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HABC Level 4 HACCP exemplar material

This document has been created to show the type of study learners should expect to receive in their examination. It consists of an example HABC assessment HACCP case study for Vegetable and Bean soup followed by an example report.

It is important to note that this is an example. It is not meant to be a definitive answer and there are many other relevant points which could have been identified and which would have been awarded marks.

This example has been created to provide an example of the depth and breadth of information that will be required in learners’ answers.

It is also a suggested way to lay out the report and not the only format that would be awarded marks. Any suitable, clear way will be accepted – learners will not lose marks if they use a different style of report.

It is not expected that candidates will be able to write as much as included in the sample document due to time restraints; however candidates would be expected to identify the main issues and make recommendations.

Contents

HACCP Study for vegetable and bean soup: Page 2

Introduction Page 2 Prerequisites Page 3 Scope of study Page 4 Product and process description Page 5 Flow chart Page 10 Risk Assessment matrix Page 11 Hazard Analysis Page 12 CCP Decision Tree Page 15 Verification & Validation Page 19 Methods of implementation & maintenance plan Page 19 Example report: Page 20

Prerequisites Page 20 The team Page 21 The scope/terms of reference Page 21 Process flow diagram Page 22 Hazard analysis Page 22 HACCP control chart & application of the decision tree Page 24 Monitoring Page 25 Corrective Actions Page 26 Verification, validation & review Page 27 Conclusions & recommendations Page 27

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HACCP study for: Vegetable & Bean Soup Introduction: This study covers the small-scale production of vegetable and bean soup. The fresh soup is sold chilled in two-litre tubs to catering restaurants and hotels who then reheat and serve it to customers. The factory is a modern purpose-built unit on an industrial estate where 24 people are employed working two shifts, 5 days a week. It is a family business which has expanded rapidly over the last two years and now has a turnover in excess of £1 million per annum.

Member Experience Qualification Team Role

General Manager (Sales)

5 years in food production L3 Food Safety qualification Attended HACCP seminars

HACCP Team Leader

Quality & technical Manager

3 years in food production. Employed part-time 2 days per week

Level 4 Food Safety in Manufacturing Level 3 HACCP

Team Member

Hygiene/cleaning Manager

4 years at the factory No formal Food Safety qualifications Team Member

Office Manager/ HACCP coordinator

2 years at the factory HACCP awareness certificate Team Member

Maintenance Engineer

4 years at the factory Level 2 HACCP Team Member

Factory worker 3 years at the factory Level 2 Food safety in Manufacturing Team Member

Hazards covered: The HACCP study covers food safety hazards of all types microbiological, chemical and physical. Allergens are addressed as a prerequisite. Type of study: Process-led study

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Prerequisites

PREREQUISITE

CONTROL MONITORING

CORRECTIVE ACTION

FREQUENCY DOCUMENT RESPONSIBILITY

Calibration of

Measuring Equipment

Calibration of probes and

weighing scales

Annual Current certificate of

calibration traceable to national

standards.

Engineer Remove from use and arrange

repair or replacement

Maintenance Planned Preventative Maintenance for all plant

To plan Annual plan Maintenance records

Engineer Review PPM if persistent problems

Traceability and recall All finished product is coded

and a recall system is in place

so that rapid and complete traces and recalls can take

place should a product retrieval be necessary

Annual Trace record GM Investigate errors and omissions.

Allergen control Training, separation, cleaning

Lubrication oils are nut free

Ongoing Allergen swab test GM Product recall on receipt of positive

result of undeclared allergen

Training All employees receive

documented training in

personal hygiene and cleaning procedures before commencing

work. All staff in contact with food

receive Food Safety Level 2 in

manufacturing within 3 months of starting work.

HACCP team members receive Level 2 in Principles of HACCP

As required Content of the

training course

Training records

GM Training or refresher training as

identified on review or change of

responsibilities

Personal Hygiene Hygiene Policy

All employees and other persons who enter the

manufacturing plant must

Ongoing Handswab record GM Discipline staff who do not comply

with rules

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follow the requirements for personal hygiene regarding

dress, hygienic habits and hand

wash Staff hand-swabbing

Premises The building is constructed and

maintained according to good manufacturing design

principles. The process flow from intake to despatch is

arranged to prevent product contamination.

When required Floor plan GM

Transport All vehicles used for transport

are suitable for the purpose, maintained in good repair.

