From: Food Quality & Safety magazine, June/July 2013

Embracing HACCP

by Andy Teng

Embracing HACCP
Jack in the Box relies on its HACCP program to help identify and monitor the preparations of its products.

Produce and agricultural manufacturers and processors have long embraced Hazard Analysis and Critical Control Points (HACCP) principles since they were first developed in the 1960s. For those producing meats and poultry, seafood, juices, and a few other high-risk categories, following a HACCP plan isn’t just a good practice; it’s required under federal regulations. But as only one link in the farm-to-fork food safety continuum, manufacturers and processors alone cannot protect consumers from foodborne illnesses.

Retailers and food service providers also play an important role in ensuring food safety, but most are exempted from FDA and USDA HACCP requirements even though they deliver finished products into the hands of consumers. Regulated by state and local authorities, this important segment of the continuum is increasingly turning to HACCP in response to business trends, greater awareness of potential risks, and regulatory changes at the state level, industry observers say. While broader HACCP adoption may eventually help improve food safety in stores and restaurants by providing them a time-tested framework, some observers also say it’s difficult to measure the net impact on consumer safety and the benefits to businesses that embrace it.

“Clearly people are moving in this direction if they haven’t already,” states Robert Gravani, a professor of food science at Cornell University in Ithaca, N.Y. “Most people want to raise the bar; they’re not going to want to do just the minimum.”

A faculty member at Cornell’s department of food science, Gravani teaches HACCP principles to businesses through the university’s extension program. While anecdotal, there is evidence to show that more companies are expressing an interest in how HACCP can improve food safety at their stores and restaurants, he says. This rise, he points out, stems from the fact that many retailers offer a growing menu of fresh and prepared foods—through a traditional salad bar, a hot food stand, or even a sushi bar. For example, a visit to a Whole Foods supermarket is akin to a stop at a food court because it offers a variety of traditional and ethnic foods.

“Today the number of freshly prepared foods and menu items are just absolutely astounding and tremendous. There are eat-in restaurants within retail stores. There are a lot of foods available for carry out in a variety of places, so it makes great sense to apply the HACCP principles to the preparation and services of these foods,” Gravani points out.

This shift among retailers and concerns about the growing number of foodborne illnesses have the industry reviewing and stepping up their practices. After all, there is cause for concern. According to the Centers for Disease Control’s FoodNet, which tracks foodborne illnesses across the U.S., the number of confirmed cases rose sharply last year in two categories: Campylobacter and Vibrio. Most alarming was that the incidences of Campylobacter infection rose to the highest level since 2000 even as the rate of infection for STEC O157, Salmonella, and other major food-related illnesses remained unchanged. With high-profile outbreaks becoming a regular occurrence, many companies are concerned for their customers and their brands.

HACCP At A Glance

While HACCP is a way of life for many processors and manufacturers, those in food service and retail are less enlightened. That’s because the U.S. Food Code makes it a voluntary exercise for most retailers; however, the FDA has encouraged participation by issuing a HACCP manual for retail businesses entitled Managing Food Safety: A Manual for the Voluntary Use of HACCP Principles for Operators of Food Service and Retail Establishments. In this document, the agency does urge com­panies to “take a proactive role in ensuring that the food served or sold in your establishment is safe” by developing a HACCP plan.

HACCP can be intimidating to smaller retailers and food service operators, some observers note, because it’s perceived as overly complex. Many of these organizations lack internal resources or knowledge and so stay away. But as some trainers point out, HACCP offers a rigorous approach to food safety that isn’t necessarily burdensome. They simply need to adhere to its seven principles:

  • Perform a Hazard Analysis,
  • Identify Critical Control Points (CCPs),
  • Determine the Critical Limits,
  • Establish Procedures to Monitor CCPs,
  • Establish Corrective Actions,
  • Establish Verification Procedures, and
  • Establish a Record Keeping System.

As convenience stores have expanded their food selection, the potential for problems rises without proper training and protocols.

While the system was originally developed by Pillsbury in conjunction with NASA and the U.S. Army to ensure food safety for astronauts, its principles are suitable for the broader industry. By following them, organizations can prevent rather than just react to problems in their food safety programs. It is mandatory for seafood, meat and poultry, fresh-cut produce, juice, and some specialty producers to develop and implement a HACCP plan, but retail and food service establishments such as restaurants, grocery stores, prisons, health care facilities, child and adult care centers, convenience stores, and others are exempted from federal requirements. However, a growing number of businesses are embracing some or all of these principles as part of their overall safety and quality programs because of HACCP’s proven effectiveness.

Expanded Food Offerings

One such organization is the Cenex brand of convenience stores, which is owned by CHS, Inc. Two years ago, the company certified a number of its employees in HACCP to enhance its food safety program. Since then, the company has expanded its services beyond Cenex stores to other food service operators, including Wendy’s and Dairy Queen as well as school districts and others. Bob Gumatz, manager of retail solutions, explains that the company decided to become HACCP-certified as a way to maintain quality and food safety throughout its Cenex locations, which are owned and operated by co-ops and independent dealers in 22 states. About 80 percent of the stores offer food items such as fresh sandwiches and salads and roller grill items. Some sell fried chicken, pizza, and other hot foods. The company this year will offer take-home dinner items in some locations.

