The Industry has learned about HACCP in anticipation of USDA's upcoming regulation. Whether is knows what HACCP is remains to be seen
By Ken Krizner, Senior Editor
The old cliche, "you're never too old to learn," is very applicable to the meat industry these days. After nine decades of relying exclusively on command-and-control regulations, a science-based preventative system is about to be mandated. Like many uncharted courses, there is some apprehension about this one, whether it will be successful or a waste of time and money.
Throughout the 1990s, packers and processors have been familiarizing themselves with the definition of "critical control points," and what exactly the acronym "HACCP" stands for.
It stands for Hazard Analysis and Critical Control Point, and it is a system tailored to individual plants and processes that aims to control potential hazards in the food supply.
HACCP has become the preferred approach to reduce food-borne hazards among government and food industry officials over the past three decades because of an increasing number of new food-borne pathogens, such as E. coli 0157:H7; an increasing concern among the public about chemical contamination; and the fact that the size of food manufacturing, including meat and poultry, has grown tremendously.
A properly implemented HACCP system, experts say, can reduce most types of biological, chemical and physical hazards from ever occurring.
And it is about to change how most packers and processors do business.
"We cannot say HACCP is a cure-all, but we can say HACCP is a mechanism for modernizing inspection," notes Alice Hurlbert, AMI director of Regulatory Affairs. "HACCP is an industry process-that's very important and oftentimes overlooked. It is not a government process. This is implemented by the companies themselves."
Oftentimes also overlooked is that HACCP is the embodiment of the seven principles of the National Advisory Committee on Microbiological Criteria for Foods. It is not inspection, it is not microbiological testing; it is a management system that reduces hazards associated with food.
"HACCP [is] a key element of a complete product management system," according to "HACCP A Practical Approach," a book written by Sara Mortimore and Carol Wallace. "HACCP is the most important system of food-safety management."
But the fact that HACCP is a company-implemented program-and not continuous inspection-has been lost on all interested parties, according to a food industry consultant.
"If you examine [FSIS'] comments, it looks like HACCP is something that USDA does," stresses Charles F. Cook, managing partner of Middleton, Wis.-based Cook & Thurber. "Under HACCP, FSIS' role is to verify compliance to a program that is unique to a company's products and processes. The verification is based on performance standards or predetermined limits."
Cook, a former director of regulatory affairs for Oscar Mayer Foods Corp., believes the original intention of HACCP has been lost in the rhetoric of special interest groups-government, consumer activist organizations, the inspectors' union and industry. Be that as it may, FSIS is about to mandate HACCP to an industry anxiously awaiting the final rule, which is expected within the next two months.
"We're working as hard as we can and as fast as we can to get the rule out," stresses Michael R. Taylor, USDA acting undersecretary for Food Safety.
An FSIS spokesman tells Meat Marketing & Technology that the final rule is nearly complete but still needs approval from USDA Secretary Dan Glickman and the White House Office of Management and Budget.
FSIS and industry have worked for more than a year to come to an understanding over the agency's pathogen reduction proposal, which includes written standard operating procedures, antimicrobial testing, as well as HACCP programs for meat and poultry plants with $2.5 million or more in sales. HACCP would be implemented over a one- to three-year period depending on company size.
After industry and several influential members of Congress threatened to legislate negotiated rule-making, forcing FSIS to throw out its proposal and start from scratch with industry input, the agency agreed to a series of forums to iron out differences. When the new rule is finally implemented, slaughter plants for the first time will have to test products for bacteria and meet targets for reducing harmful bacteria.
But most of the conversation for the past year has centered on HACCP.
Taylor says FSIS will change fundamentally when HACCP is adopted.
"We will have a new framework-a HACCP framework-for the plants we inspect," he points out. "This requires new tasks being performed by [FSIS] inspectors. We also have a farm-to-table strategy that says there will be roles for FSIS at the transportation stage, distribution, and perhaps greater involvement at the retail level."
Revolutionary shift in thinking
HACCP will also change the industry-fundamentally and philosophically.
"It is a good framework for pathogen reduction," says Mark Klein, spokesman for Minneapolis-based Cargill Inc. "It is a process control mechanism that depends on prevention." That's a radical concept for an industry that has depended almost exclusively on detecting and correcting problems after they occur for 90 years.
A paper written by the Institute of Food Science and Engineering at Texas A&M University argues that hazards can enter the food supply from any point of the base production system through delivery to the consumer.
"The only way to provide [meat] with less potential hazards is to institute sufficient controls throughout the production chain to prevent them from entering or occurring, and to monitor each component sufficiently to ensure that any problems that do develop are discovered and addressed prior to delivery," according to the paper.
This is HACCP, similar in concept to a Total Quality Management program, which many meat processors have instituted in the past five years.
The industry's education on HACCP begins with its seven basic steps as defined by the National Advisory Committee:
-- Analyze hazards. Potential hazards associated with a food are identified. The hazard could be biological, such as a microbe; chemical, such as mercury; or physical, such as ground glass or metal.
-- Identify critical control points. These are points along the food-production line-from its raw state through processing and shipping for consumption by consumers-at which the potential hazard can be controlled or eliminated. Examples are cooking, chilling, handling, cleaning and storage.
-- Establish preventive measures with critical limits for each control point. For a cooked food, this might include setting the minimum cooking temperature and time required to ensure a safe product. Temperature and time are critical limits.
