Is It Time for Retail HACCP?
By Sharon P. Wood, M.Sc.
In my opinion, it is past time. The retail grocery store and foodservice establishment has changed over the past 20 years. Retail in the U.S. has evolved to where it is today due to many factors. From discount to big box stores—and from mail-order businesses to mom and pop stores to large chains to online retailing—the retail industry has transformed significantly. The fact is that many of us in retail have been using the basic principles of Hazard Analysis and Critical Control Points (HACCP) for many, many years without knowing it.
Retail establishments, unlike your classic manufacturing facilities, are not routinely built for standardized work. Retailers face unique challenges with regard to process control. Some of these challenges include a broad range of employee educational levels, communication skills, language barriers and turnover rates. Retail is also known for its high rate of change over time to ensure competitiveness in the marketplace. Being diversified for the consumer base can be a competitive advantage, but this also presents challenges in providing adequate controls for high-risk food preparation processes. Production techniques are highly variable and continue to change. Suppliers, ingredients, manufacturers, specifications and menu items change frequently.
Retail grocery stores are more complex than ever before, offering a plethora of fresh, made-in-store food products. What this industry faces is how to manage these “manufacturing-like” processes in a way that prevents hazards from occurring. Retail foodservice operations also struggle with changing menus, ingredients and sustained employee knowledge and execution. These challenges can be managed well, and the more progressive retailers have found a way to do this very effectively.
Hazards in the Retail Environment
The basic hazards stated by classic HACCP include biological, physical and chemical issues that can cause food to be unsafe. These hazards must be controlled by a strong food safety management system; left unchecked, they could result in serious brand damage or financial ruin for the business.
Biological hazards include pathogenic bacteria, parasites and viruses. These can be controlled with a farm-to-fork approach to preventive actions. Physical contaminants such as metal, packaging materials and glass are just a few of the potential hazards that can be inadvertently introduced into food preparation areas. Strong personal hygiene plans and preventive maintenance strategies are good controls for these types of hazards. Chemical contamination can include food additives, unlabeled allergens and cleaning compounds. Proper storage of cleaning supplies and strategic management of raw ingredient suppliers can significantly reduce these risks.
Foodborne illness risk factors must also be considered. During food preparation, the risk of cross-contamination is high if solid controls and processes aren’t in place. With their tight allocation of floor space, retail environments may not provide much room for raw and ready-to-eat segregation. Without proper controls in place, this can raise the risk of introduction of harmful bacteria onto food contact surfaces and finished product. Other contributing factors are poor personal hygiene, inadequate cooking, improper holding temperatures and contaminated equipment. To reduce the occurrence of these risk factors, the U.S. Food and Drug Administration recommends active managerial control, a preventive approach with procedures in place for risk factor control that includes a continuous system of monitoring and verifying that the procedures are working.
During the past decade, retail food establishments have introduced specialized food processing-type operations such as curing, acidification and reduced-oxygen packaging using sophisticated technologies and equipment, which requires stricter operational procedures to mitigate potential exposure to significant health risks.
To remain successful, retailers today must not only adapt to the advances in retailing, but also implement solid processes to provide active managerial control of high-risk activities. HACCP can provide a reliable road map as well as principles to guide processes and standards. By doing this, a retailer can take a proactive role in ensuring that the food or products it sells are high quality and safe.
Mitigating Hazards with HACCP
So how does HACCP apply at retail? Basic HACCP is centered on some key principles that can be easily applied in various ways to a retail setting:
Principle 1 — Conduct a Hazard Analysis
Identify your potential hazards and evaluate them based on severity and likelihood of occurrence. Once this is accomplished for your specific processes or production schemes, decide what your control measures will be.
Principle 2 — Determine Critical Control Points
Where in your process can hazards be controlled? Probably only a few points are CCPs, where loss of control would result in the production of a potentially unsafe food product.
Look to see where such hazards can be controlled. These points would be called Control Points: a Good Manufacturing Practice (GMP), Good Retail Practice (GRP) or a Standard Operating Procedure (SOP). A CCP would be a point, step or procedure where control can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable levels.
Some of the common operational steps used in a retail and foodservice facility include receiving, storing, cooking, cooling, reheating, hot and cold holding, packaging, serving and selling. Each of these key steps should be evaluated for where control measures can be implemented to reduce risk and provide a safe product.
Be sure to use a solid decision tree process to determine your CCPs. Look at the overarching processes in your food preparation areas. Subsequent steps in the process may be more effective for controlling a hazard. More than one step may be involved in controlling a hazard, and a hazard may be controlled by a specific preventive measure.
Principle 3 — Establish the Critical Limits
This is usually the maximum or minimum value where a hazard must be controlled to prevent, eliminate or reduce it to an acceptable level of occurrence. This can often be a CCP. Examples would include proper pH of finished products, cooking temperatures, cooling processes, etc. These critical limits should be easily referenced by retail foodservice workers so that they are aware of the targets and any allowed variances.
Principle 4 — Establish Monitoring Procedures
Monitoring procedures are observations and/or measurements to assess whether a CCP is under control. These must be accurate and readily producible in the case of a regulatory investigation. Visual observations are an important type of continuous monitoring. Written or electronic records are also a must. Personnel must be properly trained on what corrective actions must be taken if the measurements are out of tolerance. You should be able to make rapid and viable adjustments to have continuity in the food preparation process or to make decisions on product disposal if warranted. Likewise, your managers in all areas should be aware of record keeping and do routine record reviews to identify trends and take action for process improvement where warranted. Random checks by leads or management can really pay off in the long run.
Principle 5 — Establish Corrective Actions
A root-cause analysis must be completed to understand the true cause of a noncompliance issue. Once the root-cause analysis is determined, proper corrective action can be implemented to permanently address it.
