How to create an effective HACCP plan for shell egg plants

Though not required for shell egg processing plants, based on the insight gained from the last shell egg recall maybe it’s time for a HACCP plan.

Every operation should have a recall and traceability plan, sanitation standard operating procedures, employee training records and pest control plan, along with any other prerequisite programs that may be needed. It is important that employees understand the need for such procedures and records. (Andrea Gantz)
Every operation should have a recall and traceability plan, sanitation standard operating procedures, employee training records and pest control plan, along with any other prerequisite programs that may be needed. It is important that employees understand the need for such procedures and records. (Andrea Gantz)

Hazard analysis and critical control points (HACCP) is a recognized preventative approach method to support the production of a safe product. Though not required for shell egg processing plants, based on the insight gained from the most recent shell egg recall, maybe it’s time for a HACCP plan.

A shell egg HACCP plan has become more complex than when they were originally envisioned. There have been new regulatory requirements including egg refrigeration, the egg safety plan, and the fluid nature of inspections. The greatest changes for shell egg processing relate to the risks that are due to continually emerging pathogens and how they are introduced to shell egg operations. These risks require operations to conduct their own risk assessments in addition to regulatory monitoring.

Egg Processing Line

The greatest changes for shell egg processing relate to the risks that are due to continually emerging pathogens and how they are introduced to shell egg operations. (Andrea Gantz)

Developing a HACCP plan is one way to evaluate risks in the production system. Egg temperature and wash water temperature and pH play key roles in reducing microbial growth in shell eggs, and a HACCP plan can be used to tie all the regulatory requirements and any additional identified risks into one safety plan.

Creating a HACCP plan starts with assembling a team of people who represent a cross-section of expertise from the operation. Some key prerequisite programs should be in place to support a HACCP plan. Every operation should have a recall and traceability plan, sanitation standard operating procedures (SSOP), employee training records and pest control plan, along with any number of other prerequisite programs that may be needed.

Conduct a hazard analysis

The HACCP team will develop a flow diagram of the entire egg production process, identifying steps in the process where significant hazards (physical, chemical and biological) can occur. Then the hazards are assessed and prevention measures, which will eliminate or reduce the hazard, are described.

With copies of the current prerequisite plans producers have in place, they should keep in mind additional prerequisite programs may need to be developed.

Other prerequisite programs may include specifications for receiving off-line eggs or your pre-harvest egg safety plan, sanitation programs, pest management programs, employee training programs, employee hygiene programs, specifications for purchasing materials (pallets, cartons, boxes, packing materials, cleaning supplies, protective garments, etc.), laboratory tests conducted, past food safety audits, etc.

Egg Packaging

With copies of the current prerequisite plans producers have in place, they should keep in mind additional prerequisite programs may need to be developed, such as specifications for purchasing materials like pallets, cartons, boxes and packing materials. (Andrea Gantz)

Identify critical control points: risk assessment

All these prerequisite programs can affect your determination of critical control points.

For each step in the flowchart, an evaluation must be made regarding biological, chemical or physical hazards for that step. Any hazard that is not covered by a documented prerequisite program must be included in your HACCP plan.

Shell Egg Plant Processing System

For each step in the flowchart, an evaluation must be made regarding biological, chemical or physical hazards for that step to ensure a safe product.

A biological hazard is the most commonly discussed type of hazard and includes Salmonella and other pathogens. A chemical hazard could come from cross-contamination in the environment or a chemical passed to the egg from the feed or water. A physical hazard in liquid eggs could include shell, metal shavings from metal equipment, etc.

When evaluating a hazard, the hazard evaluation determines if the hazard will cause potential harm to the person consuming the egg. Starting at the beginning of the flowchart, we will assume the egg packing operations obtain eggs from in-line and off-line production facilities and nest run truckload purchases.

One example prerequisite program of a biological hazard noted in the hazard analysis of the presented plan is at receiving off-line eggs. The temperature of incoming eggs will vary from season to season and from operation to operation. Source of packing materials will vary, with plastic flats, reused pulp paper flats or new flats, transport racks or pallets and how everything is cleaned.

