HACCP: A 12-STEP APPROACH

STEPHEN DOWDELL

CHICAGO -- HACCP is do-able for retailers large and small -- and better be done, if companies expect to be able to market safe, fresh food in their stores.

That was the message delivered by Fred Reimers, the corporate sanitarian at H-E-B Grocery Co., San Antonio. Reimers outlined a practical approach to Hazard Analysis Critical Control Points programs at the store level in a workshop at the Food Marketing Institute annual convention here.

Reimers presented a compelling case for implementing HACCP, the program designed to analyze the "harvest to consumption" food chain, pick out potential trouble spots where contamination might occur, implement safeguards and then monitor the system to make sure problems don't occur.

"Conservative estimates based on the Centers for Disease Control indicate that between six and 30 million Americans become ill from food-related causes, and approximately 9,000 die," Reimers said. "These figures have led some to estimate that the cost of food-borne illness in the U.S. is as high as $15 billion a year, in terms of medical expenses, lost wages, insurance costs and liability.

Reimers said the long-standing retail recipe for proper handling of fresh food, "keep it hot, keep it cold, and keep it moving," is just not sophisticated enough to cover a problem growing more complex all the time. "We based this process on perhaps a false premise, that the food being supplied under government inspection is basically safe."

The cruel reality is otherwise, he said, pointing to the now infamous outbreak on the West Coast of E. coli 0157:H7 linked to ground beef that the operator, Jack-in-the-Box, presumed was safe. That company is likely to be paying for costs in terms of lost good will and lawsuit settlements for some time to come. "I'm sure you'll all agree that less money could have been put into prevention systems than what will ultimately be paid out by the company held responsible," Reimers said.

He declared the incident a "wake up call" for retailers and regulators. "We can no longer assume that because a food is inspected by the government that it is safe. Nor can we isolate ourselves within the food chain without looking both backwards and forwards as to the safety elements put in place, to reduce the risk of food-borne illness from the products we handle."

To Reimers, the rules of the game call for HACCP as a way for the industry to control its own destiny. He walked workshop attendees through a 12-step process for creating a HACCP program based on both his own experience at H-E-B as well as a HACCP model for ground beef programs recently completed and made available by FMI.

Reimers' 12 steps:

1 Assemble the HACCP team. He recommended the team include a food technologist as the "key facilitator," with a meat department representative to round it out. Reimers also warned that HACCP must be supported by top management, "or it is doomed to failure at the start."

2 Describe the food and its distribution. "A plan should be developed for each specific food or process," he said.

3 Identify intended use and consumers of the food. "In most retail HACCP plans, the general public is the intended user."

4 Develop a flow diagram which describes the process. "Simple flow chart boxes with word descriptions of the operational steps will suffice."

5 Verify the flow program. Reimers said this is "nothing more than actually walking through the process through the facility."

6 Conduct a hazard analysis. At this point, retailers prepare the list of steps in the process where significant hazards occur and describe preventative measures. "This is perhaps the most difficult of the HACCP principles and the most important," said Reimers.

7 Identify the CCPs in the process. Reimers' advised retailers to confine HACCP strictly to food safety concerns, leaving out quality goals that can unnecessarily complicate the system.

8 Establish critical limits for preventative measures for each CCP.

9 Establish CCP monitoring requirements and procedures for making adjustments to maintain control. Reimers said this is crucial "from an operator's standpoint, as it allows him to remain in control of his process from a critical standpoint."

10 Establish corrective action to be taken when monitoring spots a problem. "The real world tells us that errors will happen," said Reimers. He said H-E-B found "that in a retail environment, decision tree matrixes provide clearly visible instructions" to "a changing work force."

11 Establish record-keeping procedures that document the HACCP plan. Again, limiting HACCP to safety CCPs is a good idea, since here any deviations would show up in reports.

12 Establish procedures for verification that the HACCP system is working correctly.