HACCP: A Guide for the Independent Operator
If you're an independent restaurant owner, the acronym HACCP (Hazard Analysis and Critical Control Points) might make you think of big institutions like hospitals, prisons, and universities. You may picture mounds of paperwork, clipboards, charts, graphs, and statistics. You may understand that HACCP plans have proven time and time again to improve establishments' abilities to protect their customers from illness and reduce product waste, but you may also think that drafting such a plan for your own small operation would require bringing in expensive consultants to conduct time-consuming analysis. This guide aims to show you that implementing a HACCP plan is likely much simpler than you realize.
"Rather than responding to a foodborne illness when it occurs, you can prevent it by taking active steps to eliminate, prevent, or reduce to an acceptable level food safety hazards that cause someone to be sick or injured."
The information presented here is adapted largely from Managing Food Safety: A Manual for the Voluntary Use of HACCP Principles for Operators of Food Service and Retail Establishments, published as a joint effort between the U.S. Department of Health and Human Services, the Food and Drug Administration, and the Center for Food Safety and Applied Nutrition. That document sums up a HACCP plan's core benefit as follows: "Rather than responding to a foodborne illness when it occurs, you can prevent it by taking active steps to eliminate, prevent, or reduce to an acceptable level food safety hazards that cause someone to be sick or injured." HACCP is about putting together a plan by which you'll monitor your procedures for risks and determine how best to prevent those risks.
As you review these best practices, please understand that the information presented here is intended to serve as guidelines only. The Managing Food Safety manual itself reassures operators that "the implementation of 'textbook' HACCP is impractical in most retail and food service establishments." Rather than establish a rigid, "by-the-book" HACCP plan, you, as an independent operator, should strive to draft a plan that you're confident your team can follow. Think of a HACCP plan the same way you'd think of a personal diet or a fitness plan: The best HACCP plan is one that you can stick with indefinitely. Regardless of how simple your plan is, any HACCP steps you do establish are likely to be worth the effort.
What HACCP Isn't
Before we jump into explaining how you can draft your own HACCP steps, let's first debunk some of the misunderstandings shared by many people.
HACCP isn't a legally-binding program. Instituting a HACCP plan in your establishment doesn’t bind you to any legal obligations, and any procedures you choose to adopt are completely voluntary. A HACCP plan only serves to benefit your establishment, your staff, and the customers you serve.
HACCP isn’t a government program. Although HACCP was developed with the involvement of government agencies, and a version of HACCP best practices is maintained by the FDA, there is no government agency responsible for regulating or issuing the dos and don'ts pertaining to any HACCP plan you choose to adopt. How you choose to implement a HACCP procedure is entirely up to you. No agency has jurisdiction over the procedures outside of what is already covered by the Health Department and food safety laws.
HACCP isn't a rigid structure. Each individual establishment's HACCP plan will be as unique as its menu and clientele. There is no one-size-fits-all approach to HACCP. Rather, each plan must be tailored for the organization it's designed to serve. You and your team have full control over what your HACCP plan will and will not cover.
What HACCP Is
Now that we've debunked a few common HACCP myths, lets spend some time understanding what HACCP is and what benefits it could bring to your establishment.
HACCP is intended to serve your establishment, not the other way around. A HACCP plan is not well-designed if it takes a toll on your staff's productivity. Your HACCP plan is designed to meet the individual needs of your establishment, and any extra duties that it creates should fit neatly within your day-to-day workflow.
HACCP is a way to prevent product waste. You'll find that many of your HACCP steps involve storing and holding food in ways that keep it safe and fresh. That's almost guaranteed to help reduce waste by preventing food from becoming spoiled or contaminated. HACCP procedures naturally lead staff to handle products with more care.
HACCP is a way to protect your guests. The core goal of a HACCP plan is to prevent hazards from making their way into the food that ends up on customers' plates. When your procedures are guided by a HACCP plan, you'll have the peace of mind provided by knowing you've taken every precaution to protect your guests' wellbeing.
