20 replies to this topic

[Cody N]

I'm working on an ingredient risk analysis and I'm wondering if chicken meal and other types of meals are considered a biological hazard. I believe that they are cooked but I'm not positive. Also, for raw meats that are a biological hazard due to the threat of salmonella and other bacteria, is it sufficient to only put "bacteria"? Or should all the threats be listed?

[john123]

In our HACCP we listed the biological risks as "food borne pathogens" rather than just bacteria, and that's seemed to appease auditors thus far.

I'm not directly familiar with chicken meal, but it seems like a product that surely has the potential for food borne pathogens to thrive with maybe a lower likelyhood. Right off the bat I think of pet food. Meal products end up in things like dog food, which doesn't need to be refrigerated but can still be contaminated with salmonela. My facility deals primarily with dehydrated vegetables, we've identified the risk and listed the precautions taken. You'll need to specify how you minimize the risk of food borne pathogens in the meal, just like the raw poultry.

[Cody N]

The facility that I work at produces dog treats so that is the reason for the different meals. I'm stating how we minimize the risk of food borne pathogens, which is all of our products reach a core temperature greater than 165 degrees. Core temps usually average around 200 degrees so we are well above the 165. Thank you for the help.

[Urban Explorer]

My plant has 7 different HACCP plans, and I've found the easiest way to manage them is be as general as possible. I say "pathogens". If you isolate a specific bacteria, then you have to prove that you test for those exact types. USDA gave us guidance as far as even mentioning listeria, that's what your control program is for, not HACCP.

It's all about the wording!

[john123]

The facility that I work at produces dog treats so that is the reason for the different meals. I'm stating how we minimize the risk of food borne pathogens, which is all of our products reach a core temperature greater than 165 degrees. Core temps usually average around 200 degrees so we are well above the 165. Thank you for the help.

In my non-expert opinion, that should be sufficient for the cooking step of your process.

Have you risk analyzed the meal prior to that kill step? Have you risk analyzed your finished product? (Basically, what do you do to prevent pathogens prior to cooking, and what do you do after they're cooked to ensure they stay clean?)

My plant has 7 different HACCP plans, and I've found the easiest way to manage them is be as general as possible

Ha, we've got 10 :-p Being as general as possible is the best way, just not to the level where you get vague. The information should all be there, and brief. Let them ask questions.

[Charles.C]

Dear All,

Sorry to have to disagree with all the previous posts . My first attempt at submission of a HACCP manual was rejected specifically for being “general” regarding bacterial pathogens. Some textbooks go even further and use the term “Microbial Pathogens”. It is obvious that a complete listing is impractical but underlisting can also be a "bone to an auditor”.

My auditor’s typical comment was – this is an indication that the writer does not understand which pathogens are involved with his product / process. So what is his logic for his validation of his cooking process / critical limits?.

My response that the final choice was regulatory defined (true) was “waved away”.

Since then I hv always prefaced my HACCP analyses for each product with a microbial pathogenic summary of the situation which enables cross referencing in following text. And yes, it can be a lot of work, although in many cases repetition is possible.

Regarding present OP, examples of typical haccp analysis decision trees for input ingredients are available on this forum. One key question is something like – If material contains pathogenic bacteria, are they "eliminated" during the subsequent process ?.

You may be interested to know that for many products US does not agree with the EC's approach regarding choice of targetted species (often Salmonella vs L.mono) for cooking step. The results of US philosophy are usually less severe (>, from memory, US consumer’s preference for undercooked burgers ). Accordingly there is also some relevance for nominating actual (HACCP) species if international “consumption” is expected.

Rgds / Charles.C

[HACCP Mentor]

I am with Charles on this one. Whenever you do your hazard analysis you need to assess specific hazards not groups of hazards. This is something that I pick up all the time as an auditor. It is not sufficient to just write "biological" or "bacteria" or "Pathogens". The same goes for physical hazards. You need to identify the individual hazard eg. Salmonella, Listeria, glass, wood, hair, pesticides, cleaning chemicals. The reason being that there is going to be different control measures for each of the hazards. For example, you would not control listeria the same way as you would control say bacillus and you would not control glass the same way as you would control say hair.

The other thing to be mindful of is not to assess the hazards as a group (See example above). You likelihood and consequences, again, will be very different. The hazard analysis is the biggest part of your HACCP program and should be treated as such. It is the time to truly identify everything that can go wrong with your product. By doing this, you can have some level of confidence that you have covered all of your potential risks to protect the business and your customers.

