CASE STUDY

Implementation of Hazard
Analysis of Critical
Control Points (HACCP)
-- A Food Safety Management
System in Pakistan

PAKISTAN INSTITUTE OF QUALITY CONTORL

304, 3rd Floor, Eden Centre, 43 Jail Road
Lahore – Pakistan
Ph: (+92 42) 7563645-7562260 Fax: 7552656
E-mail: piqc@brain.net.pk; Web Site: http:///www.piqc.com.pk

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 Implementation of Hazard Analysis of Critical
Control Points (HACCP),
“A Food Safety Management System”, in Pakistan

by

Mr. Muhammad Abdul Basit

Manager Quality Systems

Chaudhry Dairies Limited

WHAT IS HACCP?
HACCP (Generally pronounced as “Hyssop”) stands for “Hazard Analysis of
Critical Control Points”. It is a systematic and science based approach for
identification, assessment and control of food safety hazards. From a practical point of
view, it is the most effective tool to prevent the occurrence of food borne diseases and
to avoid consumer injuries and illness linked to consumption of products.

HACCP has been internationally acknowledged by FAO/WHO through Codex

Alimentarious, Ag Canada and International Life Science Institute (ILSI). It is becoming
increasingly mandatory for all food business as an effective means of ensuring food
safety, quality and as a mean of complying with new legislation. As a regulation, it has
been embraced by USA, UK, European Union, Japan, Canada, Australia and New
Zealand till now.

HACCP can easily be incorporated into ISO 9000 or TQM based quality
management systems and has got very strong relationship with systems like Risk
Management, Good Manufacturing Practices, Good Laboratory Practices, Preventive
Maintenance Systems, Non Safety Regulatory Requirements and Standards Sanitary
Operations Practices (SSOP). (HACCP and ISO relation diagram annex – 6))

HISTORY OF HACCP

• 1960 – NASA (National aeronautics and space administration) & U.S.Military

Natick Laboratory - to establish risk of Salmonella infection.
• 1971 - HACCP Concept took proper form in National Conference on Food
Protection.
• Pillsbury Company used it in U.S space program. To make the food free from
food borne hazards (bacterial & viral) to use it in space. Dr. Bauman
• 1973 – First comprehensive treatise on HACCP was published by Pillsbury
Company. HACCP principles were developed in very primary form and FDA
inspectors were trained.
• 1985 – HACCP was recommended by National Academy of Science (NAS)
USA
• 1987 – National Advisory Committee on Microbiological Criteria for Foods
(NACMCF) was established.

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 • 1989 – National Advisory Committee on Microbiological Criteria for Foods
(NACMCF) gave the final approval for HACCP document, and it was sent to
cabinet secretaries of department of agriculture, health and human services.
• 1989 – NACMCF published - HACCP Guidelines titled “HACCP Principles for
Food Production (Famous HACCP Seven Principles).
• 1989 – NACMCF’s HACCP Guide addressed only microbiological hazard,
however, it was intention of the committee to include chemical and physical
hazards. In the system.
• 1989 - Chemical and Physical hazards were included in the HACCP system.
• 1992 – Updated version was published by NACMCF that was compatible to the
Codex Committee report on Food Hygiene, published in 1991.
• 1995/6 – HACCP was first time used in US Regulations
• 1997 – UN/Codex Alimentarious HACCP System was developed and adopted
by US regulatory authorities.
• 2000 – Not only USA but Europe as well as many other areas in the world have
accepted this as a food safety system through legislation
• 2000 – Today this concept has expanded on following lines:

a) Medical Devices
b) Market-driven HACCP
c) Regulatory-driven HACCP
d) Integrated product safety system (e.g. “farm-to-table”; “concept-to-end-
use”)

SCOPE:
Increase number of terms are being used to describe the scope of this system,
‘farm to fork’, stable to table, and gate to plate. As a matter of fact, HACCP is for every
one and encompasses the entire food chain. That’s why it is said that full benefits of
HACCP can only be obtained if it is applied throughout the supply chain, i.e. from
product design and incoming material suppliers through manufacturing and distribution
up to the preparation and consumption by the end user.

