Food Safety Program Based on Process Approach to HACCP

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					Food Safety Program
Based on Process Approach to
           HACCP




         Summer 2011

                               0
       USDA Food Safety
         Requirements
•   Effective July 1, 2005
•   USDA Interim Rule published
    June 15, 2005
•   Final rules to formalize food
    safety requirements published
    on August 8, 2008 form
    comments
                                    1
       USDA Food Safety
        Requirements
Public Law 108-265
1. Request two annual food safety
   inspections for each
   preparation/serving site
   participating in NSLP and/or SBP


                                      2
      USDA Food Safety
       Requirements
Public Law 108-265

2. Public Notification
  • Post copy of most recent safety
    inspections at each
    preparation/serving site
  • Provide copy upon request

                                      3
         USDA Food Safety
          Requirements
Public Law 108-265
3. State/Federal Audits to Assure
   Compliance
   • DPI must report # of inspections to USDA
   • Info is obtained from Schedule A of on-line
      contract
   • “Meals not served” is response if there is no
     meals service at school listed on Schedule A
                                                     4
      USDA Food Safety
       Requirements
4. Implement Food Safety
  Program based on Hazard
  Analysis Critical Control Point
  (HACCP) principles
  • Schools participating in the
    NSLP and/or SBP
  • Guidance issued on June 10,
    2005
                                    5
      USDA Food Safety
       Requirements
Schools with HACCP based food
safety program in place may
retain their current program if it
includes all the HACCP
principles listed in USDA
guidance

                                     6
  Who were effected by regs?
School agencies participating in
 USDA’s NSLP and/or SBP
 926 school agencies (districts & private schools)
 Approximately 2,400 buildings
 DPI’s School Nutrition Team
 DHFS’s Division of Public Health and
  agents
 School Nutrition Association (SNA) of WI

                                                  7
 Wisconsin’s Compliance Plan

Developed by representatives from:
• DPI’s School Nutrition Team
• Department of Health/Agents who
  conduct food safety insepctions
• SNA of WI


                                    8
              Final Rule
• Effective January 14, 2010
• Codifies the food safety plan requirements
• Addresses recordkeeping requirement
• Include food safety program as part of
  state agency administrative reviews
• Extends food safety program requirement
  to school breakfast program

                                           9
               Reauthorization 2010
               HHFKA/ Public Law111-296
• Strengthens existing food safety requirements for
  all FNS programs (NSLP, SBP, FFVP, SMP, plus
  Afterschool Snack & Supper Programs)
• Food safety plan based on HACCP must be
  applied to any facility or part of facility where
  food is stored, prepared or served for FNS
  programs
• USDA anticipates minor updates for meal/milk
  service on school buses, in hallways, kiosks,
  classrooms, or other areas outside cafeteria
• Effective ASAP/n o later than 2011-12 school year
• USDA will develop “practical” guidance
                                                  10
USDA Guidance - June 2005


School Food Safety
Program Based on
Process Approach
to HACCP Principles

                            11
Purpose of School Food Safety
          Program
Ensure the delivery of
safe foods to children in
school meal programs by
controlling hazards that
may occur or be
introduced into foods
anywhere along the flow
of food from receiving to
service – USDA
Guidance
                            12
    What is Hazard Analysis
Critical Control Point (HACCP)?

A scientific and rational approach to
food safety which:
 • analyzes potential hazards
 • determines the critical control points in a
   food process
 • develops monitoring procedures to
   determine if the hazards identified are
   effectively controlled
                                             13
   Why is HACCP the “Gold
  Standard” in food service?
• Foodborne illness outbreaks are major
  financial and public relations cost to the
  food service industry
• Children are vulnerable
• Visual inspections of food product cannot
  detect pathogens
• Documented HACCP controls can prevent
  foodborne illness from occurring

                                          14
  Seven Principles of HACCP
1. Conduct a hazard analysis
2. Identify critical control points
3. Establish critical control point
   monitoring
4. Establish corrective action
5. Establish verification procedures
6. Establish record keeping
                                       15
      Differences Between
     Traditional and Process
            Approach
• Traditional HACCP focuses on recipes
• For process approach:
   – Menu items are grouped into a given
     food preparation process that have
     similar hazards
   – Actions or activities used to prevent,
     eliminate or reduce hazards are similar