[DP2006]

Cody N,

As an independent consultant I have worked with petfood producers on their risk analysis and development of food safety management systems, including HACCP to control these hazards.

Based on my quality risk management and supplier quality assurance experience in the petfood manufacturing and petfood ingredients industries over the last 30 years or so, echoes what others have said, you need to list the biological hazards individually and methods for their control.

Like it or not, due to its fundamental nature chicken meal is made from by-products of the human poultry industry (that could include carcase, necks, heads & feet and chicken viscera etc) and has the potential to contain a wide range of foodborne pathogens that can cause illness in both the animals eating the petfood, snack or treat and also the pet owners (and production staff manufacturing the product).

Whilst you will not necessarily find all of the potential pathogens in the chicken meal you buy, your risk analysis should consider assessing all of these on the basis of their severity of effect ie what is the potential effect of these pathogens on the animal and also the likelihood of occurence ie what is the chance that these pathogens will be present in the chicken meal.

Further to this you need to consider what happens at your supplier (vendor) and throughout your process eg your cook step, to minimize the risk arising from the hazards identified.

Hope this helps!
DP2006

[DP2006]

Cody N,

Forgot to add, the same logic applies to any other meals you use eg fish meal, meat and bone meal etc.

DP2006

[Urban Explorer]

The only reason I mentioned being vague, and this went against what I was taught in many haccp courses, is a high up USDA enforcement officer doing our Food Safety Assessment, told me to take out any reference to specific bacteria in the actual plan. It is okay to list the hazards in your plan summary, and you want to have validations that preclude the possibility of pathogen A or pathogen B.

Then you have auditors making snide jokes about the uSDa and you have to wonder about their objectivity. I told them flat out, the USDA recommended this format and I'm not changing it. They dropped it right there.

[john123]

I've been struggling with the above responses all day, wavering on if I should reply or not... I'll throw this out there for review, maybe it helps the OP and maybe it doesn't. I fully admit I'm the inexperienced one amongst this wealth of veterans and knowledge.

If you get very, very specific and detail oriented in your HACCP on pathogens, don't you open the door for an auditor to say "what about this one, or that one?" You create the opportunity to miss out on listing one specifically by name. We struggled with that exact same question when we rewrote our HACCP last quarter, and settled for calling them "food borne microorganisms" in our potential hazards (sorry above, I misspoke when I say pathogens). Now, under the justification for inclusion of hazard we cite various ways a food borne microorganism can be introduced to the product, everything we could think of affecting the product we receive. Then, to our preventative measure, we cite our sanitation program where we have verified our cleaning procedures are effective for killing Enterobacteriaceae, the Order in which most of the more familiar pathogens are classified (NOTE: we are a third party milling/packaging/warehousing operation for dehydrated vegetables, and we have no ownership of the product in order to perform micro tests upon receiving, so our HACCP forces us to control risk beyond the product itself).

Basically what I've learned thus far is "you have to be able to defend your procedures/policies." Given the defense above when asked why we don't list E.coli, salmonella and the many other food borne pathogens specifically on our HACCP, where might that be insufficient? If you get too detail oriented, you open the door for items to get missed and trying to manage a 100 page HACCP plan...

[Charles.C]

Dear John,

Please don't be reluctant to post any level of query. All of us here have been through the grindstone at some time or other and frequently are pretty much still in it.

Basically what I've learned thus far is "you have to be able to defend your procedures/policies." Given the defense above when asked why we don't list E.coli, salmonella and the many other food borne pathogens specifically on our HACCP, where might that be insufficient? If you get too detail oriented, you open the door for items to get missed and trying to manage a 100 page HACCP plan

One option is to include at least one source reference (ideally a recognizable org.) which contains a "comprehensive" list and actually present an own list of 4 or 5 representative nasties for the input ingredients / packaging's BCP categories together with a word like "typical". IMEX, auditors will usually be perfectly happy with the sample (assuming "E.coli" is not listed as a pathogen) and never check the reference, especially if it is a book.

This does pre-suppose you hv some knowledge of what the more significant species / pathogens / chemicals etc are (or could be). If otherwise I'm afraid that the HACCP system under discussion is genuinely questionable.

Rgds / Charles.C

PS - it may depend on the context but if doing a hazard analysis i would hv thought the terminology of "pathogens", or perhaps "microbial pathogens" (def. Disease causing microorganisms, such as bacteria, fungi, and viruses,) is more logical than foodborne micro-organisms.

