HACCP SYSTEM ASSOCIATED TRAINING. Frank L. Bryan Food Safety Consultation and Training 8233 Pleasant Hill Road Lithonia, GA 30058, U.S.A. Training is an essential part of the hazard analysis critical control point (HACCP) concept. It is so important that it should constitute an additional HACCP principle, and this should be positioned as the first principle. HACCP system associated training is different from the Codex Code of Food Hygiene training that relates to good manufacturing practices (Codex, 1997), and it is different from typical food handler training (Education Foundation, 1992). It is specific to HACCP systems and operations for the foods being processed or prepared, and it is directed at persons who are involved with the design, implementation, maintenance, verification and validation of HACCP systems. PERSONS WHO NEED HACCP TRAINING HACCP training is essential for certain groups of persons, which include: 1. Persons who conduct hazard analyses and set-up HACCP systems 2. Persons who prepare or process foods and who supervise operations at critical control points 3. Persons who monitor critical control points 4. Persons who verify monitoring 5. Persons who validate HACCP systems 6. Chief executive officers and top managers of food companies 7. Persons who administer food safety, food quality assurance and food regulatory activities Persons within each of these groups need (a) to be knowledgeable about specific aspects of their role in HACCP systems, (b) to be skilled to carry out their HACCP function, (c) to have attitudes that are conducive to establish and to implement the concept. These attributes, however, are different for various groups of persons who carry out specific activities. The persons who will be involved with the HACCP systems may know some of these attributes, but focus and priorities will need to be set during training and emphasized by supervisors. Other persons must acquire these attributes through training. Persons who conduct hazard analyses and set-up HACCP systems These persons are key for having successful HACCP systems. Often, and particularly within food processing companies, a team is formed to discuss and develop HACCP systems. The team members usually are composed of a person from the quality control or food safety (if there is one) department and others who know about the process or food safety issues. Other times, a food safety official of the company or a consultant may conduct hazard analyses, conduct challenge studies or develop the HACCP systems. A leading member of the team or the consultant, should be well informed about the epidemiology of foodborne diseases and the etiology of the agents that cause them, which are associated 15
with the product under discussion. This person should know the applicable factors that have contributed to foodborne outbreaks traced to the foods being processed or prepared or similar foods and processes. These factors usually dictate critical control points. (See paper on Present Controversies in Application of HACCP System in this proceedings [Bryan, 2001].) Because microbiological hazards are the most frequent and usually those of most severity and with the greatest number of persons at risk, these hazards and their prevention and control must be stressed in the training. Fundamental in this is (a) an understanding of sources and modes of contamination of foods, (b) operations at which pathogens survive and means to kill or reduce their populations, and (c) situations by which pathogens propagate and toxins are generated and means to prevent or delay growth of pathogenic bacteria. Therefore, key persons of the team or the HACCP consultant should understand food microbiology principles and food safety preventive and control measures as listed in Table 1. These laws or principles apply for all foods during all phases of food production, harvesting, processing, storing, marketing and preparation. They are applicable for retail and institutional foodservice operations as well as food processing plants. With an understanding of them, a team or HACCP consultant is prepared to take food safety measures as stated in the tenth law of applied food microbiology. Activities of those who develop HACCP systems are to (a) select vital operations as critical control points, (b) establish criteria that eliminates, excludes, reduces, minimizes, prevents or delays the hazards as applicable to the process and HACCP system, (c) apply effective monitoring procedures and corrective actions at operations designated as critical control points. Specifically, persons who conduct hazard analyses and set up HACCP systems must be educated in the fundamentals of chemistry, physics, microbiology, and food science and be knowledgeable about the products being processed or prepared. These persons must be aware of reservoirs of foodborne pathogens, epidemiology of the diseases that these pathogens cause and the ecology of microorganisms that cause these diseases. Knowledge necessary to interpret laboratory results that give the type, number of