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Title:
Surdick, Matthew, J
Improving the HACCP system through the application of ISO 22000
The accompanying research report is submitted to the University of Wisconsin-Stout, Graduate School in partial
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MS Risk Control
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Surdick, Matthew, J. Improving the HACCP system through the application of ISO 22000
Abstract
The purpose of this study was to develop the framework and systems to advance the
current HACCP food safety program to reflect the standard of ISO 22000. The goals of the
study were to conduct an analysis of identified food safety systems to understand the best food
safety practices, conduct a GAP analysis of the food safety system at XYZ, and finally to
conduct a need assessment focusing on organizational analysis, task analysis, and individual
analysis. The methods used in the study include a review of literature of established food safety
systems to determine necessary improvements and utilize an ISO 22000 audit checklist to
determine the gap between the current food safety system at company XYZ and the ISO
standard. The last method used in the study was a semi-structured interview guide to conduct an
interview with different levels of management at company XYZ. Information collected from the
audit checklist and semi structured interview suggest that the current system established at
company XYZ would benefit from the implementation of ISO 22000 principles. The current
system at Company XYZ fails to properly train employees and managers on HACCP principles
and pre-requisite programs indicated by the results in the audit checklist and semi-structured
interview. Implementing a training program that teaches employees and managers the basics of
the program and the reason for the program, in addition to improving management involvement
will positively affect Company XYZs food safety system.
Acknowledgments
I am sincerely grateful for the experience and knowledge that I have received through
the Risk Control Program at UW-Stout. I would also like to sincerely thank Dr. Elbert Sorrell for
his support and motivation in the completion of my field problem. Lastly, I would like to
sincerely thank my fianc and family for their wonderful encouragement and unwavering support
through the completion of my degree.
Table of Contents
...................................... Page
Abstract ............................................................................................................................................1
List of Tables ...................................................................................................................................5
Chapter I: Introduction ....................................................................................................................6
Statement of the Problem .....................................................................................................7
Purpose of the Study ............................................................................................................7
Goals of the Study................................................................................................................8
Background and Significance ..............................................................................................8
Limitations of the Study.......................................................................................................8
Assumptions of the Study ....................................................................................................9
Definition of Terms..............................................................................................................9
Methodology ......................................................................................................................11
Chapter II: Literature Review ........................................................................................................12
Chapter III: Methodology ..............................................................................................................27
Subject Selection and Description .....................................................................................27
Instrumentation ..................................................................................................................28
Data Collection Procedures................................................................................................29
Data Analysis .....................................................................................................................30
Limitations .........................................................................................................................31
Chapter IV: Results ........................................................................................................................32
Results of Literature Review ............................................................................................32
Results from ISO 22000 Audit Checklist ........................................................................34
Results from Semi-Structured Interview ..........................................................................34
Summary ...........................................................................................................................35
List of Tables
Table 1: Five Preliminary Steps and Seven Principles to HACCP 16
Table 2: ISO 22000 Basic Outline ......21
Chapter I: Introduction
The concept of food safety has been in existence for centuries and has always upheld one
main objective: to eliminate potential contamination, whether physical, chemical, and/or
biological. According to the Center for Disease Control (CDC), 1 in 6 Americans, or 48 million
people, become ill from foodborne diseases each year. More astoundingly, approximately 3,000
Americans die annually from foodborne illnesses. A contributing factor to this alarming rate of
illness is due to new challenges that manufacturers and consumers face, such as new
microorganisms and toxins, changes in food production, changes in our environments, and the
rising number of multi-state outbreaks (CDC, 2011).
Due to new threats to the health and well being of individuals in the United States,
President Barack Obama passed the Food Safety Modernization Act (FSMA) in January of 2011.
This new bill directs the implementation of food safety systems in the food industry in the United
States. This bill also recognizes animal feed processors as food processors, which requires a
detailed food safety plan indicating potential hazards (Food and Drug Administration, 2011).
With a new focus on food safety, agricultural organizations are feeling more pressure to
implement programs that analyze potential contamination in their processes; the program that is
used and regulated throughout the industry is the Hazard Analysis Critical Control Points, also
known as HACCP. Until President Obama signed the Food Safety Modernization Act requiring
a food safety system, organizations that manufactured finished products enforced their own food
safety requirements. The HACCP food safety program covers all FDA requirements for food
manufacturers and ensures that proper documentation is in place in the event of an inspection or
recall. These new requirements present new challenges for all food processors from the small
farm to the large manufacturer. These challenges include identifying potential physical,
chemical, and biological hazards, determining how to sample critical limits, identifying
monitoring procedures, establishing corrective actions, implementing a verification schedule, and
introducing effective record keeping procedures. The World Health Organization (WHO) has
identified barriers that affect the implementation of a HACCP program, which include financial
constraints, lack of expertise and/or technical support, and inadequate infrastructure and facilities
(World Health Organization, 1999a).
A potential constraint when developing a HACCP plan is identifying likely
contaminations that may enter the process through raw materials or enter the product from the
machinery used in the organizations facility. The issues discussed above will require company
XYZ to conform to the newly regulated food safety regulations. Company XYZ is a small
organization that processes dry edible beans in the upper Midwest of the United States.
Company XYZ receives, processes, and repackages beans grown in Wisconsin, Minnesota, and
North Dakota. This organization has an established HACCP program and a few select prerequisite programs that assist the food safety system, but lack the management involvement and
training needed for an effective food safety system. With the ever-growing focus being placed
on agriculture, there is significant pressure to implement an effective food safety program that
ensures safe products. The FSMA states that food processors are to identify potential physical,
chemical, and biological hazards in their raw material and in the manufacturing facility.
