Principle 5: Establish Corrective Actions. • These are actions to be taken when monitoring indicates a deviation from an established critical limit. The final rule requires a plant’s HACCP Plan to identify the corrective actions to be taken if a critical limit is not met. Corrective actions are intended to ensure that no product injurious to health or otherwise adulterated as a result of the deviation enters commerce. Principle 6: Establish Record Keeping Procedures. • The HACCP regulation requires that all plants maintain certain documents, including its Hazard Analysis and written HACCP Plan, and records documenting the monitoring of critical control points, critical limits, verification activities, and the handling of processing deviations. Principle 7: Establish Procedures for Verifying the HACCP System is Working as Intended. • Validation ensures that the plans do what they were designed to do; that is, they are successful in ensuring the production of safe product. Plants will be required to validate their own HACCP Plans. FSIS will not approve HACCP Plans in advance, but will review them for conformance with the final rule. • Verification ensures the HACCP Plan is adequate, that is, working as intended. Verification procedures may include such activities as review of HACCP Plans, CCP records, critical limits and microbial sampling and analysis. FSIS is requiring that the HACCP plan include verification tasks to be performed by plant personnel. Verification tasks would also be performed by FSIS inspectors. Both FSIS and industry will undertake microbial testing as one of several verification activities at the occurrence of the identified food safety hazard. Thinking through a HACCP Plan. While there are many steps involved with developing a HACCP Plan, at its foundation is the fundamental thinking necessary to logically work through construction of the plan based on a facility’s process. For instance, how does one step in the process lead to another and then another? Are there distinct steps in the process that are or should be maintained separately? The exercise to the right demonstrates this fundamental thinking. 1 2 3 3 1 2 Connect the shapes that correspond by number and color with one line. The lines may not cross. 3
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