Refrigerated transport is capable of maintaining product

temperature within specification, under maximum

load.

Each load is temperature checked

Delivery note has a

printed temperature record

GM

Driver

Return load

Destroy products Review

Glass Brittle Material

Control

Glass and brittle material

control procedure

Monthly Glass & brittle

material audit

Glass Breakage log

GM As identified in the procedure

Approved Suppliers The company has a procedure

for approval and monitoring of

supplier performance, including evaluation of HACCP systems,

product safety information and legislative requirements.

Purchases of raw materials and packaging are made from

suppliers on the company’s

approved supplier list.

Audit of suppliers

every 2 years

Questionnaire

Independent

Laboratory report

GM

GM

Reject or treat as non-conforming

product materials from non-

approved suppliers Review and change supplier

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Scope of Study This HACCP study covers all activities involved in the production of chilled vegetable and bean soup. It covers the production process from receipt of raw products to despatch of chilled products from the site. At each process step all potential microbiological, physical, chemical and allergenic food safety hazards will be considered and appropriate control measures will be established.

Product Post delivery storage condition

Interim storage Intrinsic product factors

Potatoes Stored below 10oC Stored below 5oC once peeled and shredded

Purchased whole, peeled and shredded on site

Carrots (bought in peeled) Chilled at 3°C Stored below 5oC once peeled and shredded

Grated on-site

Courgettes Stored below 10oC Stored below 5oC once peeled and shredded

Grated on site

Onion, purchased peeled and chopped

Stored below 5oC Stored below 5oC once peeled and shredded

If product begins to discolour it is removed from chill and disposed of

Canned canellini beans Ambient Chilled once can open Rinsed and drained prior to use. Food poisoning has been associated with pulses and beans due to presence of phytohaemagglutinin

Garlic powder

Ambient Ambient

Olive oil

Ambient Ambient Purchased in 20-litre cans

Vegetable stock powder

Ambient Ambient Contains egg, wheat, gluten

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Product and Process description Product Name Vegetable and Bean Soup

Facilities

• Food is produced in a purpose-built business unit, which produces a variety of fresh, chilled soups

• Cooking takes place in large purpose-built cooking vessels. The energy supply heating the vessels is gas

• There is linear workflow at the factory

• There are two separate cleaning areas and two sets of all cleaning equipment to prevent cross-

contamination

• Portioning is done by hand into containers. Containers are lidded and labelled by hand

• Storage units are refrigerated

• Delivery vehicles are refrigerated

• There is a separate staff room with a changing room, toilets and a small eating area. Two offices are next to

the staff area.

• Goods in and out are at opposite ends of the factory.

• Waste is stored in a dedicated area adjacent to goods in

Product description Main Process Methods

• cooked fresh soup, which is sold chilled and is to be reheated before eating

• The soup is made within 5 days of receipt of vegetables at the unit and soup is given a 5-day shelf life from

the date of cooking

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• Potatoes, carrots, onions and courgettes are rinsed in a chlorine solution and then shredded

• Each vegetable type is then placed into food-grade plastic containers, lidded and dated

• The garlic and vegetable stock is weighed and added to the diced onion before products are mixed

• The vegetables are deposited into the cooking vessel and cold, potable water is added to the mix

• The vegetables, stock and water are heated until the liquid is boiling and then the cooking vessel is lidded

and the soup is left to simmer for 30 minutes

• Beans and oil are added to the soup by hand. The soup is stirred with a plastic food-grade paddle and

product is simmered for a further 15 minutes

• The contents of the cooking vessel is emptied into chilled vessels with ice paddle attachments and is stirred

for 30 minutes until the product temperature is reduced to 10oC

• Soup is then transferred into clean, plastic containers. Food handlers use food-grade measuring jugs to fill

the containers.

• The containers of soup are then lidded and labeled. The label includes information regarding storage

conditions (‘store chilled’); heating information (‘Heat until piping hot, for best results do not boil’) and date

code.

• It is assumed that the soup will be portioned and reheated before it is eaten

• The potatoes and onions are received weekly from a local supplier.

• The carrots and courgette are placed in the chiller unit until required

• Seasoning is added during cooking, to taste

• The heating vessel and the chilling vessel with ice paddle are fitted with integral probe thermometers which

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measure the core temperature of the soup. A digital display of the temperature is available throughout

cooking and cooling. An alarm will sound if the cook temperature of 82°C is not reached in the set time.

