As your investigation begins, you will most likely find a few common systems—for example, SQF (Safe Quality Food), BRC (British Retail Consortium) and ISO (International Organization for Standardization). Selecting and developing the correct type of system and HACCP plan for your market and products is as critical as the plan itself.
At the time of this publication, a specific and documented legislative rule-set regarding use of HACCP in the US has yet to be developed for petfood. What we do see are petfood producers adopting existing formats as required by 9 CFR Part 417 (Code of Federal Regulations) for the human food industry.
Within these formats, developing and implementing a HACCP plan can be broken down to a very basic set of steps (also called principles).
If deemed significant—passing all the criteria specified in step 1—a hazard must be controlled by a CCP. The point in a process that is the last step at which a control measure can be applied and that is essential to prevent or eliminate a specific food safety hazard or reduce it to an acceptable level is the CCP for that hazard or process.
Remember, a CCP defines the type of hazard and the process location. A regular, non-critical control point in a process is typically not safety related but rather about maintaining quality or regulatory compliance. A critical control point is about safety. Examples could include measures such as:
What is the operational reference point that guarantees the hazard has been identified and killed or removed from the process? That is a critical limit: the maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled.
Basically, a critical limit establishes the absolute limit between safe vs. unsafe. So in identifying these, you want to look at food safety limits, not operational ones. Focus on studies done in your own plant or others. Other sources of data include:
Formally this step is defined, according to NACMCF (1997), as conducting a planned sequence of observations or measurements to assess whether a CCP is under control and to produce an accurate record for future use in verification.
The only way to ensure CCPs are working is to constantly monitor them. Loss of control must be identified as soon as possible. Be sure your procedures include the “four W’s plus H”: who, what, when, where and how to monitor.
One of the more common mistakes with this principle is the “when,” particularly when the monitoring is not continuous or is periodic. Some basic points to consider include:
What do you do if an issue arises—a CCP falls out of control? As mentioned on page 4, petfood safety is not yet regulated in the US, but any rules put into place by the Food and Drug Administration (FDA) will likely follow human food regulations. For example, FDA requires documented corrective actions (CAs) in food HACCP plans.
At the least, per NACMCF (1997), the CA procedures outlined in the HACCP plan should:
Again, it is important to remember that currently there is no legislation for safety in the petfood processing industry. FDA simply states now that petfood suppliers must produce Salmonella-free products.
If FDA puts petfood rules in place, it will most likely copy the protocols set up for the human food industry. For example, with food, testing of all CCPs must be tested and verified by a thirdparty laboratory, outside the production facility. While the samples are being tested by this third party, the product cannot be distributed or sold. Think of the warehousing and logistic challenges that can arise.
It is up to petfood producers to develop their own strategy or system. If they don’t, FDA most certainly will.