4 replies to this topic

[ebutera]

Each time we have an unforeseen hazard, we are required to reassess the HACCP plan.

USDA has categorized power outages are "unforeseen," so each time it happens we have to reassess.

In Northern Oklahoma this happens regularly (many times a year).

I would like to write a "power outage" program and say the hazard is no longer unforeseen.

I think i would also then have to add it to the hazard analysis.

 

Would that cover me in this instance?

[Tony-C]

Hi ebutera,

 

A power outage in itself is not a hazard.

 

What you should have in place are procedures to deal with potential hazards caused by power outages.

 

One of the most common issues would be loss of refrigeration, the hazard could be microbial growth due to product temperature rise. In this situation, the response may be as simple as to keep doors closed and monitor the product temperature to ensure it does not rise above a set limit. Other actions in this situation may include having emergency generators, moving product to alternative storage or storage on refrigerated trailer.

 

These are just examples, you need to have contingency plans to deal with emergencies and how they would affect your particular product. It is these plans that may need review after an incident. The review could determine that all the contingency plan worked perfectly.

 

Kind regards,

 

Tony

 

[G M]

I'd agree with Tony that you need a more general policy for dealing with loss of environmental controls.

 

That more general policy can cover lots of natural disasters, utility service outages, equipment failures, etc.

[Gelato Quality Lead]

I agree with the previous comments. Our Crisis Management program generalizes any disasters that could occur, but the effects that occur are talked about in detail.

 

Two examples: loss of power in freezers or a sewage backup. Either of these could be caused by a variety of events including a power outage, an earthquake, or some kind of an intentional attack. Regardless of how they occurred, you would still have a defined process to determine food safety if you lost power in your freezer.

 

Even if power outages are known to happen in your area, I would consider them to still be unforeseen since you don't know when they could happen (unless you somehow do know and then you could go through a certain program to prepare for that)

Edited by Gelato Quality Lead, 31 October 2023 - 05:58 PM.

[jfrey123]

I wouldn't put a power failure in my actual HACCP plan, as it isn't something I'd consider "reasonably likely" to occur at a level that causes a hazard (a phrase utilized by the FDA for when you determine whether a hazard is significant).  I do list power failures within my crisis management program:  there are some risk analysis templates which help you determine which crisis' are significant and relevant to your operation, and once the RA identifies a crisis that could occur, we list it in the program and detail steps in which we would take to mitigate it.

 

This year in one of my Denver plants, I got to be on-site and help walk their management through a crisis scenario:  we simulated a scenario where a blizzard produced significant snowfall, in which management decided they would send employees home for their safety.  They identified they would shutdown and discard product that couldn't be recovered into the freezers/cooler areas.  We simulated a power failure, which they determined they could monitor plant temperatures and temp logs remotely for product safety, etc (battery backups are in place for the CCP thermometers and their control systems).  We simulated the storm passed within a day, where executive management and maintenance would inspect the plant for damage before scheduling a sanitation team to start the next morning.  This would permit product to resume once it was agreed the plant was safe and back to operational status.  We also detailed warehouse management's efforts to notify inbound and outbound trucks of our closure, and reschedule all freight for docking.  QA went through to verify finished product was within shelf-life to resume shipping.  So on, so forth.  It was really eye opening for a lot of the managers and supervisors present in the meeting, and we basically went around the table to each department to ask what they believed would be impacted by a storm closure with loss of power.