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HACCP Update: Maintenance & Implementation

This month, Food Manufacturing readers were surveyed about HACCP plan maintenance and implementation. This topic was last visited for the March 2011 issue, and since that time, the HACCP planning atmosphere has changed significantly. The Food Safety Modernization Act (FSMA) was signed into law on Jan. 4, 2011, and its full implications for HACCP planning in the food industry were not yet articulated.

This article originally ran in the January/February 2012 issue of Food Manufacturing.

The HACCP Update section of Food Manufacturing is designed to offer our readers insight into the state of HACCP implementation and compliance across the Industry. We received hundreds of responses to this month's survey on implementation and maintenance of HACCP plans.

This month, Food Manufacturing readers were surveyed about HACCP plan maintenance and implementation. This topic was last visited for the March 2011 issue, and since that time, the HACCP planning atmosphere has changed significantly. The Food Safety Modernization Act (FSMA) was signed into law on Jan. 4, 2011, and its full implications for HACCP planning in the food industry were not yet articulated.

The FSMA now makes HACCP planning mandatory industry-wide, which is forcing processors who may be behind the curve on food safety to catch up — and catch up quickly. When asked how often HACCP plans were updated, survey respondents reported:

  • Annually — 51.2%
  • 2–3 times per year — 24.4%
  • 4 or more times per year — 12.2%
  • Less than once per year — 12.2%

These numbers reflect little change from last year, but worth noting is the fact that the 4.9 percent who last year reported “never” updating HACCP plans has now disappeared.

The bar graph at right lists the events that tend to prompt a HACCP change in readers’ facilities. These numbers have generally held steady from last year’s figures, except for “recommendations from auditors,” which has jumped a full 13 percent. Since this figure has grown while “changes in FDA/USDA recommendations” has not, the data suggests that food manufacturers are relying on auditors to communicate food safety needs instead of waiting for final FSMA rules to be handed down from the FDA.

As the pie chart below demonstrates, food manufacturers are seeking advice from the same experts year after year. Survey respondents reported that they do this because their sources:

  • Understand our process and know our facility — 78.6%
  • Provide useful advice — 57.1%
  • Have reasonable pricing — 21.4%
  • Are required or recommended by one or more of our customers — 17.9%

A reliable stable of experts is crucial for food safety efforts, especially at a time when food manufacturers are reporting more obstacles in developing HACCP plans. Readers reported that their obstacles include:

  • Unclear/confusing regulations — 36.8%
  • Processing a variety of products, leading to various industry standards that could apply — 34.2%
  • Conflicting information on HACCP planning given by different sources — 28.9%
  • Not knowing who to contact for help in developing a plan — 5.3%
  • Having difficulty with employee buy-in — 18.4%
  • The expense of reevaluating and maintaining a HACCP plan — 15.8%

“Processing a variety of products” is up from 16.5 percent last year, “conflicting information on HACCP planning” is up from 12.7 percent and “the expense of reevaluating and maintaining a plan” is up from 7.6 percent. These figures suggest that the new regulations are causing a bit of industry confusion over the HACCP requirements now in place for various industry segments. The expense of investigating and implementing necessary changes associated with the FSMA also seems to be taking its toll on manufacturers.

When asked whether the FSMA prompted any changes in HACCP planning, Food Manufacturing readers reported that:

  • No — 37.5%
  • Yes, we improved documentation, training or another ancillary segment of our current HACCP plan — 37.5%
  • Yes, we revised our HACCP plans — 25.0%

Though the changing regulatory environment is forcing food manufacturers to reevaluate their HACCP plans, the food industry remains committed to the program. When asked about the effectiveness of HACCP planning, 82.5 percent of readers reported a belief that the plans increase food safety.