Commercially this system is mainly applicable to;

1. All food processing facilities/factories:

• Fish industry
• Meat industry
• Beverage industry
• Cereal Industry
• Confectionary Industry
• Dairy industry
• Sugar Industry
• All other food processing concerns

2. Hotels & Restaurants

3. Hospitals
4. Specialized areas where effect of food may become critical.

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WHY HACCP
BENEFITS:

Successful implementation of HACCP brings along ;

PRIMARY BENEFITS

• Product Safety

SECONDARY BENEFITS:

• Quality improvement
• Cost effectiveness
• Loss and down time reduction
• Increase consumer confidence in product safety
• Design of line/product
• Hygiene and housekeeping
• Reduce maintenance
• Reduce inspection time
• Improve manufacturing conditions
• Competitive advantage

HACCP PREREQUISITES

1. Management commitment
2. Recourses (finance & manpower)
3. Training & education
4. Facilities (adjacent properties, building exterior/interior)
5. Raw materials controls (e.g., specifications, supplier approval, receipt and
storage, testing)
6. Sanitation and personal hygiene (e.g. master schedule, pest control,
environmental surveillance, chemical control, housekeeping cleaning (routine)
personal health and hygiene)
7. Production controls (e.g., product zone controls, foreign material control, metal
protection program, allergen control, glass control)
8. Storage and distribution (e.g., temperature and humidity control; transport
vehicle cleaning and inspection)
9. Product controls/traceability (e.g. labeling; complaint investigation and product
recall) &
10. Basic support network.

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 Good
Manufacturing
Practices

Statistical Proper
Process Control Calibration

HACCP
Supplier Good
Quality Laboratory
Assurance Practices

Preventive Incident
maintenance Management
System

Personnel Quality
And Management
Training System

The HACCP Basic Support Network

HOW HACCP IMPLEMENTED

We can implement this very effective continuos food safety improvement engine by
adopting Seven famous principles of HACCP, explained in Codex Alimentarious - a joint
publication of FAO and WHO and by adopting Implementation procedures from
reference guides.

Major Steps:

1. Decision by management to use the HACCP system

2. Training and formation of the HACCP team
3. Development of the HACCP plan document, including the following parts:

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PRELIMINARY STEPS

• Assemble a HACCP team

• Describe the product and its distribution
• Describe the intended use and consumers of the food.
• Construct a flow diagram, which describe the process.
• Verify the flow diagram on site.

SEVEN PRINCIPLES

1. Identify and list all relevant hazards, risk assessment and preventive measures

2. Identify CCPs and apply the decision tree

3. Establish target levels and critical limits for CCPs

4. Establish monitoring system

5. Establish corrective action plan

6. Establish verification procedures

7. Establish documentation and record keeping

4. Implementations of HACCP plan to establish and operate the HACCP system in

the Food Company. Team plays a key role in these activities

5. Verification auditing of the HACCP system, to determine that it is working

correctly.

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ESTABLISHING A HACCP SYSTEM IN A FOOD COMPANY:
To make the concept more understandable, in this paper, we have elaborated the
whole procedure with the help of an example- Tetra pack Ultra Heat Treated (UHT) Milk
line.

For successful results project was divided into four different stages.

Stage 1
Planning and preparation

Stage 2
HACCP studies and plan development

Defining terms of reference

Describing the product and intended use

Construction of a process flow diagram

Validation of process flow diagram/Onsite

Risk assessment & Hazard analysis

Identification of Critical Control Points (CCPs)

Establishing critical limits

Identification of monitoring procedures

Establishing corrective action procedures

Validation of the HACCP plan

Stage 3
Implementation the HACCP plan

Stage 4
Maintenance of the HACCP System
Comprehensive HACCP plan

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STAGE 1

1. HACCP Presentation to convince the top management.

2. Decision by the top management to implement this system
3. Main Team was developed

Main team was comprised of members from following areas of training.

o Team Leader (Having the back ground and skill of HAACP

implementation)
o Quality assurance
o Operations or production
o Microbiology
o Engineering

STAGE 2

1. Milestone plan development (annex -1)

Mile stone plan was covering all areas and activities to meet the requirement of
Comprehensive HACCP plan with time frame.

STAGE 2 EXECUTION:

1. Training

Following subjects were mainly covered in baseline training of concerned

personnel. (Trainings were given at different stages).

o Objective of the training

o Concept of Sanitation, Food hygiene and safety.
o Discussion on food borne diseases
o Overview of HACCP
o Use of HACCP to protect consumer safety
o Key definitions of the concepts involved in HACCP. (annex - 2)
o Preliminary steps to HACCP planning
o Techniques to work on HACCP seven principles
o HACCP plan execution/Implementation
o HACCP auditing techniques
o Post HACCP problems

After training baseline audit /Gap analysis was conducted to know the current control
measures for food safety and quality management

PRODUCT DESCRIPTION AND ITS INTENDED USE:

UHT milk is sterilized, homogenized ultra heat treated milk (obtained from buffalos or
cows) packed in tetra pack and is commonly used by people of all ages and segments
for drinking as well tea making. It is considered as a safe and quality product.

