How often do you review your HACCP plan?

• Do you have a set schedule?
• Triggered by changes?
• Audit-driven?

I am not a HACCP team leader anymore but, none of the above?

For the last plan I was directly HACCP TL, we reviewed it before changes (should never be after) and every 1-2 months.  I know that's above requirements for standards etc but unless your HACCP plan is very well integrated into your day to day, I don't see how every 6-12 months is enough.

I'm also going none of the above.  I prioritize based upon complexity. We have 7 of them. Some get reviewed every 1-3 months basis due to the complexity and adding products. Others - once a year - they are simple. 

Once a year, or more if needed due to some change, etc.   But I'd imagine this answer is going to vary greatly depending on what your plant does, it's size, etc.

I chose every 6 months, but review sometimes more than that due to our growth.  I also have gotten into the habit of updating our PRPs when they change.

End-to-end every document in the plan?  Once a year.

But like kfromNE it is more accurately based on risks and complexity.  Dead simple plan for one facility really is once a year, complicated one for a much larger facility that covers lots of products and new products added frequently has parts of it reviewed monthly.

I would love to review my HACCP before changes, but <insert management commitment rant here> as I do not have "manager" in my job title I am not privy to changes until I happen to notice them myself, or overhear people taking about something new, and the manager who is my backup and aware of all changes won't initiate or run a meeting unless I say something.... multiple times.

Should moving finished products with fish and shellfish (shelf stable in cans and glass jars) from one building to another that has no glass, no aluminum cans, and no seafood products require a HACCP review BEFORE they are moved?  :doh:  Let's add managers not allowing me to schedule a meeting because they are too busy to "let" me pull people off their regular duties <insert additional rant here>. "Just type up the changes and I will sign off on it." Okay, send me a list of ALL the changes or let me have a meeting because when you tell me the only allergen moved was "fish" and you "think" the jars are all plastic then I send you a picture of canned clams... :helpplease:.  Oh, and be prepared to explain to the auditor why stuff was moved in May, but the HACCP meeting didn't occur until 2 weeks before the audit window.

They don't understand what I'm talking about when I tell them I will NOT be doing any whitewashing for them during the next audit. I'm hoping I won't still be here for the fallout.

I like to catch things as changes occur, and at least once annually. It could be sooner (if our R&D team or Purchasing team kept getting new items in). 

Perhaps it is the wrong question?  How often you review IF your HACCP plan needs changing or a full review might be a better question.  If that's only once a year, that's probably not enough.  

Perhaps it is the wrong question?  How often you review IF your HACCP plan needs changing or a full review might be a better question.  If that's only once a year, that's probably not enough.  

Why? In my previous position, we hade not made changes to the process, the lines, the equipment, even most of the ingredients for years. I always reviewed the whole plan annually to ensure nothing had changed, but why would I need to do it more frequently, IF all of those things were the same? 

We had no change to the temps, the CCP, the testing, calbration, and verifcation were the same, why do this more frequently IF there are no changes?

Why? In my previous position, we hade not made changes to the process, the lines, the equipment, even most of the ingredients for years. I always reviewed the whole plan annually to ensure nothing had changed, but why would I need to do it more frequently, IF all of those things were the same? 

 

We had no change to the temps, the CCP, the testing, calbration, and verifcation were the same, why do this more frequently IF there are no changes?

Did you have no changes to people?  To the wider risk in the environment?  No indicators in your verification suggesting something was trending out of control?  What did you make out of interest?  Perhaps I've just never worked in a site with so little change.

Did you have no changes to people?  To the wider risk in the environment?  No indicators in your verification suggesting something was trending out of control?  What did you make out of interest?  Perhaps I've just never worked in a site with so little change.

Yes, we have had changes to people. We also had people who were there 35-40 years. They were trained when they started, they were trained when they moved into a new position. (with signatures) We had annual training. The plant was on the outskirts of a small Midwestern community, there were no major changes to the enviroment, or the businesses, or households in the area. 

We made frozen pizzas. We may change sizes, sauce, formulas, etc, but our allergens were consistent--wheat, milk, soy, and on occasion, egg. We did allergen swabbing. We tested to make sure we would catch poor sanitation. We had occasonal hits of Listeria during seasonal changes, but very little in things being out of control.

It happens. To say I need to review that plan more frequently than annually is not warranted.