                                               16
         Plan for Each
    Production/Serving Site
• Documents menu items in appropriate
  HACCP process category
• Identifies critical control points and
  control measures
• Includes monitoring responsibilities and
  forms to be used
• Establishes and documents appropriate
  corrective actions taken
• Includes records to show plan is
  operational
• Ongoing review and plan revisions
  needed
                                             17
          Nine Steps for Plan
             Development
1.   Describe each preparation/serving site
2.   Categorize menu items as process 1, 2, or 3
3.   Identify critical control measures and limits
4.   Develop and /or adapt prototype Standard
     Operating Procedures (SOPS) specific to site
5.   Establish monitoring procedures
6.   Establish corrective actions
7.   Choose appropriate monitoring records
8.   Provide training
9.   Review and revise food safety program period
                                                 18
     Step 1: Site Description
• Separate plan specific to site
• Include equipment inventory
• Floor plan is not needed for process
  approach
• Description for the individual site plan
  should reflect what is done at
  preparation/serving location
• Same set ups may have same plan
• Obtain assistance from those who prepare
  and serve

                                             19
Step 2: Categorization Process
• Start with school menus (lunch & breakfast)
• Include a la carte items and other items served
  as part of Afterschool Snack Program, Fresh
  Fruit and Vegetable Program (if applicable)
• Complete chart to indicate the category
• Minimize lists by grouping like items
  – Canned fruit
  – Dairy products
  – Purchased bread products
  – Fully cooked chicken products
• Some items to list separately:
  – Fresh melon and strawberries
  – “Casseroles” with various ingredients &
     cooling processes
                                                20
  Process Approach to HACCP

• Categorize all items including:
  – Potentially Hazardous Foods (PHF):
     ■ Egg ■ Meat ■ Dairy ■ Heated
      Vegetables/Fruits
  – Non-Potentially Hazardous Foods:
     ■ aw of 0.85   ■ pH of 4.6   ■ Hermetically
         or less        or less    sealed

• Place * by PHF (T/TC) such as melons &
  strawberries

                                                   21
  Process Approach to HACCP

Group items according to number of times
 the food goes through the “danger zone”
 (41°F. and 135°F.)
• Process #1 – No Cook
  – Menu item is not in the danger zone
• Process#2 – Same Day Service
  – Menu item takes one trip through danger zone
• Process#3 – Complex Food Preparation
  – The menu item goes through both heating and
    cooling, taking two or more trips through the danger
    zone.
                                                       22
Trips through the Danger Zone


   135°F
               0     1      1    2    3




   41°F
           No Cook   Same Day   Complex
                                          23
     Process #1 – No Cook
Receiving → Store → Prepare → Hold →
 Serve



   Sub Sandwich with Ready to Eat Ingredients




                                                24
    Process #2 – Same Day
            Service
Receiving → Store → Prepare → Cook →
 Hold → Serve
• Menu items made from canned, packaged,
  frozen, raw ingredients that involve a
  cook step.
  – Heated canned or frozen vegetables
  – Pizza
  – Fully cooked
    chicken products
                                         25
  Process# 3 – Complex Food

Receiving → Store → Prepare → Cook →
 Cool → Reheat → Hold → Serve
• Menu items with preparation steps which
  may require cooling and reheating prior to
  being served
  – Spaghetti Sauce
  – Turkey and Gravy
  – Hard boiled eggs
  – Heated Leftovers
                                          26
  Step 3: Identify Critical
 Control Points & Measures
Critical Control Point (CCP) an operational
 step in a food preparation process at
 which control can be applied and is
 essential to prevent or eliminate a hazard
Control Measures - any action or activity
 that can be used means taken to prevent ,
 eliminate, or reduce hazards to an
 acceptable level (Refer to flow charts on p.
 9-10 of prototype)
     Critical Control Points
• Points in food preparation/processing
  where controlling a step is essential to
  assure food safety
  – Receiving
  – Cold Holding
  – Cooking
  – Hot Holding
  – Cooling
  – Reheating