microorganisms, and type and concentration of chemicals present must be developed. Also, an understanding of the nature, formulation, and processing of the foods under investigation is essential. They must have a thorough understanding of the HACCP system and associated principles. Furthermore, their training should include skills to measure food ph, water activity, temperatures, and to collect samples and (for some) to make standard microbiological analyses. These sorts of information and skills are essential to identify hazards, assess their severity, and predict risks associated with operations. Hazards should be identified by more means than by fault tree analyses. They should be identified by (a) careful observations of operations for sources and modes of contamination, (b) time-temperature measurements of operations, (c) tests of ingredients or products ph and water activity, (d) analyses of microbiological, chemical and physical tests of the ingredients or products, (e) challenge studies, if applicable, and (f) field and plant evaluations. It must be understood that there are different kinds of critical control points those that eliminate, exclude, reduce, minimize, prevent and delay hazards. The effects of HACCP systems and remaining hazards and risks vary, and this should be realized. By having this knowledge and these results, it will become apparent that the traditional decision tree for selecting critical control points provides little additional help. As part of the training, either on-site experiences or simulated exercises should be used to demonstrate the trainees ability to detect hazards. These should be taken from typical food processing or food preparation situations. Time-temperature measurements should be taken, potted, and interpreted. Flow diagrams should be constructed containing symbols for hazards and indications of critical control points. For these databases, a simulated complete HACCP system should be developed. The instructor should critique these. The training-developed HACCP systems should be composed of all components of the HACCP concept. The HACCP systems may eliminate or exclude certain hazards, but not necessarily all of them. They may only reduce or minimize the hazards. These systems may and often at best only 16
minimize contamination. They may prevent propagation of the contaminant, but they may only delay this event or perhaps have no such effects. Thus, HACCP systems should be summarized and interpreted concerning what they do and don t do, and any remaining hazards pointed out and the remaining risks assessed. Such a review is critical and should be specified as another principle of the HACCP concept. These points should be stressed during training. Persons who prepare or process foods and who supervise operations at critical control points. These persons must thoroughly understand the hazards associated with the operation and the effect of previous operations on the safety of the food being processed or prepared. They must understand that food safety can only be attained if the hazards are eliminated, excluded, reduced, minimized, prevented or delayed (as applicable) at the operation for which they are responsible. Therefore, they must know the criterion or criteria and any target values for control at this operation. These persons must posses the skills to perform the operation safely and be so trained and supervised. Discipline must be instilled. At the outset of their employment, they must understand that job security depends of effective performance of the operations. Superiors must direct their attention at the safe performance of the operation and be able to carry out the operation to demonstrate and teach it to the operators and do it in their absence. Their attention must not be misdirected to trivial matters. Their attitude must be one of dedication to the food safety aspects of the operation and to train operators and to ensure that they carry out the operation as prescribed in the HACCP system. Persons who monitor critical control points HACCP systems are focused, self-monitoring activities. The person who does the monitoring may be the person (such as a cook) who is responsible for the task, a supervisor, or an employee assigned to the task of monitoring. First, these persons must be aware of the hazards associated with the operation. Their duty is to detect hazards if they exist. They must know (a) the foods and processes to monitor (what), (b) the specific site to monitor (where), (c) times and frequency to monitor (when), (d) the way to monitor (how), (e) criterion or criteria to meet, (f) actions to take whenever the critical limits have not been met, and (g) where to record the results of monitoring and corrective actions. The persons must have skills in operating the monitoring instruments and either means for their calibration or detection when the instrument is out of calibration. They must have an attitude to detect hazards or out-of-compliance situations; not just one of seeking an observation, measurement or test result that