If you’ve been through a food safety audit, then you know that non-conformities are things we would all like to avoid. HACCP non-conformities highlight where a food safety or HACCP plan is falling short of audit criteria, which can happen in several places such as documentation, hygiene, training, or food safety practices.
Receiving a non-conformity in an audit is not ideal but the importance of identifying and addressing non-conformities lies in the fact that they can pose real risks to food safety. By identifying these issues, corrective actions can be taken by your facility to make the safest food possible.
When it comes to preparing for HACCP certification no two plants are the same, but we do see trends where companies struggle with the same issues. In this article we will discuss the top five HACCP non-conformities of the previous year and dive into tips for preventing them in the future.
| Standard Number | Standard Description | Total Findings |
|---|---|---|
| 23.6 | Flow Diagram | 103 |
| 23.7 | Listing Hazards | 96 |
| 23.12 | Monitoring CCPs | 76 |
| 18 | Environmental Monitoring for Pathogens | 73 |
| 23.8 | HACCP team Identifying raw material hazards | 60 |
1. Create a Flow Diagram
The most common non-conformity we see in HACCP audits is for flow diagrams. Flow diagrams are an important part of your HACCP plan especially when it comes to documentation. You need to consider every step in your production process and keep all your documents up to date.
“A flow diagram covering all input and output steps in the process must be available for all unique product groups and processes. Process steps must be sequential and numbered.”
Description from the HACCP Audit Checklist Section: Create a Flow Diagram
Checks for your flow diagram
- Is my diagram current? Every time you update your manufacturing process, you need to update your flow diagram. Did you remove a metal detector, add roasting, or change a nitrogen flush? Then it needs to be documented so that all process steps are included.
- Is my diagram clearly identifiable? Your diagram needs to be easy to read and understand. If you have a step in your process which sorts out rejected product, there needs to be a clear reference of that separation.
- Have I included all inputs and outputs? All inputs and outputs such as air, metal detector rejects, and sort-out waste need to be legible and clearly defined.
- Are all my process steps numbered?
- Does my flow diagram have a revision date?
- Have my flow diagrams been verified by the HACCP team? It’s important to have all flow diagrams verified by the HACCP team. This includes walking the floor together as a team to verify that all steps are included appropriately. And remember, when verifying your diagram, do so as an entire team instead of one at a time.
2. Listing Hazards
“All potential hazards that are reasonably likely to occur for each product and process step must be identified. Hazards are grouped according to biological (B), chemical (C), and physical (P) hazards. Hazards must be specifically identified (e.g., Salmonella instead of microorganisms).”
Description from the HACCP Audit Checklist Section: Conduct a Hazard Analysis
Hazard analysis is where things can get a little complicated. There isn’t one straight forward list of hazards that everyone needs to include in their HACCP plan because every product and production process is unique. When creating your HACCP plan, you need to consider three types of hazards: biological, chemical, and physical. While all three are incredibly important, biological hazards are the ones which require the most vigilance.
Tips for Listing Hazards
- Hazards must be specific – Because your food safety plan is a living document, you need to be as specific as possible when listing your hazards. For example, if you have foreign material as a physical hazard, describe what foreign material could be found in your product.
- Include an assessment of likelihood and severity of the hazard – When evaluating hazards, we want to look at how likely something is to occur and how detrimental it can be to the food supply. Both these metrics are extremely important in your food safety program and should be conducted for every hazard you are controlling for.
- List the type of hazard – When listing your hazards, identify if it is a biological, chemical, or physical hazard.
3. Monitoring CCPs
When it comes to monitoring critical control points (CCPs), the first step is to determine them using the Codex Alimentarius Decision Tree (the decision tree is on page 35). This step is often completely missed when developing HACCP plans.
“Monitoring procedures must be established for each CCP to ensure compliance with the critical limits.
• The monitoring system must be able to demonstrate control and detect loss of control of CCPs.
• The precision limits and tolerances of the monitoring equipment must be considered when defining limits (e.g., tolerance of temperature probes).
• Monitoring procedures must contain details on how the measurements are taken, frequency, equipment or materials, and responsibility.”
Description from the HACCP Audit Checklist Section: Monitoring CCPs
Once you determine what your CCPs are for your process, the next step is to monitor them effectively. One common mix up with this non-conformity is failing to document verification checks on a specific CCP. Verification is a big part of a HACCP plan, but we have seen that people forget to document properly or conduct the verification all together. Remember – if you say you are going to verify at a specific step somewhere in your food safety program, you should have monitoring procedures written down as well.
Tip: Make sure that your monitoring activities are the same across all documents. For example, if you state a frequency for metal detector checks one way in your SOP, it should be stated the same way in your HACCP plan.
4. Environmental Monitoring for Pathogens
“Environmental swabbing for pathogens must be conducted in accordance with the Almond Board guidelines, Safe Food Alliance guidelines, or the equivalent, when in existence.”
Description from the HACCP Audit Checklist Section: Environmental Monitoring for Pathogens
An effective environmental monitoring program (EMP) is the best way to help prevent pathogens from spreading in your facility. As biological hazards can have a big impact on public health, this non-conformity is one you should take very seriously.
Common Issues to Avoid
- No records for verification swabbing
- Limits for pathogens are listed in SOP but not followed
- No corrective action procedures
- Environmental monitoring procedures are not followed
- High risk areas are not being swabbed
- Zones are not identified
There are many ways that an environmental monitoring program can be improved so stay vigilant! If you are new to EMP, check out The Essential Guide to Environmental Monitoring.
5. HACCP Team Identifying Raw Material Hazards
The HACCP team must conduct a hazard analysis for all raw materials, ingredients, packaging material, and process steps to identify hazards, which need to be prevented, eliminated, or reduced to acceptable levels.
Description from the HACCP Audit Checklist Section: Conduct a Hazard Analysis
Raw Materials to Consider
- Water
- Packaging Materials such as poly-woven bags
- Compressed Air (Input)
- Salt
- Nitrogen
- Ingredients (Raw Material)
It is extremely common for a hazard analysis of packaging materials to be missed. All ingredients, packaging materials, water, and compressed air need to be included in the hazard analysis process and analyzed appropriately. As always, everything must be documented when conducting a hazard analysis on raw and packaging materials and include severity and probability of each hazard occurring. The hazard analysis should mirror the steps on the flow diagrams.
Final Thoughts on HACCP Non-Conformities
Whether you are preparing for your first HACCP audit or trying to improve your score, we can all learn something from the hurdles we collectively face. After reading this article, go back to your HACCP team and double check that you have considered everything outlined above. The HACCP non-conformities laid out are those that hundreds of facilities struggle with. If you have more questions about preparing for your next audit, Safe Food Alliance is here to help. Reach out to our team at contact@safefoodalliance.com.
