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Food Safety Program
Based on Process Approach to
HACCP
Summer 2011
0
USDA Food Safety
Requirements
•
•
•
Effective July 1, 2005
USDA Interim Rule published
June 15, 2005
Final rules to formalize food
safety requirements published
on August 8, 2008 form
comments
1
USDA Food Safety
Requirements
Public Law 108-265
1. Request two annual food safety
inspections for each
preparation/serving site
participating in NSLP and/or SBP
2
USDA Food Safety
Requirements
Public Law 108-265
2. Public Notification
• Post copy of most recent safety
inspections at each
preparation/serving site
• Provide copy upon request
3
USDA Food Safety
Requirements
Public Law 108-265
3. State/Federal Audits to Assure
Compliance
• DPI must report # of inspections to USDA
• Info is obtained from Schedule A of on-line
contract
• “Meals not served” is response if there is no
meals service at school listed on Schedule A
4
USDA Food Safety
Requirements
4. Implement Food Safety
Program based on Hazard
Analysis Critical Control Point
(HACCP) principles
• Schools participating in the
NSLP and/or SBP
• Guidance issued on June 10,
2005
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USDA Food Safety
Requirements
Schools with HACCP based food
safety program in place may
retain their current program if it
includes all the HACCP
principles listed in USDA
guidance
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Who were effected by regs?
School agencies participating in
USDA’s NSLP and/or SBP
926 school agencies (districts & private schools)
Approximately 2,400 buildings
 DPI’s School Nutrition Team
 DHFS’s Division of Public Health and
agents
 School Nutrition Association (SNA) of WI
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Wisconsin’s Compliance Plan
Developed by representatives from:
• DPI’s School Nutrition Team
• Department of Health/Agents who
conduct food safety insepctions
• SNA of WI
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Final Rule
Effective January 14, 2010
Codifies the food safety plan requirements
Addresses recordkeeping requirement
Include food safety program as part of
state agency administrative reviews
• Extends food safety program requirement
to school breakfast program
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•
•
•
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Reauthorization 2010
HHFKA/ Public Law111-296
• Strengthens existing food safety requirements for
all FNS programs (NSLP, SBP, FFVP, SMP, plus
Afterschool Snack & Supper Programs)
• Food safety plan based on HACCP must be
applied to any facility or part of facility where
food is stored, prepared or served for FNS
programs
• USDA anticipates minor updates for meal/milk
service on school buses, in hallways, kiosks,
classrooms, or other areas outside cafeteria
• Effective ASAP/n o later than 2011-12 school year
• USDA will develop “practical” guidance
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USDA Guidance - June 2005
School Food Safety
Program Based on
Process Approach
to HACCP Principles
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Purpose of School Food Safety
Program
Ensure the delivery of
safe foods to children in
school meal programs by
controlling hazards that
may occur or be
introduced into foods
anywhere along the flow
of food from receiving to
service – USDA
Guidance
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What is Hazard Analysis
Critical Control Point (HACCP)?
A scientific and rational approach to
food safety which:
• analyzes potential hazards
• determines the critical control points in a
food process
• develops monitoring procedures to
determine if the hazards identified are
effectively controlled
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Why is HACCP the “Gold
Standard” in food service?
• Foodborne illness outbreaks are major
financial and public relations cost to the
food service industry
• Children are vulnerable
• Visual inspections of food product cannot
detect pathogens
• Documented HACCP controls can prevent
foodborne illness from occurring
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Seven Principles of HACCP
1. Conduct a hazard analysis
2. Identify critical control points
3. Establish critical control point
monitoring
4. Establish corrective action
5. Establish verification procedures
6. Establish record keeping
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Differences Between
Traditional and Process
Approach
• Traditional HACCP focuses on recipes
• For process approach:
– Menu items are grouped into a given
food preparation process that have
similar hazards
– Actions or activities used to prevent,
eliminate or reduce hazards are similar
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Plan for Each
Production/Serving Site
• Documents menu items in appropriate
HACCP process category
• Identifies critical control points and
control measures
• Includes monitoring responsibilities and
forms to be used
• Establishes and documents appropriate
corrective actions taken
• Includes records to show plan is
operational
• Ongoing review and plan revisions
needed
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Nine Steps for Plan
Development
1.
2.
3.
4.
5.
6.
7.
8.
9.