HACCP is a team effort. A HACCP plan works best when you involve stakeholders from all positions and levels in your operation. The Managing Food Safety manual recommends assembling a HACCP team that includes managers, as well as cooks, servers, hosts, and members of the utility crew. Each member will have his or her own valuable perspective and concerns to bring to the team.
HACCP has the potential to improve your health scores. HACCP is designed to make your procedures safer, so it's likely to naturally make your restaurant cleaner. A well-implemented HACCP plan can help correct some of the violations that may prevent you from earning a perfect health score.
Nine HACCP Steps
Developing a HACCP plan involves nine steps. Here, we'll describe each of those using practical examples you and your staff are likely familiar with.
1. Develop prerequisite programs
A HACCP program will not be an end-all solution to your food safety concerns. A number of "pre-requisite" best practices should be in place before you can expect your HACCP plan to be effective, but a safety-focused foodservice team will likely already have these procedures in place. Here are a few examples of HACCP prerequisite programs and best practices that will support your efforts. Pages 24 to 26 of the Managing Food Safety manual list several more of these programs.
- Enforce staff hygiene procedures. Hopefully, your staff members are already trained to wash their hands at the appropriate times and according to the procedures outlined in the FDA Food Code. You should also encourage them to stay home when they're sick to avoid spreading illness.
- Establish sound inventory practices. Staff members should be in the habits of checking the expiration date on every package of food they deal with and following effective labeling procedures for products they put in containers themselves. It's also essential that the staff be trained to practice first-in, first-out inventory management to ensure products are being prepped and served in the order in which they're received.
- Use color-coded supplies. Central to most HACCP plans is the prevention of cross-contamination between raw and ready-to-eat foods, which often occurs when tools and surfaces are shared to process food groups without being properly cleaned. It pays to invest in systems that help eliminate the opportunities for that cross-contamination to occur.
2. Group your menu items/products
The second step in drafting a HACCP plan involves grouping each of your products into one of three categories based on how it's received, handled, and cooked, and what state it's in during each of those phases. The Managing Food Safety manual summarizes this step as understanding the flow of food through your establishment.
A key to understanding this categorization process and why it’s important is to recognize how many times each food passes through the "danger zone," which is the range of temperatures between 41 and 140 degrees Fahrenheit in which pathogens multiply rapidly. Understanding which of these three categories each menu item falls into will help you understand how it should be treated in the proceeding steps.
Food that falls into process one is received, held, and served in an uncooked state. Food in this category includes salad greens, fresh vegetables, and pre-sliced, ready-to-eat sandwich meats. These foods should never pass into the danger zone; rather, they'll remain chilled until they're served.
Category two includes foods that are received raw and then served on the same day they're cooked. Foods in the second category include hamburgers, broiled fish, and steamed vegetables. These foods pass through the danger zone only once as they're being cooked.
Category three includes foods that involve complex preparation procedures in which they'll undergo multiple heating and cooling cycles. This includes foods like soups, sauces, and chili that are cooked in big batches, chilled for holding, then reheated prior to service. These foods pass through the danger zone multiple times.
|Process #1: Foods with No Cook Step||Process #2: Foods Cooked for Same-day Service||Process #3: Foods with Complex Prep|
|Fresh vegetables||Scrambled eggs||Sauces|
|Sliced sandwich meats||Broiled fish||Chili|
|Sliced cheese||Steamed vegetables||Taco filling|
|Tuna Salad||Steaks||Egg rolls|
3. Perform a hazard analysis
The third HACCP step involves identifying hazards. This is the "Hazard Analysis" part of the acronym and it involves going step by step through your restaurant's day-to-day procedures and identifying points at which a potential hazard may be introduced. The FDA's five "foodborne illness risk factors" can help you understand what a hazard looks like: Food from unsafe sources, inadequate cooking, improper holding temperatures, contaminated equipment, and poor personal hygiene.
It's helpful to analyze the flow of a particular item through your restaurant from the moment it's received until it's placed in front of the customer. This analysis phase should put a particular emphasis on the moments where food is allowed to enter the danger zone covered above. Any point along a product's lifecycle where it might enter that danger zone should be noted as a potentially hazardous one.
