Validation: HACCP's Final Step

Charnette Norton

In February, we discussed the steps to take in terms of verifying a HACCP system to make certain that it is working as designed. In March, we covered record-keeping, which provides the documentation you need to demonstrate that HACCP control points are being monitored regularly and correctly.

This month we'll look at the final step in HACCP program implementation—validation.

Validation is a two-part process in which you obtain evidence to confirm that the elements of your HACCP plan are in fact truly effective.

First, you must collect specific scientific documentation to show that a selected critical limit is effective in the control of specific, identified hazards, if it is implemented as specified in your program.

An example would be to document the scientific reference for temperatures that kill or control the growth of microorganisms that cause food borne illnesses. You would use regulatory standards and guidelines, scientific literature, experimental studies and qualified experts as sources of information for validation confirmation. That material would confirm that the "danger zone" is 41°F to 140°F as you set your critical temperature limits for maintaining food.

The second part of validating critical limits is to document or otherwise provide assurances that equipment or procedures used in your operation are adequate and that their operating parameters are properly established.

In validating your plan, you may find that some CCPs have been established incorrectly or insufficiently. The cooking of hamburger patties can serve as an example. It is a process that may require a more detailed CCP than simply specifying that a patty's internal temperature be measured before serving it as "ready."

If the critical limit is set at "not less than 155°F for 15 seconds," can you be assured that all patties comply with your standard? Here are some other questions you might ask:

When you look closely at your operation, you will often discover that your equipment or procedures are unique to your facility and that certain operating characteristics will become important in the validation of a critical limit.

Also, it's important to note that food safety research is ongoing. with many previous assumptions being disproved regularly.

For example, one can remember a time when wooden cutting surfaces were not allowed in commercial food prep areas. Today, as a result of research, we know that hard wood cutting boards can be just as sanitary as food grade, hard rubber or acrylic boards (in any case, all cutting boards still need to be nontoxic and nonabsorbent, kept in good condition, free of seams and cracks, and have clear labeling or color-coding.)

Here's another example: the results of some early studies indicate that some of the conventional wisdom on which we have based our codes for thawing food are not as scientifically confirmed as once thought. Further, the safe food temperature range may be too broad, resulting in quality deterioration at a faster rate than thought for many foods served, particularly using the 140°F standard.

The point is, scientific research is calling many formerly accepted standards into question. Thus, it is important to reference up-to-date, authoritative sources in your validation activities. It also may be necessary to develop your own test data to verify that the control measures that you have implemented are effective in your situation.

This is especially essential if you are using a cook chill food production system. Most local codes identify a typical product's shelf life as much shorter than that which can be used when it is produced as part of a cook-chill system. Thus, test data becomes critical if you are to show that longer shelf lives for products in your system—up to four weeks or longer—are appropriate. Your validation may require process studies, confirmation of equipment specifications, microbiological challenge studies, literature reviews and so on.

As a rule, you should validate your HACCP plan both prior to and during the implementation process. You will also need to re-validate your plan whenever significant changes are made in the process, equipment, formulation or raw materials.

For example, the purchase of a blast chiller will likely change some of your established production process standards for many food products and may trigger the need to revalidate an existing HACCP plan.

Next month our final column in this series will discuss the process of ongoing evaluation and maintenance of your HACCP program.

Charnette Norton is vice president of Romano Gatland of Texas, foodservice consultants & planners worldwide, in the regional office located in Missouri City,TX. Char Norton and Ruby Puckett coauthored the book "HACCP, The Future Challenge—Practical Application for the Foodservice Administrator."