shows whether the operation meets the specification throughout the product. The training will be specific for the hazards, operation, and monitoring tasks. Persons who verify monitoring The person who verifies monitoring is someone other than the one who does the monitoring. This person is often a supervisor or a manager or someone from the quality assurance activity of the company, although the verifier may be an outside consultant or inspector from an official agency. Whoever it is must know the criteria, standards and regulations associated with the operations. They must know who is responsible for monitoring and what, where, when and how to monitor. They must seek answers to corrective actions that have been taken when the monitoring results show that the criteria were not met initially. When records are reviewed, presentations that suggest any misunderstanding or falsifications by operators or management ought to be sought. Beyond reviewing records, (a) operations at critical control points should be observed, (b) measurements taken, (c) samples collected, or (d) tests preformed (as applicable) to evaluate the effectiveness of monitoring and safety of the operation. The verifier must not rely on the monitoring instruments used by the company, but to evaluate the process and check monitoring results with his or her calibrated instruments. Persons who do the verification must be trained to perform these tasks, and they must have an attitude to detect deviations from the critical limits and know what actions to take if the operation is out of compliance. 17
Persons who validate HACCP systems The persons who validate HACCP systems come from outside the company that is implementing the HACCP system. They could be representatives of a health department, a food-regulatory agency, or a third party that is organized for validation of HACCP systems. Whoever does this task must be trained in all aspects of the HACCP concept and understand the diseases, hazards and risks that may result if the HACCP systems are incomplete or flawed. Thus, they must know all that the persons who designed the HACCP system knew. They must realize whether a situation calls for a critical control point and be labeled as one, even if it also might be considered as a so-called prerequisite or good operational practice. Critical control points must dominate over so-called prerequisites. The whole point of the HACCP system is (a) to choose the few vital operations on which to focus attention, (b) to set criteria and (c) to monitor for assurance that the operation is carried out safely. The person or teams who validate HACCP systems must confirm this and to detect any hazards that remain after the HACCP systems are implemented. They must be able to detect (a) previously undetected hazards, (b) actions to avoid monitoring critical control points or relegating them to prerequisite category, (c) improper or ineffective monitoring, (d) monitoring with out-of-calibration instruments, and (e) falsification of the HACCP system or records. For example, monitoring records may show results of monitoring rapid cooling but not slow cooling that is also being done without record. The training must condition the person doing the validation that food safety is the objective and not insisting that there are piles of records showing attempts at HACCP system design and monitoring. Chief executive officers and top-level management These persons do not need to know the details of the HACCP approach, but they must understand that the HACCP system can offer more protection than traditional quality control activities. If HACCP systems are designed and carried out properly, they can provide high assurance of food safety. Such top-level managers must be committed to the HACCP systems and convey this to lower-level managers, and they must insist on implementation of HACCP systems for all food operations within the company. They must support training of staff toward this end and insist on discipline of workers to follow HACCP systems, monitor correctly and record truthfully. Without management commitment for HACCP systems and food safety, the result will just be a paper puppet. Persons who administer food safety, food quality assurance and food regulatory activities Food safety and quality assurance managers must understand the advantages of HACCP system and its attributes in comparison to the limitations of traditional inspections, end-product testing, and other activities. They must develop an attitude that foodborne disease prevention prevails over the number of inspections per grading period. They must often change their attitudes from... that their program results in the safest foods in the country or world... to the realization that there are hazards associated with the foods under their jurisdiction and focus on activities that detect associated hazards and their prevention and control. They must take actions to embrace the HACCP concept as a main part of their food safety program and adopt regulations that include food safety focus at critical control points. Their person must be trained in HACCP technology. PLANNING, IMPLEMENTING, AND EVALUATING HACCP TRAINING Much of planning for HACCP training consists of choosing objectives that (a) guide and direct the training program, (b) give information or tasks that must be learned (as cited above and in shown in Tables 2-8), and (c) describe what the trainee will be able to do after the training. The latter can be modified from the information and tasks to learn and be written in a format applicable for measuring or evaluating. Training approaches are the choice of the teacher within the limitation of resources, facilities, available training aids, and imagination. Information can be presented in many ways, but illustrations and 18