Furthermore, processing controls and programs are required to prevent, monitor, and eliminate
potential foodborne hazards throughout the manufacturing facility.
Statement of the Problem
Even though company XYZ has a HACCP (quality and safety) system in place to address
potential food safety issues, improvements in the current system could ensure better food safety.
Purpose of the Study
The purpose of this study was to develop the framework and systems to advance the
current HACCP food safety program to reflect the standard of ISO 22000.
Goals of the Study
program and quality program. In larger organizations, employees primary responsibilities are in
only one of these areas.
Assumptions of the Study
An assumption of Company XYZ is that a HACCP food safety program has been
properly integrated into the organization. These programs are used as a basis for implementation
of the food safety system. An additional assumption is that the study will be limited to a three
month time period for completion.
Definition of Terms
CCP Decision Tree: A sequence of questions to assist in determining whether a control
point is a CCP (FDA, para 8, 2009).
Control: (a) To manage the conditions of an operation to maintain compliance with
established criteria. (b) The state where correct procedures are being followed and criteria are
being met (FDA, para 9, 2009).
Control Measure: Any action or activity that can be used to prevent, eliminate or
reduce a significant hazard (FDA, para 10, 2009).
Control Point: Any step at which biological, chemical, or physical factors can be
controlled (FDA, para 11, 2009).
Corrective Action: Actions taken when a process deviates from the standard.
Criterion: A requirement on which a judgment or decision can be based (FDA, para
13, 2009).
Critical Control Point: A step at which control can be applied and is essential to
prevent or eliminate a food safety hazard or reduce it to an acceptable level (FDA, para 14,
2009).
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Step: A point, procedure, operation or stage in the food system from primary production
to final consumption (FDA, para 26, 2009).
Validation: That element of verification focused on collecting and evaluating scientific
and technical information to determine if the HACCP plan, when properly implemented, will
effectively control the hazards (FDA, para 27, 2009).
Verification: Those activities, other than monitoring, that determine the validity of the
HACCP plan and that the system is operating according to the plan (FDA, para 28, 2009).
Methodology
The investigator analyzed various food safety guidelines and developed a standard, which
measured the level food safety implementation. Company XYZs food safety system was
reviewed and documented using the tools developed based off the literature review. Then the
author used the information collected to determine applicable recommendation for the
improvement of the current food safety system.
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The food safety program, HACCP, was first introduced as a joint venture between NASA
and the Pillsbury Corporation in the early 1960s (Mayes & Mortimore, 2001). It was initially
created to eliminate the microbiological hazards from outer space but also increase the
confidence that the space program could effectively maintain personnel safety. The primary
basis for eliminating the microbiological hazards was to ensure that astronauts would be safe
from sickness since they would be without medical care for several weeks (United National
Industrial Development Organization, 2000). Over the past 50 years, the HACCP approach has
gained popularity in both the private and public food sectors. A major turning point with the
implementation of food safety programs was the major outbreak of Clostridium Botulinum in the
early 1970s. Clostridium Botulinum is a spore shaped bacteria that can be found in any region
of the world. The initial symptoms include nausea, vomiting, and diarrhea, which can lead to
paralysis (WHO, 1999b). In response to the outbreak, the United States FDA issued low acid
canned food regulations, which are said to be the first government regulated HACCP programs
(Keener, 1999).
Another major development for the HACCP program was the establishment of the
Codex Alimentarius second edition in 1997. The Codex Alimentarius, which in latin means food
law or code, was established by the joint Food Agriculture Organization (FAO)/WHO
Committee. This standard on food hygiene was established to protect the health of consumers
and to ensure fair practices in the food trade (FAO/WHO, 1999). The basis of the second edition
was to establish the principles and guidelines to conducting microbiological risk assessments.
The code recommends that organizations use a HACCP based approach wherever possible to
enhance food safety (FAO/WHO, 1999). HACCP has evolved over the years due to the
advances in the quality management field, which in turn has allowed food processors to develop
a food safety management system (Surak, 2006).
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Today, with the assistance of the Food Safety Modernization Act, the FDA, and the US
Department of Agriculture requires mandatory food safety programs in all food and feed
manufacturing facilities (Keener, 1999). According to the FDA the new FSMA Act will have a
legislative mandate to require comprehensive, science based preventative controls across the
food supply (FDA, 1999).
History of ISO and ISO 22000
In 1946, representatives from 25 countries joined together to create a common and
unified industrial standard; the organization created was the International Organization of
Standardization (ISO). ISO has published more than 18,500 international standards in a 60-year
time period beginning in 1947. These standards range from agriculture and construction
standards, to mechanical engineering, to state-of-the-art information technology advances (ISO,
2011). Lawrence D. Eicher, the former ISO Secretary-General, stated in the book Friendship
Among Equals The essence of ISO's history is made up of the visions, aspirations, doubts,
successes, and failures of the people who, over the past fifty years, have created this rather
remarkable organization (Latimer, 1997).
According to Morrison and Morikawa, 2004, there were three major turning points for
ISO, the first being the development of the ISO 9000 Quality Management System in the 1980s.
