Food Control, Vol. 9, No. 2-3, pp.

111-I 17, 1998

0 1998 Elsevier Science Ltd
All rights reserved. Printed in Great Britain
ELSEVIER PII: SO956-7135(97)00061-3 09X-7135/98 $19.0+0.00

PAPER

The challenge of designing

valid HACCP plans for raw
food commodities
J. A. Lee* and S. C. Hathaway’

Application of HACCP is now firmly established worldwide as the foremost

means of assuring food safety throughout the food chain. Howevel; the genuine
application of IL4 CCP principles can be difJicult in the design of ILACCP plans
for raw food commodities. This is especially the case with fresh meat and fresh
meat products.
In attempting to address these problems, the NZ MAF Regulatory Authority has
developed a generic template for design of HACCP plans for slaughter and
dressing of domestic livestock, and application of the template using sheep as an
example is presented in this paper Establishment of food safety objectives for the
particular segment of the food chain under consideration is important, and the
hazard analysis step should individually consider the different components of the
raw material (hide, headloflalslcarcass, gastrointestinal tract) and their potential
for microbiological contamination of the final product. Other tools which facili-
tate design and application of the HA CCP system are special consideration of
prerequisite programmes, use of job descriptions for slaughtermen, and a custom-
ized decision tree for identification of critical control points.
Design and verification of the HACCP plan is enhanced by reference to micro-
biological ‘targets’ established according to a standardized national microbio-
logical database aggregated from all licensed premises. In the absence of a human
health microbiological risk assessment model for particular pathogens that may be
present in meat and meat products, the food safety objectives of the HACCP plan
will probably be associated with control of hazards rather than control of risks.
0 1998 Elsevier Science Ltd. All rights reserved

INTRODUCTION in the design of process-specific plans. In this respect,

Application of HACCP is now firmly established
worldwide as the foremost means of assuring food
safety throughout the food chain. National govern-
ments and the Codex Alimentarius Commission
(CAC) are actively promoting harmonization of
HACCP principles and generic applications, and
there is increasing debate on the role of risk analysis
*MAF Regulatory Authority, 95 McGregor Road, RD2
Papakura, New Zealand and +MAF Regulatory Authority,
P. 0. Box 646, Gisborne, New Zealand.
a recent FAO Expert Consultation recommended
that ‘HACCP food safety measures should be based
on an assessment of the risks to health and the
measures chosen should be those that are least trade
restrictive’ (Anonymous, 1995).
Generic HACCP plans for raw food commodities
are now appearing in increasing numbers but many
appear to be based on a systematic application of
traditional parameters of good manufacturing prac-
tice (GMP) and existing national regulatory require-
ments rather than an assessment of food-borne risks
to the consumer. Difficulty in designing risk-based