• Once packed into cartons and labelled the cartons of soup are put through a metal detector before storage

• Soup is then placed in the chiller <5°C ready until required. The soup is despatched the following day after

cooking.

Main Hazards Identified

• Microbes surviving processing

• Cross-contamination after processing

• Contamination and multiplication of microbes after processing the vegetables

• Physical contamination from poor personal hygiene; poor maintenance; poor packaging and contaminated

product received

• Chemical contamination from the presence of pesticides on the raw vegetables, chemicals and non-food

grade packaging used.

• Allergens not considered a main hazard, as only salt, pepper and paprika are added to the vegetables. The

site also operates a nut-free policy.

Main Preventative Measures

• Approved suppliers

• Temperature control

• Modern technology for processing/cooking

• Metal detection

• Food-grade packaging

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• Linear workflow

Intended Use • The product is sold in retail outlets and schools

• Consumers include all high-risk groups.

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Process flow chart for vegetable and bean broth

Verified on 5/6/2012

by S.Sammuels (quality manager) and J. Dewson (production manager)

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Risk assessment matrix

Low > SEVERITY > High

Hig

h

>

R

ISK

>

Lo

w

1 2 3 4 5

2 4 6 8 10

3 6 9 12 15

4 8 12 16 20

5 10 15 20 25

Potential risk, but no CCP, ensure prerequisites cover

Border line risk, use decision tree to establish if step is a CCP

Probable CCP, validate through decision tree

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Hazard Analysis Process Step Identified Hazard Controls in Place Hazard Significance Justification/

Comments 1 Delivery of

products Physical contamination

• Packaging

• Plastic

• Debris

Microbiological

contamination in vegetables and garlic

Bacteria spores

Chemical contamination

• pesticides on

vegetables

• Cleaning chemicals

Reputable suppliers

Annual audits

Packaging specification Product specification

Temperature check (<5°C)

Visual inspection of packaging,

dates and label on all deliveries Reputable suppliers

Annual audits

Reputable suppliers

Annual audits

Severity

2

Likelihood

4

Score

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Reputable suppliers are

used Some products delivered

ready-prepared

2 Ambient storage Physical contamination from damaged

packaging

Dried products delivered in large polythene bags

Canned products stored off floor

in dry area Correct storage

‘No glass’ policy in storage area Lights covered with plastic

diffusers

2 1 2

3 Chilled storage Multiplication of pathogens

Chiller temperature checks three times a day.

Automated alarm on chilled storage cabinets

Cleaning routine in place

2 3 6

4 Peeling & chopping

Multiplication of pathogens due to

Limit time at ambient to less than 30 minutes

2 2 4

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prolonged time at ambient temperature

Physical contamination

from metal chopping cleavers and plastic from

handles Chemical contamination

from incorrect cleaning

Visual inspections Planned Preventive Maintenance

of the equipment on a schedule

Personal Hygiene Policy adhered to

Cleaning schedule followed

5 Place into containers

Microbiological contamination due to

incorrect cleaning and dirty containers

Physical contamination

from broken containers, poor personal hygiene.

