The first HACCP implementation principle requires a “fresh pair of eyes”
HACCP, Hazard Analysis and Critical Control Points, begins with a Hazard Analysis. Earlier we looked at the concepts behind the word Hazard and the word Analysis as applied to HACCP. In principle seeing hazards should be easy. In practice this is rarely the case.
MBWA, the acronym for Management By Walking Around is a good start for HACCP Hazard Analysis. The thing to remember is that working in the same environment every day we can become accustomed to people, practices, and procedures in our workplace. It’s easy to overlook the employee that looks a little ill, the temporary replacement that isn’t quite following procedures during a colleague’s vacation, or the food processing machine with the lid left off and the potential to introduce foreign materials greatly increased. It’s another thing to see these as an honest broker, a person, or HACCP team who sees with fresh, new eyes can view the operation, facility, staff, etc. without the built in “blinders” we may have developed.
But what does the Hazard Analyzer looks for? Again the FDA definition of Hazard, things that compromise food safety or health, is instructive. A Hazard is a biological, chemical or physical agent that is reasonably likely to cause illness or injury in the absence of its control.
So what’s on the list of things to look for? Starting with the easiest to see, chemical agents that are reasonably or likely to cause illness or injury. One can imagine a food producing, processing, or distribution operation having many such chemicals. An obvious list would contain pest control poisons, cleaning chemicals, equipment maintenance chemicals such as lubricating oil, and site maintenance chemicals such as paints. These items are certainly needed, the question is how are they stored and used? At home we store cleaners in cabinets underneath the sink where we do not store food, and these cabinets have safety locks if little children are present. And when we use them we put foods away or move them away from areas that could be potentially contaminated, by overspray for example. Likewise, paints, solvents, oils, and pesticides are stored in the garage or basement, hopefully away from food altogether and away from little hands if children are present. Checking the labels of all products for their potential to harm a person from exposure or ingestion is a good start. Monitoring those who use them to determine if their methods have the potential to contaminate food products is also a good idea. This is not to point fingers but is intended to be both educational and thorough.
Physical agents that are reasonably or likely to cause illness or injury can include small, sharp items such as pins and needles, bits of broken glass, broken ceramics (i.e. mugs and plates), or metal objects (i.e. knife tips that break off) that can become lost in food. In this regard the analysis team will want to look for small items stored above food preparation or storage areas and the condition of cooking and food preparation utensils. I recall finding a large piece of broken glass in a five gallon ice cream container inside a freezer during my high school days busboy job. The glass came from a sherbet cup. These cups were stored on a shelf above the cooler, stacked three or four high and could easily fall and break on the cooler surface if one were not careful, and finding all the pieces can be difficult. Thankfully the broken glass piece was fairly large and easily spotted. And the owner, to his credit, said to toss out the remaining product, inspect all other tubs and throw out any others that were suspect. An inspection also needs to look for the location of small or breakable items or chemical agents stored above food preparation or storage areas.
Biological hazards may be visible but are often too small to be seen. Rodents and their droppings, insects, mold and the like are visible with thorough inspection. More difficult to see are microorganisms. Sometimes these “germs” can be seen, in the case of mold for example. Sometimes their effect can be sensed with our noses, spoiled milk or cheese for example, or feel, the texture of spoiled meats or produce comes to mind. Sometimes the microorganisms cannot be detected, salmonella or e coli for example. These can only be detected through laboratory analysis. The HACCP team will need to keep products likely to contain harmful microorganisms in mind when developing procedures for food preparation. And if a Quality department is in the organization, certificates of inspection or certification of the supplier’s process can go a long way to alleviate but not eliminate concerns.
Again, the key is to perform the Hazard Analysis with “fresh eyes”, as an honest broker. By doing this the HACCP team will hopefully earn the trust of the entire organization and no one area or department will feel singled out. On to Principle 2 in our next piece.
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