Until this time, ISO was primarily known for creating technical specifications for specific
industries such as clothing size and laser technology. The second major turning point for ISO
was the development and implementation of the ISO 14000 Environmental Management
Standard in 1993 (Morikawa & Morrison, 2004). This was a major step as it started to work with
public policy and general public interest. The third major turning point for ISO was the
development of standards that support sustainability (Morikawa & Morrison, 2004). This
standard was named ISO Horizon 2010: Standards for a Sustainable World. Six decades since its
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inception, ISO has grown into the worlds largest standards development organization with well
over 14,000 standards and 148 countries in the federation (Morikawa & Morrison, 2004).
In 2005, there was an international effort to attempt to standardize the food safety system
worldwide. This effort resulted in ISO creating the ISO 22000 Food Safety Management System
(FSMS)- requirements for any organization in the food chain (Surak, 2007). The ISO 22000
FSMS was created similarly to other ISO management systems, more specifically to the ISO
9001 Quality Management System. The ISO management system forces the continuous process
improvement approach through analysis and considerations. The ISO 22000 system also takes
an integrated food safety approach in which companies are required to analyze potential food
safety hazards in final products and create preventative measures to control the hazards. State of
the art food safety systems are relatively new in the industry and are currently being driven by
customers rather than government regulation.
HACCP Fundamentals
HACCP and the ISO 22000 system were both developed with the intention of preventing
contamination in the food industry. The ISO 22000 standard was the first food safety
management system to go outside the Codex Alimentarius food hygiene recommendations set
forth in 1993 (Blanc, 2006). HACCP has evolved over the years and now has 12 established
steps, which include five preliminary steps and seven primary principles (Surak, 2007). Table 1
identifies the basic requirements to the developing a basic HACCP system.
Table 1
Five Preliminary Steps and Seven Principles of HACCP
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Step
Description
Principle One
Principle Two
Principle Three
Principle Four
Principle Five
Principle Six
Principle Seven
Surak, (2007) A recipe for safe food: iso 22000 and haccp
The first preliminary step in applying the HACCP principles is building the HACCP
team. The establishment of a HACCP team is a very important preparatory step prior to the
establishment of a HACCP plan. Prior to creating a cross-functional team, total commitment
from management must exist to ensure that the proper financial support will be in place
throughout the implementation (Hernandez, 1999). A cross-functional team should include
individuals who have specific knowledge to the processes involved and bring different
viewpoints to the group (Keener, 2007b & UNIDO, 2000). Individuals should be selected from
production, quality control, senior management, engineering, and maintenance personnel. Once
the team is established, each member should be trained on the components of the HACCP system
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to ensure that the team uses common terminology and has the same food safety focus (UNIDO,
2000).
The next step after creating the HACCP team is creating a description of the final product
that is manufactured at the particular facility. According to the United States Department of
Agriculture (1997) components of the description include common name, how it will be used,
type of packaging, shelf life, and how the product will be distributed. Product descriptions
should be tailored to each companys needs based on the amount of product it manufacturers.
The third preliminary step is identifying the products intended use. The products intended
should be based on the end users expected use of the product (FAO/WHO, 1999).
The fourth preliminary step in creating a HACCP program is the construction of a flow
diagram, which covers all steps of the process. The flow diagram should not be complex,
making it easy to understand and can include steps before and after the production of the product
(USDA, 1997). The fifth, and final, preliminary step involves the verification of the flow
diagram, which includes a walkthrough of the manufacturing process to ensure that the flow
diagram matches the actual process.
The first principle of the HACCP program is to conduct a hazard analysis, which includes
a list of steps in in the process where there is a potential for hazards to occur and the preventative
measures currently in place (USDA, 1997). A hazard is defined by the UNIDO as A biological,
chemical, or physical agent in, or condition of, food with the potential to cause an adverse health
effect (p. 7, 2000). The primary objective of creating a hazard analysis is to identify the
primary hazards in a facility that need to be controlled.
The second principle of a HACCP program is to determine the critical control points
based on the hazards indicated in the first principle. A critical limit is defined by the FDA as A
step at which control can be applied and is essential to prevent or eliminate a food safety hazard
or reduce it to an acceptable level (para 14, 2009). Critical control points (CCPs) can be
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determined through the use of CCP decision trees, which ask a series of questions related to the
effectiveness of an organizations ability to control a hazard. CCP decision trees are not
applicable to all situations, and other approaches might be recommended based on processing
specifications.
The third principle is establishing the critical limits for each designated CCP. Critical
limits are exposed as numbers or specific units of measurement such as temperature, pH level,
time, chlorine level, and/or a specific number of physical hazards found in a period of time. In
certain cases no more than one critical limit needs to be established to control a particular hazard
(USDA, 1997).
The fourth principle is establishing the monitoring procedures for each CCP. Monitoring
procedures are a scheduled measurement or observation of specific process or CCP (FAO/WHO,
1999). The USDA (p.14, 1997) recommends the following monitoring procedures for a HACCP
plan:
Identify the best monitoring technique based on the needs of each CCP.
Determine what testing procedures need to be done for each monitoring function.
Identify and train the employees responsible for completing the monitoring
process.
Verify that the employee conducting the monitoring is completing all required
documentation associated with that process. All records and documents should be
signed by the individual responsible for monitoring as well as a management
review and verification (FAO/WHO, 1999).
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Enter all the above information into a spreadsheet for proper documentation.
The fifth principle of HACCP is the establishment of corrective actions, which are a
detailed list of procedures in the event that there is a deviation from the established critical limits
at a CCP (FDA, 2009). Corrective actions can be determined prior to any deviation taking place.