Food Control 1998 Volume 9, Number 2-3 111

HACCP plans for raw food: J. A. Lee and S. C. Hathaway

HACCP plans for raw food commodities is attribut- 0 Monitoring parameters

able to: 0 Corrective action procedures
0 Verification procedures
Variability in microbiological hazards in raw
0 Documentation and recordkeeping procedures
material, which in most cases represent some level
of continuous exposure of the consumer Some of these key tasks are described in detail so
Inattention to specific food safety objectives as to illustrate practical application of HACCP for
(FSOs) to guide the development of HACCP plans raw foods.
for a particular segment of the food chain
Limited availability of valid on-line monitoring
parameters PREREQUISITE PROGRAMMES
Limitation in the jurisdiction of food safety
controls to that segment of the food chain subject Prior to designing a HACCP plan, the food premises
to the HACCP plan is expected to be able to demonstrate ongoing
A focus on the control of hazards rather than the compliance with GMP, regulatory and market access
control of risks requirements. These conditions collectively, represent
A lack of motivation within some segments of ‘prerequisite programmes’. Thus the initial task is to
industry as to the relevance of detailed food safety identify prerequisite activities and ensure they are
controls for raw food commodities covered by documented systems.
For slaughter and dressing systems, documented
If it is acknowledged that ‘HACCP implementa-
programmes considered essential prerequisites to the
tion should be guided by scientific evidence of
development of an effective HACCP plan are:
unacceptable public health risk’ (Anonymous, 1995),
innovative approaches to design and application of Potable water quality
HACCP plans will be increasingly necessary. Valida- Hygiene and sanitation of facilities and equipment
tion with respect to FSOs becomes a key issue, and (preoperational and operational)
this is especially important, in judgement of the Operator hygiene including protective clothing
equivalence of HACCP-based food safety control requirements, personal equipment and use of
programmes in different countries. It is notable that amenities
the Codex Committee of Food Hygiene (CCFH) did Training
not acknowledge the pivotal role of risk analysis and Dropped Meat Programme
the requirement for FSOs in the design of HACCP Food contact materials
plans in its recent redrafting of HACCP guidelines Repairs and maintenance
(Anonymous, 1996a), yet calls for such inclusion are Chemicals
now becoming more common in the literature. In Vermin control
fact, the 1996 US Pathogen Reduction/HACCP Rule Waste disposal
for fresh beef production includes the provision for a Ante- and postmortem inspection
premises to have an alternative frequency for [micro- Confirmation of effective prerequisite programmes
biological] testing provided it is part of the verifica- means that the HACCP team can focus on genuine
tion of a validated [authors italics] HACCP plan design of a HACCP plan for the particular product
(Anonymous, 1996b). and process selected, without having to repeatedly
address hygiene requirements common to all
processes, and applicable at most process steps in
A PRACTICAL APPROACH
each HACCP flow diagram. The prerequisite
programmes will often be generic to all processes at
In attempting to address some of the problems assoc-
an individual premises.
iated with the design of risk-based HACCP systems
for raw food commodities, the NZ MAF Regulatory
Authority has developed a generic template for fresh FOOD SAFETY OBJECTIVES
meat and seafood (Anonymous, 1997). The template
presents the following key tasks: Establishment of FSOs for the particular segment of
Prerequisite programmes the food chain under consideration is an essential
Scope task. These objectives provide the expected food
Product description and intended use safety outcome for the product as a result of imple-
Food safety objectives menting the HACCP plan and may have a qualitative
Process flow diagram or quantitative association with level of risk to the
Job descriptions consumer.
Hazard identification A qualitative association can be illustrated by a
Confirmation of food safety objectives HACCP plan for a particular segment of a food chain
Critical Control Points in which the FSO is achieved in terms of specified
Critical limits levels of control of hazards, but risk assessment infor-

112 Food Control 1998 Volume 9 Number 2-3


mation is not available to associate this level of
control with actual risks in the consumer population.
If risk assessment information is available (and this
implies knowledge on control of hazards during all
segments of the food chain), a quantitative associa-
tion can be established between the FSO for a
HACCP plan and the risks to the consumer. In this
circumstance, critical limits included in the HACCP
plan for a particular segment of the food chain will
be a reflection of decisions on acceptable levels of
risk. A graphical representation can illustrate this
concept (Figure I).
For raw products, FSOs will often be closely assoc-
iated with those outcomes achievable by GMP and
are likely to be a qualitative expression of food safety.
Risk assessment modelling to better determine
associations between the level of hazards in the final
product and risks to human health in the consumer
population will obviously strengthen such
associations.
Determination of FSOs confers the following
benefits:
A ‘target’ for the overall design of the HACCP
plan, which is related to expected food safety
outcomes (and in the ideal situation, acceptable
levels of risk in the consumer population)
Provision of a means for assessing equivalence of
food safety systems, e.g. for market access
Expression of ‘due diligence’ as commercially
expected for a food product in international trade
Clear identification of any limitations of a HACCP
plan in terms of what can be achieved in control-
ling hazards.
Quantitative control of risks
Critical limits determined according to microbial risk analysis
Quantitative control of hazards*
4I:r:::::::::::::::::::::::::::::~::::::::~b
Critical limits determined according to food safety objectives
4
(* most common situation in international trade)
Figure 1 Application of a quantitative approach to microbial food safety
HACCP plans for raw food: J. A. Lee and S. C. Hathaway
FSOs for a slaughter and dressing process are
likely to be as follows:
To minimize transfer and redistribution of micro-
biological hazards from the gastrointestinal tract
and the pelt/hide to the carcass, (including control
of grossly detectable contaminants) by application
of a HACCP plan that achieves specified microbio-
logical targets
To remove all grossly detectable abnormalities
from carcasses that are so identified at post
mortem inspection, according to specified perform-
ance criteria (sensitivity and specificity)
To identify all chemical ‘suspect’ lines of livestock
that are presented for slaughter, for subsequent
regulatory action
ON-LINE MONITORING PARAMETERS
In ovine slaughter and dressing operations, the avail-
ability of on-line real-time monitoring parameters is
very limited. Recent research has shown that grossly
detectable contamination is poorly associated with
microbial loads on sheep carcasses (Biss and Hath-
away, 1995, 1996a,b) and this limits the usefulness of
this parameter as a monitoring tool. However, job
descriptions can provide useful monitoring opportuni-
ties. Job descriptions for slaughtermen describe the
tasks that the operator is required to do at each
process step, including the food safety responsibili-
ties, and are regularly monitored as part of the
HACCP plan. Research has shown that if slaughter-
Qualitative association with
acceptable level of food safety
Food Control 1998 Volume 9, Number 2-3 113
HACCP plans for raw food: J. A. Lee and S. C. Hathaway