Chemical contamination due to incorrect cleaning

Personal Hygiene Policy adhered to

Cleaning schedule followed Metal detector used at a later

stage

Food-safe chemicals used

1 1 2

6 Chilled storage Multiplication of

pathogens

Chiller temperature checks three

times a day. Automated alarm on chilled

storage cabinets

Cleaning routine in place

2 3 6

7 Add vegetables

and water to cooking vessel

Microbiological

contamination due to incorrect cleaning and

dirty containers

Physical contamination from broken containers,

poor personal hygiene. Chemical contamination

due to incorrect cleaning

Personal Hygiene Policy adhered

to Cleaning schedule followed

Metal detector used at a later

stage Food safe chemicals used

1 1 2

8 Cook and

simmer

Survival of pathogens

due to inadequate cooking

Cook to a core temperature of

>70°C Probes used

3 3 9 The only control which

would destroy pathogens

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9 Chill using ice paddle

Spores germinate due to slow cooling

Contamination and

multiplication from micro-organisms due to

prolonged storage at ambient temperature

Cross-contamination

from paddle and cooling vessel and poor hygiene

practices

Chill to 5°C within 90 minutes

3 1 4 Chilling monitored

10 Place into jugs

and fill

containers

Cross-contamination due

to dirty equipment and

poor personal hygiene Microbiological

multiplication due to process taking too long

Hand wash

Clean equipment

Ensure time from coming out of

chilling vessel to putting lid on filled carton is less than 10

minutes

2 4 8 There have been some

problems in the past

11 Weigh, lid and Label

Microbiological contamination from

contaminated equipment

Multiplication from storage at ambient

temperature Physical contamination

from damaged packaging

Chemical contamination

from non-food-grade packaging materials

Automated process Stainless Steel

Fully washable

Easy to dismantle and clean Packaging from approved supplier

to specified standard Visual inspections

Checks on labels carried out

3 1 4 Quick flow-through

12 Metal detector Failure of metal detector,

pieces of metal are non-ferrous or too small to

be detected

Checks carried out every batch

on the metal detector

4 2 8

13 Chilled Storage Spores germinate and

multiplication if stored

Daily stock checks carried out

Temperatures checked three

4 2 8

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above 8°C Prolonged storage due to

poor stock rotation

times a day and 24-hour automated alarm system in place

14 Despatch Contamination if the packaging is split

Spores germinate and

multiplication if stored at ambient temperature

Chemical contamination from oil and fumes if

packaging is not intact

PPM Refrigerated vehicles

Driver checks

2 2 4

Q4

Will a subsequent step eliminate the

hazard or reduce it to an acceptable

level?

Q3

Could contamination with

identified hazard(s) occur in

excess of acceptable level(s) or

increase to

unacceptable level(s)?

Q2

Is the step specifically

designed to eliminate the

likely occurrence or

reduce it to an acceptable

level?

Modify step,

process or product

Q1a

Is control

necessary at this

step for safety?

CCP Decision Tree (Codex)

Q1

Do control measures

exist?No

Yes

No

Not a CCP.

Proceed to the

next step in the

process.

Yes

YesNo No

Yes

YesNo

CCP

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Step

no

Step Hazard Q1 Q1a Q2 Q3 Q4 CCP?

1 Delivery of products Physical contamination

• Packaging

• Plastic

• Debris

Microbiological contamination in vegetables and garlic

Spores

Chemical contamination

• pesticides on vegetables

• Cleaning chemicals

Y n/a N Y Y N

1a Chlorine wash Chemical contamination due to chemical not being dissolved or incorrect amount of chemical used and residue left on product

Y n/a Y Y N Y

8 Cook & simmer Survival of pathogens due to inadequate cooking

Y n/a Y - - Y

10 Place into jugs Cross contamination due to dirty equipment and poor personal

hygiene

Microbiological multiplication due to process taking too long

Y n/a Y - - Y

12 Metal detector Failure of metal detector, pieces of metal are non-ferrous or too

small to be detected Y n/a Y - - Y

13 Chilled Storage Spores germinate and multiplication if stored above 8°C Prolonged storage due to poor stock rotation

Y n/a N Y N Y

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CCP No.