[DP2006]

I've been struggling with the above responses all day, wavering on if I should reply or not... I'll throw this out there for review, maybe it helps the OP and maybe it doesn't. I fully admit I'm the inexperienced one amongst this wealth of veterans and knowledge.

If you get very, very specific and detail oriented in your HACCP on pathogens, don't you open the door for an auditor to say "what about this one, or that one?" You create the opportunity to miss out on listing one specifically by name. We struggled with that exact same question when we rewrote our HACCP last quarter, and settled for calling them "food borne microorganisms" in our potential hazards (sorry above, I misspoke when I say pathogens). Now, under the justification for inclusion of hazard we cite various ways a food borne microorganism can be introduced to the product, everything we could think of affecting the product we receive. Then, to our preventative measure, we cite our sanitation program where we have verified our cleaning procedures are effective for killing Enterobacteriaceae, the Order in which most of the more familiar pathogens are classified (NOTE: we are a third party milling/packaging/warehousing operation for dehydrated vegetables, and we have no ownership of the product in order to perform micro tests upon receiving, so our HACCP forces us to control risk beyond the product itself).

Basically what I've learned thus far is "you have to be able to defend your procedures/policies." Given the defense above when asked why we don't list E.coli, salmonella and the many other food borne pathogens specifically on our HACCP, where might that be insufficient? If you get too detail oriented, you open the door for items to get missed and trying to manage a 100 page HACCP plan...

John123,

I totally agree with your view on the "risk" of listing foodborne pathogens in detail or being vague / non specific linked to the risk that an auditor will say "why didn't you think of "that one".

Sensational headlines appear in the news from time to time linking the risk of for example an environmental contaminant with a particular health risk. An example might be some types of modern flame retardants used in furniture that are carcinogenic getting into the food chain and "allegedly" causing illness in people consuming the food that contains the chemical hazard (often at infinitesimal levels). However, there might be a long term effect.

However we need to be pragmatic about this and consider the Likelihood of Occurrence ie the chance / probability that the hazard will be present in the food or finished product, at levels that can cause illness.

To make a judgement on this we need objective, peer reviewed data ie data from reputable scientific organizations and not sensationalist headlines in the press.

Organizations like EFSA (European Food Safety Authority), exist around the world and are useful sources of information on foodborne hazards and associated risk. Alternatively there might be an "trade association" that represents your industry, for example "Chilled Food Association" in the UK and they often publish position statements on the risks associated with food safety in products manufactured by their industry. Utilisation of data from sources like these can then form part of your defence / logic in identifying certain foodborne hazards and not others.

From my experience in working with food manufacturers and ingredient suppliers with their hazard analysis, there is a lot of data available freely in the public domain through the internet.

Unfortunately, to find this and utilize this takes time, expertise and money. Based on my experience with clients I work with through my own technical consultancy, these three resources are often in short supply in some food businesses. In some cases they then have to bring in external technical support to help them achieve their goals on food safety, whether this is HACCP, BRC accreditation or ISO22000.

[Mendeljev]

In our last BRC/IFS audit , our auditor asked to be more specific in defining the microbiological aspect of our products. Her point of view was more regarding consumer safety/ answering complaints regarding off flavours / sickness / etc and possible recalls.
Therefor we are currently working on a more in depth analysis of the products and the possible pathogens that can grow if they had the chance...

I agree partly with this point of view, it is interesting, but the big question is if it's feasable to include all possible dangeours.

Kind regards

[DP2006]

In our last BRC/IFS audit , our auditor asked to be more specific in defining the microbiological aspect of our products. Her point of view was more regarding consumer safety/ answering complaints regarding off flavours / sickness / etc and possible recalls.
Therefor we are currently working on a more in depth analysis of the products and the possible pathogens that can grow if they had the chance...

I agree partly with this point of view, it is interesting, but the big question is if it's feasable to include all possible dangeours.

Kind regards

I agree with your more in depth analysis of your products and also suggest you look at any customer complaint data (if you have not already done this.

I don't think it is possible or realistic to include "all possible dangers", as the picture changes with time.

If based on the type of data indicated my previous post, your hazard analysis is like a snapshot in time. It is a record of the knowledge available at that point in time. There is always the possibility of new hazards coming along, for example food allergy to kiwi fruit is an emerging food safety hazard. How much concern was placed on radionuclides before the Chernobyl disaster in 1986?

Key point is the picture is not constant as new food hazards emerge.

