16 replies to this topic

[Jennyb723]

I have a PhD in Food Science and I have plenty of book knowledge but I’m lacking in hands on experience. My co-worker has the hands on experience but is often lacking in the “why”. For me to understand something and to get staff onboard I need to know the logic or science behind our steps.



He wants us to verify our HACCP plan, which consists of cooking and cooling temps, by watching someone take a temp at some point during the day. We calibrate the thermometer weekly and we verify all temps are correct at the end of each day (cooking and cooling).



Are people really using the ability to place a probe in a piece of meat as a verification step? We have proof the individual is properly trained and management is on the floor at all times. I just can’t seem to make logic out of this one and I can’t get my staff to own it either. If there is something that I can sink my teeth into, then I can easily get others to own it as well.




Warm regards,

Jennifer

[George @ Safefood 360°]

The verification of your HACCP plan essentially means the verification of your CCP's which as you mention are cooking and cooling. Calibration of the thermometer and checking that the results are within critical limits are reasonable verification activities. The act of verification is checking that you are doing what you say you are doing on your HACCP plan.

The procedure of actually checking how the CCP is done is not typically part of the verification details noted in a HACCP plan however this might be included in the internal audit program which is usually considered a verification activity. For cooking and cooking the location of the probe is very important for the CCP. The core temperature is what needs to be measured and if the CCP operator is not doing this correctly it may lead to a serious failure in the CCP monitoring. Training is of course the main control measure here and regular checking that the testing method is being conducted correctly would on the face appear to be a belt and braces approach but nonetheless wise depending on the local competency of operators. You may say that training backed up by daily supervision and regular auditing of the procedure is sufficient. Again it depends on the local situation.

I hope this helps you a little in understanding the logic.

[Charles.C]

Dear George,

Nice explanation.

Additionally, in the US, I guess Verification might also include Validation depending on the specific system/standard involved. (although admittedly, Jenny doesn't seem too worried about such a possibility ).

Rgds / Charles.C

[Jennyb723]

The verification of your HACCP plan essentially means the verification of your CCP's which as you mention are cooking and cooling. Calibration of the thermometer and checking that the results are within critical limits are reasonable verification activities. The act of verification is checking that you are doing what you say you are doing on your HACCP plan.

The procedure of actually checking how the CCP is done is not typically part of the verification details noted in a HACCP plan however this might be included in the internal audit program which is usually considered a verification activity. For cooking and cooking the location of the probe is very important for the CCP. The core temperature is what needs to be measured and if the CCP operator is not doing this correctly it may lead to a serious failure in the CCP monitoring. Training is of course the main control measure here and regular checking that the testing method is being conducted correctly would on the face appear to be a belt and braces approach but nonetheless wise depending on the local competency of operators. You may say that training backed up by daily supervision and regular auditing of the procedure is sufficient. Again it depends on the local situation.

I hope this helps you a little in understanding the logic.

Completely logical. I like the idea of including the physical steps of our CCP into our internal audit.

Thank you,
Jennifer

[Jennyb723]

Dear George,

Nice explanation.

Additionally, in the US, I guess Verification might also include Validation depending on the specific system/standard involved. (although admittedly, Jenny doesn't seem too worried about such a possibility ).

Rgds / Charles.C

We have an overly plump excel sheet with the summary of all our validation studies for entire processes since we have so many. We started with validation studies for each prereq and CCP to acquire the information needed to develop our HACCP plan.

Jennifer

[George @ Safefood 360°]

Dear George,

Nice explanation.

Additionally, in the US, I guess Verification might also include Validation depending on the specific system/standard involved. (although admittedly, Jenny doesn't seem too worried about such a possibility ).

