Don't TrustVerify

HACCP STEP-BY-STEP — PART X

BY CHAR NORTON, RD

Once you have set up monitoring procedures for a HACCP program and identified specific corrective actions to take when there is a failure to meet established critical limits, the next step is to verify that your system is working.

Even the most carefully planned HACCP program must be checked to ensure that procedures are being correctly followed and that established criteria are being met. The "verification and validation" steps determine if further refinement of your HACCP process is required.

Verification describes the process of documenting that all of the methods, procedures, tests and other evaluations in your HACCP plan are taking place the way they are supposed to.

Validation goes further. It is the process of ensuring that HACCP processes are giving the desired result. That is, where verification is a check to make sure procedures are occurring, validation is a check to make sure that the procedures are effective.

Verification is easier to under-stand and more successfully accomplished than validation. At the same time, if you do not validate your HACCP plan, you will have a false sense of security because your plan may be flawed. You may incorrectly believe that you have a safe food system when you may not.

If you verify your system but do not validate it, in the end you may be just as vulnerable as if you did not have a system in place at all. In fact, you may be more at risk because of a false sense of security.

For example, it's a common mis-take to try to cool a product such as a stockpot of soup in a refrigerator rather than using a blast chiller. While the refrigerator will eventually chill the soup, the long time required for temperatures to drop in the center of a large liquid mass can allow bacteria to continue to grow there, resulting in the production of foodborne pathogens and spoilage.

This is an example of a way in which a process can take place tbut which does not give a valid result. The process—cooling the soup— takes place. But the result—cooling of the entire mass of liquid within the appropriate period of time—does not.

This article will discuss verification. Next month we will look at validation.

Verification
As you work to verify your HACCP program, you will develop specific check lists to help you determine if the HACCP system is functioning as designed and that specified procedures are being followed. You will also find it necessary to establish frequencies at which these procedures should take place.

For example, you may decide that three times a day is an adequate frequency for checking walk-in refrigerator and freezer temperatures.

In another situation, you may want to check the temperatures of steam table and display refrigerators every 30 minutes. Such frequencies must be documented as part of your HACCP standards and monitored in the course of your verification audit.

Verification activities include a total review of your HACCP plan and all records; a review of any deviation is those records and the actions taken when deviations occurred; and confirmations that all identified CCPs are under control.

To verify that your system is working, here are some of the common questions to ask:

• Are the critical limits established for each product being met?
• Is sufficient documentation being maintained of periodic revalidations or independent audits that take place?
• If changes occur in any procedures, or as a result of any evaluations and process improvements, are these being adequately documented?
• Are regulatory and self-inspections on file with definitive documentation that corrective actions have been taken?
• Are training records on file for all employees and does the training record include job-specific HACCP training that takes place?
• Are records on file to document employee competency evaluations and, where applicable, employee participation in retraining programs?

Step back and take a look
There are different techniques used to "step back" and look at an entire operation with an eye toward verifying that the HACCP program is working as planned. One technique is to document each step and procedure in a video recording.

Another common practice is to collect random samples of food for microbiological analysis, accompanied by visual inspection of the operation, reviewing the entire HACCP plan with adjustments are all part of the verification process.

If this is too time-consuming for you and your staff to accomplish in your operation, you want to hire a consultant as a "second set of eyes," to observe your HACCP program and make suggestions for changes. Your local sanitarian may also be another resource to assist you in the verification of your HACCP plan. In fact, you may find that your verification process can be combined with periodic audits performed by local heath authorities.

If you decide to do a self verification of your foodservice operation, try to set the stage as if you were the consultant, local sanitarian, or the corporate HACCP guru. (Some suggested actions to take in a self verification program are listed in the side-bar on page 68. Depending upon your operation, you will want to expand on that list.)

Once you have completed your self verification, you will need to prepare a report and discuss the findings with your team as well as your management. You will also need to develop a plan to correct any deficiencies you've identified.

Next month this column will discuss ways for you to set up a record keeping system that will help in the validation process. Several options will be discussed so that you can determine the one that will work best for you.

A basic checklist for HACCP self-verification If you decide to implement a self-verification of your foodservice operation, try to set the stage as if you were the consultant, local sanitarian, or the corporate HACCP guru. This is a basic list of some of the actions to take, but, depending upon your operation, it will often need to be expanded to match a particular facility or production system. Prepare an audit form to use for your verification, covering all areas of your operation. Observe and talk to the employees, ask questions, check for competency. Document your findings. Review menu and recipes to see that they are being followed as written. Check equipment maintenance records and check calibration of equipment especially thermometers and timers. Look at the adherence to the flow charts. Check the time and temperature records for variances of established standards. Scrutinize the cross contamination potential. Go through all monitoring, training, self inspection, production, and product records. Review any corrective action taken when CCPs were not met.

Charnette Norton is vice president of Romano Gatland of Texas, foodservice consultants & planners worldwide, in the regional office located in Missouri City, TX. Presently, she is serving on active duty in Bosnia as part of U.S. Operation Enduring Freedom. Char Norton and Ruby Puckett coauthored the book "HACCP, The Future Challenge—Practical Application for the Foodservice Administrator."