8.1 Active Managerial Control and HACCP

Food safety isn't something that happens by accident—it requires intentional systems and consistent oversight. This is where Active Managerial Control (AMC) and HACCP come in. These aren't just buzzwords for the exam; they represent proven frameworks that prevent foodborne illness before it happens.

What Is Active Managerial Control?

Active Managerial Control (AMC) is the purposeful incorporation of specific actions and procedures by management to prevent the occurrence of foodborne illness risk factors. It's a proactive approach—you identify risks, implement controls, monitor performance, and take corrective action when needed.

The FDA Food Code identifies five major risk factors that cause most foodborne illnesses:

Active Managerial Control addresses these risks systematically. It's not just about having rules—it's about making sure those rules are followed every single day.

Tools for Active Managerial Control

To achieve AMC in your operation, you need specific management tools:

1. Training Programs

   • All staff trained on food safety practices
   • Documentation of training completion
   • Regular refresher training

2. Manager Oversight

   • Managers supervise critical activities
   • Direct observation of food handling practices
   • Immediate correction of unsafe behaviors

3. Standard Operating Procedures (SOPs)

   • Written step-by-step instructions for critical tasks
   • Consistently followed by all employees
   • Regularly reviewed and updated

4. Monitoring Systems

   • Temperature logs for cooking, holding, cooling
   • Time tracking for food in danger zone
   • Equipment calibration records

5. Corrective Actions

   • Clear procedures when problems occur
   • Documentation of what went wrong and how it was fixed
   • Follow-up to ensure problem doesn't recur

6. Verification and Record Keeping

   • Regular checks that systems are working
   • Documentation proves compliance
   • Records available for health inspections

What Is HACCP?

HACCP (Hazard Analysis Critical Control Point) is a food safety management system based on identifying and controlling hazards that could cause foodborne illness. Originally developed for NASA to ensure astronaut food safety, HACCP is now the global standard for food safety management.

HACCP is preventive, not reactive. Instead of inspecting finished products to find problems, HACCP builds safety into the process from start to finish.

The Seven HACCP Principles - MUST KNOW

These seven principles form the foundation of any HACCP plan. For the ServSafe exam, you must know them in order:

Principle 1: Conduct Hazard Analysis

Identify potential hazards that could occur in your food operation. These hazards fall into three categories:

• Biological hazards: Bacteria, viruses, parasites (e.g., Salmonella, Norovirus, E. coli)
• Chemical hazards: Cleaning chemicals, pesticides, food allergens
• Physical hazards: Glass, metal fragments, jewelry, bandages

For each menu item, trace the flow of food from receiving through service, identifying where hazards could occur.

Example: For a chicken breast entrée, biological hazards (Salmonella) could occur during receiving (if chicken arrives at unsafe temperature), storage (if cross-contamination occurs), cooking (if not cooked to 165°F), or holding (if held below 135°F).

Principle 2: Determine Critical Control Points (CCPs)

A Critical Control Point (CCP) is a step in the food preparation process where you can apply controls to prevent, eliminate, or reduce hazards to safe levels.

Common CCPs in Food Operations:

Not every step is a CCP. Washing produce is important, but it's not a CCP if the salad will be cooked later (cooking is the CCP that kills pathogens).

Principle 3: Establish Critical Limits

For each CCP, you must set measurable standards that distinguish safe from unsafe. Critical limits answer the question: "How will we know if this step is done safely?"

Critical Limits Must Be:

• Specific: Exact numbers, not ranges
• Measurable: Can be checked with thermometer, timer, pH meter
• Based on science: FDA Food Code, regulatory requirements

Examples of Critical Limits:

• Cook chicken to internal temperature of 165°F for 15 seconds
• Cool TCS food from 135°F to 70°F within 2 hours, and 70°F to 41°F within an additional 4 hours (total 6 hours)
• Hold hot food at 135°F or above
• Hold cold food at 41°F or below
• Reheat food for hot holding to 165°F for 15 seconds

Principle 4: Establish Monitoring Procedures

Monitoring means checking that each CCP is under control. You must determine:

• What will be monitored (temperature, time, pH)
• How it will be monitored (thermometer type, observation method)
• When monitoring occurs (every 2 hours, every batch, continuously)
• Who is responsible (specific job title, not individual names)

Monitoring Example for Cooking CCP:

• What: Internal temperature of chicken breasts
• How: Calibrated digital thermometer inserted into thickest part
• When: Each batch before service
• Who: Line cook on grill station

Why Monitoring Matters: If you don't monitor, you won't know when something goes wrong until it's too late. Monitoring gives you real-time feedback so you can take corrective action immediately.

