0. Food Safety Program Based on Process Approach to HACCP
Summer 2011

1. 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, form comments

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

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

4. USDA Food Safety Requirements
Public Law
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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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 school year
USDA will develop “practical” guidance

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

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

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

22. 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.

23. Trips through the Danger Zone
135°F
41°F
No Cook Same Day Complex

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

25. 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

26. 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

27. 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 of prototype)

28. 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

29. 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.

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

31. 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

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

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

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

35. 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

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

37. 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

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

39. 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

40. 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

41. 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

42. 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

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

44. 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

45. 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

46. 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

47. 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

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

49. 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

50. 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

51. 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

52. 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

53. 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?

54. 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

55. 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

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

57. 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?

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

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

60. 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

61. 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

62. 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

63. 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

64. 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

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

66. 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.

67. 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.

68. 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

69. 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

70. 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?

71. 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.

72. 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

73. 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

74. 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

75. 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

76. Enjoy the Rest of the Summer!