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Offering online courses for PCQI, HACCP, Internal Auditing and much more. We support Food Safety and Employee Safety solutions to customers in small to mid-size enterprises looking to train their employees online offering savings and convenience for your business.
Your hospitality business is once again open. Are your pandemic safety protocols far-reaching and evolving? Just as the hospitality industry must successfully manage infection transmission amongst staff and guests, so too must they not forget managing risk associated with hotel and restaurant suppliers and third parties. These entities pose a threat to your business via the goods and services relied upon for operation.
When it comes down to it, this risk amounts to three pieces of prevention: procurement, transporting, and receiving.
Hospitality Suppliers Management: Procurement
Beyond ensuring the goods and services purchased for your hotel or restaurant come from hospitality suppliers included on your list of approved suppliers, you must verify these companies have altered working practices to reflect the new requirement for increased infectious disease prevention. Remember, this may lead to delays and restrictions on product availability and must be factored into your purchasing timeline.
Hospitality Suppliers Management: Transporting
Similarly, the transportation process needs to maintain the safety of products on their way to your facility. How can you do this? As you review the infection control measures put in place by the supplier, ensure that they include effective and hygiene and disinfection protocols for vehicles, drivers, and packaging materials.
Hospitality Suppliers Management: Receiving
At this point, the third-party or supplier will directly interact with your staff. Thus, they should maintain the same level of hygiene protocols expected of your own team. Provide drivers with instructions on what safety and hygiene procedures to follow, such as social distancing, hand washing, and mask-wearing. Where possible, design the interaction to be as contactless as possible. To do this, communicate delivery notes and invoices electronically rather than in paper form.
Keeping your employees, your guests and your brand safe and healthy requires buy-in at every point in your operation. By following these simple protocols for procurement, transport, and receiving, your hotel or restaurant supply is one step closer to an effective POSI management program. To learn more about developing a robust infection control program that touches all parts of your business, consider our Hospitality Management Principles course.
The Food Safety Modernization Act’s (FSMA) Preventive Controls for Human Food Rule requires every food manufacturing facility to employ a Preventive Controls Qualified Individual as part of their food safety team. This person is a key component to a company’s food safety program, carrying out specific, crucial responsibilities as dictated by the regulatory body. These include tasks like developing, implementing and reassessing a Food Safety Plan.
While individuals can achieve PCQI status as a result of adequate job experience, relying on this tenure alone can and will leave your team falling short. Only formal risk-based PCQI training based on the FDA recognized standardized curriculum can effectively and properly equip individuals to understand the latest regulations and Food Safety Plan requirements. Keep reading to discover five core benefits of PCQI training.
PCQI Training Benefits
Grasp and Monitor Federal Regulations
A thorough understanding of evolving food regulations is paramount to ensuring compliance for your facility and guaranteeing your products’ safety for consumers. Alchemy Academy’s PCQI training courses break down federal regulations so that you not only ascertain how to comply with each standard but walk away with an appreciation for the value of PCQI responsibilities.
Master Hazard Analysis and Preventive Control Measures
PCQI training builds on food manufacturing professionals’ fundamental knowledge of food safety hazards and discusses the underlying principles of crafting a food safety preventive controls system. By getting to know the motivations behind food hazards, learning the process of hazard analysis, and exploring how to apply preventive control principles, future PCQIs better understand how a systematic approach helps assure safe food for consumption.
Develop an Effective Food Safety Plan
With new learnings in place, PCQI training takes a hands-on approach and walks participants step by step through building a Food Safety Plan, including identifying tools and implementation tasks. What’s more, participants of Alchemy’s PCQI training walk away with manuals, workbooks, templates, and more to help perfect their Food Safety Plan. We also discuss when to perform reanalysis to help assure you sustain a successful food safety system.
Understand the Importance of Record-Keeping Procedures
The importance of establishing and carrying out proper record-keeping procedures in a timely, complete, and true fashion cannot be overstated. PCQI training lays the groundwork for this practice, demonstrating the proper record keeping and record review systems relevant to your operation’s Food Safety Plan.
Get Direct Guidance from an FSPCA Lead Instructor
Leverage the expertise of Intertek Alchemy’s Consulting team with instruction and guidance from two of our FSPCA lead instructors. These instructors boast decades of experience and have completed robust training to provide you with the tools and resources you need to become a competent and confident PCQI.
