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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