demonstrations always enhance it. Skills are learned by practiced. Attitudes are probably learned best through the aid of mentors, who may be teachers, supervisor, an outstanding co-worker, or a renowned specialist in the field of interest. An attempt should be made to learn by doing. Thus, it would be desirable to develop a part of the HACCP system integral with the training. Practice using monitoring instruments and checking their calibration should be a part of the training for most of the groups needing training. Practical exercises that guide, for example, detecting hazards, estimating risks, selecting critical control points, and demonstrating monitoring should be used. Evaluating any training is neither easy nor reliable, although some useful information can be obtained from various attempts. Some difficulties stem from setting unrealistic goals (e.g., reduction in inspection scores or reduction of disease by a significant percentage). Most evaluation attempts concentrate on gain of information during or at the end of the training rather than in change in practices and attitudes. Evaluation must be based upon accomplishment of the course objectives and, if feasible, on change of behavior on the job. Such changes, however, are not always controllable by the person receiving the training. Instructors contributions and effectiveness also should be attempted to be evaluated by self appraisal and appraisals by colleagues and course participants. Fortunately, HACCP systems have builtin evaluation (e.g., monitoring, verification and validation) (Bryan, 1991). These features are the uniqueness of the HACCP system that can provide a high level of assurance of food safety. RESOURCES FOR LEARNING HACCP CONCEPTS HACCP training is presently available from several food safety agencies, food industry associations, food safety consulting companies, and other groups concerned with food safety. There are videos and computer software to aid in this endeavor. Texts (e.g., ICMSF, 1988; Loken, 1995; Corlett, 1998), chapters (e.g., Jouve, 2000) and manuals (e.g. Bryan, 1992; Bryan et al., 1991; WHO, 1993) have been written on the subject and for specific industries, and some of these contain tables that give generic HACCP systems that can be used as a start for developing systems. All these aids must be modified to account for the uniqueness of the product, process, equipment used, and personnel involved. Additionally, HACCP topics frequently are presented at meetings and symposia and published as articles in professional and trade journals. (Quality of these training aids, however, varies, so the user must use discretion during reading, verifying and subsequent utilization of these materials.) DETERRENTS TO HACCP IMPLEMENTATION There are deterrents to implementing HACCP systems and training associated with these systems. The primary ones are: 1. An inspection mentality and defensiveness to change are the major deterrent to implementation of HACCP systems. Persons in both regulatory and quality control activities have traditionally put emphasis on inspections of food processing and preparation environments and on testing of finish products in their food protection programs. They feel comfortable with these and resist changing their approach. Education about the HACCP concept and an ability to set priority for items in sanitary codes and food processing steps according to relative importance to food safety are needed to hurdle this barrier. Training should be aimed at this goal. 2. Misunderstanding of the HACCP concept is another deterrent. Many persons have incomplete understanding of the HACCP concept. They often think of HACCP as (a) an intensified inspection, (b) complete compliance to good manufacturing practices, (c) a gigantic record-keeping task, or (d) some special concern (e.g., disinfection) that they have been advocating or selling. This deterrent is ageless whenever a new idea is introduced. The HACCP concept, however, is an exactly-defined 19