A set protocol should be established in the HACCP plan for the proper steps an employee to take
in the event of a deviation. Corrective actions shall be reviewed monthly or annually based on
the needs of the organization and should be reviewed by the HACCP team.
The sixth principle is the establishment of recordkeeping procedures. Records are an
integral part of the HACCP program as they serve as written documentation that policies and
procedures are being followed. Records also allow an organization to trace the history of a
product from the raw material to the finished product in the event of an issue (USDA, 1997). To
follow the requirements of HACCP, records shall be completed for CCPs, establishment of
critical limits, corrective actions taken, and the hazard analysis.
The seventh, and final, principle of the HACCP program is the establishment of
verification procedures. The basis for these procedures is to verify the HACCP system is
working according to the plan. Verification procedures that can be performed are to audit the
monitoring procedures, calibrate testing equipment, sample finished product, and review
completed corrective actions.
ISO 22000 Fundamentals
The ISO 22000 incorporated the HACCP principles described in detail in the Codex
Alimentarius but also developed a management framework to improve effectiveness and
efficiency (Blanc, 2006). The ISO 22000 food safety management standard has the following
characteristics:
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Ensures that the process used to control food safety is validated, verified,
implemented, monitored, and managed;
(Surak, 2006)
One of the key components to the ISO 22000 FSMS is the integration of documented
management commitment and support (Nowicki & Sikora, 2007). The integration of these
management requirements enhances the ISO 22000 system over the basic HACCP principles.
One of the most significant requirements of the ISO 22000 systems is the commitment and
involvement of management in the food safety management system. The primary components of
a management system include:
Implementation and Operation- the first step of the implementation and operation
is defining the roles and responsibilities of employees that are associated with the
food safety management system. The second step is to provide training on the
food safety system and then establish internal and external communication.
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Once the system is implemented, management will then review the documentation to
ensure effectiveness and determine any areas requiring further improvement. Improvement
consists of management reviews, internal audits, corrective actions, verification results, and
validation results. Table 2 represents the basic requirements of the ISO 22000 FSMS. The
requirements of ISO 22000 are generic and are intended to be applicable to all organizations in
the food chain regardless of size (GFSI, 2007).
Table 2
ISO 22000 Basic Framework
ISO 22000 Clause
Number
4
4.1
4.2
5
5.1
5.2
System Requirements
Food Safety System Requirements
Establish a food safety management system
Document your food safety management system
Food Safety Management Requirements
Demonstrate a commitment to food safety
Establish a food safety policy
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5.3
5.4
5.5
5.6
5.7
5.8
6
6.1
6.2
6.3
6.4
7
7.1
7.2
7.3
7.4
7.5
7.6
7.7
7.8
7.9
7.10
8
8.1
8.2
8.3
8.4
8.5
further implement the Food, Drug and Cosmetic Act. In 1997, this was recorded as Part 110 and
was further revised and updated in 1986, to what is now regarded as Current Good
Manufacturing Practices (cGMPs)(para 4, 2007a). Keener continues to say GMP regulations
are designed to control the risk of contaminating foods with filth, chemicals, microbes, and other
means during their manufacture(para 5, 2007a). Common cGMP programs that are found in
different industries include general maintenance of facilities, pest and rodent control, proper
practice and storage of cleaning mixtures, and employee training.
Working hand in hand with cGMPs are SSOPs, which are written procedures that place
specific guidelines on a facility to ensure sanitary conditions. SSOPs are specific to each
organization and/or facility as to when areas of equipment are to be cleaned and maintained. The
two main components of SSOPs are pre-operational and operational (Keener, 2007a). Keener
describes pre-operational SSOPs as established procedures that describe the daily, routine,
sanitary procedures that occur before processing begins. The procedures must include the
cleaning of product contact surfaces of facilities, equipment, and utensils to prevent direct
product contamination or adulteration (p. 3, 2007a). ISO 22000 like many other food safety
certifications focuses on the communication of food safety goals, policies, and procedures to its
employees, customers, and visitors.
Conducting a Needs Assessment
A needs assessment is a systematic approach to studying the state of knowledge, ability,
interest, or attitude of a defined audience or group involving a particular subject (McCawley,
2009). Comprehensive needs assessment research helps document actual problems and
deficiencies (McCawley, 2009). There are four steps are that are used to create a needs
assessment for an organization (Rouda & Kusy, 1995):
1. Conduct a Gap Analysis
2. Distinguish Priorities and Significance
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gap analysis; which analyzes where a process or situation is compared to where it will be in
the future. When conducting a gap analysis, it is crucial that an auditor focuses on what is and
what is not established in the facility. The first significance of the analysis is to assess the
current state of the organization, which can include determining goals, climate, and
internal/external constraints (Rouda & Kusy, 1995). To know where an organization needs to
be, an audit or evaluation should be developed to determine what components are lacking.
According to Rouda and Kusy, 1995, the following are a list of need assessment techniques:
Direct observation
Questionnaires
Interviews
Focus Groups
Tests
Work samples
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The third step of the needs assessment is identifying causes of performance problems
and/or opportunities. When analyzing performance problems three questions need to be asked:
1. Are employees performing their jobs effectively?
2. Do they know how to do their job properly?
The fourth step to conducting a needs assessment is identifying possible solutions and
growth opportunities. Using steps one through three, deficiencies in a system have been
identified and now a corrective action must be taken. If individuals are not performing a job
effectively and efficiently a corrective action such as training and or organization development
should be used (Rouda & Kusy, 1995). Using organizational development as a tool can benefit
the organization through strategic planning and or proper team building exercises.
