Conducting a Hazard Analysis

By far, I think the biggest challenge in setting up a HACCP plan is the hazard analysis. It takes a lot of time and team collaboration to really put a good one together. You want to do a good job here because the hazard analysis will be the basis for identifying and managing your critical control points (CCPs).

The purpose of hazard analysis is to identify all the potential hazards that may be introduced or increased in the process. The process gives the HACCP team an opportunity to identify flaws in the process flow that needs to be addressed in order to adequately keep all significant hazards in check. That said, a thorough knowledge of the entire process is needed. As the team reviews each hazard, they must consider a number of questions. For example, the type of ingredients used, characteristics of the ingredients (physical, chemical and microbial), each processing step, equipment and facility design, packaging type, sanitation procedures, employee health and hygiene, storage conditions, the intended use, and the intended consumer. The FDA’s HACCP Principles and Applications Guidelines provide an excellent outline of questions to consider when conducting a hazard analysis.

The hazard analysis consists essentially of two phases. There is the hazard identification phase and the hazard evaluation phase. In the hazard identification phase, the hazards are simply listed for each ingredient and process step. In the hazard evaluation phase, the identified hazards are assessed to determine their significance and control.

Hazard Identification

Hazard identification is a brainstorming process to identify the hazards that are associated with each step of the process; whether they are introduced or increased at the process step. A common practice in listing hazards during this phase of hazard analysis is to simply note “physical hazard”, or “pathogens” as a descriptor for hazard type. However, it is better to be more specific as to the particular hazard that is being identified, unless the hazards can be controlled the same way. For example, a physical hazard such as metals can be controlled using magnets, while stones and plastic will require the use of sieves and gravity tables to separate. Hence, they should be listed separately rather than together as “physical hazards”. Biological hazards should also be identified separately where they have different characteristics and hence different control strategies; and not all together as “pathogens”. For example, vacuum packaging will control the growth of Staphylococcus bacteria which are aerobic in nature but will not control Clostridium bacteria which are anaerobic . A great resource to learn the characteristics of different types of pathogens and potential intervention strategies is the Bad Bug Book published by the FDA. 

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Hazard Evaluation

Listing all your hazards can be a tedious process but absolutely essential before moving forward. If you overlook significant hazards you are less likely to implement the controls that will be needed to eliminate or reduce them to a safe level. Hazard evaluation is where you will determine if the hazards you have identified are significant. This is

important because you don’t want to spend time trying to figure out how to control hazards that will pose little or no risk. You want to use your time focusing on the ones that are more important. So how do you know if a hazard is significant? A hazard is significant if it meets two criteria. First of all, it must be reasonable likely to occur and also pose serious threat of injury, illness or death. If the hazard is a serious threat but not likely to occur, you shouldn’t worry about it. If the hazard is likely to occur but will not cause any serious injury, don’t worry about it either. However once both criteria are met you cannot ignore it. You must deal with the hazard by identifying how it will be controlled and indicate if the measure is a CCP. Determining CCP status can be done using a CCP Decision Tree. I will deal with CCPs in a later lesson. Be aware though, that whether you decide the hazard is significant or not, you must provide a justification to support your decision. The decision is not always clear-cut, so the following is a guide to help.

A hazard may be deemed LIKELY to occur if:

1. There are no prerequisite programs to adequately control the hazard
2. Even in the presence of prerequisite programs, the hazard would still not be adequately controlled
3. Validated scientific studies have shown a strong association with the raw material and the hazard e.g. salmonella on chicken
4. Historical plant records show frequent occurrence of the hazard
5. There has been recent food safety outbreaks associated with the hazard
6. The process step will not adequately remove the hazard or will cause it to increase

A hazard may be deemed NOT LIKELY to occur if:

1. Prerequisite programs have been found to adequately control the hazard
2. Historically, even without controls the food establishment has not found the particular hazard
3. The hazard is present in insignificant amounts that is not likely to cause injury
4. Equipment are in place to effectively control the hazard e.g. screens or filters

If you use “prerequisite programs” as your justification for not considering a hazard to be significant, be sure that it is actually effective enough to adequately control the hazard. For example, a mistake would be to assume that because you have an equipment preventative maintenance program, that you don’t need to consider metal as a significant physical hazard in your meat grinding operation. That would be an error because even in the place of preventative maintenance, you are still likely to have metal as a significant hazard due to metal-to-metal contact and moving parts.

Download a template of the HACCP Analysis form and learn how to complete this step of your HACCP program.