HACCP implementation in the United States
5.2 Setting up the HACCP system
HACCP design impacts greatly on the future success or failure of the program.
However, before designing HACCP systems, companies must ensure that responsibility for HACCP rests on the shoulders of those who are primarily responsible for the business. In other words, food safety must be integrated into the company’s culture if any hope of setting up and managing an effective HACCP system is to be realized. The best way to drive changes in company culture is to give overall accountability to a senior company person.
Table 5.1 Summary of each business and the principal hazards of concern
Business Principal hazards
Meats/poultry/eggs Pathogens, metal, bone
Oilseeds Pesticides, Salmonella
Corn wet milling Mycotoxins, pesticides Flour milling Pesticides, metal, insects
Salt Metal
Juice Patulin, pesticides, E. coli O157:H7
Peanuts Pesticides, aflatoxin, metal
Malt Vomitoxin, metal, Salmonella (food malt)
5.2.1 In the beginning
Cargill’s success is built on a reputation for providing high quality products at fair market value and company businesses have always had quality control systems in place. In the late 1980s, however, times were changing. Foodborne illness outbreaks were increasing in magnitude and publicity. E. coli O157:H7 had just recently arrived on the scene as a significant foodborne pathogen.
Listeria monocytogenes was on the rise world-wide, having caused recent outbreaks in Europe and the USA. Cargill was also changing its vision for the future to become a more value-added company and realized that a more formalized approach to food safety was needed. In 1990 senior managers at Cargill appointed Dr Austen Cargill to establish a corporate food safety department for the company. Cargill senior managers had the foresight to know that a high level of commitment was needed to make food safety work properly, similar to the personal safety systems that had been established 20 years earlier.
The Corporate Food Safety Department mission was to set policies and provide guidance to each business. This strategy translated into a small core group of technically trained individuals and one lawyer to provide support for interpreting food laws. The responsibility for food safety implementation rested on the business leaders’ shoulders. This organizational structure and philosophy set the stage for food safety implementation in Cargill.
The first department task was training for the central Corporate Food Safety staff. In 1990, formal food safety programs were fairly new to most of the food industry. Although there were a few seminars and articles on food safety, most of the help came from consultants familiar with HACCP. One consultant, Dr Howard Bauman, affectionately referred to as the ‘father of HACCP’, had just retired from Pillsbury and was willing to provide guidance, especially in the area of hazard analysis. Another couple of key consultants were Dr Bill Brown and Dr Dave Theno, both of whom taught HACCP courses and helped review plans for about six months until the Corporate Food Safety staff were sufficiently trained. The main point here is that the best way for a company to get started is to enlist help from a knowledgeable person or organization. During this training period, the mission and goals of the department were more clearly defined into policies for all businesses in the company. Training for senior managers was also conducted in order for all high level managers to understand basic food safety concepts and what it takes to make HACCP successful.
5.2.2 The corporate implementation plan
The overall model used to implement HACCP into the company is shown in Fig.
5.1. Equal emphasis was placed on both prerequisite programs such as GMPs and HACCP. Cargill realized that food safety systems were valuable for all foods, not just perishable ones. However, implementation into all businesses at the same time was impossible. Based on past experiences and potential human health risks, businesses were prioritized for HACCP implementation as shown in Table 5.2.
5.2.3 The business implementation plan
Businesses chosen to implement HACCP were tasked with the responsibility of organizing these efforts with help from Corporate Food Safety. It is important for business leaders to believe in HACCP and drive implementation in their processing plants. The business first established a business team, which included the business operations manager, quality assurance (QA), sales, transportation, engineering managers and a Corporate Food Safety person to provide guidance.
A cross-functional team covering all aspects of the business is critical because food safety responsibilities fall on each of these departments. One central person was chosen to lead the business team. This person was required to have good
Fig. 5.1 HAACP implementation model.
Table 5.2 Business priority for HACCP implementation
Business Time frame (year for implementation)
1. Meats/poultry/egg businesses 1
2. Soy protein business 1
3. Malt business 2
4. Flour milling 2
5. Corn milling 2
6. Juice 2
7. Peanuts 2
8. Oilseeds 2
9. Salt 3
technical knowledge and people skills. Most of the time, the key lead was the business QA manager, but sometimes it was the operations manager.
The business needed to accomplish two goals: implementing HACCP and standardizing GMPs. Two options were identified for accomplishing HACCP implementation. The first option was to bring key members from all plants in the business together to train and develop HACCP programs that could then be taken back to all plants at once. The benefit to using this approach is that implementation can be done quickly and efficient cross-communication between managers allows for more standardized programs between plants. The disadvantage, however, is that HACCP plans can become too generic, and without input from other members of the plant team, buy-in becomes difficult.
The second option was to assemble key members at each plant and introduce HACCP to one plant at a time. This approach allows the HACCP plan to be tailored to the needs of each plant and achieves greater buy-in from plant employees. The only disadvantage is that the process is slower and cross-communication between locations is harder to achieve, resulting in diverse plans between plants that are producing the exact same product. In the end, most Cargill businesses chose the second option as the means for HACCP implementation which, in retrospect, was the right choice.