Process Step Hazard Control Measure

Critical limit

Monitoring Corrective Actions

Procedure & Frequency

Responsibility Procedure Responsibility

1 Chlorine Wash Chemical & physical

contamination

from un-dissolved

chlorine tablet

Taint from incorrect

dosage

Microbial

survival

Staff training in Safe

Operating

procedure

Correct dose

levels of

chlorine

All vegetable

chlorine

washed in correct dose

levels of chlorine

No un-dissolved

tablet

105 ppm

80 ppm

Visual check each

solution

Test with disc colour comparator each

solution

Random samples of

shredded vegetables sent for

microanalysis 1x

week Test chlorine concentration with

disc colour comparator each

solution

Food handler

Food handler

Managing director

Dissolve tablet or drain and restart procedure

Dilute to correct

concentration

Production Manager

Production Manager

Production Manager

2 Cook and simmer

Survival of pathogens due

to inadequate cooking

Cook to a core

temperature of >70°C

Probes used

75°C for 30 seconds

Automated & calibrated probes

monitor the core temperature of the

product on every

batch is cooked. An alarm will sound if

the temperature is not reached in the

time allowed

Shift Manager Log the alarm Continue to cook the

batch for the required time until the

temperature is reached

Call out engineer

Shift Manager

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3 Chill using ice paddle

Spores germinate due

to slow cooling

Contamination and

multiplication from micro

organisms due

to prolonged storage at

ambient Cross-

contamination

from paddle and cooling

vessel and poor hygiene

practices

Chill to 5°C within 90

minutes

Chill using ice paddle

Automated & calibrated probes

used

Visual checks on time Alarm on vessel if

temperature not reached

Operators Destroy product if limit is breached and soup

is above 8°C for more

than 90 minutes

Shift Manager

4 Place into jugs and fill

containers

Cross contamination

due to dirty equipment and

poor personal

hygiene Microbiological

multiplication due to process

taking too long

Hand wash Clean

equipment

Ensure time

from coming out of chilling

vessel to putting lid on

filled carton is less than

10 minutes

Dismiss staff who do not comply to personal

hygiene rules.

Managing Director

5 Metal detector Metal contamination

not detected

Effective metal

detection

Absent- Ferrous 1.5

mm

Non-ferrous 2.0 mm

S Steel 3.0 mm

Metal detection check using test

pieces

Operators. Stop line and recalibrate

Notify SM

Hold stock manufactured since

previous check.

Shift Manager

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6 Chilled Storage Spores germinate and

bacteria

multiply due to length of time

at ambient

Correct temperature

control <8oC

5°C

Automated temperature checks

24-hour alarms

operate Manual check weekly

Operator

Factory Manager

Log the alarm Manual check of

temperature if >15°C

destroy product if <15°C remove to

another unit Call out engineer

Document action

Shift Manager

Verification & Validation

Validation of the HACCP plan and decisions made were carried out before the implementation of the system. Critical limits were determined through the use

of complaint analysis and by using the CODEX decision tree.

Tests were conducted to ensure time/temperature combination during cooking and cooling was suitable. Laboratory analysis was used to establish shelf life. Tests are carried out monthly by an independent laboratory on the chilled, cooled soup to establish microbiological counts fall within the accepted level

Systems audits are undertaken on a planned programme so each is reviewed at least annually.

Methods of implementation & maintenance plan

The study has been implemented over a period of 2 weeks; key personnel and management were trained in Food Safety and HACCP awareness and CCP

monitoring, document completion and corrective actions. Documentation was described and implemented. The HACCP study is maintained through six-monthly departmental internal audits and an annual HACCP review.

Documented HACCP team meetings are held six-monthly to discuss deviations, complaints and effectiveness of any corrective actions and changes to the plan.

The HACCP system should also be reviewed in the following circumstances:

• When there are any changes to the process flow

• When there are any additions to processing equipment

• If there are any additions to the product range

• If there are any amendments to the product ingredients

• If there are any relevant changes in food law

• If there are any known failures concerning food safety

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Example report

This is an example answer. It is not meant to be a definitive answer and there may well be many other relevant points which could have been identified and which would have been awarded marks.

This is a suggested way to lay out the report: any suitable, clear way will be accepted.

This example has been created to provide an example of the depth and breadth of information that will be required in learners’ answers.

It is not expected that candidates write as much as this due to time restraints. However, they are expected to identify the main issues and make recommendations.

Prerequisites

The business has identified a number of relevant prerequisites. In the main these appear

to be suitable and if implemented effectively they will control general hazards through

the process well.

There are however, a small number of omissions which the business needs to address. For

example, there do not appear to be any prerequisite controls regarding to the following:

Water, waste control, stock rotation, pest control and cleaning. All of these are

important food hygiene aspects, which if not controlled effectively may result in food

contamination and food poisoning.

Some prerequisites which have been developed require review as they are not complete or

may not adequately control hazards. Examples of this include:

Personal hygiene where there is no mention of any controls regarding sickness and return

to work. Additionally the corrective action of disciplining staff who do not conform may

not be effective.

Allergen controls do not appear to cover labelling, so it would be necessary to review this

assessment fully before a full decision can be made regarding the suitability of allergen

controls.

The transportation prerequisite appears to focus on avoiding cross-contamination, but

does not mention the cleanliness of vehicles and cleaning regimes for cleaning vehicles.

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Approved suppliers are only audited every 2 years and it is questionable whether this is

often enough for all suppliers.

