How to Take Corrective Actions

So, you have already identified your critical control points (CCPs), set critical limits and established monitoring procedures. Remember that the purpose of the monitoring procedure is to ensure that critical limits are met. So what if a critical limit is not met? Then you will need to have corrective actions in place to fix the problem. By taking corrective actions you are able to prevent hazard from entering commerce. When deviations  from the critical limits occur that may likely result in foodborne injury, you will need to:

1. Separate and hold the affected product
2. Identify the cause(s) of the deviation
3. Decide what to do with the affected product
4. Keep a record of the deviation and the corrective action taken

Separate and Hold the Affected Products

Products that do not meet critical limits must be separated and held for evaluation. The amount to be separated will depend on the frequency of monitoring. For example, if you are checking your metal detector every four hours, then all the products that were made in the last four hours must be separated and held. However, if your system is automated, deviated products may be immediately diverted from the production line to a holding area. In this way, the resulting loss will not be as large.

Identify the Cause(s) of Deviation

Corrective action will depend on the cause of the problem. For example, if  cooking temperature is too low, this could be due to a drop in steam flow resulting from an incorrectly adjusted steam value or drop in boiler pressure. High cooling-water temperature could be due to a drop in water flow rate and hence  poor heat transfer efficiency. A high pH could be caused from inadequate acidification during the formulation or fermentation step, or improper calibration of the pH meter.

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Decide What to Do With the Affected Product

Products that have not met the critical limits must be held in such a manner as to prevent or minimize further deterioration. Therefore products may need refrigeration during the holding time. Product evaluation could involve simply re-running the product though a fully functioning metal detector in the case of metal contamination. If the correct pH was not met, the product could be reworked by adding acid to adjust the pH. In the case of under-cooking, a microbial evaluation will be required. Keep in mind however that microbial evaluation of finished products as a verification measure has significant limitations since you will generally need a very high sample size to provide a reasonable degree of certainty that the product is free from the biological hazard. This large sample size may be impractical from an economic standpoint. Where re-evaluated products have been confirmed to be unsafe, they may be re-purposed, for example diverting them to a line where they will be thoroughly cooked and formulated into a new product. However, where re-purposing is not possible, potentially contaminated products should be dumped.

Keep a Record of the Deviation and Corrective Action

A record of all corrective actions taken should be made and maintained; whether or not the product was found to be safe after evaluation. All production records associated with the deviated product must also be retained for review. Deviated products must be firmly and clearly tagged identifying the:

1. Date
2. Product name
3. Product code
4. Hold number
5. Quantity of product held
6. Name and signature of the responsible individual
7. Statement outlining cause of deviation
8. Statement outlining how the deviation was corrected

Other records may include product test results and processing authority/expert recommendations.

Reference: Scott, V. N. & Stevenson, K. E. (2006). HACCP – A systematic approach to food safety, 4th edition. Washington, DC: Grocery Manufacturers Association.