                                             28
   Critical Measures in Process
         Approach HACCP
• No Cook:
  – Cold holding or limiting time in the danger zone to inhibit
    bacterial growth and toxin production (e.g., limiting time item is
    at room temperature and discarding items that reach limits.
• Same Day Service:
  – Cooking to destroy bacteria and other pathogens
  – Hot holding or limiting time in the danger zone to prevent the
    growth of spore-forming bacteria.
• Complex Food Preparation:
  – Cooking to destroy bacteria and other pathogens
  – Cooling to prevent the outgrowth of spore-forming bacteria
  – Hot and cold holding or limiting time in the danger zone to
    inhibit bacterial growth and toxin formation
  – Reheating for hot holding, if applicable.
                                                                     29
           Control Measures
.
• Include:
  – CCPs
  – SOPs
• Critical Limits
  – Established for each processes




                                     30
        Critical Limits
The time and temperature ranges for food
preparation and service (either hot or
cold) that keeps food safe.
– Cold holding = 41°F (Maximum)
– Hot Holding = 135°F (Minimum)
– Cooking = Time + Temperature
– Cooling
– Reheating Previously Cooked

                                       31
Critical Measures & Limits
         Process 1
Example: Sub Sandwich with RTE Ingredients

                 General
                  Receive
                   Store
                  Prepare
Critical Measures & Limits
         Process 1
Example: Sub Sandwich with RTE Ingredients

          COLD HOLDING
        Critical Limit: Internal
        Temperature of 41°F
           Check & Record
            Temperatures
               SERVE
 Critical Control Measures &
            Limits
           Process 2
Example: Fully Cooked Chicken Nuggets

                General
                Receive
                 Store
                Prepare
Critical Limits – Process 2
 Example: Fully Cooked Chicken Nuggets

       COOK/REHEAT FULLY
        COOKED PRODUCTS
    Critical Limit: Internal Temperature of
           135°F for 15 seconds
      Check & Record Temperatures
     Critical Limit: Hot hold at no less
       than 135°F.
   Check & Record Temperatures
                  SERVE
Critical Control Measures &
    Limits for Process 2
 Raw Beef for Spaghetti Served on Same Day


                   General
                  Receive
                    Store
                  Prepare
    Critical Limits – Process 2
Raw Ground Beef for Spaghetti Sauce – Served Same
                      Day
      COOK/GROUND BEEF
      Critical Limit: Internal Temperature of
      165°F for 15 seconds
      Check & Record Temperatures
          Critical Limit: Hot hold at no
               less than 135°F.
        Check & Record Temperatures
                       SERVE
    Critical Control Measure
      & Limits - Process 3
Raw Ground Beef for Spaghetti Sauce – Served Next
                      Day


                     General
                     Receive
                      Store
                     Prepare
    Critical Limits – Process 3
Raw Ground Beef for Spaghetti Sauce – Served Next
                      Day

          COOK/GROUND BEEF
         Critical Limit: Internal Temperature of
           165°F for 15 seconds

        Check & Record Temperatures
   Critical Control Measures &
         Limits Process 3
Raw Ground Beef for Spaghetti Sauce – served next day

       Critical Control Point:
        COOL
      Critical Limit: Cool from 135 °F
      to 70°F within 2 hours and
      from 70°F to 41°F or lower
      within an additional 4 hours.
      Check & Record Temperatures
    Critical Limits – Process 3
Raw Ground Beef in Spaghetti Sauce – Served Next Day



      Critical Control Point:
      REHEAT
      Critical Limit: Heat to 165 °F for
      at least 15 seconds.
      Check & Record Temperatures
      Critical Control Limits &
       Measures - Process 3
Raw Ground Beef in Spaghetti Sauce - Next Day Service


        Critical Limit: Hot hold at no less
           than 135°F.
         Check & Record Temperatures
                     SERVE
Critical Control Measure
  & Limits - Process 3
 Turkey Roast (Raw – Served Next Day


               General
               Receive
                Store
               Prepare
Critical Control Measures & Limits
             Process 3
     Example: Turkey Roast (Raw) & Gravy

                  General
                   Receive
                    Store
                   Prepare
    COOK/Raw Turkey Roast
    Critical Limit: Internal Temperature
    of 165°F for 15 seconds
    Check & Record Temperatures
Critical Control Measures &
      Limits Process 3
Turkey Roast (raw) & gravy – served next day

