Where every meal gets its start How to HACCP 01 PRINCIPLE Conduct a hazard analysis 02 PRINCIPLE Determine critical control points 03 PRINCIPLE Establish critical limits 04 PRINCIPLE Establish monitoring procedures 05 PRINCIPLE Identify corrective actions 06 PRINCIPLE Verify the HACCP Plan 07 PRINCIPLE Establish recordkeeping and documentation procedures » Rediscover the building blocks of food-safety procedures. THE PROCESSES AND RULES SURROUNDING HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) practices can be overwhelming, to say the least. But the intricacies and steps of creating a HACCP plan are meant to not only guarantee that you and your team are taking all the appropriate steps to ensure food safety, but also provide documentative proof to school administrators, the media, parents and anyone else who might question the safety of school meals. This is why School Nutrition has covered this complex topic year after year. This month, SN has chosen to repurpose some of its archival content on this subject to offer a primer that you can use in your training efforts with new staff—or to refresh your own knowledge. As we wrote in 2006, adopting HACCP principles and creating a food safety plan could be as big a project as any that you have encountered in foodservice! But never fear, SN is here with this helpful HACCP summary. What Is HACCP? HACCP is defined as a systematic approach to food safety that follows the flow of food through a foodservice operation to eliminate or reduce the risk of foodborne hazards. There are seven HACCP principles: 1) Conduct a hazard analysis. 2) Determine critical control points. 3) Establish critical limits. 4) Establish monitoring procedures. 5) Identify corrective actions. 6) Verify the HACCP plan. 7) Establish recordkeeping and documentation procedures. Along with the above seven principles, the flow of food is the fundamental rule at the heart of HACCP’s process approach. Food items generally fit into one of three categories (no-cook, same-day service or complex preparation), depending upon how many trips the menu item makes through the temperature danger zone. Based on how each item is categorized, you must determine the flow of the food ingredient or complete menu item, then document this flow from start to finish. Pre-what? After understanding the basis of HACCP, you should evaluate the foundation of your current operation and assess what food-safety practices must be fixed before penning a new plan. A former SNA HACCP curriculum included the following checklist to help keep track of all the prerequisite programs so you at least have a place to start: » Pest control. Check required pest-control measures. Do you have documentation of the schedule of when the treatments are required, when they have been made and who applies treatments? » Equipment maintenance. Make sure all equipment is installed and working properly. Do ovens need to be recalibrated? » Chemical control. Make sure you know the kinds of chemicals used for cleaning and sanitizing in your cafeteria, kitchen and storage areas. Be sure you know when and how they are used, and that they are stored separately from foods. » Traceability and recall information. Can you go back and identify the source of a food item, as well as where it went in your operation from the time it was received? » Supplier control. Do you have documentation regarding the HACCP plans of your vendors? It’s important to buy food from an approved source, as you do need proof that your vendors are sanitation savvy. It’s helpful to emphasize HACCP in bid documents! » Food-temperature control. Your staff is taking the temperature of foods before they are served. But is someone taking the temperature of foods upon delivery receipt? Along with these pre-reqs, which provide a valuable opportunity to incorporate processes that have been left out of your food-safety programs, you also need to assess Standard Operating Procedures (SOPs). An SN interviewee once confessed her operation had to start recording everything back in the day when they were evaluating SOPs: “We took our temperatures, but did we document them? No. Do we now? Yes. Now we are writing down everything.” Simple protocols like this must adopted before moving on from SOP evaluations to HACCP creation or revision. SOP, Please Help Me! To provide further clarification, a Standard Operating Procedure is a set of written steps that describes how a routine practice or procedure is carried out. As a concept, an SOP is nothing new—if a prerequisite tells you that surfaces must be clean, it’s the SOP that tells you how to ensure that they meet this goal. They serve two main purposes: contain all the steps and instructions for each essential process, and take a detailed and in-depth look at the procedures themselves. While each SOP has several elements, know that an SOP will state the procedure and desired outcome; list and describe the steps; indicate the staff person or position responsible for executing them; and identify the supervisor who has ultimate responsibility for monitoring compliance. When writing your SOPs, remember to address critical control points whenever appropriate. Critical control points are the points or stages at which controls or actions must be in place and monitored or an unacceptable risk of hazard will occur, like cooking and holding, and then record the times and temperature at these points. SOPs should also include steps to: » monitor processes; » check critical limits; » document appropriate important information like temperatures; and » correct and/or report problems if they occur. A good starting place is to use the following SOP checklist. It features common areas that will benefit from having documented SOPs: Personnel » Employee health and personal hygiene » Glove and utensil use » Contact with blood and body fluids » Handwashing » Tasting method » Eating/Drinking in the workplace Purchasing » Use of approved vendors » Specification development and use Consumer Communications » Responding to a foodborne-illness complaint » Responding to a physical-hazard complaint Other » Foodservice in emergency situations » Closing the operation (end of school or afterschool service) » Opening the operation (beginning of school or breakfast service) » Visitors in foodservice It Takes a Village Now that we’ve re-hashed the basics, let’s revisit who should work to assist with writing the SOPs and the overall HACCP plan. Unless your district is very small, a team approach is found to work best. If you work in a somewhat large district, you may want to establish a district-level team that works with individual school teams to review and record processes. Teams offer the additional advantage of perspective. Be sure school teams include individuals who actually perform these processes every day. This is also a great tactic to get