When it comes to developing your company’s Food Safety Plan and cultivating a food safety culture, the benefits of PCQI training are crystal clear. Without formal training, the process takes longer, proves more arduous, and leaves your company open to vulnerabilities and non-conformities.
Take a closer look at PCQI training with Alchemy Academy’s blended eLearning resource. Taught by an FSPCA Lead Instructor, you’ll unlock the benefits mentioned above and more. Our course combines the benefits of a self-paced eLearning environment with a live virtual instructor-led session to ensure you walk away with a comprehensive and complete understanding of the new FSMA requirements.
What makes a beverage kosher? The answer begins with a discussion of where and how kosher production impacts your beverage plant. It may sound complicated at first, but we can sum up the basics of kosher production with the acronym P.I.E.: Process, Ingredients, and Equipment. This blog touches on the processes, ingredients, and equipment particular to a kosher beverage facility.
The first major piece of P.I.E. is Process. While several manufacturing processes are vital to kosher production, we’ll focus on a critical aspect of kosher beverage processes: the introduction of heat. This includes pasteurization, the most heat-intensive part of the kosher production process.
To begin, before scaling and batching, you must make sure to flush any residue from previous batches out of your equipment. If the product is pareve, the dairy residue must not be present. If the product is kosher, make sure no non-kosher residue is present.
After this step comes pasteurization, the single most kosher-sensitive part of beverage production. Whether your plant is hot-fill or cold-fill, the path a product takes through this system, and its heat source, have an enormous impact on kosher production. Your certifying agency will assess your plant’s configuration to help you identify processes that cause or may cause kosher concerns.
Kosher Beverage Ingredients
As expected, kosher beverage production also has unique ingredient concerns. Many common ingredients in commercial beverage production pose potential problems for your plant.
The most prominent ingredient concern in kosher beverages is grape. This includes grape concentrate, grape essence, grape flavor, and raising products. Why does grape pose such a problem to manufacturing facilities? Aren’t all grapes kosher? The answer, of course, is yes. However, what a facility does to that grape (its process) impacts kosher status. A vital component of this kosher-sensitivity is that grape juice is, in essence, wine. Wine’s religious significance requires precise handling rules.
Next, flavors – whether natural or artificial – serve as the building blocks of the beverage industry. They are, after all, what differentiates one product from another. When it comes to kosher, flavor can never be considered insignificant. As such, flavors for kosher beverage production must come from a reliable flavor house and be kosher certified. Liquid and powdered flavors each have unique kosher concerns. Consult with your certifying agency before you order.
Other kosher-sensitive ingredients include milk proteins, shellfish, gelatin, preservatives, and coloring. Each of these poses potential problems for pareve and equipment in your kosher beverage production.
Kosher Production Equipment
Finally, let’s take a look at the role equipment can play on your beverage plant’s kosher status. A crucial part of separating non-kosher and kosher products, a key tenant of kosher law, involves taking immense care of your equipment. Each product your run affects the equipment itself and that equipment can then affect future products. If you run dairy products, you cannot then run pareve on that same equipment. Likewise, if you run non-kosher, you cannot then run kosher.
Dedicating equipment to a single category can help you maintain this separation. Always remember that even if your equipment is dedicated, it can still be problematic if it’s considered compatible. Equipment is compatible when it looks, operates, or functions the same for kosher and non-kosher products, or dairy and pareve.
In most cases, dedicating equipment and eliminating compatibility isn’t practical. As a result, your equipment will require regular kosherizations. Take a closer look at the kosherization process in our online kosher beverage production course.
While kosher beverage production principles can seem complicated at first, boiling them down piece by piece can help your business approach kosher and succeed in the certification process. With the right processes, ingredients, and equipment in place, you have the tools to maximize your kosher production potential.
HACCP plans are the backbone of your food safety system. Built from the seven HACCP principles, these plans are mandated by regulatory bodies for the meat industry, the juice industry, and the seafood industry. In order to ensure a safe food supply, safeguard your product, and protect your brand, you’ll need to be compliant with both regulations and customer expectations.
In this blog, you’ll learn about the current status of USDA and FDA regulations for HACCP and what you need to do to comply with each.
USDA/FSIS HACCP Regulations
USDA regulations for HACCP are twofold. First, an establishment must have a written HACCP plan that includes a documented Hazard Analysis and the identification of Critical Control Points as applicable to the products. For these CCPs, a facility must identify and document critical limits, monitoring, corrective actions, verification procedures and record keeping requirements. It is normally recommended every facility should have at least one CCP identified and more as needed dependent on the results of the hazard analysis and the types of products made.
