MODIFICATION OF NACMCF HACCP
WITH RISK MANAGEMENT
TO RETAIL FOOD HACCP-TQM
 
O. Peter Snyder, Jr., Ph.D.
Hospitality Institute of Technology and Management
 

1. Hazard analysis (Principle 1): Risk assessment; Hazard identification, Exposure assessment
(Must do a full-system specification first and identify all processes.)
For each step, identify hazards of such significance that they are reasonable likely to cause illness or injury if not prevented, eliminated, or reduced to an acceptable level. The selection is by the HACCP team based on:
a. Severity (illness, magnitude, duration).
b. Likely occurrence (experience, epidemiological data, information in the technical literature).

Determine CCP (Principle 2)
Actually already done above. Controls will only relate to safety, not quality.

Establish critical limits (Principle 3): Risk assessment, Dose response
The critical limit refers to the magnitude / size of the hazard that makes very frail to very resistant people ill or hurt. It is a sigmoid dose response distribution. Normally, the government sets this for the most sensitive person, if it is set at all.
Pasteurization: 1,000 per gram salmonellae reduced to 1 per 100 grams.
Sterilization: 1 Clostridium botulinum spore per gram reduced to 1 per 12 billion grams.
 
2. Severity / probable cost: Risk characterization
Probable cost to the operator per year of customers getting sick or dying from this hazard. This can range from catastrophic (many dead, >$10,000,000) to noticeable (minor first aid, $100).
 
3. Control (Snyder): Risk management and communications
For the proposed level / size of the hazard in the food, a process control(s) that, when met, reduces the hazard to a safe level some acceptable percent of the time. These controls include: temperature, time, physical dimension, humidity, moisture, water activity, pH, titratable acidity, salt / sugar and other preservatives, free chlorine, viscosity. Proof in operation that the control is effective. (Control includes all NACMCF prerequisite programs.)
 
4. Probability of control failure (Snyder)
Do a failure mode analysis of all aspects of the control and determine the likelihood of correct performance (e.g., if a cook has a bimetallic coil thermometer, the chance of cooking a hamburger to 155F for 15 seconds is pure luck.).
 
5. Monitoring (Principle 4)
 How the cook is to monitor correct performance and corrective action by the cook to keep the process in control.
 
6. Probability that monitoring will find a critical defect (Snyder)
Probability that the cook or the customer will detect the out-of-control condition and discard the food (cook) or not eat it (customer).
 
7. Corrective action (Principle 5)
What is done with food produced out of control by whom and what record is made.
 
8. Verification (Principle 6)
Verification by the operator that the system is operating according to plan, that it is scientifically sound, that all hazards have been identified, and if controls are followed, the hazards in the food will be tolerable.

 9. Record keeping (Principle 7)
Documentation of the control of the steps.
This is a fatal error in the NACMCF plan. It should be the requirement for the operator's HACCP-TQM manual that, when followed, assures a tolerable probability of risk / insurance cost.

 10. Certification (Snyder)
This is missing from the NACMCF plan. It is what the regulatory inspection of the HACCP program is supposed to do--certify that the chance of getting ill from eating food in the establishment is tolerable because of the unit's predictable performance.
 

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