Food Safety Program Based on Process Approach to HACCP Summer 2011

USDA Food Safety Requirements Effective July 1, 2005 USDA Interim Rule published June 15, 2005 Final rules to formalize food safety requirements published on August 8, 2008 form comments

USDA Food Safety Requirements Public Law 108-265 1. Request two annual food safety inspections for each preparation/serving site participating in NSLP and/or SBP

USDA Food Safety Requirements Public Law 108-265 2. Public Notification Post copy of most recent safety inspections at each preparation/serving site Provide copy upon request

USDA Food Safety Requirements Public Law 108-265 3. State/Federal Audits to Assure Compliance DPI must report # of inspections to USDA Info is obtained from Schedule A of on-line contract “Meals not served” is response if there is no meals service at school listed on Schedule A

USDA Food Safety Requirements 4. Implement Food Safety Program based on Hazard Analysis Critical Control Point (HACCP) principles Schools participating in the NSLP and/or SBP Guidance issued on June 10, 2005

USDA Food Safety Requirements Schools with HACCP based food safety program in place may retain their current program if it includes all the HACCP principles listed in USDA guidance

Who were effected by regs? School agencies participating in USDA’s NSLP and/or SBP 926 school agencies (districts & private schools) Approximately 2,400 buildings DPI’s School Nutrition Team DHFS’s Division of Public Health and agents School Nutrition Association (SNA) of WI

Wisconsin’s Compliance Plan Developed by representatives from: DPI’s School Nutrition Team Department of Health/Agents who conduct food safety insepctions SNA of WI

Final Rule Effective January 14, 2010 Codifies the food safety plan requirements Addresses recordkeeping requirement Include food safety program as part of state agency administrative reviews Extends food safety program requirement to school breakfast program

Reauthorization 2010 HHFKA/ Public Law111-296 Strengthens existing food safety requirements for all FNS programs (NSLP, SBP, FFVP, SMP, plus Afterschool Snack & Supper Programs) Food safety plan based on HACCP must be applied to any facility or part of facility where food is stored, prepared or served for FNS programs USDA anticipates minor updates for meal/milk service on school buses, in hallways, kiosks, classrooms, or other areas outside cafeteria Effective ASAP/n o later than 2011-12 school year USDA will develop “practical” guidance

Process Approach to HACCP Principles USDA Guidance - June 2005 School Food Safety Program Based on Process Approach to HACCP Principles

Purpose of School Food Safety Program Ensure the delivery of safe foods to children in school meal programs by controlling hazards that may occur or be introduced into foods anywhere along the flow of food from receiving to service – USDA Guidance

What is Hazard Analysis Critical Control Point (HACCP)? A scientific and rational approach to food safety which: analyzes potential hazards determines the critical control points in a food process develops monitoring procedures to determine if the hazards identified are effectively controlled

Why is HACCP the “Gold Standard” in food service? Foodborne illness outbreaks are major financial and public relations cost to the food service industry Children are vulnerable Visual inspections of food product cannot detect pathogens Documented HACCP controls can prevent foodborne illness from occurring

Seven Principles of HACCP Conduct a hazard analysis Identify critical control points Establish critical control point monitoring Establish corrective action Establish verification procedures Establish record keeping

Differences Between Traditional and Process Approach Traditional HACCP focuses on recipes For process approach: Menu items are grouped into a given food preparation process that have similar hazards Actions or activities used to prevent, eliminate or reduce hazards are similar

Plan for Each Production/Serving Site Documents menu items in appropriate HACCP process category Identifies critical control points and control measures Includes monitoring responsibilities and forms to be used Establishes and documents appropriate corrective actions taken Includes records to show plan is operational Ongoing review and plan revisions needed

Nine Steps for Plan Development Describe each preparation/serving site Categorize menu items as process 1, 2, or 3 Identify critical control measures and limits Develop and /or adapt prototype Standard Operating Procedures (SOPS) specific to site Establish monitoring procedures Establish corrective actions Choose appropriate monitoring records Provide training Review and revise food safety program period