Second, the USDA requires an establishment to operate per the requirements of their HACCP plan. If you fail to meet either of these provisions, your products may be considered adulterated.
In addition, USDA may deem a HACCP system inadequate if:
The HACCP plan in operation does not meet the operations outlined in Part 417 of CFR 9. Section 417.6 (a)
Establishment personnel are not performing tasks specified in the HACCP Plan 417.6 (b)
The establishment fails to take corrective actions, as required by section 417.6 (c)
HACCP records are not maintained as required in section 417.5 or Section 417.6 (d)
Adulterated product is produced or shipped. Section 417.6 (e)
For a more in-depth look at these five scenarios and how to avoid them, consult our Basic HACCP online course.
Under the USDA, not only will you have to validate your HACCP system itself, you must validate prerequisite programs, CCP limits, and critical operational parameters for anything that has an impact on food safety, such as sanitation. Critical operational parameters could include factors like the concentration of antimicrobial lactic acid mixes or the temperature at which such a mixture is applied to a meat product.
There are two elements to keep in mind when you perform these validations, in USDA inspected establishments. The first requires scientific documentation or literature that validates the limits you chose as sufficient. The second requires in-plant validation data to prove that processes are successful. These theoretical and application elements come together for an all-encompassing validation methodology.
FDA mandates HACCP regulations for the seafood industry and juice industry. FDA also requires validation of critical limits associated with critical control points. Supporting documentation such as regulatory references, scientific studies and/or internal plant validation must be on file to validate critical limits.
The Food Safety Modernization Act was the most sweeping reform in food safety laws in more than 70 years. Signed into law on January 4, 2011, it aims to assure the US food supply is safe by shifting the focus from responding to contamination to preventing contamination. There are seven laws associated with FSMA regulations in total that promote a proactive approach to food manufacturing.
The FSMA Preventive Control for Human Food Rule requires a food safety plan is written and implemented by a PCQI. To learn more about the responsibilities of a PCQI and the road to certification, consider Alchemy Academy’s blended PCQI certification course.
Under the FSMA Preventive Controls rule, the food safety plan must contain as appliable to the operation:
Written Hazard Analysis for all operations
Preventive Controls as applicable
Supplier Programs if applicable
Recall Programs if a hazard requiring a preventive control is identified
Procedures for Monitoring Implementation of Preventive Controls
USDA and FDA each require manufacturing and production facilities to meet stringent regulations for HACCP or Preventive Controls as applicable. Take a deeper dive into these regulations, as well as how to build, implement, and manage your HACCP plan with our Advanced HACCP eLearning course – the only accredited online Advanced HACCP training solution on the market.
Not sure where to begin with food safety training or how to progress past HACCP? Consider Alchemy Academy’s new course catalogfor food manufacturing professionals.
Taking a proactive approach with an OHS program is crucial to the prevention of incidents in your facility. Not sure where to begin? By following OSHA recommended safety practices it’s easy to break down the process into manageable stages.
Keep reading to discover 4 steps to planning and implementing your introductory OHS program.
Identify Potential Hazards in Your Facility
The first step in creating any occupational health and program is to inspect your workplace for health and safety hazards, and identify the related risks. Get people involved in your regular inspections of all operations, equipment, plant vehicles, and work areas. More buy-in from your team now results in more effective processes later on.
Always remember to document these inspections to later verify corrective actions. If company policy allows, take pictures and videos. A picture is worth a thousand words!
In addition to the inspections above, you should also conduct and document incident investigations. This includes close calls and near misses, such as instances in which someone could have fallen ill or sustained injury. Treat these incidents seriously to determine and correct for their root causes. Remember, operator error is never a root cause.
Lastly, identify any foreseeable emergency scenarios in routine and non-routine tasks. Consider your operation’s context including activities in the neighborhood of your facility. For example, you might be baking cookies with relatively low danger, but your neighbors might be making ammonium nitrate fertilizer that could cause an explosion that could affect you!
After a thorough investigation of your facility, it’s time to evaluate each hazard’s risk. Take into account levels of severity, the likelihood of occurrence, and the number of potentially exposed people.
As you move to take corrective action, work on your highest risk hazards first. If you can’t immediately identify a permanent solution for each, you’ll need to use interim controls.