Perhaps it is the wrong question?  How often you review IF your HACCP plan needs changing or a full review might be a better question.  If that's only once a year, that's probably not enough.  

In this context for me, it would refer to the analysis of supporting programs.  Do my CCP records have a trend of errors?  Do customer and consumer complaints reflect we've lost control of hazards, or other hazards we haven't evaluated?  If things in my whole program are under control, I wouldn't trigger extra review of my HACCP outside of some regulatory or GFSI change we see that requires a review.

Ah just a different mindset / training process.  Perhaps it's due to different international interpretations on HACCP but a few hits on Listeria and people changes would (and did) prompt review for me.  Mostly because training doesn't replicate the experience when you lose people.

But no offence meant, just sharing my view on it.  It was completely drummed into me that any change means HACCP and that meant adverse verification results too.  No acceptance.

We do the review once a year (after verification of the CCPs, oPRPs and PRPs). Or if there are changes in the production (raw material, equipment, emerging risks, ...)

Ah just a different mindset / training process.  Perhaps it's due to different international interpretations on HACCP but a few hits on Listeria and people changes would (and did) prompt review for me.  Mostly because training doesn't replicate the experience when you lose people.

 

But no offence meant, just sharing my view on it.  It was completely drummed into me that any change means HACCP and that meant adverse verification results too.  No acceptance.

No offense taken. I don't think "Always" and "Never" should be written into a HACCP program as steadfast rules. Especially when HACCP is for each company to assess on their own.

There are several long running topics here on whether or not you need a CCP in a HACCP plan. You can say 'yes, always!' when that might not be the case. It is the same, to me, for reviewing your HACCP plan

That's where we're going to have to differ.  I think "always" in regards to reviewing risk is an absolutely valid baseline rule to have.  You review the data.  Formally decide as a team not an individual if it has impact on the existing plan and make changes if necessary.

I find it very interesting that people are looking a lot on this thread on changes to process but not so much on changes to people.  When incidents occur I'd wager that people were at least one of the root causes more often than unknown process changes.

But as I say, it was drummed into me.  Any change means HACCP and that really did mean ANY.  So we'd always review the plan as is and record, as a team that we'd excluded the change as being relevant rather than not review.

I was in a factory recently with over 40% turnover of staff per annum and nearly 10% absence.  If they're not discussing that in their HACCP plans then they're missing a risk in my opinion (not saying that was your situation).  But we used to have a HACCP meeting prompted if we were getting lots of behavioural issues even if they were safety.  But then that was a BIG site.  And if you didn't act on indicators like that they'd bite you on the bum.

Anyway, if it's working for you then it's working for you.  I just had REALLY strict HACCP tutors.   :roflmao:

@GMO:  I've worked in sites with huge turnover rates too.  The HACCP plan should reflect training for the job, and the training for the job should be sufficient in that task's part in the HACCP plan.

If one of my plants had a QA manager leave, that doesn't trigger a full review of the HACCP plan.  Plans shouldn't depend on the people, that goes to the whole "village knowledge" silo'd information problem lots of smaller companies have.  The HACCP plan should be robust enough to survive people coming and going, and the SOP's should clearly spell out duties and internal audits should verify the duties are being fulfilled.  If I lost 50% of my line workers in a site tomorrow, that's not a HACCP review issue, it's a crisis management issue and we'd activate a plan where we shut down until proper staffing can be trained.

To what I think your point was, yes, people sometimes leave and others don't pick up their slack.  "SoAndSo used to do XYZThing and no one started doing it when they left" is a common excuse, but if XYZThing was a part of the HACCP, then SomeOneElse should've been verifying SoAndSo did xyz thing.  That's why I don't feel a full HACCP review is common due to personnel changes:  the system should be stronger than the people running it.

No plans shouldn't depend on people but the change in people is a risk to your plan.

Ok, let me give you an example.  Is your knowledge now as good as it was after 2 years in the workplace?

If you were recruiting a new QA Manager and had a choice of candidates who had the same training, would you choose one with 10 years of quality and people management experience or one with 6 months.

Of course it makes a difference!  And you may need to consider as a team what could change because of that.

So for example, you lose three supervisors in production with vast experience and promote three others.  Yes you've trained them.  But in the short term, compliance in their team may not be as strong.  What mitigation and additional verification of your HACCP plan do you need to do to help ensure it's still safe?

