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    Wednesday, 30 November 2016

    HACCP: Corrective Actions

    In the latest of our HACCP article series, we looked at how to establish critical limits for your CCPs, the values that your process must not exceed whilst being monitored. But what should you do if the critical limits of your plan are somehow breached? This requires the implementation of corrective actions, steps detailed in your HACCP to deal with deviations.

    Corrective actions are implemented when monitoring results indicate a deviation from critical limits. Effective corrective actions depend upon well-planned monitoring procedures to allow them to be executed as soon as possible, minimising product contamination.

    When critical limits are broken at CCPs, corrective actions should be easily referenced from the HACCP plan and then brought into effect. They should state the correct procedures to restore process control and gauge the level of product contamination. If possible, corrective actions should always seek to correct the problem immediately.

    Examples of corrective actions could include:
    • Removing and holding product for safety.
    • Diverting products to another line where deviation is not critical.
    • Reprocessing.
    • Destroying contaminated product.

    The main goal of designing your HACCP plan is of course to keep unsafe products from leaving the processing plant, but your plan should still be designed in a manner that emphasises quick response by continuous monitoring, immediate corrective actions, and minimised contamination.

    The responsibility for enacting corrective action procedures should fall to a member of staff who fully understands the process, product, and HACCP plan. When corrective actions have been taken, records should be taken to note as such. This documentation can then be reviewed to demonstrate compliance and identify recurring problems, which can lead to the HACCP plan being amended.

    Corrective Action Components

    Effective corrective actions must:
    1. Fix and eradicate the cause of the deviation to bring the CCP back under control.
    2. Separate, evaluate, and determine disposition of affected product.

    1. Restore process control

    Corrective actions have to bring the CCP back under control. They should take care of the immediate problem, as well as dealing with any long-term issues that may arise. The short-term fix is the priority, however, so that control can be regained and the process restarted as soon as possible without any more deviations.

    The long-term consequences must also be considered, mainly to prevent future occurrence. If a critical limit deviation keeps happening and is not foreseen by the HACCP plan, the plan itself may have to be modified to stop it. If the HACCP plan is to be changed, a permanent solution to the problem should be found by eliminating the causes of the deviation.

    2. Identify contaminated products and determine disposition

    When a deviation occurs, any contaminated products need to be identified. Four steps then need to be taken to deal with the issue:
    • Step A - Determine if the product represents a safety hazard based on expert evaluation or physical/chemical/biological testing.
    • Step B - If no hazard exists based on this assessment, the product can be released.
    • Step C - If a hazard does exist, the product can either be reprocessed into a safe state, or diverted for a safe use.
    • Step D - If there is a hazard, and neither of the actions in step C can be taken, the product must be destroyed. This is generally the worst option economically so must be avoided if possible.

    The sampling procedures used in step A are of vital importance, as improper sampling techniques could lead to contaminated product being released, the ramifications of which could be disastrous. The limits of any sampling should be recognised, and in many cases bringing in an expert is the best way forward.

    If reprocessing the product has been decided as the best course of action, it is important to make sure that this doesn’t lead to the creation of any new hazards. Particular hazards of note to watch out for after reprocessing are toxic materials such as heat-resistant biological toxins. Reworked product must still be put under the same inspection as regular product to make sure it is free of contaminants.

    Corrective Action Format

    Corrective actions are usually written in the if/then configuration. The “if” part describes the circumstance, with the “then” part noting what action is to be taken.

    For example:

    IF - Temperature of milk pasteurizer drops under critical limit.

    THEN - Milk flow diverted until temperature recovers. Diverted product repasteurized. Heating units checked. Repair, re-establish control, and resume production.

    Corrective Action Records

    Predetermined corrective actions are recorded within the HACCP plan documentation. Any time a critical limit deviation occurs and corrective actions take place, it should be recorded. Corrective action records should include:
    • Product Identification
    • Description of Deviation
    • Corrective Action Taken
    • Disposition of Final Product
    • Individual Responsible for Corrective Action
    • Results of Evaluation

    Corrective actions should be closely linked to monitoring procedure records, and could be noted on the same form.

    Overall, by ensuring that your HACCP plan has a rigorous set of monitoring procedures, coupled with effective corrective actions that can be quickly applied, you minimise risk of contaminated products, and reduce the amounts of any that do arise. Whilst preventing any unsafe product reaching the consumer is of course the priority, doing so in an economically efficient manner should also be the goal. Following the steps detailed in this article will allow you to construct valid corrective actions and make sure that is the case.

    Sam Franklin

    With a master’s in Literature, Sam inhales books and anything readable, spending his working hours reformulating the info he gathers into digestible articles. When not reading or writing, he likes to put his camera to work around the world, snapping street photography from Stockholm to Tokyo. Too much of this time spent in Japan teaching English has nurtured a weakness for sashimi, Japanese whisky, and robot cafés.
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