Select and Implement Controls
Now that you’ve identified your hazards and their risks, you want to control them. So, what are your options? Several resources are available to you, such as:
OSHA compliance standards and guidance
Industry consensus standards, manufacturers’ literature, and engineering reports
Control measures used in other workplaces
Input from your workers
For complex hazards, consult with safety and health experts
Always pick controls that are the most feasible, effective, and permanent. Discuss potential solutions with your workers to make sure they’ll function in your operation. Successful controls never make an employee’s job harder. Remember when implementing protective measures to follow the hierarchy of controls: Elimination, Substitution, Engineering Controls, Administrative Controls, then PPE only as a last resort.
Again, it’s essential to immediately eliminate or control all hazards causing or likely to cause death or severe harm. Ensure that new controls do not introduce new hazards into your facility.
Complete your OHS program by verifying your work. Have you truly minimized risk in your facility? Carefully test each safety control measure put in place. Have your workers join in on all parts of your internal audit to reach a safe consensus. You may need to rethink your corrective actions, introduce more OSHA compliance training and supervision, or include a new series of procedures.
For more information, please see OSHA’s Recommended Practices for Safety and Health Programs web page at https://www.osha.gov/shpguidelines/. If you would like assistance in implementing your program, including evaluating your compliance status, please contact Intertek Alchemy!
If it’s not written down, it didn’t happen. Performing your due diligence is vital to your food safety audit process’s success and, in turn, successful production or manufacturing. Different methods exist for documenting inspection results and crafting an effective internal audit checklist. By exploring each, you’ll understand how to approach and prepare the documentation that works best for your internal audit procedures.
Internal Audit Walkthroughs
The first method, and one we do not recommend, is simply doing a walkthrough of your facility and recording any observed nonconformities. This internal audit procedure doesn’t prove to any third-party certification process that you had a structured plan of attack, objective, or scope associated with the inspection. Plant inspections are a critical part of the internal audit process. However, they need to have a specific scope and documentation to be effective.
If auditing against GFSI Systems such as SQF, BRC, and FSSC 2200, we recommend using the GFSI standard checklist for your audit. Using a standardized document ensures your internal audit team goes through each regulatory requirement, without skipping areas of your facility or processes. Since these checklists are comprehensive, break them into sub-parts and complete a portion of the standard regularly, such as monthly or weekly. The internal audit schedule should ensure that all parts of the standard undergo an audit quarterly or annually, depending on the standard requirement.
Customized Internal Audit Checklists
The third internal audit documentation method is to use customized checklists for your plant inspections or specific processes. There are several benefits to this method, including:
Guides the audit – Your internal audit team will know exactly what to review
Ensures completion of all elements – Helps auditors address the entire scope of the audit
Reinforces objective and scope – Defines whether you’re auditing a process, a product, or people
Acts as a record – provides the documentation third parties need to prove your internal audit’s thorough completion
Setting up your customized audit checklist
Customized checklists are specific to individual facilities. However, there are general items every facility should utilize. These include the date, time started and finished, areas under audit, and a record of all the internal audit team members. For plant inspections, consider (at a minimum) including representatives from Operations, Quality Assurance, Sanitation and Maintenance.
Your checklist should go beyond general items (floors, walls, ceilings) and include an area-specific examination of equipment, processes, product handling, and people. So, you’ll need space to document each area of inspection and their results. Leave room to record nonconformities and corrective actions. Identify a target date and person responsible for corrective actions that cannot see immediate completion. Always remember to follow up!
Consider what content needs to be included and the specific requirements for each as you move through departments. Identify the relevant written program requirements and food safety policies, objectives, process interactions, activities underway, staff competencies, and process-based auditing techniques.
Managing the Internal Audit Checklist
An audit checklist may be detailed or limited, depending on the experience level of your audit team. Less experienced individuals need more detailed checklists and vice versa. Update these checklists as needed or as changes occur in each area.
The internal audit results should be reviewed by the entire team and circulated to supervisors, department managers and senior leadership.
Risks of using the checklist approach
While using a customized checklist is recommended, the process is not without risks. Never let the checklist’s details drive the internal audit process to a point where your team overlooks something crucial to your facility. Using the acronym STOP helps combat this risk.
Sometimes, the best course of action is to sit back and watch. This helps the audit team see, understand, and evaluate a department’s operation, fully thinking through the processes happening around them.
Following these guidelines helps you achieve internal audit success and in turn receive high marks on your external audit. Learn more about internal audit best practices and gain expert insight into documentation procedures in our fully online courses Internal Auditing-Basics and Internal Auditing-Advanced.