managers, assistants, cooks and line staff to take a really hard look at what they’re doing and how they do it—and to buy in to the overall tenets of your food-safety plan. Additional help can be found through online SOP templates, and peers from around the district, state or even country who have already gone through the process can be great sources of information and support. After all, in this industry food safety is everyone’s responsibility! Don’t Stop Me Now! Whether you’re in a district office or behind the line, it’s understood on all levels that the rules and work flow that surround them are ever-changing. Processes evolve, equipment gets updated and both SOPs and HACCP plans must adapt with the times to stay useful. Not to mention the local food code that is in force in your community. Your SOPs certainly must conform to the local code – and if it changes, your SOPs, must change, too! After it’s all said and done (which it will be eventually, if only temporarily!), make the SOPs and the HACCP plan accessible through a binder or electronic file kept in the kitchen or work area. Some directors also give each employee a tailored binder with the specific regulations and rules that apply to the employee’s job. Others post them on the department’s intranet, if applicable. Whatever method you chose, don’t let this resource gather dust! Use plans regularly in training and keep available so that employees can review them and use them to answer questions. While this article is certainly not an all-inclusive resource, hopefully this refreshed or at least shed some light on the fundamentals of this intense concept. A few last pearls of wisdom: Don’t work alone. Don’t expect to be an expert. Don’t expect to ever be finished with your food-safety plan. Let’s look at three areas a little more closely. It’s important not try to take the whole food safety burden on yourself. Form a food-safety team and get advice from colleagues in neighboring districts. One foodservice director once proposed that this team include anyone who has a potential impact on food safety, from the custodian to the business manager! Essentially, this is a huge task, share the burden and everyone benefits. Stay humble and be open to learning more. If you are a long-time school nutrition veteran, you might consider yourself a HACCP expert. That doesn’t mean you don’t need ongoing training in the topic. HACCP planning is not something you can do just by downloading information from the Internet. It is the exceptional person that could develop a plan without at least one good workshop. Finally, don’t expect to be finished with your food-safety plan. This is not one of those projects that, once you are finished writing, you can print out and file away forever. Be prepared to revise and update the food-safety plan whenever you make changes to your operation, whether it is adding new menu items, establishing a salad bar or purchasing new equipment. Dr. Jeannie Sneed, RD, SNS, authored a past-publication for SNA titled Keys to Food Safety, and she asserted that while you are never totally done, “the stumbling block is getting started. No one has a perfect plan at the beginning. Do one bit at a time and implement in pieces and parts.” BEYOND THE “BUTS” No matter how innovative and forward-thinking you consider yourself, you likely have moments where the “idea killer” moniker fits you like a glove. Most of us are more than capable of looking at the glass half-empty and focusing on all the impediments to success – especially with a huge challenge like HACCP plans! So how do you get beyond your own bevy of “buts”? SN’s editor-in-chief offered these helpful hints to coping in our November 2006 issue. …But I’m just a manager. Your title or level of responsibility has no bearing on your powers of observation and creativity. If your idea is innovative and many of the details, pros and cons are all thought through and presented, most supervisors or other decision makers are likely to listen. Be professional and persistent. An idea mentioned casually is more easily dismissed, so pick your timing carefully, do your research and be ready to counter another person’s “buts.” …But we don’t have a budget for that. Maybe not. Don’t let that deter you! Forecast how much additional student participation is required to offset the costs related to your idea. If you have confidence that the idea can raise participation—go for it. Not confident? Downscale the idea—try it as a pilot for a limited time or take another look at the idea—is there a way it could be adapted that doesn’t have financial consequences? Make sure you exhaust all the options. …But the kids in my school will never eat that. Maybe they won’t—but you, and they, won’t know until you try. Conventional wisdom dictates that it can take as many as 100 tries to reach acceptability. If individually packaged items will help with food safety but raise preliminary alarm in regards to student acceptability, conduct a small-scale trial and test your new menu item with a small group first. Or offer a sample as a free item to all students. If children can let go of being worried that an unfamiliar food is all they have to fill them at lunch, they will be more apt to take a risk and try something new. …But the principal/teachers/custodians won’t let me. Are you sure? Have you asked? Have you asked in a way that shows the benefits of the idea and addresses the concerns that might arise? If you work in an environment that is notorious for the opposition to new ideas, think about creative strategies to get around the naysayers. It might prove helpful to get support from a few key teachers, the student government and the PTA/PTO first. Take their endorsements with you when you pitch the idea. …But I don’t know how. Find out who does know. Start by asking your boss. You are the boss? Then, check with your colleagues working in neighboring districts. Ask around at SNA chapter or state affiliate meetings, or next month at SNA’s Annual National Conference. Contact your state agency. Check back issues of School Nutrition, your state publication or other trade magazines. Look online, including SchoolNutrition.org. Contact SNA and the Institute of Child Nutrition. Use Internet discussion groups, message boards and mailing services to cast a wider net. YOUR TURN? If you feel like you have more questions about HACCP than when you started reading this article, you are on your way to a better overall understanding! That’s because this is a big topic and one question can lead to another and another after that. Simply take it one step at a time and reach out to other school nutrition professionals or community leaders who are also committed to creating a healthy environment for students. You can’t overestimate the positive benefits of food safety and its results!
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