Food Safety Plan / HACCP - Distribution
Plan Guidance Introduction
Distributors currently fall under the regulatory rules of local State Health Departments and the United States Food & Drug Administration’s Food Safety Modernization Act (FSMA) Preventive Controls for Human Food. This plan guidance page will walk through the basics of developing a FSMA Preventive Controls plan in order to achieve compliance with both State and Federal entities.
Types of companies that would use this plan would be:
- Distributors
Types of food products that would use a version of this guidance would be:
- Shelf Stable Products
- Cold Chain
Food Safety / HACCP Plan
The Food Safety Plan (HACCP or Preventive Controls) is not a stand alone program, but rather part of a larger food safety system. The foundational programs that are part of the food safety system are requently termed prerequisite programs. The term was coined to indicate that they should be in place before HACCP based systems are implemented in order to effectively manage risk from foodborne hazards. The Current Good Manufacturing Practice (GMP) regulations address requirements for many prerequisite programs. The regulation (117 Subpart B) that outlines the conditions and practices the regulated food industry must follow for processing safe food under sanitary conditions, including personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, warehousing and distribution, and defect action levels considerations. Elements of GMPs that are not covered in the Food Safety Plan are still required by regulations.
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Process Flow
The process flow of a food safety plan (HACCP or Preventive Controls) is the center of a food product’s food safety story. It tells how a company makes it’s products and also what hazards and controls are associated with each step. Here’s an example process flow for distribution – cold chain:
Potential Hazards
Biological
- Pathogen growth due to Improper refrigeration: Escherichia coli STEC/VTEC, Listeria monocytogenes
- Penicillium expansum
- Staphylococcus aureus
- Yersinia enterocolita
- Salmonella spp.
Physical
- External contamination from rain water, bird droppings, vermins / rodents, or flying insects
- RTE products are received fully packaged and are not exposed to the environment
- Foreign material contamination from outside sources.
- Physical contamination by operator / employee
- Human pathogens
- Undeclared allergens
Suggested Standard Operating Procedures (SOPs)
SOPs are related to both GMPs and Controls of Hazards in the Food Safety Plan. SOPs define the specific steps of how GMPs and Controls of Hazards mitigate food safety hazards and define a repeatable process.
- Using and Calibrating Thermometers
- Transporting Food to Remote Sites
- Cooling Potentially Hazardous Foods
- Cleaning and Sanitizing Food Contact Surfaces
- Storing and Using Poisonous or Toxic Chemicals
- Preventing Cross-Contamination During Storage and Preparation
- Receiving Deliveries
- Cleaning Building and Facility
- Allergen Control Program
- Washing Hands – To prevent foodborne illness by contaminated hands
- Employee Illness Program
- Using Suitable Utensils When Handling Ready-to-Eat Foods
Suggested Logs and Records
Monitoring records and logs must include the actual values or observation that document the actual implementation of a Food Safety Plan . For example, if a temperature is being measured, the actual temperature must be recorded rather than a check mark indicating that the temperature complied with the critical limit. To comply with regulations, information must be recorded at the time it is observed.
Here are suggested record and log types to use:
- Customer Complaints
- Corrective Action Forms
- Employee Training
- Food Safety Quarterly Audit
- Food Safety Checklist
- Raw Materials/Receiving Log
- Worker Illness Log
- Freezer Log
- Thawing Log
- Refrigerator Log
- Assembly Log
- Shipping Temperature Log
Suggested Supply Chain Documents
The safety of your product depends on much more than just what you control within your own facility. Use of an ingredient that has a history of association with a specific hazard may require a supply chain program as a control within your food safety program. Companies may have extensive supplier programs that encompass much more than food safety elements to manage their supplier expectations and performance.
Here is a list of suggested documents to obtain from your supply chain:
- Food Safety HACCP or Preventive Controls Plan for each product
- Food Defense/Business Continuity Plan
- Validation of each product and/or process and Ready-To-Eat statements (if applicable)
- Certificates of Analysis (COA)
- Third Party Audit Certificate, Report & Corrective Actions
- Product Specification
- Allergen Grid / Statement
- SDS / MSDS Statement
- Country of Origin
Additional Components for Compliance (Recommended)
The following associated food safety components are recommended to achieve compliance with State and Federal rules and regulations.
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Recall Plan
According to the Food Safety Modernization Act, Preventive Controls for Human Food regulation requires the development of a written Recall Plan when a hazard analysis identifies a hazard requiring a preventive control. Recalls are actions taken by an establishment to remove an adulterated, misbranded or violative product from the market. In other words, a product for which FDA or a state could take legal action against the company would be subject to recall.
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Verification
Verification is an important component of supply chain, sanitation, allergen and critical controls. It confirms that the Food Safety Plan is operating as intended. Validation confirms the effectiveness of the Food Safety Plan in controlling food safety hazards. The purpose of verification is to provide a level of confidence that the Food Safety Plan is 1) based on solid scientific principles that are adequate to control the hazards associated with the product and process, and 2) that the plan is being followed correctly every day of operation.
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