system of interrelated components; each having specific definitions. Education, retraining, and time seem to be the only remedies. 3. Untrained co-workers and supervisors usually expect newly trained persons (who go back to their previous job) to do the same thing as they did before the training. This problem occurs with most job-related training. Having a management commitment to the implementation and maintenance of the HACCP system and training supervisors first will minimize difficulties created by this deterrent. Workers must have self-discipline to meet food safety criteria at critical control points and to monitor effectively. Training supervisors can accomplish this first, and making management policies to accommodate modified knowledge, skills and attitudes created by the training. For HACCP to become the keystone of food safety, these deterrents must be overcome. This is our challenge. CONCLUSIONS Training is essential to implement the HACCP concept. It informs those who will be involved with the concept and stimulates them to develop and implement HACCP systems. By focusing training on applicable aspects of the HACCP concept, food handler and manager training can be streamlined so that only a few topics relating to product-specific hazards, critical control points, and monitoring procedures are emphasized rather than being courses on basic bacteriology, dish washing, vector control, and other topics often unrelated to food safety. Similarly, training for regulatory officials can be focused on critical operations that will prevent foodborne diseases, rather than on aesthetics. HACCP systems can return to the state of the art and science of food safety. To do this, however, quality control, food protection programs, and some so-called HACCP programs that depend on good manufacturing practices to substitute for critical control point, must be transformed into effective HACCP activities. These activities must depart from ineffective and inefficient elements of traditional food protection activities and focus attention on operations at which contamination can be minimized, contaminants can be eliminated or reduced, or microbial propagation can be prevented or delayed. Leaders in these fields must stimulate universal acceptance of the foodborne disease prevention HACCP systems and guide their implementation in all food operations. Training is an investment in attaining the objectives of food safety. REFERENCES Bryan, F.L. 1991. Teaching HACCP techniques to food processors and regulatory officials. Dairy Food Environ. Sanitat. 11:562-568. Bryan, F.L. 1992. Hazard analysis critical control point evaluations. A guide to identify hazards and assessing risks associated with food preparation and storage. World Health Organization, Geneva. Bryan, F.L. 2001. Present controversies in application of HACCP system. Proc. Spanish Society of Dietary and Food Science, Madrid, Spain. Bryan, F.L., C.A. Bartleson, O,D. Cook, P. Fisher, J.J. Guzewich, B.J. Humm, R.C., and Swanson, E.C.D. Todd. 1991. Procedures to implement the hazard analysis critical control point system. International Association on Milk, Food and Environmental Sanitarians. Ames, IA. Codex (Codex Alimentarius Commission). 1997. Report of the twenty-ninth session of the Codex Committee on Food Hygiene, Washington, D.C., October, 1996. Food and Agriculture Organization of the United Nations, Rome. Corlett, D.A. Jr. 1998. HACCP user s manual. Aspen Publ., Gaithersburg, MD. 20
Education Foundation of the National Restaurant Association. 1992. Applied foodservice sanitation. A certification coursebook, 4 th ed. John Wiley and Sons, New York. ICMSF (International Commission on Microbiological Specifications for Foods). 1988. Microorganisms in foods 4. Application of the hazard analysis critical control point (HACCP) system to ensure microbiological safety and quality. Blackwell Scientific Publications, Ltd., Oxford. Jouve, J-L. 2000. Good manufacturing practice, HACCP, and quality systems. In. B.M., Baird- Parker, T.C., and Gould, G.W (eds.). The microbiological safety and quality of food, Volume II. Aspen Publ., Gaithersburg, MD. Loken, J.K. 1995. The HACCP food safety manual. John Wiley & Son, New York. WHO (World Health Organization). 1993. Report of the WHO Consultation on Hazard Analysis Critical Control Point Training. World Health Organization, Geneva. WHO/FNU/FOS93.2. 21
TABLE 1. DOCTOR BRYAN S LAWS OF PRACTICAL FOOD MICROBIOLOGY AND FOOD SAFETY (AND HOW WE UNDERSTAND AND SOLVE FOODBORNE DISEASE HAZARDS) 1. Raw foods must be considered to be contaminated. Raw foods can be expected to be contaminated 2. with a variety of microorganisms, some of which can cause foodborne illness. These include raw vegetables, fruits, grains and spices as well as raw products of animal origin.?there are few practical ways to avoid their contamination. There is, at best, low assurance that pathogens are absents, despite the present day food production and processing technologies, inspection and testing activities. These actions can minimize or reduce but not eliminate contamination. 