Tips from the Experts on HACCP Implementation

The American Meat Institute on its Web page has issued tips on HACCP implementation for mid-sized processors, calling them the “Seven Habits of Highly Successful Plants.” The AMI Web site address for this and further information on HACCP is www.meatami.org/haccp/AMI_tips.htm.

Seven Habits . . .
  1. Know the regulation and how the agency is to enforce it. The final rule, technical amendments, policy clarifications and Directives 5400.5 and 5000.1 should be your bible. Understand the Inspection System Procedure Guide (ISP), which replaces the Inspection System Guide (ISG), and how it dictates the types of Noncompliance Records (NRs) that inspection personnel can write. Make sure your written programs meet the Basic Compliance requirements. Use FSIS Forms 5000-1 (HACCP), 5000-2 (SSOPs) and 5000-3 (E.Coli) to ensure your written programs meet the basic requirements.
  2. Implement HACCP early. Work out the bugs in your own system (i.e. ensure monitoring frequencies are being met, paperwork issues are corrected, corrective actions are taken and appropriate).
  3. Know your HACCP plans, including pre-requisite programs, and processes. Plant personnel should be able to communicate how plans function (including how prerequisite programs function) and meet the requirements of the regulation. Be prepared for the awareness meetings. This is the plant’s opportunity to explain your program and the reasons for the decisions your plant made. Use overheads to walk inspectors through your decision making process. Have available the backup data (scientific literature, in-plant data, etc.) for those decisions. Make sure the people present at the awareness meetings are the individuals who can answer questions about the program.
  4. Manage your records and record keeping practices. Record keeping is one of the biggest implementation issues. Records should be scrutinized for accuracy. Specifically, records should be checked to ensure they are filled out properly, critical limits have been met, monitoring frequencies have been met, verification frequencies have been met, corrective actions have been taken when appropriate and clearly explained. They should also be examined for any indication that the critical limit is on the edge of becoming out of control. Plants should also be able to trace a product through the process by the records generated during monitoring activities.
  5. Manage their (FSIS) records. If a plant get a Noncompliance Record make sure it is appropriate and justified. The ISP has changed dramatically, and it does not include all the things the ISG did. Appeal those that are not correct. Specifically, make sure the “procedure code” and referenced regulations are appropriate to the issue. And as usual, appeal those with which you disagree.
  6. Track and compare deviations. Track and compare both the critical limit deviations your plant finds and the NRs (HACCP and SSOPs) that the inspector writes. Questions that should be asked include: Are the plant and the agency finding the same things? Is the inspector finding things the plant isn’t? Why? What trends are developing? Answers to these questions will help plants correct things before they become a major problem.
  7. Make sure all your corrective actions meet the requirements of 417.3. Create a corrective action document that has the four requirements (cause of the deviation is identified and eliminated, CCP is under control after corrective action is taken, measures to prevent recurrence are established and no product that is injurious to health or otherwise adulterated enters commerce) of 417.3 on it.