Steps to Starting and Implementing a HACCP Plan

Implementation and certification:

There are a number of reasons why a facility would implement a HACCP plan, outside of the need to comply with the FSMA. For example, a customer may require their suppliers to be HACCP certified, or they may want to use a HACCP certification as a marketing tool — a seal of feed safety approval. If they choose to take that route, an accredited third-party HACCP auditing firm must audit the facility.

HACCP audits are used to verify the effectiveness of the overall HACCP system. As part of the audit, the third party will:

• Review records (SOPs, HACCP plan, etc.)
• Review adherence to manufacturing and housekeeping procedures
• Have discussions with employees to gauge their understanding of the HACCP program and their responsibilities
• Review equipment calibration records
• Review employee training records

After the initial comprehensive third-party audit, additional partial audits typically will be conducted over the next two years. On the fourth anniversary of the initial audit, the audit cycle starts over with another comprehensive audit.

A facility may also choose to implement HACCP, but forego a third-party audit. According to Epperson, many companies implement the seven principles of HACCP simply as a way to discover any weaknesses or potential hazards in the facility. But they may not need to, or be able to, produce the fees for the audit and certification process.

“They recognize the value of HACCP in regard to what it can do to improve the safety of their processes and their facility, but it may not be necessary to become certified if their customers are not asking them to become certified.”

Whether or not implementation ends in a third-party audit and certification, completing the seven principles of HACCP is worth the effort as an aid in complying with the Food Safety Modernization Act.