Principle 6 — Establish Verification Procedures
Verification is a process that establishes the truth and reality of the issue. This activity can determine the validity of your food safety process and compliance with your programs. Taking a product sample and reviewing procedures around data management, records and processes are both verification-type procedures.
Principle 7 — Establish Record-Keeping Procedures
We’ve all heard it: “If it isn’t written down, it didn’t happen.” Keeping records is important to understanding repeat issues and a deeper problem. Processes can be adjusted if proper trends are managed and understood. Use your data! Records can provide history, traceability and evidence when questions arise regarding processes. Examples of records include equipment calibration, temperature monitoring, receiving logs, material safety data sheets, employee training records, SOPs, GMPs, ingredient or finished product specifications and any verification or validation of your processes.
HACCP Is Part of the Overall Food Safety Management System
HACCP is not a stand-alone program. HACCP systems must be built upon a firm foundation of compliance with current GRPs and SOPs. SOPs are procedures used to accomplish the overall goal of maintaining GRPs. GRPs and SOPs directly affect the retail environment and should be considered prerequisite programs to HACCP or any food safety management system. When GRPs and SOPs are in place, HACCP can be more effective because it can concentrate on the hazards associated with food or preparation activities and not on the retail environment or maintenance of facilities.
Solid prerequisite programs must be in place to build a secure foundation for applied HACCP-based food safety management systems. Included in the list of retail prerequisite programs are a solid employee training program, good basic sanitation, allergen management, temperature control and records, recipe/process instructions, first-in/first-out procedures, personal hygiene standards, integrated pest management, chemical management program, preventive maintenance plans and other SOPs.
Quality management systems are also quite novel for the retail industry but in fact can provide a unique approach to standardized work. This approach can use systematic thinking, transparency and diagnostic discipline to assist you with the continued reduction of food safety and quality problems. These systems can provide elements to your program such as organizational structure, data management approaches, resource management, customer satisfaction, continuous improvement, product quality, sustainability, transparency and independent audits as well as a process for corrective and preventive action. These are all sound approaches to building solid prerequisites and foundations for HACCP and your food safety management program.
Retailers should not fear using the basic HACCP principles. In fact, implementation of “textbook” HACCP is impractical in most retail and foodservice establishments. HACCP provides a sturdy road map to address risk and build a solid food safety management system, but not all of the standard HACCP language may apply to the retail setting. With this said, you can bet that it does provide the necessary tools to a common-sense approach for identifying and controlling risk factors. You must recognize that the implementation of HACCP principles varies as much as the products in the retail environment. It is also important to realize that HACCP has no single correct application. In fact, that’s the beauty of HACCP. It’s a map that provides many routes to the implementation of a variety of sound food safety management systems that can be sustained and consistently executed.
There are innovative ways to insert HACCP-based principles into specific parts of your retail operation. Take in-house, customized certification for high-risk processes. You can design your certification using the HACCP approach and provide strong training for your employees, standards for your processes and rules for facilities that house these higher-risk processes. Sustaining these certifications can lead to expanded applications in other areas of your business.
At the end of the day, food safety should be “just the way you do things” across your establishment. It should be integrated into your operation just like any other action you take to run your business.
Retail HACCP: Its Time Has Come
So back to the first question: Is it time for retail HACCP? HACCP has been around for more than 50 years and has been proven time and time again as a way for food manufacturers and handlers to establish a high level of control over product safety. HACCP is a logical and thorough process control system designed to identify and control hazards. Isn’t that what every retailer wants? HACCP also focuses on prevention and control of food safety problems and on specific, highly “controllable” points in the process chain. All retailers want to head off problems before they occur to protect their customers and brand.
Using HACCP as a template for approaching risk in your operations can provide a sound and proven system for risk reduction. Many progressive retailers have already figured this out and have been using the basics of HACCP for many years as a footing for more robust food safety management. With new regulatory scrutiny on retailers, it is important that the industry trains its employees and educates its management on the fundamentals of running a food-safe environment. HACCP can provide a strategy and serve as a guide for novices. I recommend basic HACCP training for all retail personnel handling food products as a start. Don’t forget those who are designing your facilities, maintaining them and procuring your equipment. These people assist in building processes and products. They need to understand the risks involved.
So how do you get started? Start with the basics. Master Sanitation, basic food safety and basic HACCP training would be top priorities. Then build upon these with the integration of personal hygiene guidelines, pest management and chemical programs. Usually the hardest job for the quality assurance (QA) leaders is influencing the culture of their organizations and making these programs a key foundation for all new business activities. Working upstream when the ideas are generated and making food safety a part of the conversation before a new process or product is launched can save your business money and time in rework. Key metrics can be communicated that can assist with that CEO and merchant-level conversation. Once the foundation is laid, dive into HACCP and start chipping away. Identify your highest risks and start there. Begin your plan by building relationships and establishing your vision for food safety and quality. As QA professionals, we are in a very unique time where regulatory focus can justify action more today than ever before. Begin your transformation!
Finally, don’t do it alone. Use the many tools that are available through FDA and the retail industry. Network, network, network. Many retailers do not feel that food safety is a competitive advantage and are more than willing to share their experiences. Attend conferences that can provide a one-stop venue for learning the basics as well as learning more about innovative technology and programs that others have verified.
It is through a united effort that we as retailers can set the stage for this new regulatory environment. Our customers should feel confident in our ability to continue to innovate and diversify while providing the safest, freshest products for the families we serve.
Sharon P. Wood, M.Sc., is the director of food safety, technical services and regulatory affairs at H-E-B supermarkets.