Describe each preparation/serving site
Categorize menu items as process 1, 2, or 3
Identify critical control measures and limits
Develop and /or adapt prototype Standard
Operating Procedures (SOPS) specific to site
Establish monitoring procedures
Establish corrective actions
Choose appropriate monitoring records
Provide training
Review and revise food safety program period
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Step 1: Site Description
• Separate plan specific to site
• Include equipment inventory
• Floor plan is not needed for process
approach
• Description for the individual site plan
should reflect what is done at
preparation/serving location
• Same set ups may have same plan
• Obtain assistance from those who prepare
and serve
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Step 2: Categorization Process
Start with school menus (lunch & breakfast)
Include a la carte items and other items served
as part of Afterschool Snack Program, Fresh
Fruit and Vegetable Program (if applicable)
• Complete chart to indicate the category
• Minimize lists by grouping like items
– Canned fruit
– Dairy products
– Purchased bread products
– Fully cooked chicken products
• Some items to list separately:
– Fresh melon and strawberries
– “Casseroles” with various ingredients &
cooling processes
•
•
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Process Approach to HACCP
• Categorize all items including:
– Potentially Hazardous Foods (PHF):
■ Egg ■ Meat ■ Dairy ■ Heated
Vegetables/Fruits
– Non-Potentially Hazardous Foods:
■ aw of 0.85
or less
■ pH of 4.6
or less
■ Hermetically
sealed
• Place * by PHF (T/TC) such as melons &
strawberries
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Process Approach to HACCP
Group items according to number of times
the food goes through the “danger zone”
(41°F. and 135°F.)
• Process #1 – No Cook
– Menu item is not in the danger zone
• Process#2 – Same Day Service
– Menu item takes one trip through danger zone
• Process#3 – Complex Food Preparation
– The menu item goes through both heating and
cooling, taking two or more trips through the danger
zone.
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Trips through the Danger Zone
135°F
0
1
1
2
3
41°F
No Cook
Same Day
Complex
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Process #1 – No Cook
Receiving → Store → Prepare → Hold →
Serve
Sub Sandwich with Ready to Eat Ingredients
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Process #2 – Same Day
Service
Receiving → Store → Prepare → Cook →
Hold → Serve
• Menu items made from canned, packaged,
frozen, raw ingredients that involve a
cook step.
– Heated canned or frozen vegetables
– Pizza
– Fully cooked
chicken products
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Process# 3 – Complex Food
Receiving → Store → Prepare → Cook →
Cool → Reheat → Hold → Serve
• Menu items with preparation steps which
may require cooling and reheating prior to
being served
– Spaghetti Sauce
– Turkey and Gravy
– Hard boiled eggs
– Heated Leftovers
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Step 3: Identify Critical
Control Points & Measures
Critical Control Point (CCP) an operational
step in a food preparation process at
which control can be applied and is
essential to prevent or eliminate a hazard
Control Measures - any action or activity
that can be used means taken to prevent ,
eliminate, or reduce hazards to an
acceptable level (Refer to flow charts on p.
9-10 of prototype)
Critical Control Points
• Points in food preparation/processing
where controlling a step is essential to
assure food safety
– Receiving
– Cold Holding
– Cooking
– Hot Holding
– Cooling
– Reheating
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Critical Measures in Process
Approach HACCP
• No Cook:
– Cold holding or limiting time in the danger zone to inhibit
bacterial growth and toxin production (e.g., limiting time item is
at room temperature and discarding items that reach limits.
• Same Day Service:
– Cooking to destroy bacteria and other pathogens
– Hot holding or limiting time in the danger zone to prevent the
growth of spore-forming bacteria.
• Complex Food Preparation:
– Cooking to destroy bacteria and other pathogens
– Cooling to prevent the outgrowth of spore-forming bacteria
– Hot and cold holding or limiting time in the danger zone to
inhibit bacterial growth and toxin formation
– Reheating for hot holding, if applicable.
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Control Measures
.
• Include:
– CCPs
– SOPs
• Critical Limits
– Established for each processes
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Critical Limits
The time and temperature ranges for food
preparation and service (either hot or
cold) that keeps food safe.
– Cold holding = 41°F (Maximum)
– Hot Holding = 135°F (Minimum)
– Cooking = Time + Temperature
– Cooling
– Reheating Previously Cooked
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Critical Measures & Limits
Process 1
Example: Sub Sandwich with RTE Ingredients
General
Receive
Store
Prepare
Critical Measures & Limits
Process 1
Example: Sub Sandwich with RTE Ingredients
COLD HOLDING
Critical Limit: Internal
Temperature of 41°F
Check & Record
Temperatures
SERVE
Critical Control Measures &
Limits
Process 2
Example: Fully Cooked Chicken Nuggets
General
Receive
Store
Prepare
Critical Limits – Process 2
Example: Fully Cooked Chicken Nuggets
COOK/REHEAT FULLY
COOKED PRODUCTS
Critical Limit: Internal Temperature of
135°F for 15 seconds
Check & Record Temperatures
Critical Limit: Hot hold at no less
than 135°F.
Check & Record Temperatures
SERVE
Critical Control Measures &
Limits for Process 2
Raw Beef for Spaghetti Served on Same Day
General
Receive
Store
Prepare
Critical Limits – Process 2
Raw Ground Beef for Spaghetti Sauce – Served Same
Day
COOK/GROUND BEEF
Critical Limit: Internal Temperature of
165°F for 15 seconds
Check & Record Temperatures
Critical Limit: Hot hold at no
less than 135°F.