Gumatz says by investing in a HACCP program, the company wanted to ensure the Cenex brand maintained the highest safety culture. With foodborne incidents on the rise, CHS management sought to make sure one incident doesn’t end up tarnishing the entire brand. Additionally, as convenience stores have expanded their food selection, the potential for problems rises without proper training and protocols.

“If someone at a Cenex store in Wisconsin ate food and got sick and that got publicized, don’t you think people in Washington State or Montana are going to drive by their Cenex store and say, ‘Isn’t that the place where people got sick eating their food. Let’s go across the street,’” poses Gumatz. “We don’t want to react. We are being proactive.”

In working with various companies, Gumatz says the level of HACCP understanding among retail and food service businesses and state and local inspectors varies widely. Typically, large corporations with a dedicated safety staff are well-versed in HACCP principles, but others had trouble with even the acronym. His experience with health inspectors is similar, with some states actively promoting a HACCP approach in the retail and food service segment while others strictly abiding by the Food Code (see sidebar). The disparity in knowledge is reflected in the commitment that different organizations make to food safety and quality.

Bob Gumatz

“Certainly a lot of our most engaged, fully committed ­clients embrace it.”

—Bob Gumatz, manager of retail solutions, CHS, Inc.

“Certainly a lot of our most engaged, fully committed clients embrace it. They want it, and they understand what it means for food quality and safety. We also have people on the other end of the spectrum who jump on the bandwagon because everyone else is doing it,” he adds.

For HACCP to yield results, operators must commit and adhere to a well-deliberated process, Gumatz says. They must understand that in retail and food service, HACCP may require businesses to simplify their offerings. For instance, Gumatz’s biggest client offers more than 350 menu items—which can certainly make implementation unwieldy. Furthermore, this segment of the industry poses particular challenges because of its wide variety of products, its types of operations, and its organization sizes. Retailers and food service establishments can range from those with a simple single store to the national chains that operate thousands of facilities across the country.

For larger chains, economy of scale affords them the resources to embrace HACCP early on. For San Diego-based Jack in the Box, HACCP has been part of its food safety program for years, and the company requires all of its food manufacturers to have their own plans in place, explains Ann Marie McNamara, the company’s division vice president of food safety and regulatory compliance. With more than 2,500 restaurants in the chain, Jack in the Box relies on its HACCP program among others to help identify and monitor the preparations of its products.

McNamara explains HACCP is pervasive throughout its restaurant operations and all employees are trained to adhere to its principles and held accountable. “Every job has critical control points associated with it, so we train each employee in the steps important to producing safe food,” she says.

McNamara notes that even though food processing and manufacturing are different from food service and retail, HACCP principles are universally applicable. As long as organizations make the effort to effectively design and adhere to best practices and monitor and verify their processes, they can achieve the desired results regardless of the type of products they make or the size of their operations, she adds.

As food service providers and retailers continue to evolve and broaden their offerings, and as the industry and regulators continue to grapple with a growing number of foodborne illnesses, initiatives such as HACCP will likely gain adopters seeking a proven and effective method of food safety assurance.

Teng is a freelance writer and former interim editor of Food Quality & Safety magazine based in New Jersey. He can be reached at

HACCP at State Level: Colorado Enacts Regulations for High-Risk Foods

While most food service and retailers are exempt under the U.S. Food Code from having a HACCP plan, some local and state authorities now mandate its implementation for specific products. For example, Colorado as of March 1 began requiring HACCP for high-risk foods processed by modified atmospheric packaging, sous vide, or cook-chill methods. In some instances, preapproval from state or local inspectors are required; in others, the plan must be made available upon inspection.

Nicole Grisham, the direct service compliance and LAP coordinator within the Division of Environmental Health & Sustainability at the Colorado Department of Public Health and Environment, says the new rules are part of the state’s risk-based approach to ensuring food safety. In requiring HACCP for these foods, regulators want to minimize the potential for outbreaks. With this segment of the food industry increasingly broadening its offerings, especially in products at high risk of contamination, Colorado wants to make sure those businesses at least have good operating procedures in place.

One reason for concern is the state’s passage of the Colorado Cottage Foods Act last year, which made it easier for small, home-based producers to sell products. Grisham says while it was a boom for the cottage food industry, some of those producers have “pushed the envelope” of what they can sell, creating safety hazards in some instances. The act “has really encouraged people to push that envelope and start expanding and doing unique things that fall under specialized processes,” she notes.

While the state’s HACCP mandate is one way to ensure producers follow good practices, Grisham also laments that most small and even some midsized companies don’t understand it and how to comply. To help, the state offers annual training courses for regulators also open to industry.




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