DP2006

[HACCP Mentor]

Keep in mind "recommended" - that means it is not set in stone. You can format information how ever you want as long the actual information meets the criteria you are being audited against. Different auditors and government inspectors will always have different opinions on how they want to see information. The main thing is that you have the information there and correct to start off with.

Please also remember that the USDA audit criteria (or rules) may not be the same as your third party/customer standard audit criteria. It is always better to ensure your information is written to cover the more stringent of the two and cover your business risk. If an auditor asks "why is this in your plan?" you can answer with "it is a requirement of our third party certification". I see businesses who remove information based on what an auditor has said but then they get pinged at the next audit for not having it there (different audit criteria).

The whole purpose of HACCP is to identify and control food safety risk. By being more specific in your hazed identification you can better ensure that you have put the best and most suitable control measure in place.

The only reason I mentioned being vague, and this went against what I was taught in many haccp courses, is a high up USDA enforcement officer doing our Food Safety Assessment, told me to take out any reference to specific bacteria in the actual plan. It is okay to list the hazards in your plan summary, and you want to have validations that preclude the possibility of pathogen A or pathogen B.

Then you have auditors making snide jokes about the uSDa and you have to wonder about their objectivity. I told them flat out, the USDA recommended this format and I'm not changing it. They dropped it right there.

[HACCP Mentor]

This is exactly why the major GFSI standards (SQF, BRC etc) require you to review and update your hazard analysis and HACCP plan on an ongoing basis.

I agree with your more in depth analysis of your products and also suggest you look at any customer complaint data (if you have not already done this.

I don't think it is possible or realistic to include "all possible dangers", as the picture changes with time.

If based on the type of data indicated my previous post, your hazard analysis is like a snapshot in time. It is a record of the knowledge available at that point in time. There is always the possibility of new hazards coming along, for example food allergy to kiwi fruit is an emerging food safety hazard. How much concern was placed on radionuclides before the Chernobyl disaster in 1986?

Key point is the picture is not constant as new food hazards emerge.

DP2006

Edited by HACCP Mentor, 16 January 2013 - 03:09 AM.

[KTD]

Interestingly, I have had the exact opposite experience as Destinee. I have been told by several USDA FSIS EIAOs (high level investigative personnel) that the HACCP plan must identify those pathogens that are relevant to the product. For raw poultry in the US, that is normally taken to be Salmonella - with Campylobacter coming on strong. If I go into RTE product, I better address Lm. The point being, that as indicated a couple times in this thread, how do you develop and implement PRPs and CCPs if you don't discuss what you are addressing?.

[Urban Explorer]

Interestingly, I have had the exact opposite experience as Destinee. I have been told by several USDA FSIS EIAOs (high level investigative personnel) that the HACCP plan must identify those pathogens that are relevant to the product. For raw poultry in the US, that is normally taken to be Salmonella - with Campylobacter coming on strong. If I go into RTE product, I better address Lm. The point being, that as indicated a couple times in this thread, how do you develop and implement PRPs and CCPs if you don't discuss what you are addressing?.

An EIAO was the one who told me to take out all the references to specific pathogens in the plan (in the hazard analysis section)! Kind of funny I guess, even those guys can't agree with each other.

[George @ Safefood 360°]

NO GUYS - Charles et al are correct. Your identification of pathogenic hazards has to be specific. Not all pathogens are the same and you cannot correctly risk assess them as one homogenious family. You need to state the specific pathogen and from this you can determine the risk based on a charactisation of the hazard and exposure assessment. It will also allow you to determine your target pathogen in regard to controls. This should be the most robust and hardiest of the bugs and give you the control you need. Finally, validation of a CCP intended to control a pathogenic hazard is not really possible without specific identifcation of the hazards concerned.


George

[sadean]

I also agree with Charles. Anytime I do a HACCP plan, and I have done many which have been through the scrutiny of CFIA (Canadian regulators), I list the specific pathogens of concern. This is then used in the validation of the product. If you use general terms, how do you know if your CCP is sufficient enough to control the pathogen of concern. Different pathogens require different kill temperatures, water activity, etc. In my validation, I would state the pathogens identified in the hazard analysis, then I would include the scientific data which has the relevant data to prove that my CCP is effective. You also want to identify the pathogens to determine if your C of A's cover the pathogens of concern. For example, if you receive a RTE peanut product and they don't test for salmonella and you identify it as a hazard, the CofA can't be the control for this hazard as it isn't controlling it.