line jobs are carried out repeatedly according to the nents and abnormalities as sources of hazards and is
job description, decreased microbiological contamina- useful because there is very little knowledge on a
tion will be the outcome. These descriptions are also routine basis of the prevalence of specific pathogens,
very useful training tools for new operators. or the distribution of specific pathogens on a carcass.
Similarly, there is unlikely to be on-line monitoring
tools for specific pathogens.
HAZARD ANALYSIS For a slaughter and dressing process, the HACCP
team should divide the raw material into three
Hazard analysis begins with identification of food components; hide, head/offals/carcass, gastrointestinal
safety hazards associated with the raw material, and tract, and individually consider their potential as
establishment of a priority list. For slaughter and sources of hazards (Table I) in or on the final product
dressing it can typically be applied to chemical and (Table 2). Thus the hazard identification at each
physical hazards but microbiological hazards have to process step takes into account the following:
be dealt with in a generic way (compared to many
other food processes where individual pathogens are l Raw material hazards
able to be considered). This generic approach for l Transfer and redistribution of raw. material
microbiological hazards utilizes raw material compo- hazards during the slaughter and dressing process

Answer each question in sequence at each process step for each identified hazard

Ql. Could the hazard be present in or on the product*

at unacceptable** levels at this step?

. .

Yes - give reasons and go to 42 No - not a CCP. Proceed to next identified hazard

42. Is there a control measure available at this step

that would prevent unacceptable** levels of the hazard?

. .

Yes - this step is a CCP No - not a CCP. Answer 43

Answer 43

. .

Q3. Is there a control measure available at a previous step which would significantly contribute to
preventing unacceptable ** levels of the hazard at this step?

. .

Yes - retrospectively assign No - If the answer to 42 also was no, consider

the previous step as a CCP whether any subsequent steps can control the hazard or
whether redesign of the process/product is necessary to
ensure a control measure is available

Proceed to next identified hazard

1 Product - edible component of final product

I)* Unacceptable- as demonstrated by data (scientific literature, applied research or on-site experience) associated with
achieving the food safety objectives established for the process. In the determinationof unacceptability,hazards
should be considered in terms of:

Level
Frequency
Transfer and redistribution
Severity of effect on consumer
Figure 2 CCP Decision tree

114 Food Control 1998 Volume 9 Number 2-3

 HACCP plans for raw food: J. A. Lee and S. C. Hathaway

Table 1 Hazard identification for raw material (delete those hazards not applicable to the livestock species selected)

Raw material component Biological hazard Chemical hazard Physical hazard

Carcasslheadioffals Bl-microbiological hazards Cl-chemical hazards associated Pl-(as applicable to species)

associated with grossly
detectable abnormalities e.g.
fever, abscesses
B2-Microbiological hazards not
grossly detectable e.g
.Toxoplasma gondii within the
musculature; bacteraemia
B.?-visible parasites
with identified chemical
residues e.g. suspect lines,
injection site lesions (ISLs)
C2-chemical hazards associated
with unidentified chemical
residues e.g. anthelmintics,
antibiotics, environmental
contaminants

Gastrointestinal tract B4-microbiological hazards* Not applicable Not applicable

associated with faeces and
ingesta e.g. Salmonella spp.
Yersinia spp

Fleece/hide/pelt BS-microbiological hazardst Not applicable Not applicable

associated with contamination
of fleece/hide/pelt, with faeces,
dirt e.g. Salmonella spp.
Yersinia spp

