Top 5 HACCP non-conformities – and how to fix them

Why is the HACCP plan the food safety system for excellence?

For at least 50 years, HACCP has been the main protocol proven to adequately manage and understand food safety. When a recall or an intoxication happens, most of the times the root cause analysis was due to poor prerequisites implementation, rather than to an inadequate HACCP design.

For example; allergens issues. It is alarming to see the number of recalls due to the wrong label being used on a food product. In the UK, over 40 (around half of all the allergy alerts) were issued between June and December 2019 and in the US, during the same time period, almost 20% of recalls (over 50) were reported by the FDA.

Food elaborators understand very well the legal consequences that a failure means on the HACCP Plan and HACCP System.
Over my 20 years of auditing the HACCP standard all over the world, these are the top 5 non - conformities and some suggestions how to resolve them:

1. The flowchart

When verifying the flowchart, one can conclude that it was made in one specific moment. This can be verified by the date of the document and the signature of the responsible person. When you compare the flowchart to the actual running production in the plant there are normally big differences. There is only one line running but the flowchart shows that the plant has 7 lines, and that some products are packed in containers, others are bulk, and some products are seasonal. I usually ask the auditee about this, how and when the flowchart was made and if all these products were made on that same day? The answer is of course no, only one product was running on the line at the time.

My recommendation: make the flowchart over time and make it reflect the different scenarios, includes all products under the HACCP study. Record all products being produced on different days, walking the line by all the members of the HACCP Team

2. Severity of physical hazards

It is very common to see that CCP’s are accommodated and set to certain result levels that are desired by the company. This happens many times with metal detectors and x-ray devices. The hazards need to be identified and included in a decision tree, i.e. Codex. It is common to see that in those steps of the process where physical hazard detectors are present, the severity and the probability of occurrences of hazards are set too high. At the same time in other steps of the process where no detectors are present the severity and probability of occurrence are set too low. The problem is that the severity of the hazard cannot vary within the SAME hazard. This is determined by the effect the hazard has on the final consumer.

My recommendation: review the HACCP hazard analysis in order to evaluate if you have this error, and make sure the severity in all steps of the process is coherent for each specific hazard.

3. Lack of specifics

Sometimes the word “microbial” is used in a situation to alert, for example at raw material reception. This is often used to explain that a pathogen microorganism could be present in the step. This is not specific enough. It should also be explained what could happen to the
microorganism in this step: presence, multiplication, survival. It is the same for allergen hazards, especially when there is not a risk of cross contamination during production. For example, in rice and in paprika elaboration. In these categories the cross-contact contamination of allergens (soy, gluten) could happen during transport, and writing “allergens” as the hazard description is not correct. Remember that “the devil is in the detail”.

My recommendation: be specific in the hazard analysis, even if the hazard in the process has a low probability of occurring. In high risk environments, high care or ambient high care processes, the potential microorganism behavior must be evaluated for each step, in order to describe adequate control measures.

4. Manipulated metal detectors

All metal detectors must be verified during an audit. The auditor normally asks to see a step with a metal detector in operation with the responsible operator at normal operating conditions. If the metal detector fails to detect a Fe, NoFe or SS test piece, the HACCP corrective action protocol will be activated. It is not acceptable in this case to change the metal detector program or line velocity until it detects the standard in order to avoid the corrective action.

My recommendation: investigate those situations where the metal detector does not detect the test piece, instead of overseeing and underestimating the scenario.

5. No product description, only final product technical sheets

Some companies seem to omit to produce an important document, the Product Description. This is one of the HACCP steps that have been in use for more than 50 years. The HACCP has 5 preliminary steps and 7 principles. There is a very solid technical foundation for every preliminary step and every principle. Not all people are aware of this. When the auditee is asked about the production description the answer could be that this information is found in the Final Product Technical Sheet. A Product Description is fundamental for the HACCP Plan.

My recommendation: if you find that your company does not make a distinction between Product Description and Technical Sheet, make sure to review the HACCP standard in order to produce the appropriate documentation.

The HACCP Plan is a living document:

Remember that the HACCP Plan is not a document that after it is finalized should be kept in a binder on the shelf. It should be reviewed periodically within the Team at least on monthly basis. Questions should be asked like:

Do we have new suppliers?
Has R&D – under the pressure from a client launched a new product with potentially new hazards?
Is there a serious trend regarding client claims?
Has any important regulatory law taken effect?

Questions of this nature are important to keep your Team alert.

Look at the ISO 22000: 2018 - 10.2 Continual improvement, under the section validation of control measures.

The HACCP plan must be challenged on a regular basis!

About the Author:

Leila J Burin, PhD Food Chemistry.

Lead Auditor in BRC, IFS, FSSC 22000, etc. Academic Coordinator in “Portal de Inocuidad” (www.portaldeinocuidad.com).

I work as a food safety auditor since more than 20 years. I started my career in Latin America and for the last 10 years I have been working in Europe. I have a scientific background with a PhD in Chemistry and over the years I works with most standards and categories in the food industry such as HEINZ, BRC, IFS, FSSC22000, SQMS, LIDL, and several others. Since 2010 I am also the Training Coordinator for “Portal de Inocuidad” which is an on-line service for Spanish speaking food safety professionals.