The team:

First appearances indicate that a multidisciplinary team approach has been used,

however it is noted that there is no representation on the HACCP team by any

production management personnel. This is a little concerning as many controls and

monitoring procedures need to be implemented and applied by these personnel. In

addition, the HACCP team leader has little formal training and is the general manager

for sales. It is not a good idea to have a sales manager leading a HACCP team as there

may be conflicts of interest between sales and food safety costs.

It is also noted that contrary to the information provided in the prerequisites regarding

training, not all team members have suitable food safety or HACCP training and indeed

some have none and others only a very low level of training. No information is provided

on when this training took place.

The Scope/terms of reference:

The scope identifies the start and end points of the study and the hazards identified

through the process. There appears to be some confusion with regards to allergen control

as at one point it is identified these are covered as a prerequisite and later it is identified

they will be covered in this study.

The type of HACCP study has been outlined as process-led, although the study is just for

a single product, which is unusual. It would be better to either group similar products or

to have conducted a product led study if only a small number of products are made using

different processes.

Information has been provided regarding product ingredients, although the intrinsic

product factors on onion relate to corrective actions regarding spoilage, which could

indicate a lack of understanding as to what the intrinsic factors may be.

Allergens are mentioned as ingredients of the vegetable stock powder even though they

are supposedly controlled by prerequisites.

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The description of the process is clear and succinct and covers most of the main

processes, although it is noted that there is no mention of dry and interim storage of

products.

There is a mention of waste at this point: it would be better if this were considered as a

prerequisite.

Main preventative measures are outlined. The intended use of the product is identified as

being for retail and schools, catering establishments are not identified. No mention is

made of the fact that the product is intended for reheating prior to service and this

should have been identified at this point.

There is no mention of the specific pathogens which are associated with this product or

any specific legislation. Both should be included where appropriate.

The process flow diagram:

The process diagram is clearly laid out and has been validated as accurate by the quality

manager and production manager. However there is no representative from production

management on the HACCP team and it has recently been validated as correct.

On closer inspection however it is noted that it is not entirely correct, mainly due to the

fact that all the vegetables appear to go through the same process, which is not actually

correct as some are bought in ready peeled and others require peeling and the fact that

the packaging line should also feed the lids on the process flow.

Although dry goods and oil are delivered and stored, they do not appear to be added to

the product at any stage.

Further information would be required to determine whether this was correct for all

occasions and also if there were any rework flows.

Hazard Analysis:

The business team has made a good attempt at a hazard analysis and it is encouraging to

see that a risk assessment matrix has been used to help identify significant hazards

through the process. This is important, as if risk is not identified then it could lead to a

hazard which is not significant being identified as a critical control point or a hazard that

is significant not being identified as critical.

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Where there is a problem with regards to the risk matrix though is that scoring has been

carried out eat each step and all of the hazards, whether physical, chemical, or

microbiological have been scored together. It would have been much more effective to

have risk-scored each hazard at each step individually as this would have meant that

attention was focused on the most significant hazard at each step.

Most decisions made through the process appear to be correct and there is a good level of

detail included for most hazards.

Areas which would require further information to be provided or would require some

alterations or additions to the hazard analysis, though, include:

Step 2: the hazard of microbiological contamination and multiplication does not appear

to be addressed. Before a decision can be made with regard to whether this is controlled,

it would be necessary to review the prerequisites fully.

Step 3: some of the controls are actually monitoring (reference to checks). Also the

hazard identified refers to multiplication of pathogens, but the control of cleaning

actually controls contamination.

The step of washing the product has been missed off from the hazard analysis and yet is

included later as a significant hazard.

Step5: the control of metal detection is at a later stage and should not be included as a

control at this step.

Step6: monitoring actions have been identified as controls. Checking a chiller does not

control the multiplication of bacteria, it is the temperature which controls this and there

is no reference as to what this temperature should be.

Step 8: further information would be required on whether 70oC is a suitable temperature

to destroy micro-organisms, as it does not appear to be very high.

The step of adding the beans has been missed from the hazard analysis, which is

surprising since there was some detailed information regarding hazards from this

ingredient in the terms of reference.

Step 9: germination of spores has correctly been identified as a potential hazard and

there are specific controls for this. The scoring of the risk assessment is not correct

though and the reasoning is not acceptable. This should have been identified as a

significant hazard.

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HACCP control chart & application of the decision tree:

It is noted that the codex decision tree has been applied to all significant hazards

identified and for most hazards the decision tree appears to have been applied correctly,

however there are a few errors.

