Process and Product Changes Require HACCP Re-Validation
Food safety, products and processes are always changing. To keep pace with these changes and demonstrate continued commitment to food safety through HACCP compliance, establishments need to re-evaluate their food safety management systems.
Hazard Analysis and Critical Control Points (HACCP) plans must undergo at least an annual review and update. However, a HACCP revalidation is also triggered by changes to either a product or processing method that could affect the hazard analysis.
Failure to keep HACCP plans up to date can have disastrous consequences, not only for business, but also for consumer health. In recent incidents the failure to re-validate a HACCP plan following process and/or equipment changes resulted in the production of unsafe food. This was then distributed as normal, with terrible consequences; people reportedly died, many more became ill, and there were widespread product recalls.
When Should Re-Validation Occur?
HACCP re-validation is no different to the initial validation, but can be triggered by events including:
- Product or process changes.
- System failure.
- Changes to a product’s distribution system.
- Updates/corrections to customer handling instructions.
- New scientific or regulatory information.
Under the principles of HACCP an establishment is required to validate the effectiveness of its HACCP plans in controlling food safety hazards identified within the hazard analysis. To effectively re-validate the plan, all elements need to be revisited. An HACCP plan comprises several elements:
- Hazard analysis.
- Supporting documentation.
- Prerequisite programs.
- Historic monitoring and testing records.
The task is not to monitor operations, or verify whether work has been completed according to the plan but to validate that an establishment’s plan can and will work. The focus of re-validation is to collect and provide scientific basis for decisions made during the development or reassessment of a HACCP system and provide evidence of hazard control. At the same time, the establishment will continue to operate within the existing HACCP plan. The re-validation does not occur in isolation, but alongside the establishment’s day-to-day operations for concurrent implementation.
HACCP Revalidation Process
There are two distinct elements to the validation/re-validation process:
Scientific/technical evidence for the HACCP system
Scientific and technical documentation should be collected and presented to support the critical control points and demonstrate compliance to current best practice and legal requirements. This material could include articles from peer-reviewed scientific journals, a documented study, published guidelines or in-house data. It should identify the hazard (biological, physical, radiological and/or chemical), the level of hazard prevention required, all critical parameters/conditions, how it will be achieved and how implementation and its success will be monitored.
Demonstrate the control measures identified in the scientific/technical documentation. In-plant observations, measurements, microbiological tests and any other information that demonstrates the critical control measures written into the HACCP system. The establishment needs to gather enough data to be able to demonstrate that the process can be operated effectively on a daily basis.
Who can Conduct Revalidation?
A qualified HACCP Auditor must conduct re-validation but the multi-disciplinary HACCP team that is responsible for developing, implementing and maintaining the HACCP system should support them.
Demonstrate Commitment to Safety
HACCP certification instantly demonstrates to customers your commitment to producing or trading in safe food. This evidence based approach can be particularly beneficial when you are subject to inspection by regulatory authorities or stakeholders.
Our global network of food experts carries out HACCP audits and helps you focus on the hazards that affect food safety and hygiene. It is then possible to systematically identify where the hazards are, by setting up control limits at critical points during the food production process.
Food Scientific and Regulatory Affairs Manager
SGS North America, Inc.