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President- The president of the organization has complete control of the office personnel
and has the final authority to establish new policies and procedures.
Plant Manager- The plant manager is responsible for production controls, implementation
of programs and procedures, and overall system performance. Decisions on monitoring
and corrective actions on quality and food safety fall on the responsibility of the plant
manager.
VP of Receiving and Procurement- Receiving and procurement are the first steps to
limiting the potential for hazards to enter the facility. This important role is to monitor all
incoming raw product prior to storage, identifying type, quality, and potential hazards.
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This individuals role is to work directly with the president, assisting in decision-making.
It is also the responsibility of this individual to assist the plant manager with process
changing decisions.
Shipping Manager- The shipping manager has control over the final step of the process
before the product leaves the facility. The shipping manager reports to the plant manager
on a daily basis for updates on shipping schedules and changes in production. This role
has the responsibility of working with other warehouse personnel on the preparation of
finished product for shipping.
The semi-structured interview and audit were conducted on a voluntary basis. There were
no consequences for any individual who declined to participate. All participants were
encouraged to ask any questions pertaining to the structure of the audit and interview prior to
starting.
Instrumentation
The first instrument used in analyzing the organizations established food safety
programs and procedures was an audit checklist. The audit consisted of yes or no questions
related to each of the fundamental components of ISO 22000. The checklist focused on current
management responsibilities, communication procedures, hazard analysis, and the establishment
of prerequisite programs. The first portion of the checklist indicates Managements responsibility
and their commitment to food safety through a mission statement, a vision statement, and
established programs.
The second portion of the checklist was the established communication procedures. This
determined how deficiencies, new programs or procedures, and any updates are communicated
throughout the organization. The third section of the checklist identified key components to the
HACCP system, which included identifying hazards, establishing CCPs, identifying critical
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limits, and the procedures to monitor and verify each established CCP. The fourth, and last,
section of the audit checklist was based on established pre-requisite programs.
The second instrument used in the study to determine the organizations needs was a
semi-structured interview guide. This guide was facilitated by an interview conducted by the
researcher utilizing key personnel in the organization. The semi-structured interview guide
focused on six major components: management support, prerequisite programs, establishment of
HACCP principles, documentation, and verification and principles. The procedures for the semistructured interview included asking open-ended questions, which were designed to promote
conversation between the researcher and the interviewee. The major components were used to
start the interview and lead into more specific questions with the process, structure, and
programs. The structure of the interview was developed based on the literature reviewed
pertaining to ISO 22000 components.
Data Collection Procedures
Due to the extensive food safety background with food safety systems and the
understanding of the plant processes, the plant manager was selected to assist in the audit process
and conduct the gap analysis with the researcher. The audit was conducted by asking a series of
questions related to each component of the ISO 22000 standard. The questions were asked in a
format in which resulted in a yes or no answer. Any components that were answered as nonapplicable (N/A) or as unknown were documented in the comments box next to the question.
Any additional comments added to any of the components of the ISO 22000 system were added
to the comments section in audit form.
The semi-structured interview was designed to identify established or lacking
components of the food safety system and was conducted between the investigator and HACCP
experienced management personnel. The President, Plant Manager, Vice President of Receiving
and Procurement, and the Shipping Manager completed the interview in a two-day period. As
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interviewees answered questions related to the ISO 22000 system, the interviewer recorded the
responses utilizing a voice recorder and detailed notes. This procedure was conducted to ensure
that answers were recorded accurately.
Data Analysis
The main objective of this study was to determine deficiencies in the current system and
to identify potential improvements following the ISO 22000 food safety management principles.
Based on the importance of understanding food safety principles in the organization, the
positions of interviewees were included in the results to determine if there are deficiencies in the
overall structure. The first instrument used in the study was the audit checklist conducted with
the Plant Manager. The audit checklist results were analyzed to determine the deficiencies,
which were presented with response; No. The basis of this analysis was to identify key programs
and procedures that are established or lacking at the facility.
The interview instrumentation will be analyzed to determine if there are any differences
in answers between the different subjects. The basis for this interview is to compare the
identified established programs in the audit checklist to the how each program is implemented in
organization. Proper implementation includes training to all employees on the components of the
program or step-by-step procedures. Differences in answers will display lack of overall
management buy-in throughout the organizations structure. The audit and interview responses
were analyzed based on the three major points.
These points are:
1. Current implementation of HACCP policies and procedures- these were measured by
analyzing the results of the interview compared to the components of the ISO 22000
standard. An important part of implementation is employee training on the specific topic;
employees should have a knowledge base for HACCP policies and procedures.
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2. GAP between current HACCP system and ISO 22000 principles- these are measured by
using the audit checklist to determine what ISO 22000 principles are implemented in the
facility.
3. Food safety training needs- food safety training needs is determined through the semistructured interview. The interview will establish the amount of training on specific
components of a food safety system.
Limitations
The primary limitation in the study was the lack of employees with experience in the
HACCP food safety system. Company XYZ is a small organization that requires many of its
personnel to perform other related tasks. For example, the plant manager also oversees the
HACCP program and quality program. In larger organizations, employees primary
responsibilities are in only one of these areas.
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entering into a process. The HACCP system utilizes a seven-step process to identify the
likelihood of risk and associate controls to reduce or eliminate potential hazard (Varzakas &
Arvanitoyannis, 2008). It has been suggested that the implementation of HACCP doesnt
provide enough system control to prevent some food borne illness outbreaks (Keener, 1999).
