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How to Develop a HACCP Plan for California

Manager writing HACCP plan

What is HACCP?

HACCP stands for Hazard Analysis and Critical Control Point. A HACCP plan is a strategy for preventing food contamination at critical points of the food process.

Depending on what type of business you run and where you operate, you may be required to have a HACCP plan. Even if you’re not required to develop a formal HACCP plan, it’s a good idea to become familiar with and implement basic HACCP principles in your establishment.

HACCP requirements in California

If you have a business that sells or distributes food to consumers in California, you may be required to have a HACCP plan if you do any of the following things:

  • Smoke food as a method of food preservation rather than a method of enhancing flavor
  • Cure food
  • Use food additives or add vinegar as a method of food preservation rather than a method of enhancing flavor
  • Have a display tank with molluscan shellfish that are offered for human consumption
  • Use acidification or water activity to prevent Clostridium botulinum
  • Package potentially hazardous food using a reduced-oxygen packaging method
  • Custom process animals
  • Manufacture or distribute fish products
  • Process juice or other products that include juice as an ingredient
  • Prepare food using another method that requires a HACCP plan, including sous vide and other cook/chill methods that involve reduced-oxygen packaging

If any of the above activities apply to you, check with your local regulatory agency about what specific requirements you need to fulfill and the process you need to follow.

In general, if your business is required to have a HACCP plan, the state of California requires that you do the following:

  1. Conduct a hazard analysis. The FDA Hazard Analysis Worksheet can help you think through potential hazards in every step of your food preparation process. The worksheet is available in Appendix 1 of the FDA’s e-book Fish and Fishery Products Hazards and Controls Guidance.
  2. Create a flow diagram that summarizes your food preparation process and the critical control points associated with it. A sample flow diagram is in Appendix 2 of the FDA’s e-book.
  3. Develop a HACCP plan. The FDA HACCP Plan Form can help guide you through the plan development, including creating controls for potential hazards, monitoring and verification procedures, and correction procedures. You can find the form in Appendix 1 of the aforementioned e-book.

Although federal regulations don’t require you to use the FDA’s standardized HACCP Plan Form, using it can help speed up regulatory review.

HACCP plan example

The following is an example of a HACCP plan for yellowfin tuna, based on the FDA’s standardized form:

Company Name: Tuna Inc.

Company Address: 123 Tuna Way, Santa Monica, CA 90291

Product Description: Yellowfin tuna (Thunnus albacares). Fresh tuna steaks vacuum-packaged in plastic bags.

Method of Distribution and Storage: Distributed and stored frozen.

Intended Use and Consumer: To be fully cooked before consumption by the general public.

Significant Hazard(s) (includes potential species-related hazards as well as process-related hazards): Parasites are reasonably likely to occur in Thunnus albacares. Clostridium botulinum is also reasonably likely to occur during the process of vacuum-packaging tuna.

Critical Control Points: The fish will be frozen and packaged, then pasteurized to kill C. botulinum bacteria. The package will also be labeled with instructions to cook tuna to 155°F to kill bacteria.

Critical Limits for Each Preventive Measure: Initial freezing will occur at negative 31°F; after the fish is frozen solid, it will be held at negative 4°F for at least 24 hours (FDA has stated these temperatures are cold enough to kill parasites). Similarly, pasteurization will follow the FDA’s recommendations.

Monitoring
What (What will be monitored?) How (How will it be monitored?) Frequency (How often will it be monitored?) Who (Who will monitor it?)
Temperature of frozen tuna Check freezer thermometer and fill out a temperature log The log will be checked at least once every 24 hours; in other words, each new shipment of fish will be checked at least once in the freezing stage Evening shift manager

Corrective Action(s): Evening shift manager will: prevent fish from moving to the pasteurization stage until it has been held at negative 4°F for at least 24 hours; determine (if possible) the shift during which the error occurred; and remind (or assign another shift manager to remind) employees of critical limits for frozen tuna.

Records: In accordance with federal law, the following records will be kept for work done in the past two years:

  • Name and location of the company
  • Temperature logs, which should include the date, time, and the signature or initials of the person checking the temperature

Verification: The following verification actions will take place:

  • Each day: Make a visual check of the freezer thermometer and temperature log. Make sure the thermometer doesn’t look damaged and that there’s sufficient paper and ink to allow employees to fill out the log.
  • Each week: Review monitoring and corrective action records to ensure they were completed and any deviation from the critical limits was appropriately addressed.
  • Each year (or more often depending on manufacturer recommendations): Calibrate the freezer thermometer to ensure it’s working correctly.

After you’ve completed your HACCP plan, you should sign and date it. Keep the plan on file at your establishment. You may also want to keep your hazard analysis notes in case a health inspector asks to see them.

For a basic introduction to HACCP, check out our 7 Steps of HACCP poster or our food manager training course.

— Jessica Pettit

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