Intentional adulteration is only carried out after careful study and preparation by an attacker – is your food defense program equally prepared to address such acts? Motivation, capability, and vulnerability come together to compose food defense threats. Motivation often determines the adulterant and tactics that a perpetrator chooses to use. In addition to the threat itself, you must understand these potential drives for adulteration to help you address vulnerabilities in your process and keep the food system secure.
The three most prominent food defense threat motivations include:
Economically Motivated Adulteration or EMA
Terrorism against the food system occurs to cause fear, public health harm, or social and economic disruption. A terrorist may add toxic chemicals or a microbial pathogen directly to food set for public distribution.
Disgruntled employees, consumers, or competitors may or may not intend to cause public health harm but may seek to harm a company’s reputation through recalls when they carry out intentional adulteration. Each of these instances is an example of sabotage.
Dissatisfied employees represent intelligent adversaries with special access to and knowledge of your food production process and food defense program. This familiarity with your facility, procedures, security, and preventive control measures makes them of heightened concern. Consumers and extreme activists often carry out or threaten attacks on the food system to highlight a cause, such as using products thought to cause environmental harm.
Economically Motivated Adulteration
You may have heard EMA referred to as food fraud. This example of motivation involves the intention to make money fraudulently, evade regulation, or gain an unfair economic advantage.
There are multiple EMA methods, such as substituting expensive ingredients with cheaper ones to increase profit, adding unapproved ingredients to increase taste or volume, or mislabeling ingredients to avoid tariffs.
Individuals who commit intentional adulteration are creative, adaptable, and resourceful. Consider the three types of motivation and how to prevent and address them when creating your food defense program. To learn more about food defense threats, roles, and what happens after intentional adulteration occurs in a facility, consider Alchemy Academy’s Food Defense Supervisor online course.
Whether you’ve weighed the benefits of product diversification and have already entered the kosher food industry or you’re just getting your feet wet, you may find yourself curious about the steps to kosher certification. What can you expect from a formal inspection of your kosher program, and what can you do to prepare? This blog will help you better grasp the rabbi’s visit, no matter where you are in your kosher production journey.
Who is the Rabbi Auditing Your Facility?
Rest assured, the rabbi visiting your facility has years of experience studying Jewish law, particularly Kosher laws, under his belt. Of course, his knowledge base doesn’t end there. In addition to his familiarity with these rules, he has a working familiarity with food processing. After all, to properly audit and give your facility certification, the rabbi must be familiar with what you do, how you do it, and why you do it.
As you welcome the rabbi into your facility, cultural sensitivity is crucial. You may want to consider certain practices to make him more comfortable. To learn more about these precautions, consult Alchemy’s online Managing Kosher Production course.
Who Interacts with the Rabbi?
When a rabbi visits your facility, he’ll need to interface with multiple divisions of your team. Each is a vital proponent of your kosher food production and thus your compliance with kosher rules. These may include:
Research and Development (R&D)
Kosher Inspection Blog Post
He’ll want to talk to R & D to ensure that any reformulations or new items keep kosher laws in mind as they progress through development. Next, the rabbi will consult with quality assurance. The QA team represents the interest of your consumer. As such, the rabbi enlists them to make sure they include the Kosher consumer’s interests in all areas.
Of course, your production is paramount to the inspection. Beyond inspecting your production processes, he’ll go through records, schedules, formulas, and more. He may request to speak with engineering to verify there’s no cross-contamination of equipment or lines, and he’ll consult receiving to ensure they abide by kosher rules. Your maintenance and cleaning staff will also need to meet kosher sanitation specs to receive kosher certification.
What Happens During the Kosher Inspection for Certification?
Again, inspections come in all shapes and sizes. However, there is an outline of the basics you can expect during your journey to kosher certification. In a typical facility, the visit lasts for about an hour. Sometimes this is shorter, sometimes longer. Most of the time, these visits are unannounced and happen on a regular schedule.
The rabbi will visit all of the departments listed above, being careful to check production records and schedule. He’ll check storage areas and raw materials to make sure you have separated kosher products and ingredients from non-kosher ones.
Remember, the rabbi treats every audit as confidential. True, full, and accurate information is needed to inspect your kosher food production practice properly. As such, they understand they are guardians of proprietary and confidential information – perhaps that which acts as the basis of your entire business – and act accordingly.