*Hazard may be transferred from one raw material component to another as either unseen or grossly detectable contamination.
tHazard may be redistributed on a raw material component as either unseen or grossly detectable contamination

l Other hazards associated with individual
steps (including inputs)
DECISION TREE
A customized decision tree has been developed for
the slaughter and dressing process which analyses the
significance of identified hazards or hazard groups in
terms of FSOs and thereby determines CCPs (Figure
2). Field experience in NZ suggests that the decision
tree example included in the Codex HACCP guide-
lines (Anonymous, 1996a) has limitations when
applied to raw food processes, and these can be
addressed by:
Clearly defining the unacceptable prevalence/levels
of hazards prior to consideration of control
measures at a particular step
Applying control measures only to those preva-
lences/levels of hazards that are unacceptable
Providing a formal feedback loop for further
consideration of control measures, rather than only
referring to subsequent process steps
Linking the HACCP plan to agreed food safety
objectives
Applying the customized decision tree to an ovine
slaughter and inverted dressing operation under field
conditions in NZ (Anonymous, 1997) has identified
four generic CCPs:
l Receiving of livestock
l Flaying during forequarter workup
0 Pelting
0 Retain rail trimming
VALIDATION
Validation is a key issue which is often neglected in
currently available HACCP plans for raw meat and
process meat products. In parallel with FSOs, validation is
enhanced by reference to microbiological perform-
ance targets established according to a standardized
national microbiological database aggregated from all
licensed premises on a routine basis (Hathaway and
Cook, 1997).
Microbiological targets incorporated in FSOs will
be established according to:
l Within-premises performance
l Equivalence with national performance
l Continuous improvement under HACCP
l Differentiated targets for product with specialist
end-uses, e.g. chilled cuts
CONCLUSION
The quantitative language that is currently part of the
HACCP lexicon, e.g. hazard analysis, establishment
of ‘critical limits’, ‘acceptable’ levels of food safety,
requires the setting of FSOs as desired outputs of the
particular segment of the food chain to which a
HACCP plan is being applied. In this sense, HACCP
will be an essential vehicle in future consideration of
the equivalence of food safety control systems for
internationally traded food, and judgements of equiv-
alence will be very difficult without documentation
(and validation) of FSOs.
Designing valid HACCP plans for raw food
commodities present special challenges and it is NZ
MAFRA’s view that selection of CCPs in HACCP-
based systems for raw foods should be on the basis
that they will provide enhanced food safety assur-
ances to those provided by adherence to GMP and
current regulatory requirements, and/or they provide
greater benefit/cost ratios for particular food safety
characteristics than those achieved by GMP and

Food Control 1998 Volume 9. Number 2-3 115

HACCP plans for raw food: J. A. Lee and S. C. Hathaway

‘Lgble2 Process step hazard identification for slaughter and inverted dressing of lambs and sheep
Process Step Raw material Transfer+ of Redistributiont of Other inputs
hazards to hazards on product
Components Hazards* product* Component Hazards

