured showing what is measured, the critical limits, and corrective action. The implementation of the plan often takes longer than the preceding stages.  

Stage 12. Review the system

There are two parts to the review stage. The first is to carry out the verification processes we established earlier but in the system after implementation. If the verification of the system shows that it is not controlling hazards effectively, the system will need to be revised by going back to the hazard analysis stage.

The second part of the review stage is designed to ensure the system remains current. This means our HACCP system needs to be reviewed in the following circumstances:

• Changes to the HACCP team

• Introduction of new product types

• Changes to the process covered by the HACCP system

• Introduction of new technology

• Changes to legislation

• Periodic (annual or biannual) verification of entire system by full audit

• Customer complaint related to food safety

You have just encountered three ways of checking whether our HACCP is right: Validation, Verification, and Review. Are these similar words with similar meanings? What do you think each means in the HACCP context? Give yourself 5-10 minutes to think about this, and then click ’Next’ to continue with this lesson.