Alchemy Academy Resources for Your Kosher Food Production and Certification
To further prepare for kosher food certification and ensure your kosher program includes all of the essential, consider Managing Kosher Production Online. This in-depth course leverages the Orthodox Union’s Rabbi Avrohom Stone experience and knowledge to provide participants with a step-by-step walkthrough of kosher rules, concepts, and program components. Start learning today!
As COVID-19 changes the way we interact and travel, hospitality management must adopt new solutions and re-asses their existing practices to combat infection transmission. The average uncontrolled rate of infection is three people for every infected person. Yet even though this risk exists, infection control measures can help your team mitigate threats.
Of course, not all control measures are created equal. Hospitality management personnel must decide which control measures to put in practice. To do so, you need to understand their hierarchy of effectiveness. This blog will outline each, helping you accommodate new standards and keep people safe.
The most effective means of control, elimination of a hazard enables us to remove the possibility of risk exposure altogether. Consider this your first point of defense. Examples of elimination, and therefore breaking the train of transmission, include removing a complimentary fruit basket from the front desk or the decorative pillows from guest beds.
When elimination isn’t an option, move to substitution. Substitution replaces a hazard. For example, hospitality management chooses to transition from a traditional door where guests need to touch a handle to installing an automated door requiring no physical contact. Here the hazard still exists, but a substitution makes it less likely to affect your guests.
If a substitution is off the table, we have the option of engineering controls to mitigate risk. Engineering controls cast a wide net. Simple installations, operational changes, and significant infrastructure alterations are all examples of this type of hospitality solution.
Note that substantial alterations should only occur where the reduction of risk is proportional to the investment required.
Next, warnings promote awareness on behalf of workers and guests. Signs, visuals, guidelines, etc. all serve as warnings in your facility.
Personal protective equipment (PPE) is hospitality management’s final solution and should be reserved for when all other hazard control options fail or are unavailable as options. Remember, PPE is not a hazard control and does nothing to eliminate hazards. While PPE is a crucial aspect of preventing the spread of infection, removing or managing a hazard’s source always takes priority.
Knowing the right infection control measures to employ for your business is critical to sustained success. Beginning with elimination and ending with personal protective equipment, these hospitality health and safety procedures are an important cornerstone of your operation’s larger POSI Response program. When employed correctly, each ensures your team doesn’t waste valuable resources, like time and money, and the chain of transmission remains broken.
What is HACCP and where did it come from? HACCP, which stands for Hazard Analysis and Critical Control Point is a system that prioritizes and controls potential hazards in food production and its supply chain, which arose around the 1960s. At this time, the National Aeronautics and Space Administration’s (NASA) needed a way to ensure safe food (thereby preventing foodborne illness) for its astronauts on active missions, thus developing HACCP principles.
Today (and back on Earth), HACCP plans are the foundation of Food Safety Plans everywhere. As such, the HACCP process applies to the entire food supply chain, from food manufacturing, production to distribution. The first step in HACCP training is to understand the seven HACCP principles.
The HACCP Process
A HACCP plan pulls from seven distinct principles:
Conduct a Hazard Analysis
Identify Critical Control Points
Establish Critical Limits
Develop Monitoring Procedures
Decide on Corrective Actions
Create Verification Procedures
Form Record-Keeping Procedures
HACCP Principle 1: Conduct a Hazard Analysis
Hazard analysis is the most important principle used in the HACCP plan. This critical practice identifies the biological, chemical, or physical hazards that could occur at each step in your manufacturing process. Once identified, ask yourself, “Is this hazard significant or reasonably likely to occur?”. Make sure to justify your answer and determine which control measures you have in place for those hazards.
It’s critical to identify all the potential hazards that could be associated with the raw materials, processes, and finished products to assure you identify all the controls necessary. This assures the production of safe food products.
HACCP Principle 2: Identify Critical Control Points
The second principle in the HACCP process is to identify critical control points. Critical control points are steps or procedures at which you can apply control to prevent, eliminate, or reduce a hazard to an acceptable level.
Typical examples of CCPs include cooking processes, chilling, and metal detection. However, CCPs are specific to a facility’s unique manufacturing process and products and must be properly identified to control significant or reasonably likely to occur hazards.
HACCP Principle 3: Establish Critical Limits
Once you identify where CCPs exist in your production, you must identify the critical limits you need to meet for each CCP. A critical limit is a minimum value to which a hazard needs to be controlled to ensure a food product’s safety.