  Critical Control Point:
   COOL
  Critical Limit: Cool from 135 °F
  to 70°F within 2 hours and
  from 70°F to 41°F or lower
  within an additional 4 hours.
  Check & Record Temperatures
Critical Limits - Process 3
 Example: Turkey Roasts (raw) & Gravy


  Critical Control Point:
  REHEAT
  Critical Limit: Heat to 165 °F for
  at least 15 seconds.
  Check & Record Temperatures
Critical Control Measures & Limits
               Process 3
     Example: Turkey Roasts (raw) & Gravy

     Critical Limit: Hot hold at no less
        than 135°F.
     Check & Record Temperatures
                  SERVE
Critical Control Measures &
      Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated
                   Leftover


                   General

                   Receive
                    Store
                   Prepare
  Critical Limits – Process 2
Example: Fully Cooked Chicken Nuggets – Heated
                   Leftover
          COOK/REHEAT FULLY
           COOKED PRODUCTS
       Critical Limit: Internal Temperature of
              135°F for 15 seconds
         Check & Record Temperatures
        Critical Limit: Hot hold at no less
          than 135°F.
      Check & Record Temperatures
                     SERVE
Critical Control Measures &
      Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated
                   Leftover

    Critical Control Point:
     COOL
   Critical Limit: Cool from 135 °F
   to 70°F within 2 hours and
   from 70°F to 41°F or lower
   within an additional 4 hours.
   Check & Record Temperatures
     Critical Limits – Process 3
Example: Fully Cooked Chicken Nuggets - Heated Leftovers


      Critical Control Point:
      REHEAT
      Critical Limit: Heat to 165 °F for
      at least 15 seconds.
      Check & Record Temperatures
Critical Control Measures &
            Limits
          Process 3
Example: Fully Cooked Chicken Nuggets - Heated
                   Leftovers
     Critical Limit: Hot hold at no less
        than 135°F.
     Check & Record Temperatures
                  SERVE
Step 4: Develop/Adapt SOPs
SOPs are written instructions for a food
service task that reduce food safety
hazards. Usually written to include:
– Who?
– What?
– When?
– Where?
– How?
– Why?


                                           53
    Components of USDA’s SOPs
• Purpose (What)
• Scope (Who does this apply to)
• Keywords (New terms)
• Instructions (How, Where and When)
• Monitoring (Why)
• Corrective Action (What to do if there is a
  problem)
• Record Keeping
                                            54
  SOPs Developed by DPI School
   Nutrition Team for Prototype
• Adaptation of USDA’s & Iowa State
  University SOPs
• Include WI Dept. of Health Services Food
  Code Fact Sheets
• Minimized number of SOPs by grouping
  items - examples:
  – No bare hand contact with glove use
  – Manual and Machine dishwashing
• Monitor for critical control points Only
                                             55
 What SOPs Do You Need?
• Address critical control measures
  for process 1, 2 & 3 potentially
  hazardous foods in your
  operation

• Provide food safety foundation


                                      56
   Step 5: Establish Monitoring
            Procedures
• Considerations:
  – What is monitored?
  – How will you monitor?
  – When and how often will you monitor?
  – Who will be responsible for monitoring?




                                              57
    What is Monitored
Critical control measures
Most involve measurements
 involving temperature & time



                &
                                58
            Who Monitors
•   Directly associated with the operation
•   Trained and knowledgeable
•   Accessible to monitoring activity
•   Responsible
•   Specify position and back up




                                             59
  Step 6: Establish Corrective
             Action
• Needed whenever a critical limit is not
  met
• Must be carried out immediately
• Employees must know what is expected
  and how to make right decision
• Determined for all CCPs
• Include summary in each school plan

                                            60
       Corrective Action
Example
 Cooler not maintaining 41°F temperature
 – Is cooler is working properly?
 – Is thermometer calibrated?
 – Report temperature reading to supervisor if
   cooler is not working properly
 – Supervisor contacts service repair person if
   thermometer is accurate