Let's look at each step in the lifecycle of a particular product. We'll use the example of a chicken dish that's received in a raw and refrigerated state, then held until it’s cooked and served to highlight how HACCP principles apply to each step.
- Receiving: While it's impossible to know for sure how the chicken was handled before it arrived at your door, your proper due diligence begins with receiving goods from reputable vendors that you trust. When the item arrives, verify immediately that it is at a safe temperature. An infrared thermometer is an easy way to check the surface temperature of a received product. Your five senses can help you look for other signs that hazards may be present in this step. Look for signs like unusual odors and pools of liquid that indicate the product has risen above that temperature on its journey to your restaurant.
- Storage: As soon as you've verified that your received chicken in is good condition, it should be taken to the appropriate storage facility, whether that be a walk-in cooler or a reach-in refrigerator or freezer. Your HACCP plan should include a step to keep an eye on that equipment's internal temperature. It's a good idea to record the measured temperature of that equipment hourly to verify that the food it holds doesn't leave the safe temperature zone. Hazards in this step include the risk of equipment failing and allowing food to enter the danger zone.
- Preparation: The chicken in question should only be handled by trained staff members who know to take all the proper precautions when they prepare the dish - including to only let the food come in contact with clean tools and surfaces, and to clean and sanitize those once preparation is complete to avoid cross-contaminating subsequent products. Cross-contamination is the greatest food-safety hazard during this step, and this is where the color-coded tools we mentioned in the pre-requisite programs section will come into play.
- Cooking: When it's time to cook the chicken, staff should know what internal temperature the product needs to reach before it can be deemed safe for consumption. The cook responsible for this step should know how to use a thermometer to verify that the chicken has reached the proper temperature. The hazard here is sending the chicken to be served before it has reached the proper internal temperature.
- Serving: Once the chicken has finished cooking, it's time to plate and serve the product. The major hazard to threaten the product during this phase is cross-contamination from dirty tools, hands, or surfaces.
4. Implement control measures in prerequisite programs or at critical control points and establish critical limits
The fourth step in drafting a HACCP plan is to identify the "critical control points" at which the potential hazards discovered in step one can be prevented or controlled. These are points in your procedures at which staff can take specific actions to eliminate hazards or reduce them to acceptable levels.
HACCP best practice guides place an emphasis on the "critical" part of critical control points. A control point is critical only if it can be considered "absolutely essential" that this point be controlled, meaning that the hazard it seeks to eliminate won't be eliminated somewhere further along in your documented procedures.
An example of a critical control point in the chicken-cooking process outlined above is the step at which the chicken is cooked to its safe temperature. This step should be considered critical because it is the last point along the flow of that product to the customer at which any bacteria present in the chicken will be killed. The cook must verify that the product reaches its safe temperature before it's served.
You must also establish critical limits for each control point defined in this step. Critical limits are defined as "parameters that must be achieved" before a hazard can be considered to be controlled. Each limit must be "measurable and observable." Back to the chicken example, the critical limit is that the product must reach the FDA-recommended internal temperature of 165 degrees Fahrenheit. Any temperature under that limit should be considered unsafe.
The Managing Food Safety manual contains a long list of critical control points for each phase in the food product life cycle. Be sure to review those before you begin the process of developing your own plan.
5. Establish procedures to monitor Critical Control Points
HACCP principle five involves establishing procedures to monitor the critical control points established in step four. Since each of those points is paired with a measurable and observable critical limit, it's easy to determine what should be monitored. The majority of the work involved in this step will involve determining how each limit will be monitored.
Your HACCP step five should establish which members of staff are responsible for monitoring which control points and which tools they should use to do so. You may choose to designate managers to monitor certain points and kitchen staff to monitor others. You'll also have to decide how often each point will be monitored.
Returning to our chicken example, the HACCP team may choose to designate a cook to occasionally check the temperatures of several pieces in a batch of chicken. This step would require that the cook know how to use a properly-calibrated thermometer and to understand what critical limits he or she is observing for. Should that individual observe a temperature that falls outside of the established limits, he or she will need to know which corrective actions to take, which we'll explore in step six.