These critical limits must be validated. To do so, you may need to conduct internal tests or consult outside resources like regulatory guidelines or scientific studies.
HACCP Principle 4: Develop Monitoring Procedures
The fourth step in the HACCP is to establish procedures for monitoring your CCPs and using those results to adjust the process as needed. Monitoring observes whether a CCP is under control (does not exceed the critical limits) and provides a record for verification. Monitoring is either continuous, like automated temperature control systems, or non-continuous, such as visual evaluations.
Your monitoring procedure should consider:
How you will perform the monitoring?
Who is responsible for monitoring?
What you are actually checking and why?
How will you record results?
How frequently will you carry out monitoring?
Monitoring responsibilities must be assigned to qualified personnel who are properly trained to perform the tasks and record the results.
HACCP Principle 5: Decide on Corrective Actions
Next, you’ll want to decide on corrective action procedures. In the event that a deviation occurs and you fail to meet the critical limit, you must have predefined actions ready to set in place. This practice makes sure that no contaminated product enters commerce and determines how to properly dispose of the affected product.
Identify preventive measures to prevent a recurrence
Maintain records of the actions taken
HACCP Principle 6: Create Verification Procedures
The sixth HACCP principle is to establish verification procedures. Here, you’re double-checking that your HACCP plan is correctly carried out and is effective.
CCP process step verification
Calibration of monitoring instruments
Overall check that the food safety system is working as intended
HACCP Principle 7: Form Record-keeping Procedures
You must have records in place to prove your food is produced safely. The HACCP records serve as evidence that your planned monitoring and verification happens as expected, your production stays within critical limits, your corrective actions are in place, and that your product is safe to distribute.
A good rule of thumb to follow is that not documenting an activity is as good as the activity never happening. In other words, documentation provides irrefutable evidence to demonstrate your team follows the HACCP plan to regulators and auditors. There’s no way around it! These records must be complete, accurate, and timely. Remember, HACCP records are legal documents so you want to make sure they are right and accurate.
The following are types of HACCP records commonly requested by FDA and USDA Inspectors:
Critical control point records
Critical limits records
CCP Monitoring records
Records associated with deviations
Verification activity records
HACCP Plan and supporting documents
Resources & HACCP Certification
Alchemy Academy offers many comprehensive solutions for HACCP training and HACCP certification at both Basic and Advanced levels. These fully-accredited online courses help participants develop and master the HACCP principles outlined above. Start learning with us today!
The Food Safety Modernization Act’s (FSMA) Preventive Controls for Human Food Rule ensures safe manufacturing, processing, packing, and holding of foods meant for human consumption in the US. Under this regulation, FSMA requires that a Preventive Controls Qualified Individual, or PCQI, develop and implement a site’s food safety plan. But what exactly is a PCQI, and what are their responsibilities?
What is a PCQI?
A PCQI is an individual who, according to FSMA, “successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized by the FDA or otherwise qualified through job experience to develop and apply a food safety system.” PCQIs are often employees but can be pulled in from outside of your facility.
Your operation may need to utilize more than one PCQI, and that’s perfectly alright! It’s always recommended to have at least a primary and back up PCQI designated at each site. It’s also wise to train Food Safety Team Members as PCQI’s so they can make the best contribution possible to the Food Safety Plan.
What are the Responsibilities of a PCQI?
A PCQI has four primary responsibilities to a food safety system. These include:
Writing the Food Safety Plan
Validating the Food Safety Plan
Overseeing Record Review
Reanalyzing the Plan When Required
Writing the Food Safety Plan
Food Safety Plans are your preventive control system’s guiding hand. PCQIs assure that hazard analysis, preventive controls, supply-chain programs, and a recall plan are part of your Food Safety Plan. They’ll also need to delineate procedures used for monitoring, corrective actions, verification, and record keeping.
Validating the Food Safety Plan
A PCQI should perform or oversee validation and most verification activities. Sometimes, these two terms can prove confusing. To break it down, verifying assures that your team follows the programs as intended while validation ensures that those programs are accurate and effective in controlling food safety hazards.
Because these concepts are scientific in nature, a PCQI must perform or oversee validation. Only process preventive control limits require validation by the FDA. This means any parameters or values associated with supply-chain, sanitation, or allergen preventive controls need not be validated for FDA compliance, however, companies certified to Global Food Safety Initiative (GFSI) standard must validate these programs as well for audit compliance. Even sites that are not pursuing GFSI certification should consider validation of all preventive controls identified at the facility.
