7.3 HACCP Principles & Food Code Compliance

HACCP Principles & Food Code Compliance

Overview of Hazard Analysis Critical Control Point (HACCP)

Hazard Analysis Critical Control Point (HACCP) is a systematic, science-based preventative approach to food safety designed to identify, evaluate, and control biological, chemical, and physical hazards throughout the food production process. Originally developed in the 1960s by the Pillsbury Company in collaboration with NASA to ensure safe food for spaceflights, HACCP is now mandated by federal regulatory agencies (FDA and USDA) and serves as the cornerstone of modern healthcare foodservice sanitation management. Unlike traditional end-product testing, HACCP focuses on preventing food safety hazards before they occur.

The 7 HACCP Principles

A comprehensive HACCP plan follows seven sequential principles established by the National Advisory Committee on Microbiological Criteria for Foods:

Principle 1: Conduct a Hazard Analysis

Identify potential biological (e.g., Salmonella, Listeria), chemical (e.g., cleaning sanitizers, pest control sprays), and physical hazards (e.g., glass, metal shavings, bone fragments) across all menu items and processing steps. Evaluate hazards based on severity and likelihood of occurrence.

Principle 2: Determine Critical Control Points (CCPs)

A Critical Control Point (CCP) is a specific step in the food operational flow where control can be applied to prevent, eliminate, or reduce a food safety hazard to an acceptable level. Common CCPs in foodservice include receiving, cooking, cooling, reheating, and hot holding. (For example, cooking raw chicken is a CCP to eliminate Salmonella).

Principle 3: Establish Critical Limits

A critical limit is a maximum or minimum physical, biological, or chemical parameter (such as temperature, time, pH, or water activity) that must be met at each CCP to control the identified hazard. Critical limits must be measurable and objective. (Example: Cooking chicken breast to a minimum internal temperature of 165°F for at least 1 second).

Principle 4: Establish Monitoring Procedures

Monitoring involves planned, systematic observations or measurements to determine whether a CCP remains within established critical limits. Procedures must define who monitors, what is measured, how it is measured, and how frequently. (Example: A cook measures internal roast beef temperature using a calibrated digital probe thermometer every 30 minutes during hot holding).

Principle 5: Establish Corrective Actions

Predetermined steps taken immediately when monitoring indicates a deviation from a critical limit. Corrective actions must identify how to bring the process back under control, determine the disposition of the affected food, and document the event. (Example: If soup in a hot-holding steam table drops to 128°F, the corrective action is to rapidly reheat the soup to 165°F within 2 hours or discard it).

Principle 6: Establish Verification Procedures

Activities, other than routine monitoring, that confirm the HACCP plan is scientifically sound and operating effectively according to design. Verification includes calibrating probe thermometers, auditing temperature logs, reviewing corrective action records, and conducting micro-testing of equipment surfaces.

Principle 7: Establish Record-Keeping & Documentation Procedures

Maintain comprehensive written records documenting the HACCP system. Records include supplier invoices, temperature monitoring logs, corrective action logs, equipment calibration records, and staff HACCP training records.

Cleaning vs. Sanitizing Standards

Effective sanitation requires understanding the fundamental difference between cleaning and sanitizing:

• Cleaning: The physical removal of visible food soil, dirt, grease, and food residue from surfaces using detergents and friction. Cleaning does not kill microorganisms.
• Sanitizing: The application of heat or chemicals to a clean surface to reduce pathogenic microorganisms to safe public health levels (a 99.999% reduction or 5-log reduction). Surfaces must be thoroughly cleaned and rinsed before sanitizing, as organic soil inactivates chemical sanitizers.

Manual Warewashing (3-Compartment Sink)

Healthcare foodservice facilities using manual dishwashing must operate a standard 3-compartment sink with designated drainboards for soiled and clean items:

[ Soiled Drainboard ] ➔ [ Sink 1: WASH ] ➔ [ Sink 2: RINSE ] ➔ [ Sink 3: SANITIZE ] ➔ [ Clean Drainboard (AIR DRY) ]

1. Compartment 1 (Wash): Wash dishes in warm water with detergent at a minimum temperature of 110°F (43°C).
2. Compartment 2 (Rinse): Rinse items thoroughly in clean, warm water to remove detergent residue.
3. Compartment 3 (Sanitize): Sanitize using one of two approved methods:
   • Hot Water Sanitizing: Immerse clean items in hot water maintained at 171°F (77°C) or higher for at least 30 seconds.
   • Chemical Sanitizing: Immerse items in an approved chemical sanitizer solution for the required contact time:
     • Chlorine: 50–100 ppm (water temp 75°F–100°F, contact time ≥7–10 seconds).
     • Iodine: 12.5–25 ppm (water temp ≥75°F, contact time ≥30 seconds).
     • Quaternary Ammonium (Quat): 200 ppm (water temp ≥75°F, contact time ≥30 seconds).
4. Air Drying: All dishes and utensils must air-dry completely on clean drainboards before storage. Towel drying is strictly prohibited by the Food Code due to cross-contamination risks.

Mechanical Warewashing Machines

Mechanical dishwashers use high temperature or chemical sanitizers:

• High-Temperature Machines:
  • Wash cycle temperature: 150°F to 165°F (66°C).
  • Final sanitizing rinse cycle temperature: Must reach at least 180°F (82°C) at the manifold (and at least 160°F at the dish surface). Note: Water temperatures above 194°F (90°C) must be avoided because water vaporizes into steam before sanitizing dish surfaces.
• Low-Temperature (Chemical) Machines:
  • Wash cycle temperature: 120°F (49°C).
  • Sanitizing cycle: Relies on chemical sanitizer (e.g., 50 ppm chlorine) injected into the rinse water.

Facilities, Water Safety & Integrated Pest Management

• Backflow Prevention & Air Gap: A cross-connection is a physical link between safe potable water and non-potable drain or sewer lines. The only completely reliable, non-mechanical backflow prevention method is an air gap—an unobstructed vertical space through atmosphere between the water supply outlet and the flood-level rim of the fixture. The air gap must be at least twice the diameter of the water supply pipe, and never less than 1 inch.
• Integrated Pest Management (IPM): A proactive strategy combining three core principles:
  1. Deny pest entry to the facility (install 16-mesh screen doors, air curtains, and door sweeps).
  2. Deny pests food, water, and shelter (store food 6 inches off floor and away from walls, repair leaks).
  3. Work with a licensed Pest Control Operator (PCO) to eliminate infestations safely.