How to Develop a HACCP Plan and Implement Active Managerial Control

In This Article:

• Why is active managerial control important?
• Achieving Active Managerial Control in Your Establishment
• What is HACCP?
• HACCP’s 7 Principles

Implementing a food safety management system puts in place steady procedures to prevent foodborne illness. These may include, but are certainly not limited to:

• Personal hygiene program (download our handwashing best practice chart here, and learn about handwashing best practices here)
• Supplier selection and specification program
• Cleaning and sanitation program
• Facility design and equipment maintenance program
• Food safety training program
• Quality control and assurance programs
• Standard operating procedures (commonly referred to as SOPs)
• Pest control program

HACCP plans may vary slightly from one operation to the next, but the main principles are the same. For a HACCP plan to succeed, it should be based on a written plan and specific to that operation’s menu, customers, equipment, and adaptable to their already implemented procedures and processes.

Each HACCP plan is unique. What works for one operation may not necessarily work for another. However, there are seven key principles of an effective HACCP system. 

1. Conduct a Hazard Analysis

Review your current menu and processes, asking questions along the way to evaluate your setup and identify potential hazards. These questions should span your entire operation, from the ingredients in your menu selections, the design of your facility, the uses of your equipment, current sanitation efforts, employee health and hygiene practices, etc.

Some basic questions to start with include:

• Does the food contain sensitive ingredients that could present a microbiological, chemical, or physical hazard (fish bones, pesticide residues, salmonella, etc.)?
• What are the sources of the food, from the geographical region to the specific supplier?
• Does the kitchen layout provide adequate separation between raw and ready-to-eat foods?
• Can the facility and equipment be easily and readily cleaned and sanitized?

The more detailed, the better. The U.S. Food and Drug Administration (FDA) has a great resource on HACCP application guidelines, including a host of helpful questions to ask when developing a HACCP plan.

2. Identify Critical Control Points

Critical control points are the steps in which the operator and food handlers can control. Identifying these is essential for the prevention and elimination of the hazards identified in the first step, or at the very least, the reduction to safer, acceptable levels.

Critical control points are located at any step where hazards can be prevented or reduced. These can be present in any phase of the flow of food. These should be carefully developed and documented, and used only for food safety.

Examples of critical control point might be the refrigeration of precooked foods to prevent the growth of bacterial, or heating foods high enough to kill pathogens before serving. 

3. Establish Critical Limits

Critical limits are the maximum or minimum value in which a biological, chemical, or physical hazard must be controlled at the critical control point for the prevention, elimination, or reduction of a hazard. These are used to distinguish between safe and unsafe conditions. These limits may be based on factors related to the conditions for bacterial growth (Food, Acidity, Temperature, Time, Oxygen, Moisture – FAT TOM) or others as identified in your initial hazard analysis. Each control point will have one or more measures to assure appropriate prevention.

4. Determine Proper Monitoring Procedures

Regular monitoring is your best defense. It serves three purposes:

1. Facilitates the tracking of the operation
2. Helps determine when there is potential for loss of control and deviation from established critical control points
3. Provides written documentation for verification

Monitoring should be continuous and implemented in all operating procedures.

5. Execute Corrective Actions

The purpose of the HACCP system is to readily identify hazards and proactively establish prevention strategies. Again, the point of active managerial control is to be proactive instead of reactive when an issue arises. When you’re forced to react, there’s a higher risk of a small issue ascending into a full-blown crisis. However, sometimes mishaps happen. This is when corrective action is needed.

Three steps should be taken to execute corrective actions effectively:

1. Determine and correct the cause of non-compliance
2. Determine the way in which the non-compliance occurred
3. Record that corrective actions have been taken

6. Draft Verification Procedures

Verification determines the validity of your HACCP plan. Verification procedures evaluate whether the facility’s HACCP system is functioning according to their plan. Here’s an example of verification procedures, per the FDA: 

7. Implement a Documentations Procedure

Include a summary of the hazard analysis, the HACCP plan, support documentation like validation records, and additional records created during the implementation of the plan.

Implementing Your HACCP Plan

After you formulate your HACCP plan, it’s time to implement. This is facilitated by top management who should devise a plan and assign out those who will be responsible for maintaining it. It’s crucial that everyone involved has the correct training on this new system, starting first with the initial HACCP coordinator and team, and stemming down from there.

After the initial HACCP plan is completed, it’s time to draft applicable procedures and forms, deploy processes for monitoring and maintaining the plan, and what corrective actions will look like. Since there are so many stages of implementing a HACCP system, it is recommended to set timelines to complete each activity.