Building a HACCP program: verification and record keeping

Jorge Hernandez

This year we have taken you step-by-step through the development of a personalized food safety plan for your establishment. In January’s article, “How to Begin Developing a Food Safety Program,” you evaluated your establishment’s current commitment to food safety training and practices. You learned that a food safety system cannot be built without food safety knowledge and correct Standard Operating Procedures (SOPs). You became aware of basic pre- requisites: proper personal hygiene, sanitation, equipment maintenance and good suppliers. To create the foundation for a total food safety system, you accessed the experience of regulatory agencies, educators, trainers and other establishments implementing food safety systems.

In our article, “Keeping Food Safety Hazards in Check,” you began working with the principles of the Hazard Analysis Critical Control Point (HACCP) system to produce a personalized food safety program. First, you conducted a hazard analysis to identify potentially hazardous foods, areas of possible cross-contamination and places where a breakdown in food safety could occur. You then learned that a “critical control point” (CCP) is a step that must be done correctly to keep food safe. CCPs in the day-to-day process will vary depending upon the food and the way it is received, stored, prepared and served.

In the article, “Is Your Food Safety Plan Working,” you learned to keep CCPs under control using monitoring procedures to ensure they met “critical limits”—the minimum or maximum value of food safety factors such as temperature and time—for the prevention of food hazards. If a food’s CCP is cooking, for example, then its critical limit is the minimum internal temperature it must be heated to in order to be safe. You then developed procedures to monitor your CCPs, decided how often to check possible food safety hazards, and established who in the operation would be responsible for the process. You also determined specific corrective actions in case a critical limit is not met.

Up to this point you have validated your commitment to food safety by learning the basic principles of the HACCP system and personalizing that system to keep the work environment safe. But no system is perfect at first. A total food safety system is, by definition, a system that has been tested and proven effective in preventing foodborne illness. Before a HACCP plan can be considered complete, you must create a system of verification that reviews procedures daily to identify what is working well and where modifications are necessary.

Verification and Recordkeeping

Do your food safety practices work as intended? Are changes needed? After establishing HACCP procedures, you must verify that each step leads to proper food safety results. Verification procedures may include evaluation of CCPs and critical limits to determine if they are still appropriate; confirmation that monitoring alerts staff about hazards; and visual inspections to ensure that corrective actions are always taken.

“Food safety procedures are not good if our employees don’t use them, or don’t use them systematically,” says David Jacobson, director of restaurant operations at the Prescott Brewing Company, an independent full-service restaurant and brewery in Prescott, Arizona. “Verification proves that we are accomplishing our food safety goals. It also provides extra insight into our safety measures—the first time we verified our HACCP procedures, we discovered hazards that we were unaware of initially. Because we went back to verify, we were able to address those hazards and prevent them from becoming food safety problems.”

When you verify, watch for procedures that work in theory, but need adjustment to be effective in a constantly changing restaurant environment. HACCP is a living plan that needs modification when any new element enters the establishment; A new menu item, supplier, process or piece of equipment could change the food hazards and the effectiveness of procedures.

For health officials such as David Ludwig, manager of the Environmental Health Division for Maricopa County Health Department in Arizona, HACCP verification builds a bridge between industry goals and health regulations. “If we send out inspectors with 44-item checklists, we give mixed messages to both the owners and the employees. A positive relationship between regulators and the industry is crucial for the inspection process to be constructive,” says Ludwig. “The Maricopa County Health Department has a HACCP alliance with local industry partners—they send us their HACCP information and we tailor our inspections using their individual Critical Control issues.

Established records help the process of verification by tracking food safety actions. “The most efficient verification process addresses previously documented problems to double-check the accuracy of the control action,” states Ludwig. Examples of records include time-temperature logs, SOPs, calibration records and product specifications. Maintained records should include information gathered when performing monitoring activities, taking a corrective action, checking equipment function, and dealing with supplier specifications.

Because hazards may change, plan to regularly evaluate monitoring charts, records and hazard analysis checklists for performance. In addition, specify who should perform what documentation, when it should be performed, and how. “With electronic processes, recordkeeping is becoming much easier,” says David Ludwig. “When a challenge occurs, you can now use your pre-established HACCP computer database to record both the problem and the corrective action you take. Once your HACCP plan is up and running, you may be able to reduce recordkeeping even further. A well-engineered HACCP plan, thoroughly reviewed by the establishment and regulatory officials, could result in a set SOP that makes certain recordkeeping unnecessary.” Remember, while developing your HACCP plan, keep all documentation on computers or other accessible formats as it will be used in plan verification and modification later.

Putting It All Together

Training, the last step in the creation of the HACCP plan, allows you to put all the pieces together. A training program integrates safety procedures, corrective actions and recordkeeping methods into each employee’s job duties to create uniform reactions and behavior. Specific HACCP procedures can also be easily included in your establishment’s pre-existing food safety training program or general orientation session for new hires.

Whether you are starting from scratch or adding to your establishment’s present employee training, a good HACCP training program should:

For Prescott Brewing Company, which makes all of its food from scratch, HACCP techniques are integral to employee training. “Our 60 employees follow HACCP just like they follow our recipes or implement any other procedure. It just becomes part of what they do,” says Jacobson. Incorporating HACCP into a formal training program promotes adherence to procedures while instilling food safety principles.

Darden Restaurants of Orlando exemplifies the enduring value of food safety training. “We first implemented our HACCP plan in 1979, before food safety awareness or training programs became prevalent,” says C. Dee Clingman, vice president of quality assurance for Darden Restaurants. “Darden Restaurants was the first restaurant company in the U.S. that required mandatory foodservice manager certification. Today, the company operates four different restaurant concepts with establishments across North America, all of which include our HACCP training.

When you put together the basic steps of the HACCP plan—conducting a hazard analysis, determining CCPs, establishing critical limits, setting up monitoring procedures, implementing corrective actions, and verifying and documenting procedures for training—you create a living and evolving food safety program. As your company changes and grows, so will your HACCP procedures.

With procedures verified and staff trained, you now have a complete HACCP system in place. Through your commitment to food safety and daily use of your HACCP program, you know your staff has the knowledge and tools to keep proper food safety procedures top of mind in your establishment.

Jorge Hernandez is director of technical education at the National Restaurant Association Educational Foundation.