FSIS requires all meat processing establishments to provide and implement an approved HACCP Plan. The HACCP Plan is often supported by many Pre-requisites.
A meat establishment’s Food Safety System must provide an HACCP Plan for each product process that they produce. Meat establishments include those who process beef, pork, chicken, goat, sheep, etc. For example, if an establishment has seven different processes, they must have seven HACCP Plans within their HACCP System explaining the steps in each of those processes. Along with the HACCP plans, a system of Pre-requisites must be available to “back-up” the HACCP System.
Pre-requisites cover vital components of the entire Food Safety System. Pre-requisites will include the SSOP, GMP, Pest Control Program, Cooler Temperature Logs, Sampling Programs, Employee Training Reports, Recall Protocols, Security Policies, and so on. Basically any documentation or steps that pertain to the products HACCP plan is a pre-requisite.
It’s very important review all pre-requisites related to the Food Safety System and document any findings when performing this review. If the pre-requisite requires documentation (such as a Cooler Temperature Log), then these should be documented with an actual temperature check, date, time, and initial or signature, and be available for review as needed. As with the HACCP, SSOP, and GMP systems being written specifically according to the design and flow of the establishment, so will the pre-requisites.
Pre-Requisites for HACCP
The HACCP Pre-requisites will vary according to each establishment – “establishment specific”. Each pre-requisite is normally monitored and documented on some form of record keeping system for the establishment and Inspection Personnel to occasionally review. In a way, pre-requisites are an “insurance system” for HACCP. Following are some examples of pre-requisites explained in more detail.
Product Receiving Temperatures
In establishments that receive meat product from other establishments, it is necessary to obtain a temperature (with an approved and calibrated thermometer) of the product upon arrival at the receiving establishment. This temperature will “validate” the product was at a safe temperature upon arriving. Normally, this temperature is no higher than 40 degrees Fahrenheit. If the temperature exceeds more than an acceptable level, there is a possibility for pathogenic growth (salmonella, E. coli O157:H7, or Listeria) and this product should be rejected.
Some form of record keeping system should be maintained of these temperatures and this record keeping system must be maintained in some form of filing system for review if requested by Inspection Personnel.
Storage Cooler Temperatures
After receiving the product and validating that it was at an acceptable temperature, the product is then stored in a cooler. This cooler should also be monitored for temperature – proving that the product was held or stored at an acceptable temperature to reduce any pathogen growth.
These temperatures should also be documented on some form of log (normally twice per day) and this log should also be maintained and stored in a filing system for review when needed. Maintaining proper cooler temperatures will validate that the product was maintained at a proper temperature.
Non-Meat Ingredients Receiving
Most meat establishments also produce products of multiple ingredients such as sausage, hot dogs, bologna, and other “spiced” product. These ingredients are normally shipped to the receiving establishment in which they will further use these ingredients to “blend” into the meat product to produce the final product. To validate the non-meat ingredients, it is often recommended to perform an organoleptic (or visual) inspection of this product. Since most of these ingredients are not required to be refrigerated, the organoleptic inspection will normally verify whether the products were acceptable or not. As with meat receiving, the organoleptic inspection should also be documented and results recorded as acceptable or not acceptable.
Standard Sanitation Operating Procedures
The Standard Sanitation Operating Procedures (SSOP) are written procedures explaining how the establishment is maintaining sanitation. It is these procedures that are followed to provide a sanitary working environment for the entire food processing facility. The SSOPs are “plant specific” meaning they are written according to the facilities and products produced in the establishment. Pre-requisites to HACCP, the SSOPs are vital to validate sanitation is well maintained while HACCP validates that Critical Control Points are met.
The SSOP recordkeeping system will likely be more complicated than product receiving logs or storage cooler temperature logs. The SSOP is broken up into smaller components known as the Pre-Operational Sanitation Check (which is performed prior to operations) and the Operational Sanitation Check (performed during operations). Each of these components requires a record keeping system documenting any deficiencies or findings as well as any corrective actions explaining how sanitation was restored – and whether or not any product was involved.
Good Manufacturing Practices
Good Manufacturing Practices are somewhat similar to Standard Sanitation Operating Procedures, but not as vital. While the SSOPs, in a way, are linked directly to the HACCP Plan, the Good Manufacturing Practices, or GMPs, are linked to the SSOPs. Like the SSOP, the GMPs are “plant specific”.
GMPs include checks such as Employee Hygiene, Sanitizer Temperatures, Sanitizing of Equipment, Safe Handling of Product, Monitoring Dry Storage Areas, Proper Use of Hair Nets, and Pest Control. And again, the GMP checks must be documented to show evidence that the checks were performed.
Pest Control Program
No matter whether it is a home, business, or food processing facility, rodents and insects can cause major issues! Most importantly, pests need to be refrained from entering any areas where food is processes – especially where food is processed in mass production intended for commerce. A written pest control program is ideal to help control and eliminate any issues that may arise from rodents and insects. While the pest control program is a pre-requisite to HACCP, it should also be implemented in the home, business, and ALL food processing facilities.
Infestation or any signs of rodents or insects are monitored by USDA Inspection Personnel. If signs of pests are noticed, it is possible that Inspection Personnel may temporarily suspend operations until the situation is under control. It is the Inspectors responsibility to verify that the processing establishment is monitoring the entire facility for insects and rodents.
While product testing is directly connected to HACCP, it is an important pre-requisite. Product testing includes steps in which the establishment will actually collect a specified amount of incoming or finished product and submit this “sample” to an approved laboratory (or in-plant laboratory) for analysis. Laboratories are capable of performing a variety of tests, but typically in the red meat industry they test for E. coli O157:H7, Salmonella, and Listeria Monocytogenes. These bacteria are on the “top of the list” as the most dangerous to humans derived from meats.
Documentation of ALL testing should be carefully recorded and maintained on file for future reference. Testing also assures the general public that the establishment is producing a safe and wholesome product.
Final Words on Pre-Requisites for the Food Safety System
The pre-requisites listed above highlight a few of the most common of the pre-requisites, and these will vary according to the needs of the establishment. As a reminder, all pre-requisites identified in the Food Safety System must be monitored and documented in some form – which is decided by the establishment owner or management. The documentation should be reviewed on a daily basis and Inspection Personnel will review this information as well.
Producing a clean, safe, and wholesome product is the primary objective of any food producing facility. HACCP, SSOPs, GMPs, and all the pre-requisites make up the Food Safety System, but it is the responsibility of the product handlers to truly verify a wholesome product is produced.