Rgds / Charles.C

Yes Charles. I believe you are correct. Cooking and cooling have a unique place in the wonderful world of verification and validation. The key point here is that regardless of how the operator is checking the core temperature if he/she is checking the 'hottest' part of the oven for example there is still a major risk even if they are doing it correctly. The validation is critical and may require multi point mapping of the oven to ensure the 'cold' spot is identified and this is used in all cases to check the CCP. The logic is that if the cold spot reaches the critical limits then so too will the rest of the oven which is hotter. Is this verification or validation? Who knows these days but it doesn't really matter. For Jennifer, it is critical that this mapping excercise is conducted using a certified probe and the data is retained on file as 'Validation' of the CCP. Almost as important as how the operator is conducting the test.

[Jennyb723]

Yes Charles. I believe you are correct. Cooking and cooling have a unique place in the wonderful world of verification and validation. The key point here is that regardless of how the operator is checking the core temperature if he/she is checking the 'hottest' part of the oven for example there is still a major risk even if they are doing it correctly. The validation is critical and may require multi point mapping of the oven to ensure the 'cold' spot is identified and this is used in all cases to check the CCP. The logic is that if the cold spot reaches the critical limits then so too will the rest of the oven which is hotter. Is this verification or validation? Who knows these days but it doesn't really matter. For Jennifer, it is critical that this mapping excercise is conducted using a certified probe and the data is retained on file as 'Validation' of the CCP. Almost as important as how the operator is conducting the test.

We validated the temperatures of our batch process for our initial start up to determine our cold spots. We also checked for our "hot spots" in our cooling process since it is also a batch process. How often should we continue to validate since we are a new facility to ensure our initial results are the same? We also have a sous vide process. How would you recommend validating the temps in a continuous cook and cool tank? We initially validated the temperature from the probe (placed in the thickest cut of meat) attached to the cook tank was the same as our calibrated thermometer by checking various samples.

Thanks,
Jennifer

[Charles.C]

Dear Jenny,

I am only too happy to leave a full answer to yr query to George but my guess is that yr question may depend on the practical details, eg how much (absolute) temperature variation within the oven and also how close the actual values are to yr specific critical limits / (or, hopefully, operational limits?).

By way of comparison, for a (continuous) cooking process (shrimp), my experience is that it is (auditorially) necessary to do minimum 5 runs (per "trial" validation) to prove that a sufficient log bacterial reduction achieved, each time using the largest size probed shrimps as representing the worst case scenario.

Verification, eg end-product microbiological data may also be involved.

Rgds / Charles.C

[Tony-C]

I have a PhD in Food Science and I have plenty of book knowledge but I’m lacking in hands on experience. My co-worker has the hands on experience but is often lacking in the “why”. For me to understand something and to get staff onboard I need to know the logic or science behind our steps.

He wants us to verify our HACCP plan, which consists of cooking and cooling temps, by watching someone take a temp at some point during the day. We calibrate the thermometer weekly and we verify all temps are correct at the end of each day (cooking and cooling).

Are people really using the ability to place a probe in a piece of meat as a verification step? We have proof the individual is properly trained and management is on the floor at all times. I just can’t seem to make logic out of this one and I can’t get my staff to own it either. If there is something that I can sink my teeth into, then I can easily get others to own it as well.

Warm regards,

Jennifer

Hi Jennifer,

To add to the good advice offered by Charles and George:

I assume that your cooking is to a minimum core temperature and there is no time factor?
Validation would also involve demonstrating that your cooking and cooling process renders the food/meat microbiologically safe based on the maximum initial microbiological load
One of your measurements is time to cool the meat?