Step 1: Site Description Separate plan specific to site Include equipment inventory Floor plan is not needed for process approach Description for the individual site plan should reflect what is done at preparation/serving location Same set ups may have same plan Obtain assistance from those who prepare and serve

Step 2: Categorization Process Start with school menus (lunch & breakfast) Include a la carte items and other items served as part of Afterschool Snack Program, Fresh Fruit and Vegetable Program (if applicable) Complete chart to indicate the category Minimize lists by grouping like items Canned fruit Dairy products Purchased bread products Fully cooked chicken products Some items to list separately: Fresh melon and strawberries “Casseroles” with various ingredients & cooling processes

Process Approach to HACCP Categorize all items including: Potentially Hazardous Foods (PHF): ■ Egg ■ Meat ■ Dairy ■ Heated Vegetables/Fruits Non-Potentially Hazardous Foods: ■ aw of 0.85 ■ pH of 4.6 ■ Hermetically or less or less sealed Place * by PHF (T/TC) such as melons & strawberries

Process Approach to HACCP Group items according to number of times the food goes through the “danger zone” (41°F. and 135°F.) Process #1 – No Cook Menu item is not in the danger zone Process#2 – Same Day Service Menu item takes one trip through danger zone Process#3 – Complex Food Preparation The menu item goes through both heating and cooling, taking two or more trips through the danger zone.

Trips through the Danger Zone 135°F 0 1 1 2 3 41°F No Cook Same Day Complex

Process #1 – No Cook Receiving → Store → Prepare → Hold → Serve Sub Sandwich with Ready to Eat Ingredients

Process #2 – Same Day Service Receiving → Store → Prepare → Cook → Hold → Serve Menu items made from canned, packaged, frozen, raw ingredients that involve a cook step. Heated canned or frozen vegetables Pizza Fully cooked chicken products

Process# 3 – Complex Food Receiving → Store → Prepare → Cook → Cool → Reheat → Hold → Serve Menu items with preparation steps which may require cooling and reheating prior to being served Spaghetti Sauce Turkey and Gravy Hard boiled eggs Heated Leftovers

Step 3: Identify Critical Control Points & Measures Critical Control Point (CCP) an operational step in a food preparation process at which control can be applied and is essential to prevent or eliminate a hazard Control Measures - any action or activity that can be used means taken to prevent , eliminate, or reduce hazards to an acceptable level (Refer to flow charts on p. 9-10 of prototype)

Critical Control Points Points in food preparation/processing where controlling a step is essential to assure food safety Receiving Cold Holding Cooking Hot Holding Cooling Reheating

Critical Measures in Process Approach HACCP No Cook: Cold holding or limiting time in the danger zone to inhibit bacterial growth and toxin production (e.g., limiting time item is at room temperature and discarding items that reach limits. Same Day Service: Cooking to destroy bacteria and other pathogens Hot holding or limiting time in the danger zone to prevent the growth of spore-forming bacteria. Complex Food Preparation: Cooling to prevent the outgrowth of spore-forming bacteria Hot and cold holding or limiting time in the danger zone to inhibit bacterial growth and toxin formation Reheating for hot holding, if applicable.

Control Measures . Include: Critical Limits CCPs SOPs Established for each processes

Critical Limits The time and temperature ranges for food preparation and service (either hot or cold) that keeps food safe. Cold holding = 41°F (Maximum) Hot Holding = 135°F (Minimum) Cooking = Time + Temperature Cooling Reheating Previously Cooked

Critical Measures & Limits Process 1 Example: Sub Sandwich with RTE Ingredients General Receive Store Prepare

Critical Measures & Limits Process 1 Example: Sub Sandwich with RTE Ingredients COLD HOLDING Critical Limit: Internal Temperature of 41°F Check & Record Temperatures SERVE

Critical Control Measures & Limits Process 2 Example: Fully Cooked Chicken Nuggets General Receive Store Prepare

Critical Limits – Process 2 Example: Fully Cooked Chicken Nuggets COOK/REHEAT FULLY COOKED PRODUCTS Critical Limit: Internal Temperature of 135°F for 15 seconds Check & Record Temperatures Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Critical Control Measures & Limits for Process 2 Raw Beef for Spaghetti Served on Same Day General Receive Store Prepare