3. Spores survive cooking. Spore forms of bacteria usually survive routine cooking/heat processing and reheating. Therefore, the process must be designed to kill spores (e.g., retorting), or expect that after the heating step, spores will be present 4. Vegetative forms of foodborne pathogens also may survive heating. Principle 1 indicates risks of eating raw foods, and implies the importance of a kill step during processing or preparation. Vegetative forms of microorganisms, however, may or may not survive cooking/heat processing and reheating, depending on time-temperature exposures of the foods. This exposure is influenced by t;he intrinsic characteristics of the food (e.g., its ph and water activity), initial microbial population types and quantity, thickness of food mass, and viscosity of the food). 5. Some microbial toxins are heat stable. Certain bacterial toxins (e.g., staphyloenterotoxin, emetic us, histamines) survive reheating (e.g., boiling)., If these toxins are allowed to generate during storage, reheating cannot be expected to render the foods safe. 6. Post-heating contamination can readily occur. Foods, particularly cooked/heat processed foods, can readily become contaminated when they are touched either by bare hands or by hands, gloves, equipment or utensil surfaces that previously (and without intervening thorough washing) contacted raw foods. Additionally, cleaning cloths and aids can spread contaminants, and when they remain damp for a long duration, bacteria can multiply on them. Contamination can be spread from other environmental sources (e.g., contaminated cooling or cleaning waters, aerosols, dust, splash, drippage, back siphonage), but typically these are minor sources in comparison to raw incoming foods and bare hands of worker. 7. Pathogenic foodborne bacteria can multiply in foods. If cooked foods are contaminated by bacterial spores, the spores may germinate and the resulting vegetative cells, as well as those bacteria that subsequently reach the foods, will multiply...if the foods contain essential nutrients, have a ph, a water activity, and a redox potential at which the bacteria can multiply and do not contain sufficient quantities of inhibitory substances or competitive microorganisms that inhibit growth of pathogens... if given enough time within a temperature range at which the bacteria can multiply. Temperatures close to the optimum at which the bacteria multiply will result in the most rapid increease in populations. The multiplication rate decreases progressively as temperatures move from the optimum toward the maximum and minimum limits. 8. Bacteria can multiply even in foods during refrigerated storage.can multiply even in foods during refrigerated storage. Bacteria will multiply in large masses of foods and in foods that are stored in large container (e.g., >3 inches or >9 centimeters) while in refrigerators. Lids impede cooling. When they are used, food depths must be reduced to compensate for this. Stacking of pans impedes air circulation. Furthermore, even in properly stored foods, some foodborne pathogens (e.g., Listeria, Yersinia, Aeromonas, and non-proteolytic varieties of Clostridium botulinum) can multiply at temperatures below 41 o F (5 o C), but their growth rate is slow. 9. Foodborne diseases are expensive. Besides suffering from the illness, sometimes hospitalization, and occasionally deaths, the economic impact of foodborne illness can be quite high to the patient and family and tto the place where the implicated foods were produced, processed, prepared and served. 10..Table 1. Doctor Bryan s laws of practical food microbiology and food safety (and how we understand and solve foodborne disease hazards...continued... 11. Murphy s Law is always apt to occur. That is if something can go wrong, it will... and some day it will occur unless effective food safety measures are designed in the operation, implemented and maintained. 12. Foodborne diseases are preventable. For this to occur, however, all persons involved with food production, distribution, processing, preparation and storage must (a) be aware of the hazards associated with their (and previous and subsequent) operations, (b) employ means either to prevent or control the hazards, (c) set control limits (criteria) at vulnerable operations (critical control points), (d) monitor operations at the critical control points, (e) immediately correct deviations from established criteria or when the operation gets out of control., This is implement of the hazard analysis critical control point (HACCP) system (without confusion and intermixing of lesser important issues that relate to aesthetics and general sanitation) for all potentially hazardous foods. 22