Principle 5: Identify Corrective Actions

When monitoring shows that a critical limit has not been met, you must have a predetermined plan for what to do. Corrective actions answer: "What do we do when something goes wrong?"

Every Corrective Action Must Address:

1. The food: What happens to the unsafe food?

   • Hold and evaluate
   • Discard if cannot be made safe
   • Re-cook if undercooked
   • Rapidly cool if cooling limits not met

2. The cause: Why did the problem occur?

   • Equipment malfunction?
   • Employee training gap?
   • Process needs adjustment?

3. Prevention: How do we prevent this from happening again?

   • Retrain staff
   • Repair or replace equipment
   • Revise procedures

Corrective Action Example:

Problem: Chicken breast cooked to only 155°F (critical limit is 165°F)

Corrective Action:

1. Food: Continue cooking until chicken reaches 165°F for 15 seconds
2. Cause: Grill temperature was too low; employee didn't check thermometer calibration
3. Prevention: Calibrate thermometer daily; retrain cook on proper cooking temperatures

Principle 6: Verify the System Works

Verification confirms that your HACCP plan is working as intended. This is different from monitoring (which happens during production). Verification happens periodically to make sure the overall system is effective.

Verification Activities Include:

• Reviewing monitoring records to ensure procedures are being followed
• Calibrating equipment (thermometers, pH meters) to ensure accuracy
• Observing employees to confirm they follow SOPs correctly
• Testing final products occasionally (e.g., send samples to lab)
• Reviewing the HACCP plan at least annually or when menu/process changes

Who Verifies? Usually a manager or someone other than the person doing the monitoring. Fresh eyes catch problems that become invisible to those doing the work daily.

Principle 7: Establish Record-Keeping and Documentation

Documentation proves your HACCP system works. Without records, you have no evidence of compliance during health inspections or legal proceedings.

Required HACCP Records:

Record-Keeping Best Practices:

• Write in ink, never pencil
• Include date, time, initials of person who made entry
• Correct errors by drawing a single line through mistake, initialing, and writing correct information
• Never erase or use correction fluid
• Keep records organized and easily accessible

Putting It All Together: Sample HACCP Plan

The Relationship Between AMC and HACCP

Think of Active Managerial Control as the broad management philosophy, and HACCP as a specific tool to achieve it.

• AMC asks: "Are we actively preventing foodborne illness risks?"
• HACCP provides the systematic method to answer "yes."

Not all operations need a formal HACCP plan. The FDA Food Code requires HACCP primarily for operations that perform certain complex processes (like smoking food as a method of preservation, curing food, vacuum-packing food, or treating juice on-site).

However, all operations should use HACCP principles as part of Active Managerial Control—even if a formal written HACCP plan isn't required. The mindset of identifying hazards, controlling critical points, monitoring, and keeping records benefits every food operation.

Common HACCP Mistakes

Understanding what NOT to do is just as important as knowing the correct procedures:

On the Exam

HACCP questions often test:

• Order of the 7 principles (Memorize them in sequence!)
• Definition of CCP (where you can control a hazard)
• Critical limits vs. monitoring (limit = standard; monitoring = checking the standard)
• When corrective action is needed (when critical limit is not met)
• What records to keep (monitoring logs, corrective actions, verification)

Memory aid for the 7 Principles: "Hot Dogs **Can't **Make **Charlie **Very Reliable"

1. Hazard analysis
2. Determine CCPs
3. Critical limits
4. Monitoring
5. Corrective actions
6. Verify
7. Records