Critical Limits – Process 2 Raw Ground Beef for Spaghetti Sauce – Served Same Day COOK/GROUND BEEF Critical Limit: Internal Temperature of 165°F for 15 seconds Check & Record Temperatures Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Critical Control Measure & Limits - Process 3 Raw Ground Beef for Spaghetti Sauce – Served Next Day General Receive Store Prepare

Critical Limits – Process 3 Raw Ground Beef for Spaghetti Sauce – Served Next Day COOK/GROUND BEEF Critical Limit: Internal Temperature of 165°F for 15 seconds Check & Record Temperatures

Critical Control Measures & Limits Process 3 Raw Ground Beef for Spaghetti Sauce – served next day Critical Control Point: COOL Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours. Check & Record Temperatures

Critical Limits – Process 3 Raw Ground Beef in Spaghetti Sauce – Served Next Day Critical Control Point: REHEAT Critical Limit: Heat to 165 °F for at least 15 seconds. Check & Record Temperatures

Critical Control Limits & Measures - Process 3 Raw Ground Beef in Spaghetti Sauce - Next Day Service Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Critical Control Measure & Limits - Process 3 Turkey Roast (Raw – Served Next Day General Receive Store Prepare

Critical Control Measures & Limits Process 3 Example: Turkey Roast (Raw) & Gravy General Receive Store Prepare COOK/Raw Turkey Roast Critical Limit: Internal Temperature of 165°F for 15 seconds Check & Record Temperatures

Critical Control Measures & Limits Process 3 Turkey Roast (raw) & gravy – served next day Critical Control Point: COOL Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours. Check & Record Temperatures

Critical Limits - Process 3 Example: Turkey Roasts (raw) & Gravy Critical Control Point: REHEAT Critical Limit: Heat to 165 °F for at least 15 seconds. Check & Record Temperatures

Critical Control Measures & Limits Process 3 Example: Turkey Roasts (raw) & Gravy Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Critical Control Measures & Limits Process 3 Example: Fully Cooked Chicken Nuggets – Heated Leftover General Receive Store Prepare

Critical Limits – Process 2 Example: Fully Cooked Chicken Nuggets – Heated Leftover COOK/REHEAT FULLY COOKED PRODUCTS Critical Limit: Internal Temperature of 135°F for 15 seconds Check & Record Temperatures Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Critical Control Measures & Limits Process 3 Example: Fully Cooked Chicken Nuggets – Heated Leftover Critical Control Point: COOL Critical Limit: Cool from 135 °F to 70°F within 2 hours and from 70°F to 41°F or lower within an additional 4 hours. Check & Record Temperatures

Critical Limits – Process 3 Example: Fully Cooked Chicken Nuggets - Heated Leftovers Critical Control Point: REHEAT Critical Limit: Heat to 165 °F for at least 15 seconds. Check & Record Temperatures

Critical Control Measures & Limits Process 3 Example: Fully Cooked Chicken Nuggets - Heated Leftovers Critical Limit: Hot hold at no less than 135°F. Check & Record Temperatures SERVE

Step 4: Develop/Adapt SOPs SOPs are written instructions for a food service task that reduce food safety hazards. Usually written to include: Who? What? When? Where? How? Why?

Components of USDA’s SOPs Purpose (What) Scope (Who does this apply to) Keywords (New terms) Instructions (How, Where and When) Monitoring (Why) Corrective Action (What to do if there is a problem) Record Keeping

SOPs Developed by DPI School Nutrition Team for Prototype Adaptation of USDA’s & Iowa State University SOPs Include WI Dept. of Health Services Food Code Fact Sheets Minimized number of SOPs by grouping items - examples: No bare hand contact with glove use Manual and Machine dishwashing Monitor for critical control points Only

What SOPs Do You Need? Address critical control measures for process 1, 2 & 3 potentially hazardous foods in your operation Provide food safety foundation

Step 5: Establish Monitoring Procedures Considerations: What is monitored? How will you monitor? When and how often will you monitor? Who will be responsible for monitoring?

