Establishing Proactive Risk-Based Management Systems

by Wyman Philbrook

In last month’s column I discussed risk assessment in a food service operation by both regulatory and on-site management personnel. In this column we will outline systems that can be used to identify and establish a method of control regarding these risks. In the coming months we will delve deeper into these systems and the foundational programs that they are built on.

The first system is active managerial control which translates into an on-going proactive method of addressing the major root causes of food-borne illness. The Center for Disease Control (CDC) amasses data and research on the number and causes of reported food-borne illness in the USA and around the world. Reviewing this information gives solid scientific proof of the main contributors to outbreaks. The CDC has determined that there are 5 main contributing factors to the majority of reported food-borne illnesses. I use the term reported because an individual may have an illness such as Campylobacter or Norovirus and attribute it to a flu bug and never report it. The cause of illnesses may never be definitively identified during an investigation so we may hear what the likely cause/source was. Based on confirmed reports the five major factors are:

  • Purchasing food from unsafe sources
  • Failing to cook food adequately
  • Holding food at incorrect temperature
  • Using contaminated equipment
  • Practicing poor personal hygiene

Active managerial control is both understanding and addressing these factors and developing methods and procedures that will address the needs of your operation. All facilities even chain restaurants that use the same kitchen layout will have unique characteristics. Vendors, local environmental conditions, staffing, skill and knowledge levels will always be a constant variable between two operations. Management addresses potential risks by evaluating the operation and developing policies and procedures that manage these risks. Key actions are monitoring the application of these policies and procedures to insure their effective implementation by the staff and verifying that they are still managing the risks. Updating as needed when they are not effective or when new regulations and science address new risks or the effectiveness of current procedures.

The second system is HACCP which is misunderstood by many people who throw the acronym around in conversation and on marketing & advertising. It was initially developed for NASA to address the concerns of a food-borne illness occurring during a manned space flight. Hazard Analysis Critical Control Points (HACCP) is a term that can describe a written plan that is part of a HACCP system. I am contacted often by companies who want me to give them a HACCP Plan because the regulatory agency says they need one. Many companies and stand alone operations will reach out and contract a reputable HACCP trained consultant to advise or assist in the development of the HACCP plan and implementation of a HACCP system.

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A consultant can assist, advise and mentor the HACCP team in the development of a HACCP plan and a HACCP system. Management should be aware that a HACCP plan is unique to your operation and requires input from you and your staff members. A consultant should have the knowledge and integrity not to provide a boilerplate plan and a bill for services rendered without working with the on-site staff to customize. A HACCP plan and system need to be built on the solid foundation of Prerequisite Programs (PRPs). Some examples of these programs are policies, standard operating procedures (SOPs) and sanitary standard operating procedures (SSOPs). These procedures and policies need to be in writing, implemented, and enforced by management. These would also be used in an active managerial control system previously mentioned; in fact if you currently had an effective program in place it would be much easier to build a HACCP system on it. These policies and procedures would include employee hygiene, cleaning and sanitizing, purchasing and receiving, pest control, etc. (these will be topics in future columns) Building on what is in place and is effective, the steps to develop a HACCP plan would be:

  • Establish a HACCP team that has representatives from key areas in the operation that handle food from delivery to service i.e. management, purchasing, culinary and service personnel. One individual should be trained in the principles of HACCP.
  • Describe the food product and its intended use. How is it served? Do you serve high-risk populations?
  • Construct a flow diagram of the food products and confirm its accuracy on site. Product comes in to the facility is stored, prepared, cooked and served. Some operations may prepare and cook in advance so there is a cooling and reheating step.
  • Conduct a hazard analysis to determine the likelihood of biological, physical or chemical hazards affecting the food throughout its flow through your facilities and determine what has to be controlled. Realistically decide the likelihood of something happening and the severity/consequences if it does happen. Example: Chicken must be cooked properly because it is known to carry salmonella and it can cause sickness and potentially death or severe injury particularly to young adults, the elderly or immune compromised individuals.
  • Determine what must be done to control the hazard, how it will be monitored and what needs to be done if it is not in control. Referencing the chicken above, you would cook it to 1650 F and monitor it with a thermometer and continue to cook it if it was under the correct temperature.
  • Management or their designees would ensure that the procedures were being followed consistently and that records were being kept either in writing or electronically.

HACCP plans can be developed around a single recipe like sushi rice or a similar process such as foods that are cooked and served. When something different happens in the process a new plan must be developed. i.e. cooling cooked food and then reheating and serving. The regulatory guidelines have determined that certain processes that are similar to food manufacturing for storage & shelf-life, i.e. smoking, curing, fermenting, vacuum-packaging and sous-vide, all require HACCP plans that are submitted for approval. The likelihood and severity of something not being controlled in the process is high ( i.e. Botulism). A HACCP plan is a document that when implemented and continually reviewed & updated, becomes an effective HACCP system. The best analogy is it is a battle plan that you change and update as needed to win the battle.

There are many companies like mine that can assist with the development and implementation of a food safety management system and can also provide introductory and specialized training to meet the needs of your operation.
As stated, columns that go into more depth in these different areas will be coming in future issues.