                                                  61
   Step 7: Maintain Records
• Food Safety Plan
• Records to be kept
  – Receiving logs (or make use of invoices)
  – Cold Holding Temperature logs
  – Monitoring (cooking, cooling, and reheating and
    other Critical Control Points)
  – Corrective action
  – Calibration records
  – Training logs
• Documentation of activities provides proof that
  reasonable care was exercised in the event your
  school is implicated in a foodborne illness

                                                      62
   How long must records be
            kept?
• Any combination records that include
  production plans - 3 years plus current
• Monitoring records food safety
  inspections - 6 months
  Recommendation: Keep monitoring
  records for school year to support food
  safety plan and keep two most current
  food safety inspection reports

                                            63
    Step 8: Provide & Document
              Training
• Basic food safety
• Specific to
  Process approach to
  HACCP & the food safety plan
• Annual training schedule
• Documentation of training shows
  there is employee participation in
  plan
                                       64
    Important Competencies
•   Basic food safety knowledge
•   Employee health reporting responsibilities
•   Proper handwashing/glove use
•   Thermometer usage and calibration
•   SOPs
•   Recordkeeping procedures



                                             65
         Helpful Job Aids
• Signage and posters at strategic locations
• Written recipes and daily production
  plans that designating process category
• CCPs in written recipes
• Monitoring logs that includes temperature
  ranges for cold holding, hot holding, etc.



                                           66
   Step 9: Review & Revise Food
            Safety Plan
• Review and revise food safety plan at least
  annually or as often as necessary to reflect any
  changes
• Changes may include:
   –   New equipment
   –   New menu items
   –   Different vendors
   –   New programs
   –   Reports of illness
   –   Comments on a health inspection report
   –   Other factors or changes in procedures.
                                                     67
   Step 9: Review & Revise Food
         Safety Plan, cont.
• Meet HHFK Act of 2010 provision which
  requires review and update for all FNS
  programs
• Consider making appropriate revision to DPI
  prototype SOPs/monitoring logs now listed on
  DPI website for:
  – Breakfast Served in Classroom
  – Milk/juice transported in coolers
  – Prototype transport sheets for lunch, breakfast,
    afterschool care snack

                                                       68
     Food Safety Plan Review
        Food Safety Inspection
• Determine if there is a completed plan for
  each site
  – Accurate Description
  – Menu items categorized by process type
  – SOP specific to food service operation &
    followed
  – Employees understand and follow SOPs
• Select three SOP’s to determine if
  applicable and implemented
• Review monitoring records for three days
  selected at random since last inspection
                                               69
Food Safety Plan Review, cont.
• Are records maintained?
  – Review by choosing 3 random days in
    current school year to verify all records
    kept.
  – Check to see if:
    • Appropriate temperatures are monitored and
      recorded.
    • Records appear accurate and consistent.
• Are corrective actions documented if a
  critical limit is not met?
                                                70
   Food Safety Plan Review,
            cont.
 Is there a Employee Food Safety
  Training Program in place?
 Plans reviewed and updated annually
  and when there are changes?
 Report will be left summarizing results
  of plan review.
 If there is no plan available:
  Must display inspection report that states “no
   plan”.
  Expect follow up – environmental specialist will
   notify DPI.

                                                      71
   Overall Considerations
 Time
 Simplicity
  Make changes in operation to make that possible
    Batch cooking to minimize holding
    Purchase /order fully cooked meat items
    Limit number of process 3 by eliminating cooling step
 Specific to food service operation
 Support and recognition from administration
  & others
 Involvement & Input
 Continuous Improvement
                                                             72
Successful Implementation
    Recommendations
Work with school administration to
develop strong school agency wide food
safety and security policy to cover:
–   School food service
–   Food brought from home
–   Vending
–   Field trips
–   Concessions
–   Use of facility by outside groups
–   Access to the school kitchen
                                         73
Successful Implementation
    Recommendations
1. Required food safety certification for all
   management/supervisory personnel
2. Provide food safety education for all
   employee & students
3. Develop self inspection programs
4. Stay informed about current food safety
   regulations
 Where to direct questions?
Contacts/Resources:
• Julie Shelton(School Program
  Regulation Compliance)
• James Mack (WI Food Code &
  Contact info for DHFS or Agent, &
  Fee Schedule)
• Person who conducts food safety
  inspections
                                      75
Enjoy the Rest of the
      Summer!
                        76

				
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