These systems controls include good manufacturing practices and other supporting pre-requisite
programs. The ISO 22000 Food Safety Management System applies the same principles of
HACCP but places a greater deal of emphasis on pre-requisite programs and overall management
commitment. The emphasis on management commitment resembles other management standards
as it has the following elements (Surak, 2007):
Policy Statements
System Improvement
Management Review
The ISO 22000 system utilizes an approach that food safety is more than just a quality
control program but requires a cross functioning organization. Through the implementation of
ISO 22000 principles, organizations are improving system performance with the involvement of
research and development, engineering, purchasing, sales, and human resources (Surak, 2006).
By involving other departments into the food safety system, the organization creates a complete
understanding of proper food safety practices that can be emphasized at all levels. Not only does
this system require a cross functioning team, but it also requires more involvement in manpower,
improvement, and involvement of the HACCP team, and places higher emphasis on the food
safety system (Blanc, 2006). ISO 22000 incorporates and enhances the HACCP system to create
an effective food safety management system (Surak, 2007). The literature review also provided a
33
basis for the creation of the audit checklist that was used to determine the current gap between
Company XYZs HACCP system and the ISO 22000 FSMS.
Results from ISO 22000 Audit Checklist
The audit checklist conducted with the plant manager established the level at which
Company XYZs current food safety system was operating. Company XYZ has established
some of the critical components to the ISO 22000 system but fails to have proper training to
assist in the implementation of the programs. Programs in clause 7.2 that need improvement are:
Allergen Control Program, Security Program, and Preventative Maintenance Program. Training
programs for pre-requisite and HACCP components are essential to the implementation of a
successful food safety management system (Surak, 2006). Corrective actions for pre-requisite
programs are not currently being documented by managers, which were indicated in response of
clause 7.2. The corrective actions serve as a basis for improvement and are required to show
improvement in process deficiencies.
In addition to the lack of training programs, a lack of management support in the HACCP
and in the pre-requisite programs could suggest a deficiency in the management system. Clause
5.3 indicates management was not involved in the development, implementation, or evaluation
of the food safety management system.
Results from Semi-Structured Interview
The semi-structured interview established a clear divide between management and
employees on food safety principles at Company XYZ. The first topic was based on
understanding of HACCP components. Based on the results provided, respondents understand
food safety and the importance of establishing controls in the facility. The interview shows that
while employees have an understanding of hazards, they lack the technical training to identify
the sources of contamination in the processing line. Additionally, while the new Plant Manager
at Company XYZ has an extensive background and overall knowledge of HACCP and food
34
safety, this individual lacks the resources to apply the basic concepts. All respondents answered
that they understand the major concerns in food safety with recalls, glass awareness, lack of
industry knowledge, and food hazards being the primary concerns. These elements are all part of
a food safety system, however, suggest that a reactionary approach is used to identify food safety
concerns. A successful HACCP program should proactively identify and reduce the likelihood of
food safety concerns opposed to waiting for the negative event to happen first (Keener, 2007b).
The second topic was managements commitment to food safety, which is a key
component to ISO 22000 system. Respondents indicated that while commitment to food safety is
present through physical controls, there is a clear need for improvement. The president
suggested that providing the managers with more resources, such as time and the tools necessary
to conduct food safety training, would improve managements commitment to food safety.
Additionally, another area of concern is the financial support that would be necessary to
implement an effective food safety management system.
Training was the third and last topic of the interview. Respondents suggest that there is a
serious deficiency in current food safety training programs at Company XYZ. The president and
vice president of receiving and procurement suggest there is a training program in place for some
pre-requisite programs, however, the shipping manager indicated there is no training currently in
place. This individual also indicates that employees are trained only by other employees. This
method of training does present successful real life examples but fails to present a consistent
message put forth by management. Suggestions for improvement include setting aside more
time for training, improving managements commitment to training, implementing a consistent
training program for employees and managers.
Summary
The purpose of this study was to identify areas of improvement for Company XYZs
food safety system using components of the ISO 22000 Food Safety Management System. This
35
chapter provided a synopsis of the results collected by the study. The first objective of the study
was to identify the current food safety systems. This was accomplished by reviewing literature
on HACCP and ISO 22000 Food Safety Management Systems.
The second objective of the study was to conduct a gap analysis between current food
safety systems and the components of ISO 22000. By utilizing the information gathered in the
literature review, an audit checklist was created to determine the current level of the food safety
system at Company XYZ.
The third and last objective of the study was to conduct a needs assessment focusing on
organizational, task, and individual needs. The needs assessment was facilitated using a semistructured interview guide that focused on current food safety system, management commitment,
and training. The information gathered from the audit checklist and semi-structured interviewed
were used to determine the recommendations presented in Chapter V.
36
Chapter V: Discussion
Restatement of the Problem
Even though company XYZ has a HACCP (quality and safety) system in place to address
potential food safety issues, improvements in the current system could ensure better food safety.
Purpose of the Study
The purpose of this study was to develop the framework and systems to advance the
current HACCP food safety program to reflect the standard of ISO 22000.
Goals of the Study
1. Conduct an analysis of identified food safety systems in order to understand the best food
safety practices.
2. Conduct a GAP analysis of the food safety system at XYZ.
3. Conduct a needs assessment focusing on organizational analysis, task analysis, and
individual analysis.