& What is Monitored Critical control measures Most involve measurements involving temperature & time &

Who Monitors Directly associated with the operation Trained and knowledgeable Accessible to monitoring activity Responsible Specify position and back up

Step 6: Establish Corrective Action Needed whenever a critical limit is not met Must be carried out immediately Employees must know what is expected and how to make right decision Determined for all CCPs Include summary in each school plan

Corrective Action Example Cooler not maintaining 41°F temperature Is cooler is working properly? Is thermometer calibrated? Report temperature reading to supervisor if cooler is not working properly Supervisor contacts service repair person if thermometer is accurate

Step 7: Maintain Records Food Safety Plan Records to be kept Receiving logs (or make use of invoices) Cold Holding Temperature logs Monitoring (cooking, cooling, and reheating and other Critical Control Points) Corrective action Calibration records Training logs Documentation of activities provides proof that reasonable care was exercised in the event your school is implicated in a foodborne illness

How long must records be kept? Any combination records that include production plans - 3 years plus current Monitoring records food safety inspections - 6 months Recommendation: Keep monitoring records for school year to support food safety plan and keep two most current food safety inspection reports

Step 8: Provide & Document Training Basic food safety Specific to Process approach to HACCP & the food safety plan Annual training schedule Documentation of training shows there is employee participation in plan

Important Competencies Basic food safety knowledge Employee health reporting responsibilities Proper handwashing/glove use Thermometer usage and calibration SOPs Recordkeeping procedures

Helpful Job Aids Signage and posters at strategic locations Written recipes and daily production plans that designating process category CCPs in written recipes Monitoring logs that includes temperature ranges for cold holding, hot holding, etc.

Step 9: Review & Revise Food Safety Plan Review and revise food safety plan at least annually or as often as necessary to reflect any changes Changes may include: New equipment New menu items Different vendors New programs Reports of illness Comments on a health inspection report Other factors or changes in procedures.

Step 9: Review & Revise Food Safety Plan, cont. Meet HHFK Act of 2010 provision which requires review and update for all FNS programs Consider making appropriate revision to DPI prototype SOPs/monitoring logs now listed on DPI website for: Breakfast Served in Classroom Milk/juice transported in coolers Prototype transport sheets for lunch, breakfast, afterschool care snack

Food Safety Plan Review Food Safety Inspection Determine if there is a completed plan for each site Accurate Description Menu items categorized by process type SOP specific to food service operation & followed Employees understand and follow SOPs Select three SOP’s to determine if applicable and implemented Review monitoring records for three days selected at random since last inspection

Food Safety Plan Review, cont. Are records maintained? Review by choosing 3 random days in current school year to verify all records kept. Check to see if: Appropriate temperatures are monitored and recorded. Records appear accurate and consistent. Are corrective actions documented if a critical limit is not met?

Food Safety Plan Review, cont. Is there a Employee Food Safety Training Program in place? Plans reviewed and updated annually and when there are changes? Report will be left summarizing results of plan review. If there is no plan available: Must display inspection report that states “no plan”. Expect follow up – environmental specialist will notify DPI.

Overall Considerations Time Simplicity Make changes in operation to make that possible Batch cooking to minimize holding Purchase /order fully cooked meat items Limit number of process 3 by eliminating cooling step Specific to food service operation Support and recognition from administration & others Involvement & Input Continuous Improvement

Successful Implementation Recommendations Work with school administration to develop strong school agency wide food safety and security policy to cover: School food service Food brought from home Vending Field trips Concessions Use of facility by outside groups Access to the school kitchen

Successful Implementation Recommendations Required food safety certification for all management/supervisory personnel Provide food safety education for all employee & students Develop self inspection programs Stay informed about current food safety regulations

Where to direct questions? Contacts/Resources: Julie Shelton(School Program Regulation Compliance) James Mack (WI Food Code & Contact info for DHFS or Agent, & Fee Schedule) Person who conducts food safety inspections

Enjoy the Rest of the Summer!