Organic Processing Vo1.6 #6 - November/December 2009

may have strict regulations on use of chemicals, it’s important to check for chemical, pesticide and drug residues. In organic operations, the area to pay the most attention to would be the surroundings, including the water used and potential overspray from conventional operations. A hazard analysis for pathogens might also look at pathways for unexpected hazards, such as those tracked in on employee shoes or boots not cleaned before entering the food plant.

Principle 2: Determine Critical Control Points (CCPs). Using insight gained through the analysis, facilities can identify points where they can control or reduce hazards. One example is to establish the point where a product actually is baked or cooked to a temperature needed to kill a pathogen. The point where that temperature ought to be reached, and its point of measurement, is a CCP.

Principle 3: Establish Critical Limits. A critical limit is a maximum and/or minimum value or physical parameter to which the CCP must be controlled in order to prevent, eliminate or reduce the hazard. An example would be the limits of both the time and temperature at which the product would have to be processed and held in order to kill a pathogen, or chilled to prevent pathogen growth.

Principle 4: Establish Effective Monitoring Procedures. This can include planned observations or other assessment measurements such as temperature recording and monitoring equipment, or a record of “test and hold” procedures and results if pathogens are likely to occur as hazards. Track the data from these assessments and create an accurate record for verification in the future. To continue the example above, one might have a thermometer measure and record the temperature during the process at set time intervals or as a continuous process.

Principle 5: Establish Corrective Actions. Action is necessary when critical limits are exceeded or monitoring procedures fail. Prior noted records will show these deviations. Pre-planned corrective actions can be used to prevent products that may be hazardous from reaching consumers. These actions could include “test and hold” procedures or recall procedures.

Principle 6: Establish Verification Procedures. This step goes beyond verification of the HACCP plan itself and includes looking at whether the HACCP plan is actually functioning in harmony with the facility or whether it is just “placed on top” of normal operations. Can