The second business goal was to develop standardized GMPs. Although most plants within a business had similar GMP requirements, they were not the same between plants and quite often not formally managed. It was decided that basic prerequisite GMP programs needed to be standard for all plants in each business in order to lay a solid platform for HACCP. While HACCPs were being written at the plant level, GMP/prerequisite program requirements were being standardized at the business team level. The draft GMP program was sent out to all plants for review and comment and then finalized over roughly a six-month time frame. Standardized GMPs included personal hygiene, sanitation, pest control, water control, air control, recall, labeling, maintenance, rework procedures, purchasing and transportation. To raise the importance of GMPs as a foundation for HACCP, a more formalized process of managing GMPs was also implemented, using a HACCP management framework. The process for development of both HACCP and GMP systems is shown in Fig. 5.1. For simplicity’s sake, only the HACCP portion of the model will be discussed in more detail.
5.2.4 The individual primary conversion facility implementation plan After Corporate Food Safety and the business determined the strategies for implementing HACCP, real efforts began to make HACCP come alive in the plant. Figure 5.2 shows the basic steps that were followed. The first step involved formation of a plant Food Safety Committee, a cross-functional team quite similar to the business team. This team normally consisted of the plant manager and someone from engineering, transportation, QA, a plant microbiologist (if available), the business food safety coordinator and a
representative from the Corporate Food Safety Department. A plant food safety coordinator was chosen to lead local HACCP implementation efforts. Usually this person was the plant QA manager. It is important to note that the plant food safety coordinator was not responsible for doing all the work. Instead, this person organized meetings and followed up to ensure that all work was being done. The plant Food Safety Committee then participated in a two-day on-site HACCP training course led by Corporate Food Safety, with help from the business food safety coordinator. Being able to conduct in-house training is a big advantage for a large company because courses can be tailored to a specific need and many employees can be trained at one time. This is much more effective than sending one or two people to an outside course. During this two-day event, all products made using a common process were grouped together, for example, all ground beef products. Most processing locations ended up with one to five processes. The plant Food Safety Committee then chose one process group and started writing the first HACCP plan.
The hazard analysis phase usually took the most time to complete, but it was important that all potential hazards were considered. Open discussion must be encouraged during hazard analysis and, in the end, all potential hazards should fall into one of four areas:
Fig. 5.2 Processing plant HACCP development model.
1. Controlled or minimized by CCPs.
2. Controlled or minimized by GMPs.
3. Considered to be of such a low risk that no control is needed.
4. Designed out of the process.
This last option is not always considered but can be the best way to eliminate hazards. As an example, during a hazard analysis for chicken slaughter, one team member pointed out that when bins were dumped into a vat, water from the wheels of the bin could drip down the side of the bin and get into the food, increasing the risk for pathogen presence. The best solution was to modify the bins to prevent water from dripping into the product. The potential hazard was engineered out of the process and therefore no formal control was needed.
Quite often, potential hazards were minimized by the presence of several GMPs and therefore no CCP was needed. This is an important point because although GMPs cannot substitute for a CCP, collectively they can minimize the potential for hazards to occur, thus eliminating the need for a CCP. Sanitation is a good example for Listeria control. It is well known that Listeria monocytogenes is commonly found in meat and poultry processing plants and that sanitation programs are the best means to control it. Generally, there is not one sanitation step by itself that is critical for Listeria control. All sanitation steps on all equipment and environmental sources are equally important. The collective pieces of a sanitation GMP minimize the potential for Listeria to occur, so a CCP after a kill step is rarely needed.
Generally, the plant Food Safety Committee completed the first HACCP plan over a three-month time frame. The plant manager and plant food safety coordinator then conducted a general food safety session for all employees to explain the HACCP plan and why it was important to the employees and the company. In addition, specific training was given to employees with CCP responsibilities. Training was generally conducted over two weeks. After training was completed, the HACCP plan for a particular production process was implemented and the group started on the next one in order of priority.
5.2.5 Resource management
Many companies wonder about the cost of implementing HACCP systems.
Quite frankly, the cost is based on how well the business has been run prior to HACCP. A previously well-run business will meet 80–90% of all HACCP needs. In this situation, the majority of costs are related to training, document modification, and capital improvements to the facility. Very seldom are additional people required unless the business is large or complex.
In 1990, when the Cargill Corporate Food Safety Department was established, the director of food safety was equivalent to a business president.
Two corporate food safety coordinators guided businesses through the process and one administrative support person was added to tie everything together. In 1991, the budget for the fledgling department of this $45 billion company was
less than $500,000 per year. At the business and plant level, no full-time people were added. Instead, responsibilities for implementation were added to existing positions. HACCP was seen as a normal part of doing business. Money was allocated on an as-needed basis to correct facility and equipment problems that were identified during hazard analysis, HACCP, or GMP implementation. Over the last ten years Cargill has spent millions of dollars in redesigning/upgrading facilities. No formal process has been established to track spending, because quite often expenditures to improve a process result in production benefits as well as food safety benefits.