6. Establish corrective actions
Step six establishes in specific terms what actions should be taken if any critical control point is observed to fall outside of its acceptable parameters. In our chicken example, an appropriate action to correct a temperature below the critical limit would be to continue cooking the product until it reaches the appropriate food-safe temperature defined in the control point's critical limits.
Other control points may necessitate more involved corrective actions be taken. For example, it may be necessary to discard food when its temperature was observed or believed to have risen outside the window deemed safe by the critical limits established for any relevant control points.
Each time a corrective action is taken, your HACCP team must assess whether any changes should be made to the HACCP plan to avoid similar incidents in the future. The team member(s) responsible for executing that corrective action should be sure to follow any record-keeping procedures as per step nine.
7. Establish verification procedures
The seventh step in drafting a HACCP plan is to establish a verification procedure by which you'll regularly monitor and verify that the plan is being executed properly. This step should be performed by a person other than the one in charge of carrying out the procedure being verified. Using our temperature verification example from step four, you may consider assigning a member of your wait staff to observe how that control measure is executed.
The observer should ensure that the responsible party is carrying out his or her action according to the established HACCP plan. This step is likely to reveal opportunities to improve the plan, clarify instructions, and improve staff training procedures. It will expose any inconsistencies or gaps within the HACCP plan and help you identify room for improvement.
8. Establish record-keeping procedures
The eighth major HACCP principle involves record keeping, particularly in regards to logging where control points fall outside of their critical limits. Documenting those instances and what corrective actions were taken will help you identify trends and gaps in your HACCP plan. These records can prove vital to drafting new procedures and improving your training program.
Any records you're currently keeping, especially when they're part of the pre-requisite programs described above, can be folded into your HACCP procedure. Any step during which you record the temperature of a product, for example, is useful HACCP data to maintain. Equipment calibration records should also be folded into your HACCP records, since they show that the other records and actions you are taking are accurate.
As with the HACCP plan itself, the best record-keeping procedures are the ones that you can stick with and won't put an undue burden on your HACCP team. You'll find it's not necessary to record every piece of data pertaining to your HACCP program. Rather, you should choose to record the data that keeps your program on track.
Health inspectors appreciate the ability to see written records. It shows them that you take food safety seriously. Keep in mind, though, that inspectors can't rely on records to validate that you're in compliance. Likewise, no records can be used to cite a violation of the health code. In the event that litigation is ever brought against your company, a robust set of records will prove that you've taken all the proper steps to prevent hazards from affecting your customers.
9. Conduct Periodic Validations
A HACCP plan serves no purpose unless it can be shown to work. That's where the ninth HACCP principle of periodic validation comes in. This becomes especially important when any of the following events occur:
- You add a new product to the menu.
- You install a new piece of equipment.
- You begin to receive a product from a new vendor.
Many operators choose to validate their plans once a year regardless of whether an above event occurs. Validation involves reviewing the plan to see if all critical control points are still relevant and whether new points need to added. Critical limits should be reviewed to validate whether they're realistic and complete.
HACCP validation may be performed entirely by your internal team or with the help of an outside consultant or health inspector. The latter approach provides opportunities to receive feedback and suggestions from other industry professionals about how your plan can be improved and streamlined.
The Managing Food Safety manual includes a validation worksheet to make the process simple. It's written in the form of a flowchart that will guide you through each step in the process and indicate what actions should be taken for each.
Additional HACCP Resources
We hope that this overview of how to write a HACCP plan can help you feel more optimistic about implementing a one of your own. Here are a few more resources for information on HACCP.
- North Carolina Restaurant and Lodging Association HACCP Information. NCRLA.org.
- How to Implement a HACCP Program in Your Restaurant Greg McGuire. foodservice.com.
- HACCP Plan vs. Health Inspection Jonathan Deutsch, Ph. D. Restaurant Business Online.
- A Food Safety Focus: Jack in the Box Foodservice Equipment & Supplies. Lisa White. Feb. 28, 2006.
- NYC Department of Health Food Protection Training Manual. New York City Department of Health and Mental Hygiene.