HACCP Validation and Review Process

When validating your HACCP procedures, how often and what guidelines does everyone go off of. I would like to make sure my HACCP program is as strong as possible. Myself and my HACCP team review our HACCP program on an annual basis. These individuals are trained in knowing HACCP but are not committed as I am to the program. I actually have a basic document I use on an annual basis to cover all areas of our HACCP program. I would like to know if what I am doing is adequate or if I need to strenghten my review process?

Attached is the document we currently use to review our HACCP plan. I would like to know from HACCP experts out there how I am doing with my annual validation methods.

THanks!

Dear DL1988 -

     There are dozens of HACCP checklists out there, so you are unlikely to find a 'perfect' one. If this one works, and everyone understands it, then it works - just need to review it periodically to ensure it is current. There have been innumerable arguments here and elsewhere as to reassessing against Codex or regulations. FDA appears to be headed towards Codex - USDA FSIS obviously is regulatory driven. If you are or are seeking GFSI certification, you do need to cover Codex points, even if under FSIS...

     The one thing I notice - due to your format - is that you may not be reassessing frequently enough. You should reassess EVERY time a change occurs - essentially everything in Section 1. Also, don't forget people - new hires, layoffs, language barriers, etc. Since you indicate that you have had a HACCP plan for years, I am going to assume that you are USDA FSIS regulated. If so, don't forget that FSIS now requires the documentation of any and all HACCP reassessments conducted...with the exception of the annual reassessment IF no changes are determined to be needed.

DearDL,

As per comments in previous post evaluation is rather difficult due absence of certain items.

(1) What is the scope?, eg checklist is targeted to comply with ?

(2) What are yr definitions of validation, verification ? Maybe answered by (1).

For example,  here is a quote from a  FDA retail manual -

VALIDATION means, for the purpose of this Manual, to focus on scientific and technical information to determine if the food safety management system in place will effectively control the food safety hazards once implemented.

 

Note the caveat, and the last 2 words. But the latter  have been substantially re-interpreted / expanded in various later documents. An illustrative example (va1) is given below.

Yr proposed checklist appears to be (partially) based on an FDA-NCIMS document which was apparently developed for milk –

va2 - FDA haccp validation checklist.pdf   113.27KB   622 downloads

However I noticed you have added some verification (yr word) activities into the validation list. This IMEX is atypical of the format of other haccp treatments. Normally it is the reverse presentation (or complete separation as per 2008 Codex), eg   as in the original NACMCF document.

As per va2, the title of  “annual validation” seems to be interpreted as equivalent to an annual review of the haccp system. Confusing terminology IMO. “Annual Review” is also a popular term within interpretations of the  verification function (although at least the defs. of Ve have remained fairly stable with time AFAIK). Comes back to a question of  clarifying definitions again. (Not a criticism of present checklist, just a general comment.)

Or is the checklist  targeted to FSIS as mentioned in previous post ?. US totally not my area but the current FSIS requirement seems rather different in implementation  assuming this, beautifully presented, document (2013) reflects their current thinking –

va1 - FSIS HACCP_Systems_Validation.pdf   750.34KB   537 downloads

For comparison to va1 (2013), here is another, nicely presented but older, retail manual  based on the (ca.2002) FDA original. The differences to va1 are pretty obvious.

va3 - Massachusetts Validation-verification Plans,retail, 2003.pdf   1.97MB   401 downloads

I agree with KTD’s comment on frequency. The topic of “immediate revalidation" seems to have been missed altogether (and also  in va2 attachment).

I would also predict that some of the items in va2 would be interpreted elsewhere as part of verification (or even revalidation! :smile: ).

Anyway, perhaps you could confirm if the intention is to comply with (milk?) requirements similar to va2 ?  Or FSIS? or ?

Rgds / Charles.C