TABLE 2. KNOWLEDGE, SKILLS AND ATTRIBUTES THAT PERSONS WHO CONDUCT HAZARD ANALYSES AND SET -UP HACCP SYSTEMS OUGHT TO ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand the basic principles of food microbiology Understand operations and food flow patterns of processing and preparing the types of foods for which HACCP systems are to be applied Know the important factors that contribute to foodborne disease outbreaks Understand sources of contamination of foodborne pathogens and indicator organisms and their usual modes of spread to foods for situations for which HACCP systems are to be applied Understand the principles of microbial survival and destruction for situations for which HACCP systems are to be applied Understand the principles of microbial growth for situations for which HACCP systems ar to be applied Know where to locate dependable sources of information on the HACCP concept Develop skills in measuring ph, water activity, time-temperature exposures, disinfectant concentrations and for sampling foods Develop skills in diagramming food flow and inserting symbols where hazards occur and at critical control points Develop skill in making and interpreting time-temperature graphs Develop observational skills so as to identify sources and modes of contamination, likelihood of survival and opportunities for microbial grothw during hazard analyses Develop skills in setting up HACCP systems, including listing of operations, associated hazards, assessment of severity of their outcomes and risk of occurrences, types oc critical control points, critical limits, monitoring procedures, corrective actions, and verification procedures Develop skills in interpreting scope and limitations of HACCP systems and any remaining hazards and their risks Become curious to learn food processes and food safety interventions Develop insight into limitations of traditional food protection activities Develop a positive attitude that effective HACCP systems are the most effective and efficient approach to food safety Realize that HACCP systems do not necessarily eliminate or even prevent all hazards and be willing to pass information about remaining hazards and risks and subsequent control measures on ;to the user Become stimulated to conduct hazard analyses and set up HACCP systems Develop ability to assess priorities of hazards based on their severity and risks 23
TABLE 3. KNOWLEDGE, SKILLS AND ATTITUDES THAT PERSONS WHO PROCESS OR PREPARE FOODS AT CRITICAL OPERATIONS OUGHT TO ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand that some hazards have relatively high risks of occurrence as a result of certain processes and practices Develop a basic understanding about contamination, survival and growth of foodborne pathogens; hence, an understanding of the hazards oof their operations and those that proceeded them Know appropriate control and preventive measures for their operations and appropriate criteria for these measures Realize that risky operations (critical control points) must be under control and monitored to have a high degree of assurance of control Have skills in performing their operations Develop skills in either monitoring or supervising and verifying monitoring Realize that certain operations can be risky and if improperly carried out, they can result in an outbreak of foodborne illness Become stimulated to either monitor critical control points or insist that they are monitored and results recorded (if applicable) and to take immediate action when results indicate that criteria for control are not met so as to make the operation safe Put high priority and focus of attention on food safety measures rather than on trivial matters Understand that employment and job security depends on performing operations safely at critical control points properly 24
TABLE 4. KNOWLEDGE, SKILLS AND ATTITUDES THAT PERSONS WHO MONITOR CRITICAL CONTROL POINTS OUGHT TO AXQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand that there are hazards associated with operations and that monitoring is essential to ensure food safety Learn the criteria for control (critical limits) at critical control points Know foods and processes to monitor (what), sites to monitor (where), times and frequencies to monitor (when), and methods of monitoring (how) Know actions to take when monitoring indicates that criteria are not being met at critical control points Know where to record results of monitoring and corrective actions Develop skill in observing operations or measuring attributes of food or process, as applicable to the monitoring procedure Develop skills in using all appropriate measuring and testing instruments and equipment Develop skill in calibrating monitoring instruments or detecting that these instruments are out of calibration Develop skill in filling-in monitoring work sheets or forms Develop an understanding of the importance of their tasks for food safety Become aware that hazards associated with operations must be controlled at certain (critical) operations Learn that during monitoring hazards should be sought rather than to record data that indicates the critical limit and whether it was met throughout the produce Become stimulated to report to supervisor conditions that do not meet control criteria 25
