SANITATION STANDARD OPERATING PROCEDURES (SSOP)
Although sanitation records must be kept, they are not treated as HACCP records in the regulation. By keeping them separate from HACCP, no formal corrective action or verification records are required. When problems occur, simply correct the problem. The sanitation checklists will document that control was reestablished. For example, if sanitizer concentration is lower than the level specified in the Sanitation Standard Operating Procedure (SSOP), replace it and record the new concentration at the next scheduled check. Example sanitation checklists are available from Maryland Sea Grant or the National Seafood HACCP Alliance.
The SSOP and Hazard Analysis provide the justification for selecting the Critical Control Points of the HACCP plan. They allow for a simpler HACCP plan and are, therefore, very important. The in-plant process establishment studies are the other necessary components of the example plans. Consult with a process authority for assistance with this documentation at your plant.
Sanitation records must document eight sanitation areas identified in the regulation. The following language is quoted from the regulation:
(a) Sanitation SOP. Each processor should have and implement a written sanitation standard operating procedure (herein referred to as SSOP) or similar document that is specific to each location where fish and fishery products are produced. The SSOP should specify how the processor will meet those sanitation conditions and practices that are to be monitored in accordance with paragraph (b) of this section.
(b) Sanitation monitoring. Each processor shall [must] monitor the conditions and practices during processing with sufficient frequency to ensure, at a minimum, conformance with those conditions and practices specified in part 110 [GMPs] of this chapter that are both appropriate to the plant and the food being processed and relate to the following:
(1) Safety of the water that comes into contact with food or food contact surfaces, or is used in the manufacture of ice;
(2) Condition and cleanliness of food contact surfaces, including utensils, gloves, and outer garments;
(3) Prevention of cross contamination from insanitary objects to food, food packaging material, and other food contact surfaces, including utensils, gloves, and outer garments, and from raw product to cooked product;
(4) Maintenance of hand washing, hand sanitizing, and toilet facilities;
(5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants;
(6) Proper labeling, storage, and use of toxic compounds;
(7) Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces; and
(8) Exclusion of pests from the food plant. The processor shall correct in a timely manner, those conditions and practices that are not met.
(9) Sanitation control records. (See Sanitation Audit Forms (examples).) Each processor shall maintain sanitation control records that, at a minimum, document the monitoring and corrections prescribed by paragraph (b) of this section. These records are subject to the requirements of Sec. 123.9.
(d) Relationship to HACCP plan. Sanitation controls may be included in the HACCP plan, required by Sec. 123.6(b). However, to the extent that they are monitored in accordance with paragraph (b) of this section they need not be included in the HACCP plan, and vice versa.
The SSOP and sanitation checklists address the above sanitation monitoring areas. Any test results that support SSOP's, such as laboratory reports indicating the microbiological safety of water and ice, should be retained as sanitation records.
Sanitation controls and related records generally should not be included in the company's HACCP plan. SSOPs are best used to control food safety hazards associated with the plant environment (e.g. maintenance of facilities, cleaning and employee hygiene) and HACCP is most effectively applied to hazards related to product characteristics and specific processing steps.