You don't have to read through and tweak every word in your HACCP plan in every review.  But if you're not considering potential risks, however small through change processes, you're missing something.

Too many HACCP plans are folders on a shelf not lived processes.  That is where incidents happen.

To me to do THE HACCP review IS a thorough review of all aspects.

To me, you can't call it a review, when you adjusted the training or the wording to better explain the goings on in one area, one department. You may have reviewed that section, but if you didn't look at all the interlocking aspects, you will also have incidents.

No plans shouldn't depend on people but the change in people is a risk to your plan.

 

Ok, let me give you an example.  Is your knowledge now as good as it was after 2 years in the workplace?

 

If you were recruiting a new QA Manager and had a choice of candidates who had the same training, would you choose one with 10 years of quality and people management experience or one with 6 months.

 

Of course it makes a difference!  And you may need to consider as a team what could change because of that.

 

So for example, you lose three supervisors in production with vast experience and promote three others.  Yes you've trained them.  But in the short term, compliance in their team may not be as strong.  What mitigation and additional verification of your HACCP plan do you need to do to help ensure it's still safe?

 

You don't have to read through and tweak every word in your HACCP plan in every review.  But if you're not considering potential risks, however small through change processes, you're missing something.

 

Too many HACCP plans are folders on a shelf not lived processes.  That is where incidents happen.

I see your point, but it also almost allows for a relaxed attitude regarding the verifications of effectiveness based on the "village knowledge" of experienced personnel.  If you're depending on those three lost supervisors to keep the wheels on the program, then the program is too people dependent IMO.  It lacks the efficacy checks that should be built in, because if I have to add additional checks to ensure PRP's and CCP's are properly monitored based on three new supervisors, then those additional checks should've been there all along. 

To your other example, of course we hire the person with 10 years of experience, but that doesn't mean the program is going to have fewer checks in it than if we had a less experienced QA manager.

I think we're going to have to agree to disagree.

But I will make one last point.  I think this goes back to culture.  I believe a lot of the technical community think you can write down every control in a HACCP plan and that's job done.  That involvement and motivation of people to follow those controls is either something they don't need to do or nothing to do with HACCP.  I fundamentally disagree as wherever you are getting a person to do a task the possibility, nay, probability it will not be completed as designed is significant but even more so if you don't have the right skill in roles and have high position turnover.  And the word is "skill" in my view, not "training" as the latter only confirms someone can regurgitate facts, not that they are competent to the point of being able to challenge, understand risk etc.  

And absolutely you can build verification activities involving front line managers into systems but where those systems meet people always has the risk of tasks completed on paper but not in reality.

In any case, I'm convincing nobody here so I'll remove my soapbox

Hi folks,

My Waffleometer is off the radar with the comments in this topic. Let’s not post to get our post numbers up, okay?

Typically we review HACCP plans immediately when there are emergencies related to our ingredients, materials, products, suppliers, industry crisis etc.

But normally we would review any changes in a monthly HACCP team meeting or as a result of Senior/Top Management monthly reviews.

There appears to be a certain agenda here where we as technical people should be micromanaging all aspects of our sites for example personnel changes, food safety culture.

We don’t review HACCP plans when there are personnel changes, that is ridiculous.

The Senior Management Team including Department Managers are typically responsible for ensuring that the site has adequate resources including personnel and that they are competent. If management have concerns regarding the lack of competency of personnel then adequate management and supervison should be put in place. This has sweet FA to do with the ‘HACCP Plan’.

Kind regards,

Tony

Ok.  I've obviously annoyed people on here.

I'm not claiming that you need to change your HACCP plan if one person leaves but if that one person is the HACCP team leader, perhaps you do.  Or if your entire technical team has turned over in 18 months, it's indicative something is really blooming wrong with your food safety.  If you have huge absence or turnover of operations staff you have risk.

You are very welcome to ignore my comments but for what bizarre reason would I be just posting to up stats?  For what exactly?  

I'm posting on this as someone very experienced in HACCP who feels this is an overlooked issue which speaks to the lack of integration into the day to day workings of food factories.

If that's not of interest.  Ok, crack on.  You do you.   :biggrin:

Once a year, during management review . Or there have an changes of the process.