TABLE 5. KNOWLEDGE, SKILLS AND ATTITUDES THAT PERSONS WHO VERIFY MONITORING OUGHT TO ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understanding hazards of operations being monitored Learn criteria for control of operations being monitored Learn the most efficient means of monitoring critical control points of operations of concern Know what, when, where and how to monitor and who is responsible for monitoring Understand that verification must be done either at the time operations are done or of records recorded at the time or of samples taken at that time Develop skills in using monitoring instruments and equipment Develop skill in calibrating monitoring instruments or in detecting that they are out of calibration Develop skills in observing operations for hazards and for detecting improper monitoring procedures and failures of monitoring Develop skills in reviewing monitoring records to detect hazards and remaining risks, missed critical control points, falsification of records and actions taken when critical limits were not met Develop curiosity in detecting changes in operations from those for which the HACCP system was planned Become stimulated to insist on proper monitoring and on taking immediate action whenever monitoring indicates that criteria have not been met Become stimulated to report to supervisor and/or person responsible for HACCP system whenever findings indicate that criteria are not met, that monitoring is done incorrectly, that operations have been modified Become to look for and report hazards that ;have not been addressed in the HACCP system 26
TABLE 6. KNOWLEDGE, SKILLS AND ATTITUDES THAT PERSONS WHO VALIDATE HACCP SYSTEMS OUGHT TO ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand, know and/or learn the same information listed for those who conduct hazard analyses, set-up HACCP systems, and verify HACCP systems (See Table 2) Develop skills similar to those whom conduct hazard analyses, develop HACCP systems and verify HACCP systems Orient skills toward interpreting data rather than conduction hazard analyses and verification (See Tables 2 and 4) Develop skills to use instruments to verify monitoring Understand that many HACCP systems are poorly designed and ineffectively monitored, and that they need modification Be alert so that the company executives or employees do not manipulate date or operations during the validation review Determine whether all hazards have been considered in the HACCP system Determine whether appropriate critical control points have been selected Determine whether monitoring is being done effectively Evaluate whether the HACCP system is in place and being maintained Have and understanding the some companies substitute good manufacturing practices to avoid monitoring critical control points or monitor equipment or operations that show critical limits being met but other similar equipment or operations used are not monitored 27
TABLE 7. KNOWLEDGE, SKILLS AND ATTITUDES THAT CHIEF EXECUTIVE OFFICERS AND TOP MANAGERS OF COMPANIES OUGHT TO ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand the principles, components and key definitions of the HACCP concept Have leadership skills Realize the value of the HACCP system in providing a high degree of food safety for products processed by the company or prepared in the establishment Become committed to implement HACCP systems for all hazardous foods and that employee monitor critical control points effectively Ensure that the person or persons who develop HACCP systems within the company are qualified to do so (See Table 1 for principles to understand and Table 2 for specific knowledge, skills and attitudes) Insist on discipline of staff to monitor critical control points effectively and record truthfully Insist on a job security policy that embraces the HACCP concept 28
TABLE 8. KNOWLEDGE, SKILLS AND ATTITUDES OF PERSONS WHO ADMINISTER FOOD SAFETY, FOOD QUALITY ASSURANCE AND FOOD REGULATORY ACTIVITIES MUST ACQUIRE AS A RESULT OF TRAINING KNOWLEDGE SKILLS ATTITUDES Understand what the HACCP system really is; this includes it s principles, components and definitions Have an understanding of the epidemiology of important foodborne diseases and the ecology of the agents Understand the common factors that contribute to outbreaks of foodborne illnesses and their relationship with critical control points Know measures for preventing and controlling foodborne diseases Either have or develop basic communications, leadership, and managerial skills Apply ;the Pareto Principle to classify health hazards, sanitary deficiencies and aesthetic concerns into vital and trivial matters Review present regulations and modify them to address and emphasize vital preventive and control measures for foodborne diseases Realize that inspection mentality is a major barrier to implementation of HACCP systems and devise and take actions to dispel this and install a foodborne disease prevention attitude on the part of the staff Understand that certain operations (sanitary code items) are vital to food safety while many others are of only trivial or of minor significance, and change program emphasis to activities that relate to the vital ones Develop insight into limitations of traditional food protection activities Develop a positive attitudes that HACCP is the most effective and efficient approach to food safety Realize that some companies short cut HACCP or falsify records Become stimulated to train staff in HACCP technology 29