Methods and Procedures
To accomplish the goals of the study, the methods consisted of a literature review, audit
checklist, and a semi-structured interview. These methods assisted in the collection of
information related to company XYZ and the areas that could be improved related to food safety
programs and training.
A literature review was used to analyze two food safety systems, HACCP and ISO 22000
FSMS, and identify the specific components to each. The literature also served as the basis in
creating the audit checklist, in which each component of the ISO 22000 system was broken down
and questions were created based on each clause.
An audit checklist was conducted with Company XYZ to determine the current gap
between the current implemented food safety system and the requirements of the ISO 22000
37
FSMS. The results were used to determine deficiencies in the system and assisted in the
application of the semi-structured interview with employees.
A semi-structured interview was conducted with four members of Company XYZ, which
included the president, vice president of receiving and procurement, plant manager, and shipping
manager. The information attained from the interview assisted in the completion of the third
goal; conduct a need assessment focusing on organizational analysis, task analysis, and
individual analysis.
Major Findings
The audit checklist and semi structured interview used in the study indicated there was a
strong deficiency in the training of employees and managers as well as a lack management
involvement in the food safety system. There are a few major critical programs established that
will create a foundation for implementing further controls. Company XYZs current food safety
system utilizes a reactionary approach to identifying food safety hazards in product and the
facility.
Limitations
A primary limitation in the study was the lack of employees with experience in the
HACCP food safety system. Company XYZ is a small organization that requires many of its
personnel to perform other related tasks such as the plant manager also oversees the HACCP
program and quality program. In larger organizations, employees primary responsibilities are in
only one of these areas.
Conclusions
Objective 1 was to conduct an analysis of identified food safety systems in order to understand
the best food safety practices. The following conclusions were developed based on the results:
38
39
Company XYZ will be better served by implementing the ISO 22000 components to
improve their current food safety system. The current HACCP system fails to implement
a structured management commitment that would better serve the employees as well as
improve system effectiveness.
Pre-requisite programs provide the basic foundation to support a food safety management
system. Pre-requisite programs are designed for supporting an infrastructure and
establishing a clear hygiene program in a food manufacturing facility (Nowicki & Sikora,
2007). These programs also assist in the prevention of introducing food safety hazards
from the work environment.
Objective 2 was to conduct a GAP analysis of the food safety system at Company XYZ. Based
on the results, the following conclusions were developed:
Based on the results in appendix A, there is a clear gap between the food safety system at
Company XYZ and the component of the ISO 22000 food safety management system.
Company XYZ answered 58% of the questions with a yes indicating that that the
programs or procedures have been implemented. In comparison, 42% of the programs or
procedures are currently not being completed.
40
The results show that there are many critical components that Company XYZ has
established to reduce likelihood of food safety hazards. Major programs that are
established to assist the food safety system are: HACCP program, preventative
maintenance program, good manufacturing practices, allergen program, glass program,
pest control program, and document control program. These programs build a strong
foundation for future improvement of the food safety system.
Finally, the results show there are critical components missing that effectively verify and
validate the current food safety system. Verification and validation steps that are missing
are the proper training on pre-requisite program and the HACCP principles. In addition
there is a lack of management involvement with the creation, implementation, and
validation of the current food safety system.
First, the current system implemented at Company XYZ is based on reactive measures
instead of proactive measures. Actions are based on what customers are indicating as
issues instead of creating a system that identifies hazards before they enter the processing
facility.
Finally, there is a strong need to implement a training program that emphasizes the need
for workplace practices that focus on food safety. There were clear differences in opinion
of current training levels indicated in the semi-structured interview. The difference in
opinion of training levels indicates the lack of an established training program.
Recommendations
Based on the results from the study, the following recommendations were made
regarding the food safety program at Company XYZ:
41
Expand the responsibilities of the food safety team leader (HACCP Coordinator) to
include more interaction with top management on current issues in training and
implementation and updates of the foods safety system. The food safety leader is a
critical link in the implementation of the food safety system (Surak, 2007).
Develop a food safety-training program that emphasizes the pre-requisite programs and
the food safety system components. Prior to the implementation of the training program,
it is vital that there is management commitment and employee buy-in to the food safety
programs. The lack of buy-in from employees and managers will result in a deficient
training program and could lead to an ineffective food safety program. Employees and
managers should be trained on the fundamentals of the program, the importance of the
program, and how the program relates to the employees tasks. Suggested training topics
are:
o Background of Food Safety- Teach employees the history of food safety and
current updates in regulation. Understanding the evolution of food safety will
contribute to the foundation of your food safety system.
o HACCP principles- Train employees on the five preliminary steps and seven
principles of HACCP. It is vital that employees and managers understand how
HACCP is created and the basic steps to identify and control potential
contaminates.
o Critical Control Point Training- Train employees and managers what steps in the
process are identified as critical control points and the critical limits associated
with those steps. Operators in the processing line need to understand why a
specific process is a critical control point and the consequences associated with
the critical limit.
o Hazard Awareness Training- Teach employees how to recognize physical,
chemical, and biological hazards that could be potentially originate in raw product
or result from equipment breakdown. This training will also cover hazard
investigations, which will allow employees to assist in the identification of hazard
type and point of origin.
o Pre-requisite Program Training- Train employees on each program and how they
create a foundation to support the food safety system.
42
1. Analyze the Safe Quality Food (SQF) standard and determine the relation between ISO
22000 and SQF.
