Integrating with prerequisite programmes

HACCP is not a separate project. Codex describes a food hygiene system as prerequisite programmes, supplemented with control measures at CCPs as appropriate, that together ensure food is safe and suitable for its intended use. Treat it as one system.

Codex says prerequisite programmes should be well established, fully operational and verified, where possible, and that HACCP will not be effective without them.

Your hazard analysis depends on your prerequisites. When you score glass as unlikely because lights are covered, the light covers become part of your reasoning. If you score cross-contamination as low because of a cleaning programme, that programme now carries real weight. So list the prerequisites the plan relies on, give each one an owner, and verify them. If a prerequisite fails, your risk scores may no longer be true.

GHPs that need greater attention sit between routine GHPs and CCPs. Cleaning equipment that touches ready-to-eat food, allergen clean-downs, hand hygiene in a high-risk area, and the separate complex equipment that FSA guidance on E. coli O157 requires for raw and ready-to-eat food can all be examples. Greater attention may include a higher frequency of application, of monitoring and of verification.

Join up the systems you already run. Use one calendar for monitoring, verification, audits and reviews. Use one log for deviations and corrective actions, whatever their source. Link HACCP with supplier approval, complaints, training, maintenance, traceability and product development. New products should enter the HACCP process at the design stage, not after launch.

Keep the priorities clear. If food safety limits sit in the same list as quality specifications, staff may treat them alike. Mark clearly which limits are critical to safety.

Maintenance is a good example of why integration matters. A planned service of the blast chiller may reduce capacity for a day. If engineering and production do not talk to the HACCP team, nobody will check whether the cooling limit can still be met.