HACCP Principle 2: Determine the Critical Control Points

Easy to imagine, may be more difficult to do

HACCP, Hazard Analysis and Critical Control Points, begins with a Hazard Analysis. Now that the actual and potential hazards are identified, hopefully as an “honest broker” with “fresh eyes” as was discussed in the previous piece, it’s time to look at the Critical Control Points, CCPs. As was noted about conducting a Hazard Analysis, Determining the Critical Control Points (CCPs) is easy to imagine, but may be more difficult to do.

Assuming the hazards are well identified, one can imagine there may already be controls in place. For example, if a large industrial or commercial grinder or mixer is used to grind or blend ingredients, the opening may be large enough for a person’s arm to be inserted and injured. Many times these invaluable machines come with some sort of safety devices designed in to prevent such occurrences. The safety guard is intended to prevent injury to workers by preventing them from being injured or their clothing from being caught and potentially drawing them into the machine.

Many times workers are often in a hurry or the safety device is misplaced and they proceed to use the mixer without it. While the worker believes they will be safe and thankfully accidents do not often happen, they don’t realize the safety guards may also prevent items from inadvertently falling into the food and potentially being broken up by the mixer into small, difficult to see pieces, posing a hazard from physical objects to those who consume them. Not using the devices therefore poses not only a safety hazard to the operator but to the consumer of the food as well. The CCP to prevent such an occurrence is the use of the safety guard.

Additionally, consider when assessing the use of the mixer that the introduction of hazardous biological materials may be possible. Certainly employees handle food with bare hands, but the potential for contamination from microorganisms on the skin are a real concern. If a worker is wearing a hat it can help prevent hair from falling into the food, but do we know if this hat is reserved for work or worn at other times during the worker’s non work life? And if a worn apron falls inside a bowl may have been clean when the shift started, but what potential biological hazards does it contain during this operation? In these cases the guard could again prevent an employee’s hand or clothing contaminating the food. The CCPs in these cases would be the washing of the operator’s hands, the use of sanitary headcovers and work clothing that are resanitized regularly. The CCPs would include making sure that the hand, headgear and clothing cleaning is sufficient to remove harmful microorganisms. In operations where cleaning chemicals are used, one CCP is training workers in the proper use of the chemicals. An additional CCP could be inspection of storage areas and practices to insure the cleaners are not in the food preparation area unless they are to be used. It is easy to put the cleaner on the shelf during the cleaning operation and then forget about it being there, leading to a potential hazard. Pesticides and maintenance chemicals will require additional consideration to enact the proper CCPs.

Continuing with the mixer, the introduction of hazardous chemicals need also be considered. The mixer is typically cleaned regularly using chemical cleaners that while they may be considered nontoxic can potentially cause some sort of stomach distress. The CCP here would be to insure proper cleaning to eliminate or reduce harmful microorganisms to non hazardous levels but also to insure proper rinsing to remove all traces of cleaning chemicals. Another area to consider is storage of cleaners and such materials. The CCP review will want to examine whether or not cleaners and other chemicals such as pesticides are stored above food preparation areas such as the mixer. This way inadvertent spills or leaks will be prevented.

Taking a look at larger scale commercial or industrial processes, many employ full automation and control, a national bread bakery for example. CCPs are generally well identified and the appropriate controls are in place. Often there are an array of sensors to measure every factor in the process: weight of each ingredient, preparation temperature, time, and in some instances color, smell and taste which advanced sensors can perform for some products. Sensing whether by a person, machine or in a laboratory is important to help identify the control point. In an oven or freezer for example, temperature sensors will need to be placed where the temperature is critical to be effective in helping control hazards such as microorganisms. The point of control in this example the operation where the temperature needs to be achieved to kill a germ in the case of the oven or prevent germs from multiplying in the case of the freezer. The actual control in the oven is not the sensor but the thermostat it’s attached to that turns on or off the heat supply to maintain the temperature. The CCP determination in this example is to make sure the oven reaches and maintains the proper temperature for the required time not only to insure the product is baked properly but the insure that harmful microorganisms are killed.

The CCP determination may add an additional step, taking the internal temperature of the baked food for example. Some can relate to this when they visit a restaurant that will only serve hamburgers cooked medium or more since the management believes this will help insure that dangerous microorganisms such as salmonella or e coli are killed whereas they may not be if the beef were prepared rare.

The key to determining the CCPs is they are the Points where the Control whether automatic or manual can make a difference. Training and awareness will need to be institutionalized not only by the HACCP team members but the entire operation. The team will want to include those most familiar with the operations and procedures to insure their list is complete. And the rule of thumb is even if it seems unlikely, include it. Seeing food related illness headlines almost daily lead me to counsel excess caution even where none would normally be called for.