-- Establish procedures to monitor the control points. Such procedures might include determining how cooking time and temperature should be monitored.
-- Establish corrective actions to be taken when monitoring shows that a critical limit has not been met. For example, re-processing or disposing of food if the minimum cooking temperature is not met.
-- Establish effective record-keeping to document the HACCP system. This is a key element in case of product recall.
-- Establish procedures to verify that the system is working consistently. For example, testing time- and temperature-recording devices to verify that a cooking unit is working properly.
"HACCP is only as good as the people managing it," Cargill's Klein stresses. "From top to bottom, how well-trained individuals are will affect the success [or failure] of a HACCP program."
Cook notes, however, that a concept of "process management," based on principles similar to those applied to HACCP is a better idea for the industry.
He focuses his processed management philosophy on three points: food safety, quality and profitability.
He describes visiting a HACCP pilot plant several years ago and asking the manager if he believed his product was safer under HACCP.
"He said no-the plant was already producing a safe product," Cook recounts. "But [the plant manager] believed HACCP was good because it was making him more money. It was forcing [the plant] to continually manage and improve its processes." Continuous improvement, a focal point in process management, is a concept that Cook believes has not been discussed in the current HACCP debate.
He pointed to standard operating procedures (SOPs), which plants will be required to document under the new regulation, as a point where the HACCP rule gets off track. He argues that a "standard" operating procedure eliminates the theory of continuous improvement.
"If it is 'standard,' it is understood it will never change," Cook stresses. "Conditions change daily in plants, but SOPs [under FSIS' plan] assume that there will never be changes. That precludes SOPs from effectively working in the daily environment of a plant."
Cook's point about HACCP confusion is echoed by others. From her dealings with the industry, AMI's Hurlbert has observed that most people believe inaccurately that HACCP and microbiological testing are synonymous. Microbiological testing is different from
HACCP, although microbiological testing could be considered an element of a HACCP program.
"A company may need microbiological testing, but it isn't necessarily a component of HACCP," Hurlbert says.
Klein warns that HACCP "is not the complete equation, just part" of a food-safety plan that also includes microbiological testing, SOPs and good manufacturing practices (GMP).
Some elements that an SOP document should cover include: personal hygiene, plant sanitation, pest control and water control.
Some elements that a GMP document should cover include: transportation pallets, proper placement of product in the truck, hide removal and how the internal cuts are made on a carcass.
"A HACCP plan that does not include SOP and GMP procedures is an incomplete HACCP plan," Klein argues. "They are separate, but intertwined. [SOPs and GMPs] are nothing more than common-sense practices."
Since beginning its HACCP program two years ago, Sun Land Beef Co. has seen a "change in awareness of employees," from supervisors to hourly people, according to Murle Schraeder, plant manager for the Tolleson, Ariz.-based company. "Everyone is involved," he notes. "The biggest thing that needs to be done is a written document that covers every aspect of an operation. That's why everyone needs to be involved."
Schraeder adds as a warning: "Any item that processors put into a HACCP program needs to be attended to. They better live by that document or their HACCP program will not work."
Since initiating its HACCP program, Sun Land Beef has added a microbiological laboratory and lab technician to its food-safety arsenal.
Another part of the equation to food safety is new technologies, such as steam pasteurization, chemical dehairing, steam vacuum, trisodium phosphate and chlorine dioxide.
"Technological innovation by industry will play a key role in achieving the food-safety goals [industry and government] share," Taylor stresses. "Partnerships and communication between industry, government and the scientific community are necessary to meet the public's demand for a safer food supply."
Sun Land's Schraeder admits the job is never complete.
"We do a lot of communicating with our customers, especially those who buy grinding materials because of the emphasis on ground beef," he says. "You have to keep after it to make it work."
No time like the present
If all goes according to USDA's plan, sometime by the middle of 1997 HACCP implementation will go into affect.
However, the top packers and processors, which account for more than 90 percent of the meat sold in the United States, have already instituted HACCP programs in their plants.
An AMI survey last year indicated that 66 percent of processors and packers have written HACCP plans, 72 percent have at least one HACCP-trained employee, and 47 percent have provided line workers with some HACCP training.
Yet, some have not-especially smaller processors-and time is growing short. However, there are many classes, seminars and generic HACCP models that are available.
While HACCP is tailored to individual plants, there is enough information from which to start a generic plan. There are certain "common occurrences" that every slaughter floor experiences, for example. The next step for individual plants would be to add operational points unique to their own processes.
"You don't have to create the wheel; it's already been created," Klein says. "If a company is at ground zero, it should not wait; it should go ahead and learn about HACCP."
And if a company already has a HACCP program, "further develop and interpret an understanding of that program," AMI's Hurlbert urges. "The more understanding a company has, the better. I've talked to [executives] who began HACCP programs five years ago who found it very beneficial and believe they will have easier transitions when mandatory HACCP arrives."
It's easy to see that when mandatory HACCP does become the regulatory rule of the meat industry, school will not be dismissed-school will remain constantly in session.
The Principle of the Matter
The seven HACCP principles as established by the National Advisory Committee on Microbiological Criteria for Foods:
1. Conduct a hazard analysis.
2. Identify critical control points in the process.
3. Establish critical limits for preventive measures associated with each critical control point.
4. Establish critical control point monitoring requirements.
5. Establish corrective action.
6. Establish effective record-keeping procedures.
7. Establish procedures for verifying that the HACCP system is working correctly.