1. Receive Carcass/head/offaIs Bl,B2,Cl,C2

GIT B4
Fleece/pelt BS
2. Wash Carcass/head/offaIs Bl,B2,Cl,C2
GIT B4
Fleece/pelt B5
3. Pen Carcass/bead/offals Bl,B2,Cl,C2
GIT B4
Fleece/pelt B5
4. Antemortem Carcass/bead/offals Bl,B2,Cl,C2
GIT B4
Fleece/pelt B5
5. Stunning conveyor Carcass/head/offals Bl,B2,Cl,C2
GIT B4
Fleece/pelt B5
6. Stunning Carcass/head/offals Bl,B2,Cl,C2
GIT B4
Fleece/pelt B5
7a. Thoracic sticking Carcass/head/offals Bl,B2,Cl,C2 B4,B5 Weasand clips Nil
GIT B4
Fleece/pelt B5
7b. Halal sticking Carca&ead/offals Bl,B2,Cl,C2 B4,B5
GIT B4
Fleece/pelt B5
8. Forequarter workup Carcassihead/offals Bl,B2,Cl,C2 B5
GIT B4
Fleece/pelt B5
9. Hindquarter workup Carcass/bead/offals Bl,B2,Cl,C2 B4,B5
GIT B4
Fleece/pelt
10. Rip down Carcass/head/offals :: B2,Cl,C2 B5
GIT B4’
Fleece/pelt B5
Il. Pelting Carcass/head/offals Bl,B2,Cl,C2 B5
GIT B4
Fleece/pelt B5
12. Foretrotter removal Carcass/head/offals Bl,B2,Cl,C2
GIT B4
13a. Trim Carcass/head/offals Bl,B2,Cl,C2 B4,B5
GIT B4
13b. Pre-evisc wash Carcass/bead/offals Bl,B2,Cl,C2 B4,B5
GIT B4
14. Head removal Carcass (trimmed, Bl,B2,Cl,C2
washed)/head/
offals
GIT B4
15. Evisceration Carcass/offals Bl,B2,Cl,C2 B4
GIT B4
16. Postmortem insp Carcass Bl,B2,Cl,C2 B4,B5
16a. Retain Carcass Bl,B2,Cl,*C2 B4,B5
16b. Reinsp Carcass B2,Cl,C2 B4,B5

Carcasses able to contact each other after step 16 on main chain and step 16b if retained
17. Trim Carcass (passed) B2,Cl,C2 B4,B5
18. Scales Carcass (passed) B2,Cl,C2 B4,B5 Tickets ink Nil Nil
19. Final wash Carcass (passed) B2,Cl,C2 B4,B5 B4,B5

*B-Biological:
Bl-Microbiological hazards associated with grossly detectable abnormalities
B2-Microbiological hazards not grossly detectable
B3-Visible parasites not applicable for ovines
B4-Microbiological hazards associated with faeces and ingesta from GIT (i) unseen (ii) associated with gross contamination with faeces/
ingesta
BS-Microbiological hazards associated with fleece/pelt (i) unseen (ii) associated with gross contamination from fleece/pelt
C-Chemical:
Cl-Chemical hazards associated with identified chemical residues
C2-Chemical hazards associated with unidentified chemical residues
‘Cumulative effect through the process.
ZProduct - edible component of final product.
*Carcasses associated with these hazards are sampled and retained according to current MAFRA (M&S) specification. The carcasses may
progress through the remainder of the process as retained product.

116 Food Control 1998 Volume 9 Number 2-3


current regulatory requirements. In the case of red
meat slaughter and dressing systems, recognition of
linkages with risk analysis is essential and HACCP
plans that incorporate a very limited number of CCPs
are likely to be the most effective and practical
expression of the above goals.
REFERENCES
Anonymous (1995) The use of hazard analysis critical control
point (HACCP) principles in food control. FAO Food and
Nutrition Paper 58, Rome
Anonymous (1996a) Hazard analysis and critical control point
(HACCP) system and guidelines for its application. Report of
the 29th Session of the Codex Committee on Food Hygiene.
Alinorm 97/13A, Appendix II. Codex Alimentarius Commis-
sion, Rome
HACCP plans for raw food: J. A. Lee and S. C. Hathaway
Anonymous (1996b) Pathogen reduction; Hazard Analysis and
Critical Control Point (HACCP) Systems. Food Safety and
Inspection Service, USDA. Federal Register.61:144
Anonymous (1997) A Guide to HACCP Systems in the Meat
Industry. Ministry of Agriculture, Wellington
Biss, M. E. and Hathaway, S. C. (1995) Microbiological and visible
contamination of lamb carcasses according to pre-slaughter
presentation status: implications for HACCP. Journal of Foood
Protection 58. 776-783
Biss, M. E. and Hathaway, S. C. (1996) Effect of pre-slaughter
washing of lambs on the microbiological and visible contamina-
tion of the carcases. Vrerinary Record 138, 82-86
Biss, M. E. and Hathaway, S. C. (1996) The effect of different
on-line dressing practices on microbiological and visible
contamination of lamb carcasses. NZ Veterinary Journal 44,
55-60
Hathaway, S. C. and R. L. Cook. (1997) A regulatory perspective
on the potential uses of microbial risk assessment in inter-
national trade. International Journal of Food Microbiology 36,
126-133
Food Control 1998 Volume 9, Number 2-3 117