Kind regards,

Tony

[KTD]

Dear Jenny -
It sounds like you are regulated under USDA FSIS. As such, realize that you are dealing with regulatory, not neccesarily scientific, HACCP. At some point in time, you will be subject to a Food Safety Assessment (FSA), where your entire food safety system will be reviewed with an eye towards regulatory compliance. You mentioned that you are a new facility - this increases your chances of an FSA sooner rather than later.
There is a regulatory requirement that one component of verification is observation of CCP monitoring...sounds like observation of the monitoring person or activity, in your case. This verification that your HACCP system is working as implemented encompasses everything about the CCP monitoring activity - performance of taking a temperature, proper documentation (all the blanks filled out correctly), correct time (is the monitoring time when the monitor starts, when the temperature equilibrates, or when the documentation is completed?), is the form header filled out, etc. You can set the frequency of this verification activity based on what you can support scientifically, historically, by the literature, etc. Realize that you need to prepare for the unexpected - if you require one monitoring verification daily, what happens when you lose power for the day, have already successfully produced several batches, but have not yet conducted a monitoring verification?
Several months ago, USDA FSIS issued multiple documents addressing it's definitions of, and expectations for, both validation and verification. Rather than clog up the blog, let me know, and I can forward these directly to you.

[Jennyb723]

Dear Jenny -
It sounds like you are regulated under USDA FSIS. As such, realize that you are dealing with regulatory, not neccesarily scientific, HACCP. At some point in time, you will be subject to a Food Safety Assessment (FSA), where your entire food safety system will be reviewed with an eye towards regulatory compliance. You mentioned that you are a new facility - this increases your chances of an FSA sooner rather than later.
There is a regulatory requirement that one component of verification is observation of CCP monitoring...sounds like observation of the monitoring person or activity, in your case. This verification that your HACCP system is working as implemented encompasses everything about the CCP monitoring activity - performance of taking a temperature, proper documentation (all the blanks filled out correctly), correct time (is the monitoring time when the monitor starts, when the temperature equilibrates, or when the documentation is completed?), is the form header filled out, etc. You can set the frequency of this verification activity based on what you can support scientifically, historically, by the literature, etc. Realize that you need to prepare for the unexpected - if you require one monitoring verification daily, what happens when you lose power for the day, have already successfully produced several batches, but have not yet conducted a monitoring verification?
Several months ago, USDA FSIS issued multiple documents addressing it's definitions of, and expectations for, both validation and verification. Rather than clog up the blog, let me know, and I can forward these directly to you.

Thank you and yes please forward these to me. Yes we are under USDA FSIS and I have reached to others in a similar field and they too verify the process of the employees monitoring the temps once daily. I guess it just seems silly to call this a verification step.

Thank you,
Jennifer

Edited by Jennyb723, 20 December 2012 - 09:18 PM.

[Charles.C]

Dear jenny,

Re email address - Don't be surprised if you get some free spam as well !

Rgds / Charles.C

[Charles.C]

Dear All,

Just for the benefit of any interested readers, this discussion is further extended to FSIS related, non-CCP temperature monitoring here -

http://www.ifsqn.com...dpost__p__57592

Rgds / Charles.C

[Jennyb723]

Dear jenny,

Re email address - Don't be surprised if you get some free spam as well !

Rgds / Charles.C

Gee, thanks. So the "email me" function is useless. Any way to delete my email address?

[Jennyb723]

Dear All,

Just for the benefit of any interested readers, this discussion is further extended to FSIS related, non-CCP temperature monitoring here -

http://www.ifsqn.com...dpost__p__57592

Rgds / Charles.C

These two are not related. One is discussing temperatures in food while the other is discussing electronic temperature monitoring of refrigerators and freezers. Close though.

[Tony-C]

Gee, thanks. So the "email me" function is useless. Any way to delete my email address?

Hi Jenny

You can edit the post and remove your e-mail link

Kind regards,

Tony

[Charles.C]

Dear Jenny,

There is an alternative communication procedure called Personal Messenger ("pm").

See - http://www.ifsqn.com...ore&module=help
(2 entries)

Rgds / Charles.C

PS - i think this option is only functional for members with >= 10 posts as in present case.

PPS (added) - of course one primary function of a forum is to offer other people the opportunity to comment also.

PPPS (added) - i do agree with you that the provision of an "insert email address" option is illogical. Unfortunately the set of "buttons" comes as a pre-set package.