2. Conduct further semi-structured interviews with employees located in the processing line
to more accurately determine levels of training.
43
44
References
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Retrieved from http://www.iso.org.ims
CDC. (2011, August 15). Cdc and food safety. Retrieved from
http://www.cdc.gov/foodsafety/cdc-and-food-safety.html
Ehiri, J. E. (1997). A Survey of HACCP Implementation in Glasglow: Is the information
reaching the target? International Journal of Environmental Health Research
FAO/WHO, (1999). Codex alimentarius- food hygiene basic texts
Food and Drug Administration, (2009). Hazard analysis and critical control points principles and
application guidelines Retrieved from
http://www.fda.gov/Food/FoodSafety/HazardAnalysisCriticalControlPointsHACCP/HA
CCPPrinciplesApplicationGuidelines/default.htm#defs, (para 8-27)
Galosich, A. (1999). Operation HACCP. National Provisioner .
GFSI. (2007). What is iso 22000?. The Food Business Forum
Hernandez, J. O. (1999). How to develop a food safety program. Restaurant Hospitality,
(January), 106-110.
ISO. (2011). The iso story. Retrieved from
http://www.iso.org/iso/about/the_iso_story/iso_story_foreword.htm
Karl Ropkins, A. F. (2003). Development of Hazard Analysis by Critical Control Points
(HACCP) Procedures to Control Organic Chemical Hazards in the Agricultural
Production of Raw Food Commodities. Critical Reviews in Food Science and Nutrition
(43), 287-316.
Keener, K. E. Purdue University, Purdue Extension. (2007a). Ssop and gmp practices and
programs. Retrieved from http://www.ces.purdue.edu/new
Keener, K. E. Purdue University, Purdue Extension. (2007b). Overview of haccp Retrieved from
http://www.ces.purdue.edu/new
Keener, L. A. (1999). Is haccp enough for ensuring food safety? Food Testing and Analysis,
(October/November),
Latimer, J. A. (1997). Friendship among equals.
Mayes, T., & Mortimore, S. (2001). Making the most of haccp. Cambridge: Woodhead
Publishing Limited.
Lopez, S. R. (2003). The role of pest control in haccp. AIB, 12-16.
Miller, J. A., & Osinski, D. I. (2002). Training needs assessment. SHRM,
Nowicki, P. A., & Sikora, T. A. (2007). Food safety assurance according to codex alimentarius
and iso 22000 standard. Polish Journal of Food and Nutritional Sciences, 57(4), 489-493.
Rouda, R. O., & Kusy, M. I. (1995). Needs assessment- the first step. Tappi Journal,
Surak, J. O. (2006). Strengthening the food safety management system. Quality Progress,
(October/November),
Surak, J. O. (2007). A recipe for safe food: Iso 22000 and haccp. Quality Progress, (October),
United Nations Industrial Development Organization (UNIDO), (2000). Hazard analysis and
critical control points (haccp). Retrieved from http://www.unido.org/doc/31861
USDA. (1997). Guidebook for the preparation of haccp plans United States Department of
Agriculture.
Varzakas, T. H., & Arvanitoyannis, I. S. (2008). Iso 22000 & haccp in ready to eat vegetables.
International Journal of Food Science and Technology, 1729-1741.
World Heath Organization, (1999a). Strategies for implementing haccp in small and/or less
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http://www.who.int/foodsafety/publications/fs_management/en/haccp_smallbus.pdf
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http://www.who.int/mediacentre/factsheets/fs237/en/
46
.
ISO
22000
Clause
Numbe
r
System Requirements
4
Food Safety System Requirements
Established Food Safety Management System
4.1
(FSMS)
Does the organization have an established Food
Safety Management System?
Has the system been certified by an external party?
Documentation to support the Food Safety
4.2
Management System
Does the organization have documentation to support
the FSMS?
Are food safety management documents controlled?
Are procedures established to control FSMS records?
5
Food Safety Management Requirements
5.1
Food Safety Management Commitment Policy
Is there an established Food Safety Management
Commitment Statement?
Is Management Commitment Statement visible for all
employees?
Have top management signed the Food Safety
Management Commitment Statement?
Is there a food safety vision statement?
Is there a food safety mission statement?
5.2
Food Safety Policy
Is there a food safety policy?
Is the food safety policy posted for all employees?
Have managers implemented food safety policy
throughout the organization?
5.3
Plan your food safety management system
Are top managers involved in the development of the
FSMS?
Are top managers involved in the implementation of
the FSMS?
Are top managers involved in the evaluation of the
FSMS?
5.4
Clarify the FSMS responsibilities
Yes
No
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Comments
47
48
5.5
5.6
5.7
5.8
6
6.1
6.2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
49
6.3
6.4
7
7.1
7.2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
50
7.3
7.4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
51
7.5
7.6
7.7
7.8
7.9
7.10
8
8.1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Records are
retained for a five
year period
X
X
X
X
X
X
X
X
X
52
8.2
8.3
8.4
8.5
X
X
X
X
X
X
X
X
X
X
X
X
Question 1:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 2:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 3:
President
VP of Receiving and
Procurement
Plant Manager
53
54
Shipping Manager
Question 4:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 5:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 6:
President
VP of Receiving and
Procurement
55
Plant Manager
Shipping Manager
Question 7:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 8:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 9:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 10:
President
56
VP of Receiving and
Procurement
Plant Manager
Shipping Manager
Question 11:
President
VP of Receiving and
Procurement
Plant Manager
Shipping Manager