Your Hazard Analysis and Critical Control Points (HACCP) plan is there for a reason, and not complying with it is considered a non-conformance. Even though HACCP plans have been a legal requirement since 2006, I see the same non-conformances cropping up time and again.
To help you improve your plan, here are the top-five audit non-conformances:
• Validation. The HACCP plan is often validated prior to the current HACCP team being in place, as the line/factory may have been in production for years. This can make it difficult to find the validation information, but without this, a firm cannot guarantee that safe food will reach the consumer when challenged.
• Hazard analysis. Companies often group together hazards, such as plastic, metal and glass, under the same banner. But it does not mean they have the same control measures. So, different hazards should be separated.
• Critical Control Point (CCP) determination. Often, a company identifies the wrong decision tree within their HACCP plan, which can mean it also identifies the wrong CCPs. Another issue is when a team identify one decision tree, but actually use another to get the answers they want. The auditor should and must be able to use the decision tree named in the plan.
• Corrective action. This is when businesses become more concerned with dealing with the symptoms of a problem rather than addressing the cause. Sometimes, staff use a temporary fix, hoping the problem goes away – this is a disaster waiting to happen. Root cause analysis can be used to identify the correct cause so the problem can be resolved.
• Scope. You should summarise your firm’s food safety intent in a concise statement at the front of the HACCP plan. Often, the scope will be lacking key statements. A good scope will lay out for the business and the auditor what the HACCP plan aims to do.