Step 1a has been included; this was not included in the hazard analysis and appears to

have been added as an afterthought. More information would be required to determine

why this has been included as a significant hazard, but the hazard identified does appear

to be significant. The decision tree has not been applied correctly here, although the final

outcome has ended up being the same. If the answer to question 2 is ‘yes’, then this will

become an automatic critical control point and further questions should not be asked.

10, ‘place into jugs’: here the decision tree has not been applied correctly. Question 2 of

the decision tree asks if the step is specifically designed to eliminate hazards or reduce

them to a safe level. The step of putting soup into jugs is not carried out for food safety

reasons. It is likely that the team has confused the fact that they fill the jugs in a hygienic

way with the fact that the step is designed to keep food safe.

All other decisions made are correct.

The HACCP control chart is, in the main, correct and detailed enough to identify suitable

controls and corrective actions suitably, but there are some reasonably large omissions.

There are also some errors made with regards to controls and critical limits.

CCP2: the critical limit is incorrect; as it is a control not a critical limit. To establish a

suitable critical limit it is advised that the business conducts scientific tests, including

testing for specified micro-organisms in the product as well as time trials.

CCP 3: This step has been included as a critical control point even though the hazard

analysis did not identify it as a significant hazard. It is possible that it has been added at

a later stage, but there is no mention of this. The critical limit for this step is incorrect.

‘chill using a paddle’ cannot be considered a critical limit as critical limits should be

measurable and unambiguous, they are the difference between acceptable and

unacceptable. The terminology used here refers to a control measure, not a critical limit.

An example of the critical limit may be chill to 5oC within 2 hours (although this would

have to be validated).

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CCP4: No controls or corrective actions have been identified with regards to cross-

contamination hazards and these need to be included if they are considered critical. If

they are not considered critical then hazard should not have been applied against the

decision tree.

In CCP 6 the target temperature and critical limit are incorrectly identified. The critical

limit should be more stringent than the target and in this case they are the wrong way

round.

For other identified critical control points, the controls and critical limits identified

appear to be reasonable and link to clear, recognisable parameters. It would be necessary

to identify the scientific data utilised to make decisions and to check that they were

correct and appropriate before a final decision could be made. This is why it would have

been helpful to have identified likely pathogens associated with the product when

completing the terms of reference, as it would have helped to identify if controls were

suitable.

Monitoring:

The HACCP plan has identified the procedures for monitoring, the frequency and the

responsibilities, which is good. In some cases these are a little vague and more information

will be required to validate that they monitor the hazards effectively.

For CCP 3 the monitoring activities have not been identified as this step has been

identified as critical, it is essential that monitoring systems are in place and are effective.

More information will be required with regards to why it is the shift manager’s

responsibility to monitor temperatures at CCP2, but at CCP 3, this is the responsibility of

operators. As both are monitored via automated probes and alarmed, it would seem

logical that both are monitored by persons in a similar job role.

For CCP 4 the monitoring identifies that metal detection tests will be carried out, but

there is no indication of the frequency of this and therefore it is possible that it isn’t

carried out often enough or is unreliable. Additional information regarding this would be

required and a suitable frequency, for example, each hour during production, should be

included.

It is encouraging to see that in the main the responsibilities for monitoring lies with the

food production operator, although it would be necessary to identify that the operators

had been adequately trained.

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No indication is given on the plan with regards to where the monitoring activities are

recorded. It would have been useful to link the activity to a record and further

information regarding records need to be requested. A visual inspection of these will also

help to establish that the monitoring activity is suitably recorded at the correct step in

the process.

Corrective actions

Corrective actions outline what is required and also indicate who is responsible for the

corrective action, which is good. Most of the information regarding corrective actions

appears to be correct and appropriate. However there are some omissions, for example:

CCP 1: whilst there are controls in the process, there are no corrective actions with

regards to the actual product. Examples of suitable corrective actions regarding the

product would include re-washing or, if product had already been made or sold, it may

include quarantine, disposal or recall.

CCP3: only has a product corrective action, no process corrective action to ensure the

process is effectively controlled is included. Examples of suitable corrective actions

regarding this may include maintenance and repair, review of policies, recipes and

procedures, in particular amounts processed in the time scales allocated.

