Corrective action

A deviation is a failure to meet a critical limit or to follow a GHP procedure. A corrective action is any action taken when a deviation occurs. It has three jobs. It re-establishes control. It separates the affected product and decides what happens to it. And it prevents or minimises a repeat.

Codex says specific written corrective actions should be developed for each CCP. They are decided in advance, so that nobody has to work out the right answer under pressure.

The first job is to get the process back under control. Repair the fridge, turn up the oven, or stop the line.

The second job is to deal with the food. Separate it, label it, and do not let it move on. Then work out how much is affected. If monitoring was not continuous, the business should decide what product may have been affected. In practice this usually means going back to the last good check.

Here is an example. A walk-in chiller was fine at the 10pm check and reads 12°C at 7am. Nobody knows when it failed. So everything held in that chiller since 10pm is potentially affected, even if it looks and smells normal.

Then decide what happens to the food. It may be possible to reprocess it, or to use it for something else, or it may have to be destroyed. Some problems cannot be cooked away. Toxins from Staphylococcus aureus, for example, may mean the food must be destroyed. A named person with enough knowledge should decide, and may need expert advice.

The third job is to stop it happening again. Ask why it happened until you find the root cause. If a cook undercooked a batch because the oven was running cool, retraining the cook will not fix the oven. Sometimes retraining is the right answer. Often it is not.

Record the details, including the cause and what happened to the food. Records of corrective actions should be reviewed from time to time to spot patterns and to check that the actions work.

If the food may already have left your control, more is required. Under Article 19 of Regulation (EC) 178/2002, a business that considers its food does not meet food safety requirements must start to withdraw it and tell the competent authorities. If the food may have reached consumers, the business must tell them why and, if necessary, recall it.