DRAFT
Section 7: Management Control


  • Components of an Effective HACCP Program
  • Food Safety Through Quality Assurance:  Policies, Procedures and Standards Manual
  • Food Operation Evaluation

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    Components of an Effective HACCP Program
            The most important element of an effective HACCP-based food safety program is the management process, which pre-controls the system to assure that food products are safe. Government's responsibility is only to verify that the operation is following agreed-to HACCP policies, procedures, and standards to produce safe food products for human consumption.  A major reason that most food safety regulations, at the present time, are ineffective is that they do not require unit management to demonstrate how food products are safely produced, stored, served, and sold.  Rather, they are based on the false premise that government inspection is control.  Government inspection of food operations does not assure food safety.  Employees on the line who handle the food can check each item and ensure the safety and quality of food.  Management's pre-control responsibility is to educate and train employees in safety-validated food-handling techniques and provide adequate resources for continuing improvement of employees and process.
            The following are the six components of an effective HACCP program.  These must be in place in order to assure virtual zero-defect control of the hazards.

    1.  Management, supervisor, and employee responsibility for food safety

      a. Demonstrate management commitment through food safety promotion actions. (e.g., safety committees, incentives, awards, etc.).
         1) Set challenging, measurable, and attainable safety improvement  goals.
         2) Set the safety example in all activities.
         3) Interview employees, during walk-around, to hear and respond to their suggestions for process improvement.
      b. Allocate sufficient resources to accomplish food safety goals.
      c. Establish an organizational chart that shows assigned line and staff responsibility for control of food hazards.
      d. Establish a system to measure the economic saving of doing the right tasks correctly the first time.
      e. Develop food safety committees.
      f. Establish accountability measures for meeting food safety responsibilities.
      g. Hold regular staff meetings to reinforce the safety principles and to listen to employee improvement suggestions.
      h. Implement ongoing inspection and monitoring programs to identify and improve controls of changing workplace hazards.
      [. Take action to maintain and improve process control and stability.
    2. Hazard analysis and control
      a. Identify and analyze food hazards through food safety audits, environmental monitoring, and self-inspections to identify hazards in each job that could lead to foodborne illness.
      b. Examine each job for hazards and list the following:
          1) Sequence of job process steps, identifying ingredients, time, temperature, and equipment essential to hazard control
          2) How hazards can lead to illness
          3) Procedures and guidelines that, when used, will control the hazards.
      c. Make arrangements for a hazard control, quality assurance manager to be available on all work shifts.
      d. Evaluate the safety performance of new equipment, supplies, and materials before purchase, and processes before implementation, to assure production of safe food.
    3.  Written program with clearly stated goals and objectives for food safety assurance that promotes safe and sanitary working conditions and has a clearly stated plan for meeting the goals and objectives.
            Owner(s) / Manager(s) will:
      a. Write a food safety policy statement concerning hazards and controls specific to the workplace.
      b. Write a food safety action plan and program clearly describing how food safety assurance and safety improvement goals will be met.
      c. Develop and implement written food safety procedures and guidelines.
      d. Write plans for conducting and documenting at least an annual review of the program effectiveness, and then, for improving the program based on the findings.
      e. Institute appropriate equipment programs to cover the calibration, use, cleaning, maintenance, and eventual replacement of equipment.
    4.  Communication and training
            Owner(s) / Manager(s) will:
      a. Communicate the food safety program to all employees.
      b. Allow for employee input in bringing hazardous food operating conditions to management's attention.
      c. Provide training prior to all new job assignments, including training on specific hazards and controls.
      d. Update training at least annually or as work processes and ingredients change.
      e. Maintain records of training (date, topic, content, attendance).
      f. Train supervisors in pertinent food safety matters, food safety leadership, coaching, and employee empowerment to take action at any time to prevent a problem.
      g. Evaluate training needs to determine specialized training and retraining.  Use supervisors and employees to give feedback as to how to improve training.
    5.  Investigation and correction of process control problems
            Owner(s) / Manager(s) will:
      a. Develop procedures for reporting process control problems, problem investigation, corrective action, and follow-up.
      b. Conduct workplace inspection of facilities and equipment (e.g., refrigeration, cooking and hot holding devices, pot and dish washing and sanitizing, insect and rodent control) for problem prevention.
      c. Write reports following process control problems, showing what preventive or corrective action is being taken to prevent similar problems; for example:
          1) Equipment modified
          2) Work method modified
          3) Equipment changed or added
          4) Employee retrained or special needs accommodated.
      d. Maintain, summarize, and analyze foodborne illness data (e.g., first reports of illness) to determine tasks and operations where incidents have occurred.  Take action to prevent recurrence.
    6.  Program enforcement
            Owner(s) / Manager(s) will:
      a. Write an enforcement statement on safe food operation practices, food safety rules, and standard operating procedures.
      b. Maintain records of disciplinary actions and warnings.
      c. Develop policies that hold all personnel accountable for fulfillment of food safety responsibilities.  (Safety is behavioral control.  Everyone is responsible for his or her safety behavior.)
    Food Safety Through Quality Assurance:  Policies, Procedures, and Standards Manual
            All of this information is assembled in a foodservice HACCP-based QA policies, procedures, and standards manual.  See Table 2-6, which describes the contents of this type of document.

    Food Operation Evaluation
            There is a fundamental management principle that says, "If a standard is not measured, it will not be enforced.  The Food Operation Evaluation form (Table 7-1) enables the operator to validate the operation to assure that standards are followed and that the processes are stable.  (If Table 7-1 does not print properly, click here for separate image.)
            Stability is the basis for continuous quality improvement and continuously safe products.  The results of this evaluation should never be used to punish employees, but only to coach them and to assure improved performance.


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