CCP4: May provide an interesting insight into the ethos of the company and it indicates

that there may have been problems with personnel. This may be why it has been included

as a CCP suddenly? It is interesting to note that the corrective action is to dismiss staff,

and that the managing director is responsible for this. It appears to be a little harsh.

Additionally, one would question whether or not the product is still going to be sold.

There need to be product corrective actions in place.

CCP5: has outlined that if the critical control point has been exceeded, stock needs to be

put on hold, but what happens after that regarding the stock? Does it get used, reworked

or rejected? It would probably have also been a good idea to investigate the cause so that

suitable process corrective actions could have been included.

CCP6: For this CCP, the temperatures do not match the critical limit or targets (they

exceed both). There is no mention of time out of temperature. Will this potentially affect

the shelf life of the product?

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Verification, validation & review

Most of the information required with regards to verification and validation has been

included, but it is very brief and could have been expanded upon. For example, how is the

HACCP plan validated and verified? What tests are done? This section requires more

depth of information if it is to be useful and effective. It is quite superficial and does not

really give any detail of specifically how the plan can be validated and verified.

There is no differention in the plan regarding validation and verification and this may

lead to omissions.

Conclusions & recommendations:

Overall, this is a good attempt for a small company and most decisions and controls

appear to be sound and control the hazards identified. There are a few areas of concern

and it is suggested that these are remedied as soon as possible. Some of the other

questions identified in this report may well be answered suitably once further information

has been provided.

For a small number of hazards and controls, in particular hand fill of the jugs, it would

seem that there may have been a ‘knee jerk’ reaction to a problem and it is suggested

that some time is invested at the next HACCP team meeting to discuss whether this step

is indeed a CCP at all and if it is to identify suitable and effective controls and critical

limits.

For ease and to help prioritise actions the following table provides some recommendations

and timescales to ensure the HACCP is suitable and effective:

Area Action Reason

Prerequisites Develop prerequisites for

water, waste, stock

control, pest and

cleaning.

Include suitable controls

regarding sickness

reporting and return to

work procedures. Assess

Prerequisites are an important part

of ensuring food sold by a business is

safe to eat. They ‘lay the foundations’

of food safety and allow the business

to concentrate on their specific

hazards when developing the HACCP

study.

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whether the corrective

action for this pre

requisite is suitable.

Include suitable controls

for cleaning of transport

vehicles

Consider reducing the

time between audits for

high risk suppliers.

Team Ensure all team members

are suitably trained in

both food hygiene and

HACCP

There are legal and good practice

reasons to ensure HACCP team

members are suitably trained

Scope Review and clarify points

so that there is no

confusion or ambiguity,

in particular allergen

control and waste

If the scope and terms of reference

are clear and complete, it will enable

the team to manage their HACCP

and hazards more effectively

Process flow diagram Review to include all

processes for each

vegetable and validate to

ensure all process are

included, and that it is

accurate for all occasions

If the flow chart is inaccurate or

incomplete then it may lead to

significant hazards not being

identified in the hazard analysis

Hazards analysis Review to ensure it is

complete and includes

assessment of all steps

and hazards. It is

suggested that all hazards

are considered at each

step.

A review of the scoring

Considering each hazard at every step

will ensure that no hazards are

missed and that the controls in place

actually match the specific hazard

and do not become too generic

Completing this will help to ensure

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system in the hazard

analysis should be

conducted. These

decisions made should be

made via use of scientific,

historical and legislative

data when determining

significance through use

of the risk assessment

matrix,

that critical control points are not

wrongly assigned.

Decision tree Retrain the team in the

correct use of the

decision tree, particularly

step 10 where the

decision tree has been

used incorrectly.

It is important to consider whether

this step has become a CCP justified

on the risk it posed, or whether it

was a ‘knee jerk’ reaction to an

isolated incident. If it does not really

justify being a CCP, the team should

remove it. CODEX identifies that the

number of CCPs should be limited.

This is to allow businesses to

concentrate on the real hazards in

their business. Other less significant

hazards can be controlled through

prerequisite controls.

Verification/validation

and review

It is recommended that

this is reviewed and that

the business provides

some more detail with

regards to both

validation and

verification methods to

ensure that they are

comprehensive and

robust.

If the system is not effectively verified

and validated it is possible that the

system is not correct or effective, but

it is believed the food produced is

suitable and managed well. This could

lead to unsafe or contaminated foods

being produced.