HACCP Explained (with help from Healing Herbs)

As Flower Essences are classified as foods in the UK a HACCP plan is an important measure that can be incorporated into a business to show that all necessary safety procedures are being taken to adequately meet current Food Safety Regulations. If visited by your local environmental health office (EHO) the may request to see your HACCP procedure document and question you about it – you will be given time to update or change anything that they don’t deem appropriate or suitable.

HACCP stands for Hazard Analysis Critical Control Point. It is used to examine a company’s system by looking at the product produced and the processes used to do this, identifying all steps in the products cycle of development which are critical to food safety. (A Hazard Analysis).

For each process used in the development of the product, three hazard types are evaluated:

Biological/Microbiological Hazards – These are commonly caused by contamination of ingredients, improper cooling, poor sanitation, poor personal hygiene and cross contamination.

Chemical Hazards – These include agricultural/horticultural chemicals, industrial chemicals, naturally occurring toxicants, environmental contaminants and food chemicals.

Physical Hazards – These could be debris in raw materials, contamination during food processing, materials entering food during distribution and intentional tampering.

Any hazard identified is then assessed to produce a hazard severity and risk score and Critical Control Points are established. A CCP is a step at which control can be applied and is essential to prevent, eliminate or reduce a food safety hazard to an acceptable level.

Critical limits, the maximum or minimum value to which a physical, chemical or biological parameter must be controlled at a CCP, are also established. These limits need to be continually followed in work practice.

The Critical Control Points should then be monitored in the work place, with a planned sequence of observations and measurements repeatedly carried out, ensuring each CCP is adhered to, that safety controls are in place, maintained and reviewed. (HACCP assessment forms are used for this).

Although individual companies need to devise their own safety procedures relating exclusively to themselves, at Healing Herbs in 2002 the following CCPs were adopted (they will have now been updated to fall into line with recent legislation – see *).

CCP1 – Personal hygiene (a biological/microbiological and physical hazard). To eliminate this people wash hands on starting work in a new area, wear protective personal clothing, aided by staff completion of a Foundation Food Hygiene Course.

CCP2 – Receipt and store of raw materials and packaging (a physical hazard). To overcome this all goods are checked on arrival for damage and dirt and return any breached materials to the supplier. Continual monitoring our goods throughout production for glass breakages or contamination, disposing of any that are not adequate.

CCP3 – Setting up labelling machine, printing and labelling (a physical hazard). To avoid any problems here people observe for glass shards, use clean bags and trays, routinely clean machinery and handle bottles with care.

CCP4 – Preparation of filling room and adding mother tincture to brandy (a biological/microbiological, chemical and physical hazard). To prevent hazards here people observe for any glass shards, use 40% Abv brandy which kills any biological contaminants, practice good personal hygiene and use eco friendly cleaning agents.

CCP5 – Assembly of 40 bottles into sets and alcohol awareness. All bottles are sleeved to safeguard against intentional tampering and label our product showing that it contains brandy.

Thus, the main safety issue at Healing Herbs is contamination of our product. This is controlled by the use of 40% Abv. Brandy, which would kill anything of this nature. All other safety issues concern glass, which is controlled for at every step in our product production.

HACCP was initially developed in America, in the 1960’s, in a quest for quality and safety in the Food and Drink Industry. It has been constantly developed and was last amended and approved by UN/FAO in 1997.

Hazard Analysis is a requirement under the Food Safety (General Food Hygiene) Regulations (1995), which came into force out of the EU Directive 93/43/EEC, to identify all steps in production activities which are critical to food safety, and then, to ensure adequate safety controls are in place, maintained and reviewed. This applies to anyone who sells or processes food (except those in primary food production) and HACCP is a recommended way in which to meet the requirements of these current regulations, helping to ensure business success, profitability and growth.

* The EU regulations have now adopted the 7 principles in the Codex alimentarius:

Identify potential Hazards

Determine points/procedures/operational steps that can be controlled to eliminate hazards(CCP).
Establish critical limits which must be met to ensure CCP is under control
Establish a monitoring system
Establish corrective action when monitoring indicates CCP not under control
Establish verification procedures
Establish suitable documentation concerning all procedures

In simple terms a HACCP document highlights any potential risks of contamination during your whole production process (including making your mother essences) and what you are doing to prevent them as much as is reasonably possible.

How to put your HACCP document in place:

You make your own, review it yourself, control the hazards and keep a full record of any problems. That’s it.

Make a full list of every process involved in manufacture.
List all possible hazards throughout all processes.
Determine what are the hazards.
Physical: for instance broken glass in product.
Biological: for instance bacteria growing in product.
Chemical: for instance contamination of the product.
Evaluate the degree of possibility that any hazard will occur.
Evaluate the degree of danger to the end user should any hazard occur. This involves assigning a value to the risk:
For each risk allocate a points score like this:
Critical Control Point No 1: Incoming Goods
Process: incoming supply of glass bottles.

Hazard: that there is contamination from the transport vehicle (eg oil) which may transfer to the product. Risk: assessed as 2 Hazard: assessed as 1 Overall point score of 3 out of a possible 6 but anything which scores above 0 still needs to be considered. Action: examine all incoming goods and determine if packaging is damaged and if goods are dirty. Deviation Report: if goods are damaged or dirty record the delivery date, consignment etc and the action taken: to remedy the problem and zero the risks/hazard to ensure that future supplies are better.

As you work through the whole production process it will emerge that there are a number of Critical Control Points:

Delivery of goods
Labelling bottles
Filling bottles
Storage of materials etc etc

Where these HACCP occur you need to have an active plan in place to analyse the problem and record, using a ‘deviation report form’, when it occurs and what was done to make good.

A couple of obvious pointers

The risk of bacterial contamination is high if you fill bottles in your kitchen on the same table as cutting up meat for the dog. The stage of production therefore becomes a Hazard Analysis Critical Control Point. What you decide to do to reduce the hazard and the degree of risk is up to you but your HACCP plan should look at the problem and record how you propose to limit the risk.

The chemical contamination of your essence making bowls is probably low but if you wash them in detergent is there a possibility of that creeping into the mother essence? Or is there a degree of risk associated with the water used?

In food production the biggest risk is microbiological and if we use alcohol as a preservative then that is sorted. But what strength of alcohol is required for the finished product to be certainly safe?

HACCP planning is not difficult to do but requires some thought and time to make your plan. Once it is done keep the folder with your active files and use it as a constant record for all actions taken that refer to control of good manufacturing practice.

There is now a requirement for the person(s) responsible for the implementation and monitoring of the HACCP To have been adequately trained.

If you have any queries on this do get in touch and we will try and help you as much as we can.