Check & Record Temperatures
SERVE
Critical Control Measure
& Limits - Process 3
Raw Ground Beef for Spaghetti Sauce – Served Next
Day
General
Receive
Store
Prepare
Critical Limits – Process 3
Raw Ground Beef for Spaghetti Sauce – Served Next
Day
COOK/GROUND BEEF
Critical Limit: Internal Temperature of
165°F for 15 seconds
Check & Record Temperatures
Critical Control Measures &
Limits Process 3
Raw Ground Beef for Spaghetti Sauce – served next day
Critical Control Point:
COOL
Critical Limit: Cool from 135 °F
to 70°F within 2 hours and
from 70°F to 41°F or lower
within an additional 4 hours.
Check & Record Temperatures
Critical Limits – Process 3
Raw Ground Beef in Spaghetti Sauce – Served Next Day
Critical Control Point:
REHEAT
Critical Limit: Heat to 165 °F for
at least 15 seconds.
Check & Record Temperatures
Critical Control Limits &
Measures - Process 3
Raw Ground Beef in Spaghetti Sauce - Next Day Service
Critical Limit: Hot hold at no less
than 135°F.
Check & Record Temperatures
SERVE
Critical Control Measure
& Limits - Process 3
Turkey Roast (Raw – Served Next Day
General
Receive
Store
Prepare
Critical Control Measures & Limits
Process 3
Example: Turkey Roast (Raw) & Gravy
General
Receive
Store
Prepare
COOK/Raw Turkey Roast
Critical Limit: Internal Temperature
of 165°F for 15 seconds
Check & Record Temperatures
Critical Control Measures &
Limits Process 3
Turkey Roast (raw) & gravy – served next day
Critical Control Point:
COOL
Critical Limit: Cool from 135 °F
to 70°F within 2 hours and
from 70°F to 41°F or lower
within an additional 4 hours.
Check & Record Temperatures
Critical Limits - Process 3
Example: Turkey Roasts (raw) & Gravy
Critical Control Point:
REHEAT
Critical Limit: Heat to 165 °F for
at least 15 seconds.
Check & Record Temperatures
Critical Control Measures & Limits
Process 3
Example: Turkey Roasts (raw) & Gravy
Critical Limit: Hot hold at no less
than 135°F.
Check & Record Temperatures
SERVE
Critical Control Measures &
Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated
Leftover
General
Receive
Store
Prepare
Critical Limits – Process 2
Example: Fully Cooked Chicken Nuggets – Heated
Leftover
COOK/REHEAT FULLY
COOKED PRODUCTS
Critical Limit: Internal Temperature of
135°F for 15 seconds
Check & Record Temperatures
Critical Limit: Hot hold at no less
than 135°F.
Check & Record Temperatures
SERVE
Critical Control Measures &
Limits Process 3
Example: Fully Cooked Chicken Nuggets – Heated
Leftover
Critical Control Point:
COOL
Critical Limit: Cool from 135 °F
to 70°F within 2 hours and
from 70°F to 41°F or lower
within an additional 4 hours.
Check & Record Temperatures
Critical Limits – Process 3
Example: Fully Cooked Chicken Nuggets - Heated Leftovers
Critical Control Point:
REHEAT
Critical Limit: Heat to 165 °F for
at least 15 seconds.
Check & Record Temperatures
Critical Control Measures &
Limits
Process 3
Example: Fully Cooked Chicken Nuggets - Heated
Leftovers
Critical Limit: Hot hold at no less
than 135°F.
Check & Record Temperatures
SERVE
Step 4: Develop/Adapt SOPs
SOPs are written instructions for a food
service task that reduce food safety
hazards. Usually written to include:
– Who?
– What?
– When?
– Where?
– How?
– Why?
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Components of USDA’s SOPs
Purpose (What)
Scope (Who does this apply to)
Keywords (New terms)
Instructions (How, Where and When)
Monitoring (Why)
Corrective Action (What to do if there is a
problem)
• Record Keeping
•
•
•
•
•
•
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SOPs Developed by DPI School
Nutrition Team for Prototype
• Adaptation of USDA’s & Iowa State
University SOPs
• Include WI Dept. of Health Services Food
Code Fact Sheets
• Minimized number of SOPs by grouping
items - examples:
– No bare hand contact with glove use
– Manual and Machine dishwashing
• Monitor for critical control points Only
55
What SOPs Do You Need?
• Address critical control measures
for process 1, 2 & 3 potentially
hazardous foods in your
operation
• Provide food safety foundation
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Step 5: Establish Monitoring
Procedures
• Considerations:
– What is monitored?
– How will you monitor?
