ISSUE5

The purpose of HACCP COUNTDOWN is to alert the seafood processing industry of strategies for the successful implementation of HACCP and related food safety programs. We will keep you informed of developments in training and sources of information. These newsletters highlight topics which, if followed, should prepare processors for HACCP inspection. Please contact any of the indivduals listed on page two with questions or topics needing clarification.

Establishing Corrective Actions

Corrective Actions are procedures implemented to regain control at a Critical Control Point (CCP) when Critical Limits are violated. Corrective Actions must be taken and documented whenever monitoring reveals such a problem. A Corrective Action requires two actions: (1) correct and eliminate the cause of the deviation and restore process control and (2) identify the product that was produced during the process deviation and determine its disposition. Typical Corrective Actions for affected product include (1) segregating and holding product for testing, (2) diverting product to another use where the deviation is not critical, (3) reprocessing, (4) rejecting raw material at receipt, and (5) destroying the product.

All Corrective Actions must be thoroughly documented by recording (1) the nature of the deviation, (2) a description of the implicated product, (3) the Corrective Action taken including final disposition of the product, (4) the individual taking the Corrective Action, and (5) results of any tests or evaluations performed.

Just as two or more Critical Limits may be established to control a hazard at a CCP, more than one Corrective Action may be appropriate. Destroying product should be a rare and last resort. Consider the following example. A blue crab processor established Critical Limits for his fresh crabmeat cooler of more than 40°F for 6 hours. One night, the compressor failed and the Critical Limits were exceeded, as indicated by the chart recorder. The processor followed his Corrective Action plan: (1) measure product temperature, (2) if product is less than 45°F, regain temperature control and market as usual, (3) if product is 45-50°F, regain temperature control and pasteurize the product, (4) if product is above 50°F, regain temperature control, pasteurize the product and hold for evaluation by a process authority, and (5) if not cleared for sale, destroy the product. Since containers of fresh crabmeat are traditionally iced even in refrigeration, the processor only needed to proceed through step 2.

This example raises several points. Appropriate Corrective Actions relate directly to the hazards of concern. The blue crab processor determined that pasteurization would destroy pathogens of concern in fresh crabmeat but not the toxin produced by Staphylococcus aureus, a bacterium usually introduced by employees. Fortunately, staph usually requires significant temperature abuse to release toxin and is not reasonably likely to occur under 50°F. The process authority would probably recommend a staph toxin test under step 4 of the example. This example illustrates how a Corrective Action plan can minimize the quantity of implicated product or the severity of corrective actions. If only one row of crabmeat in the cooler exceeded 45°F, just that product would require pasteurization. Remember, too, that HACCP does not deal with quality issues unrelated to food safety. If the crabmeat warmed and began to spoil, the processor would not try to salvage the product with pasteurization. The crabmeat could even be deemed adulterated due to decomposition and unsaleable by regulation. However, this issue is outside the scope of the company's HACCP program.

Verification

Periodic procedures implemented to confirm the appropriateness, effectiveness and consistent administration of the HACCP plan are referred to as Verification steps. Verification includes several types of HACCP checks which can be grouped as those that (1) determine if the HACCP plan is valid, that is, properly designed to control hazards and (2) confirm that the plan is accurately monitored and followed. Because numerous activities are often considered verification functions, including government inspections, Verification is sometimes thought to be the most confusing of HACCP principles. But it need not be. For simplicity, we will separate verification steps into those that are performed routinely, and those that are conducted occasionally.

Routine Verification

• The FDA HACCP regulation requires that an HACCP-trained individual periodically review HACCP monitoring and corrective action records, signing and dating them. These reviews should determine that the records are complete, that CCP monitoring records are logged at the frequencies identified in the company's HACCP plan, and that the appropriate Corrective Actions were followed. Record reviews must be performed at least weekly.
  
  
• All instruments used to monitor for Critical Limit compliance must be periodically calibrated. For example, check a refrigerated storage room thermometer in agitated ice slush (32^oF) or against a standardized thermometer for accuracy. The regulation does not mandate a calibration frequency but, in the event of discrepancies, limit the scope of the problem by calibrating often.

Occasional Verification

• Process verification studies (for example, product temperature profiles during cooking) or product test results that can be used to support (validate) the HACCP plan are important verification records.
  
  
• The HACCP plan must be reassessed whenever a change occurs in the product or process which may affect food safety, or at least annually even if no changes are evident. Typically, the HACCP team will review and verify the flow diagram and Hazard Analysis for each product to determine if the existing plan requires modification. An audit of consumer complaints, HACCP and sanitation records should complete the review.

ISSC Course and Other Commodity Specific Training

A program for softcrab producers will be offered in 1998; contact Mike Oesterling or Bob Fisher at VIMS, (804) 642-7165, or Tom Rippen (see below). Althougn not certified by an independent agency such as AFDO or the ISSC, health departments from Maryland and Virginia recognize the program and encourage industry participation.

A one-day course for shellfish shippers (SS) and reshippers (RS) will also be offered in 1998; it is certified by the ISSC and complies with the training requirement of the FDA HACCP regulation for licensed SS and RS seafood business categories.

For Information and Assistance

HACCP courses nationally, HACCP models and HACCP links are available on the Internet: http://www-seafood.ucdavis.edu/

For assistance, contact the seafood specialist in your area:

David Green, North Carolina State University, (919) 726-7341
George Flick, Virginia Tech, (540) 231-6965
Mike Jahncke, Virginia Tech, (757) 727-4861
Tom Rippen, University of Maryland, (410) 651-6636