Hazard Analysis Critical Control Points or HACCP for short – It’s the foundation for food safety worldwide, the program that brought food manufacturing into alignment, and a powerful tool for pinpointing risk. What is even more powerful is to look at HACCP thru the lens of a specific industry. Take the tree nut industry; some pathogens of concern are Salmonella and Listeria monocytogenes, which may not occur at the same level in other types of produce.
When we look at non-conformities for a specific industry, we can see the things tree nut companies struggle with, break the requirement down, and offer some solutions. Below is data collected from HACCP reports of tree nut facilities in the past year. This article explores the top three non-conformities our team has seen while auditing and the expectations for pre-requisite programs that support the HACCP program.
When looking at HACCP Non-conformities, it is important to understand that whichever food safety stage your company is in, Good Manufacturing Practices (GMPs) and HACCP principles are the foundation on which each company improves and builds its food safety program. HACCP is also the backbone of the Global Food Safety Initiative (GFSI) benchmarked Safe Quality Food Initiative (SQFI) and British Retail Consortium (BRC) Audits. Once you create your program, you should use your HACCP audits to verify your HACCP plan.
The Top Three HACCP Non-Conformities Explained
1. Section 03: Sanitary Operations – this area accounts for 25% of the non-conformities!
Sanitary operations is a section that covers many parts of the production facility. When preparing to meet the requirements in this GMP based section, consider the following:
- How am I handling building maintenance and sanitation?
- Are the tools I’m using food-safe, and am I keeping them clean?
- Does my facility cleaning plan meet the Sanitary Operations requirements?
- How am I controlling for cross-contamination?
- What is my plan for pest management?
Problem: This section has three common areas of confusion: accurate labeling, cross-contamination, and improper pest control.
Labeling and Proper Labeling: We often see no label present, or the label does not reflect what is inside. It is essential, whether it is chemicals, waste, or tools, that you place each in the container or bin specified in your plan. Examples:
- A grey container is used for storing trash when the grey color container is designated for reworking product.
- A blue food-contact bucket being used to store sampling bags, a red rag, and a spray bottle containing sanitizer at the Receiving area.
Cross-Contamination: When it comes to cross-contamination, you want to focus on tools, equipment, and personnel, as these are the easiest ways to occur in the plant. Personnel, especially, can create bad habits that can lead to contamination.
- A Metal Detector Operator dropped a metal detector test piece on the floor before testing the inline Metal Detector. The MD Operator picked the test piece back up without doing the following: changing gloves or washing hands and sanitizing the test piece before checking the metal detector.
- A red non-food contact broom was placed inside a food contact grey product container.
Improper Pest Control: The most significant issues we have seen with this non-conformity have to do with using traps correctly.
- A rodent trap was blocked in the shop.
- A snap trap was found outside on top of a roll up door ledge and not located on ground level.
- A snap trap was not on the facility’s pest control map.
Solutions in three parts: With labeling, create your color-coding system and stick to it. And as always, don’t forget to train your team on the plan you’ve made. Follow-thru from the team is just as important as the HACCP plan that is created.
To address cross-contamination issues, it is a good idea to look at your company’s food safety culture. A well-developed food safety culture starts from the top-down, with commitment from the management team to make food safety a priority. If you have trouble convincing decision-makers that food safety is a priority, let them know that a measurable food safety culture is becoming the norm. This year, SQF’s new code specifically called out a need for a food safety culture, and it is already required by many GFSI certifications, which are needed to sell to most large retailers.
When it comes to pest control, spot check frequently and make employees aware that you are having issues with this section so they can be part of the solution. Sometimes cleaning personnel move traps and don’t put them back. If your team understands the purpose of the traps and how they work, they will keep it in mind to move the traps back in place. If you work with a third-party pest control service, check-in on them to ensure that they perform the service you expect of them. You can do this by conducting an internal audit and placing numbers in traps, and having your service technician bring back the numbers.
2. Sections 02: Plants & Grounds
In this section, the areas where mistakes are made have to do with damage to the building and how that damage can allow pests to enter the plant.
- Gaps in the wall/roof junction are large enough for pest entry.
- Open-ended pipes stored behind a Fumigation Storage Shack located outside which can pose a pest harborage risk.
- A false plywood wall where a forklift had accidentally crashed through—creating pockets on the base of the wall.
- Gaps around the large sliding doors, peeling paint, rusting pipes, and pinholes in the ceilings were found where fiber and sacks are stored.
Damage to the Building
- Water was dripping into a grey trash bin and collecting on the ground under the cardboard collection rack, outside from the oil mill.
- The rain gutter over the shipping dock area was observed, with grass growing inside of the gutter.
- Weatherstrips on exit man doors were missing on the bottom of the door.
- The forklift entry door wall (brick wall) from the prunes processing area to the finished goods warehouse was observed to have some damaged bricks on the wall.
Solution: If you see something, report it. Get your employees involved more frequently. Explain the “Why” to your staff. If they understand why and see that you care, they will care.
3. Sections 05: Equipment & Utensils Design
Section 5 relates to the state of our equipment; is it broken? How long have I had it? Are my repairs safe even if they are temporary? With utensils, our auditing team sees minor fixable mistakes.
- A Forklift was observed with cardboard secured to the roof of the forklift cage to protect the driver from the rain and is a temporary repair.
- Duct tape was used to keep a piece of metal intact after the incline belt and before walnuts enter the bucket elevator. The duct tape is above the open product line.
- Shoelaces were used to hold a pipe in place by the vibratory of laser 1.
Wear & Tear
- A Forklift in the line had a torn seat cover with exposed insulation.
- At the cleaning line, there was a vinyl curtain strip around the opening for bucket elevators that was worn out (torn and frayed) from the normal wear and tear of moving parts.
- A white water hose close to the product had many gashes in the hose fabric. This created many fibrous pieces to stick out of the hose material.
Improper Use & Storage
- There was a blue scoop (color coding designated for raw product contact) at the outside wall of the cleanroom. The color code chart nearby did not state designation for use.
- The plastic bin liner dispenser dowels were open-ended throughout the plant, posing a risk for product harborage.
- A wooden handle tool was used in the production area, which can contribute to foreign material in the product.
Solutions: Have a proper work order process for maintenance. Be sure that your team is closing work orders. Follow-up is critical in this section. It is also essential for there to be continued management commitment to keeping up with the maintenance of the facility. Repairs are a financial investment. These types of repairs need to be prioritized so QA teams can do their jobs effectively. If the product is not safe for consumption, everyone loses.
The beauty of the food industry is that we are constantly evolving (like the pathogens we protect against). It’s important to learn from one another and realize that no company is perfect. Many companies struggle with the same issues, especially if they work with the same commodities. It’s easy to see non-conformities as frustrating, but auditing, and especially internal auditing, should be seen as a tool to make your food safety program stronger.
If you need assistance with your food safety program, reach out to the Safe Food Alliance team at firstname.lastname@example.org. We would be happy to help.