The Food Safety System, as a whole, must also undergo validation. Ideally, your PCQI conducts validation before the actual implementation of the food safety plan. However, regulations require you to complete this step within 90 calendars days of production. If necessary, a longer period is allowed if the PCQI provides written justification.
Overseeing Record Review
There are two types of record reviews: a review of the Food Safety Plan itself and a review of implementation records. Implementation records document – you guessed it – the implementation of the food safety plan. In other words, they demonstrate that you do what you say and say what you do.
All records should be originals, true copies, or in electronic format. They should also be complete, accurate, and timely. For example, FSMA regulations require the review of monitoring and corrective action records within seven working days.
Much like validation, reviewing these records prior to product release, so that you can prevent potential recall and other unintended consequences of a deviation, is best. What’s more, PCQIs should revisit these records with adequate frequency.
Reanalyzing the Plan
Reanalysis verifies that the Food Safety Plan is still applicable and relevant through onsite observations and the aforementioned record reviews.
PCQIs should perform reanalysis every three years or whenever significant changes to your facility’s processes occur. Significant changes can include changes to raw materials, formulations, finished products, and equipment process flows. The following events also constitute instances that require reanalysis:
information becomes available about a new hazard
a system failure such as discovering an ineffective preventive control an outbreak
an unanticipated deviation occurs
Your Food Safety Plan should always be current and reflect your actual operations. Perform reanalysis as often as needed to assure this. The Food Safety Team should manage the reanalysis process and assure each reanalysis is properly completed and documented.
A Preventive Controls Qualified Individual plays an impactful part in making certain your food safety system operates as intended. This person will produce, validate, and reanalyze your Food Safety Plan. They’ll also work to review the associated records.
Want to learn more about PCQI responsibilities and earn your certification? Our accredited PCQI course, developed by the Food Safety Preventive Controls Alliance (FSPCA) in partnership with the FDA, is your training solution. Sign up today!
These days, knowledge of foodborne illnesses extends far beyond the food industry professionals. Consumers are more informed and cautious than ever before, with outbreaks sickening millions each year. Cross-contamination caused by food safety and sanitation deficiencies is often the culprit.
By implementing produce sanitation and sanitary design practices via well-thought-out sanitation programs, we can eliminate this threat to public safety, guarantee the production of safe foods, and inspire confidence in consumers.
Effective Sanitation Programs for Produce Safety: The Basics
While the Food Safety Modernization Act (FSMA) Preventive Controls Rule outlines specific sanitation and sanitary design requirements for produce safety, the backbone of a compliant and effective sanitation program is thorough documentation.
Your program’s document should clearly outline all the processes and procedures employees need to follow to meet the plan’s objectives. It should include Standard Sanitation Operating Procedures (SSOP) – a step-by-step description of cleaning and sanitation procedures used to maintain equipment and the environment – as well as your unique sanitation protocols.
Your facility’s sanitation protocols must consider:
A hygienic zoning program that identifies and classifies areas of your facility, from food contact surfaces to regions outside of the processing room
Controlling traffic flow between various zones in a facility to minimize the potential of cross-contamination
Employee best practices, like wearing smocks and gloves, proper hand washing, etc.
Appoint a qualified staff member with appropriate training and education to review the program and oversee its implementation. Note that without the proper tools and resources for the individuals involved, including time, even the best plans may prove ineffective.
Sanitary Design in Produce Equipment
Next, you’ll need to apply distinct sanitary design principles to your program. Sanitary design is the application of design techniques that allow timely and effective cleaning of your facility and equipment. This eliminates the potential for cross-contamination vehicles to pose a threat to your production and offers several other long-term, including the production of safe foods to protect consumer health and your company’s reputation. Other benefits include:
Effective cleaning and sanitation
Elimination of harborage sites
Exclusion of pests
Verification, Validation, and Beyond
Of course, you must practice verification and validation of your protocols, including environmental monitoring, as part of your produce sanitation program. Always review, analyze, and report your results. From here, your team should develop and employ corrective and preventive actions when necessary.
For a deeper understanding of specific sanitary design principles related to facilities, infrastructure, and equipment, consider our Essentials of Produce Safety eLearning Course. Developed in partnership with the Produce Marketing Association (PMA), this course is an affordable solution for businesses looking to manage produce safety risks while learning the latest industry best practices.