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CONSTRUCTION OF FLOW DIAGRAM:

Milk procured through field staff is brought to the factory milk reception and during
processing, passes through pasteurization, UHT section, aseptic filling, and tray
packing/shrink wrapping area before going to the warehouse. From warehouse it is
transported to the distribution network. (Flow diagram annex 3)

FLOW DIAGRAM WAS VERIFIED ONSITE:

USE OF SEVEN PRINCIPLES OF HACCP:

After the provision of basic requirements, by adopting seven HACCP principles, risk
assessment was done, all hazards were listed and high-risk points were identified as
Critical Control Points by using HACCP decision tree (decision tree annex – 4). To
check these hazards on CCPs Control limits were definitely the requirement, so these
standards were identified. Monitoring procedures, frequencies and assigned
responsibilities were among the needs to observe these critical limits effectively, which
were finalized in the next stage. It was also defined that what corrective action could be
necessary in case of deviation from critical limits.

Information collected through this exercise was used to complete the following
HACCP control chart.

CCP Process Hazard Preventive Critic Monitoring Corrective Action

No step Type action al Procedur Frequency Responsibil Procedur Resp.
Limits e ity e
1 Filter P, B Cleaning, No Cleaning Hourly Pasteurizati Replace Paste
Replaceme choki on operator immediat urizati
nt. ng or ely if on
dama damage opera
ge is done tor

HACCP Control Chart

Completed HACCP control chart (annex 5)

STAGE 3

Following steps were adopted to fulfilled the requirements of Stage 3 -

Implementation

o Determination of method of implementation

o Setting up implementation team
o Agreement on actions and time table
o Training sessions for implementation staff.
o On line training of supervisors/Line operators/workers
o On line Critical Control Points (CCPs) identification
o Pasting of CCP stickers and trading of line staff regarding CCPs
o Review of HACCP documents/formats
o Setting up monitoring system
o Setting up equipments and facilities
o Establishing process capability
o Establishing record keeping requirement

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 o Confirmation of actions completed.
o Verification of implementation through audits
o Necessary action against findings

STAGE 4

1. Maintaining the system

2. Review of post implementation problems
3. Decision of effective measures to over come post HACCP complications

Following model was adopted to fulfill the requirements of Stage 4 - maintaining

HACCP

Stage 4
Maintaining the HACCP system

Defined standards and Ongoing maintenance

regular audit

Data analysis

Problem Corrective and

Solving preventive action

HACCP plan re-

validation

Documentation
controlled update

MAKING HACCP ALIVE

MAJOR BOTTLENECKS IN DESIGNING, IMPLEMENTATION AND MAINTENANCE:

• Management’s diluted vision/Lack of interest

• Hazards linked to raw materials/ weak supplier support
• Too many CCPs
• Take too long to put modifications in place
• Money to implement modifications
• Time is a constraints because others specialized packages have to be covered
at the same time
• Coordination of HACCP Team and availability to attend the HACCP
maintenance meetings
• Discontinuation of HACCP status report

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HACCP IN PAKISTAN
SCOPE:

Same as internationally

AWARENESS:
Awareness of the system is very poor but processor and consumer
awareness/consciousness is increasing day by day, especially processors involved in
the export industry are being forced by their customers to get HACCP certification in
order to continue the business.

REGULATIONS:
In Pakistan Pure Food Rules there is no such provision of this system but food
hygiene and safety is emphasized.

BOTTLENECKS WHILE IMPLEMENTATION OF THIS SYSTEM IN PAKISTAN:

o Management diluted vision and weak commitment

o Short term business strategies
o Absence of regulation/laws
o Ineffective check and non serious behavior of the regulatory bodies
o Lack of awareness among the producer/manufacturer
o Lack of consumer awareness
o Absence of quality culture
o Unavailability of pre-requisites like GMP, GLP, preventive maintenance and
SSOP.
o Weak raw material control
o Weak procedure control
o Lack of sanitation and personnel health
o Improper recall system
o Unavailability of resources (finance, trained Manpower)
o Unavailability of experts.
o People reluctance for change/ Conservation of ideas

FUTURE OF THIS CONCEPT:

As the concept is emerging as the pre-requisite of food business world over and has
become mandatory by regulation in different parts of the world. In the years to come, it
seems, no movement across the borders for food products could be possible without
HACCP certification. Even in recent years, Pakistan has been facing this problem in the
export of Fish industry. Customers from abroad are demanding food safety certificate
but it is not possible so early. Definitely, it will take time, and a lot of resources and
expertise would be also required to undertake this activity. Govt of Pakistan has
requested for relaxation to continue this worthy source of revenue and has got time
period of two years to be get this system in place. To meet the dynamic business
environment, authorities need to very vigilant, informed and practical otherwise a big
chunk of foreign exchange obtained through this sector will be lost.

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