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Food Safety Program Based on Process Approach to HACCP Summer 2011 1

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Food Safety ProgramBased on Process Approach to

HACCP

Summer 2011

1

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

2

USDA Food Safety Requirements

Public Law 108-2651. Request two annual food

safety inspections for each preparation/serving site participating in NSLP and/or SBP

3

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

4

USDA Food Safety Requirements

Public Law 108-2653. 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

5

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

6

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

7

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 TeamDHFS’s Division of Public Health and

agents School Nutrition Association (SNA) of WI

8

Wisconsin’s Compliance Plan

Developed by representatives from:

• DPI’s School Nutrition Team• Department of Health/Agents

who conduct food safety insepctions

• SNA of WI9

• 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

10

Final Rule

• 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

11

Reauthorization 2010HHFKA/ Public Law111-296

USDA Guidance - June 2005

12

School Food Safety School Food Safety Program Based onProgram Based onProcess Approach Process Approach to HACCP Principlesto HACCP Principles

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

13

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

14

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

15

Seven Principles of HACCP

1. Conduct a hazard analysis2. Identify critical control points3. Establish critical control point

monitoring4. Establish corrective action5. Establish verification procedures6. Establish record keeping

16

• 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

17

Differences Between Traditional and Process

Approach

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

18

Nine Steps for Plan Development

1. Describe each preparation/serving site2. Categorize menu items as process 1, 2, or 33. Identify critical control measures and limits4. Develop and /or adapt prototype Standard

Operating Procedures (SOPS) specific to site5. Establish monitoring procedures6. Establish corrective actions7. Choose appropriate monitoring records8. Provide training9. Review and revise food safety program period

19

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

20

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 processes21

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 ■ pH of 4.6 ■

Hermetically or less or less sealed

• Place * by PHF (T/TC) such as melons & strawberries

22

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.

23

Trips through the Danger Zone

24

135°F

0 1 1 2 3

41°F

No Cook Same Day Complex

Process #1 – No Cook

Receiving → Store → Prepare → Hold → Serve

Sub Sandwich with Ready to Eat Ingredients

25

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

26

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

27

Step 3: Identify Critical Control Points &

MeasuresCritical 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

29

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. 30

Control Measures

.• Include:– CCPs– SOPs

• Critical Limits– Established for each processes

31

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

32

General

Receive

Store

Prepare

Critical Measures & Limits Process 1

Example: Sub Sandwich with RTE Ingredients

Critical Measures & Limits Process 1

Example: Sub Sandwich with RTE Ingredients

COLD HOLDING

Critical Limit: Internal Temperature of 41°F

Check & Record Temperatures

SERVE

General

Receive

Store

Prepare

Critical Control Measures & Limits

Process 2Example: Fully Cooked Chicken Nuggets

Critical Limits – Process 2Example: Fully Cooked Chicken Nuggets

SERVE

Critical Limit: Hot hold at no less than 135°F.

Check & Record Temperatures

COOK/REHEAT FULLY COOKED PRODUCTS

Critical Limit: Internal Temperature of 135°F for 15 seconds

Check & Record Temperatures

General

Receive

Store

Prepare

Critical Control Measures & Limits for Process 2

Raw Beef for Spaghetti Served on Same Day

Critical Limits – Process 2Raw Ground Beef for Spaghetti Sauce – Served

Same Day

SERVE

Critical Limit: Hot hold at no less than 135°F.

Check & Record Temperatures

COOK/GROUND BEEF

Critical Limit: Internal Temperature of 165°F for 15 seconds

Check & Record Temperatures

General

Receive

Store

Prepare

Critical Control Measure & Limits - Process 3

Raw Ground Beef for Spaghetti Sauce – Served Next Day

Critical Limits – Process 3Raw 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 3Raw 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

General

Receive

Store

Prepare

Critical Control Measure & Limits - Process 3Turkey Roast (Raw – Served Next Day

Critical Control Measures & Limits Process 3

Example: Turkey Roast (Raw) & Gravy

General

ReceiveStore

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 3Example: 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 2Example: Fully Cooked Chicken Nuggets – Heated

Leftover

SERVE

Critical Limit: Hot hold at no less than 135°F.

Check & Record Temperatures

COOK/REHEAT FULLY COOKED PRODUCTS

Critical Limit: Internal Temperature of 135°F for 15 seconds

Check & Record Temperatures

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 3Example: 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

LeftoversCritical 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?

54

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

55

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

56

What SOPs Do You Need?

• Address critical control measures for process 1, 2 & 3 potentially hazardous foods in your operation

• Provide food safety foundation

57

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?

58

What is Monitored

Critical control measuresMost involve measurements involving temperature & time

59

&&

Who Monitors

• Directly associated with the operation

• Trained and knowledgeable• Accessible to monitoring activity• Responsible• Specify position and back up

60

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

61

Corrective Action

ExampleCooler 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

62

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

63

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

64

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

65

Important Competencies

• Basic food safety knowledge• Employee health reporting

responsibilities• Proper handwashing/glove use• Thermometer usage and calibration• SOPs• Recordkeeping procedures

66

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.

67

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.

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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

69

Food Safety Plan ReviewFood 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

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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?

71

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 ConsiderationsTimeSimplicity

Make changes in operation to make that possibleBatch cooking to minimize holdingPurchase /order fully cooked meat itemsLimit number of process 3 by eliminating cooling step

Specific to food service operationSupport and recognition from

administration & othersInvolvement & InputContinuous Improvement

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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

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Successful Implementation

Recommendations1. 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

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Enjoy the Rest of the Summer!

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