– When and how often will you monitor?
– Who will be responsible for monitoring?
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What is Monitored
Critical control measures
Most involve measurements
involving temperature & time
&
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Who Monitors
•
•
•
•
•
Directly associated with the operation
Trained and knowledgeable
Accessible to monitoring activity
Responsible
Specify position and back up
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Step 6: Establish Corrective
Action
• Needed whenever a critical limit is not
met
• Must be carried out immediately
• Employees must know what is expected
and how to make right decision
• Determined for all CCPs
• Include summary in each school plan
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Corrective Action
Example
Cooler not maintaining 41°F temperature
– Is cooler is working properly?
– Is thermometer calibrated?
– Report temperature reading to supervisor if
cooler is not working properly
– Supervisor contacts service repair person if
thermometer is accurate
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Step 7: Maintain Records
• Food Safety Plan
• Records to be kept
– Receiving logs (or make use of invoices)
– Cold Holding Temperature logs
– Monitoring (cooking, cooling, and reheating and
other Critical Control Points)
– Corrective action
– Calibration records
– Training logs
• Documentation of activities provides proof that
reasonable care was exercised in the event your
school is implicated in a foodborne illness
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How long must records be
kept?
• Any combination records that include
production plans - 3 years plus current
• Monitoring records food safety
inspections - 6 months
Recommendation: Keep monitoring
records for school year to support food
safety plan and keep two most current
food safety inspection reports
63
Step 8: Provide & Document
Training
• Basic food safety
• Specific to
Process approach to
HACCP & the food safety plan
• Annual training schedule
• Documentation of training shows
there is employee participation in
plan
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Important Competencies
•
•
•
•
•
•
Basic food safety knowledge
Employee health reporting responsibilities
Proper handwashing/glove use
Thermometer usage and calibration
SOPs
Recordkeeping procedures
65
Helpful Job Aids
• Signage and posters at strategic locations
• Written recipes and daily production
plans that designating process category
• CCPs in written recipes
• Monitoring logs that includes temperature
ranges for cold holding, hot holding, etc.
66
Step 9: Review & Revise Food
Safety Plan
• Review and revise food safety plan at least
annually or as often as necessary to reflect any
changes
• Changes may include:
–
–
–
–
–
–
–
New equipment
New menu items
Different vendors
New programs
Reports of illness
Comments on a health inspection report
Other factors or changes in procedures.
67
Step 9: Review & Revise Food
Safety Plan, cont.
• Meet HHFK Act of 2010 provision which
requires review and update for all FNS
programs
• Consider making appropriate revision to DPI
prototype SOPs/monitoring logs now listed on
DPI website for:
– Breakfast Served in Classroom
– Milk/juice transported in coolers
– Prototype transport sheets for lunch, breakfast,
afterschool care snack
68
Food Safety Plan Review
Food Safety Inspection
• Determine if there is a completed plan for
each site
– Accurate Description
– Menu items categorized by process type
– SOP specific to food service operation &
followed
– Employees understand and follow SOPs
• Select three SOP’s to determine if
applicable and implemented
• Review monitoring records for three days
selected at random since last inspection
69
Food Safety Plan Review, cont.
• Are records maintained?
– Review by choosing 3 random days in
current school year to verify all records
kept.
– Check to see if:
• Appropriate temperatures are monitored and
recorded.
• Records appear accurate and consistent.
• Are corrective actions documented if a
critical limit is not met?
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Food Safety Plan Review,
cont.
 Is there a Employee Food Safety
Training Program in place?
 Plans reviewed and updated annually
and when there are changes?
 Report will be left summarizing results
of plan review.
 If there is no plan available:
 Must display inspection report that states “no
plan”.
 Expect follow up – environmental specialist will
notify DPI.
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Overall Considerations
 Time
 Simplicity
 Make changes in operation to make that possible
 Batch cooking to minimize holding
 Purchase /order fully cooked meat items
 Limit number of process 3 by eliminating cooling step
 Specific to food service operation
 Support and recognition from administration
& others
 Involvement & Input
 Continuous Improvement
72
Successful Implementation
Recommendations
Work with school administration to
develop strong school agency wide food
safety and security policy to cover:
–
–
–
–
–
–
–
School food service
Food brought from home
Vending
Field trips
Concessions
Use of facility by outside groups
Access to the school kitchen
73
Successful Implementation
Recommendations
1. Required food safety certification for all
management/supervisory personnel
2. Provide food safety education for all
employee & students
3. Develop self inspection programs
4. Stay informed about current food safety
regulations
Where to direct questions?
Contacts/Resources:
• Julie Shelton(School Program
Regulation Compliance)
• James Mack (WI Food Code &
Contact info for DHFS or Agent, &
Fee Schedule)
• Person who conducts food safety
inspections
75
Enjoy the Rest of the
Summer!
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