General feed hazards include receiving and storage of the grain and other ingredients. The biological hazard in feeds is Salmonella; currently, that is the only one under regulation.

The two types of chemical hazards are mycotoxin levels and drug medication carryover. Mycotoxin levels in the feed may affect the safety of the product for animal and human consumption. Drug medication carryover may occur if there is commingling in the feed bins with previously medicated feed or if bins are improperly sequenced or not flushed.

Establish critical limits

A critical limit is a maximum or minimum value at which a biological, chemical or physical hazard must be controlled to prevent, eliminate or reduce the identified food safety hazard.

For each critical control point (CCP) identified, operational limits or boundaries must be set. If the process remains within these limits, hazards are being controlled effectively.

Monitoring

Monitoring is a planned sequence of observations or measurements to establish whether a CCP is under control. Monitoring instances must be properly documented to produce an accurate record for future verification and of monitoring procedures based on an identified lot of product.

All CCPs must be monitored to determine compliance with established critical limits. Companies want to be proactive in preventing any biological contaminants from reaching the consumer. However, egg operations who want to rigorously look for risk are faced with the dilemma of what they must report if they find something that has not yet caused a problem.

Based on the regulations and the reportable biological controls, there is no incentive for companies to be proactive in their microbiological monitoring. This reporting requirement serves as a disincentive for operations to explore and test to be proactive.

Corrective actions

Deviations are a failure to meet a required critical limit for a CCP, and corrective action must be outlined to bring the process back into compliance. Deviations from critical limits when monitoring indicates an out-of-control CCP. Corrective action should be implemented quickly.

Corrective actions must:

  1. Determine the cause of the deviation
  2. Determine how the deviation can be corrected
  3. Determine how the deviation can be prevented from happening again

The response or prevention solution must be implemented and documented.

The safety decision for a CCP is what happens to the product in the lot where the deviation occurred. The deciding party should be predetermined so the monitor knows who to ask. Documentation must show how much product is impacted, the date and time of the impact and what was done with the product in question.

Corrective actions must also specify the disposition of all product produced during the period the CCP was out of control.

Establish record-keeping procedures

Records serve as written documentation of the facilities compliance with its HACCP plan and allow the facility to trace the history of its operations should a problem arise. If reviewed regularly, trends in monitoring results can provide early warnings to avoid deviations, narrow the scope of the recall and, in legal actions, well-maintained records can be good supportive evidence.

Record retention guidelines are dictated by HACCP regulations. Records must be kept for HACCP plan development, hazard analysis, critical control point determinations, setting of critical limits, handling of deviations, and results of verification and validation studies. Also, HACCP implementation records must be maintained. There is not a specific format for CCP records, but the following information must be included:

  • Title and date of record
  • Product identification
  • Critical limit
  • Monitor’s signature
  • Reviewer’s signature

Verification

Verification is a process to make sure the plan is being carried out as written. This may serve as a regular review audit for your HACCP plan. Management personnel should oversee this process, verifying that the system works. This may include record reviews of monitored measurements being taken and recorded to assure they are at the appropriate times and to evaluate if the plan assures the plant is operating in compliance with the HACCP plan.

Verification must also include a procedure for pre-shipment signoff for each product to determine that all CCPs have been met before the packed eggs leave your operation. You will also need to write up a schedule, process and documentation procedure as a part of your verification plan for routine calibration of all equipment used in monitoring.

Validation

Validation is making sure that the plan is effectively addressing food safety concerns. When validating a HACCP plan, several factors must be considered. Those include the food safety hazards that are likely to occur and have been identified. The control measures in the plan must be validated. This ensures the identified hazards, critical limits and their control measure are scientifically sound and monitoring procedures and frequencies adequate, etc.

It is up to the operation to determine the best way to validate its plan to ensure it is working effectively to control identified hazards. At the very least, an operation should document scientific data used to set the critical limits. They should also be able to justify why the monitoring schedule and procedures have adequately identified all significant hazards.

A comprehensive shell egg HACCP extension publication is being completed.

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