Incorporating HAACP practices into a commercial business model

[Gina Cavaliero]

There is much discussion about HAACP practices and how they might be incorporated into aquaponic commercial operations.  While meat HACCP systems are regulated by the USDA, and seafood and juice are regulated by the FDA, the use of HACCP is currently voluntary in other food industries.

 

I'd like to explore the 7 HAACP principals and how they might relate to Aquaponics.  What should a commercial venture consider when incorporating these principals and what issues might there be that are exclusive to aquaponics?

Here are the 7 principals as outlined on Wikipedia

Principle 1: Conduct a hazard analysis. – Plans determine the food safety hazards and identify the preventive measures the plan can apply to control these hazards. A food safety hazard is any biological, chemical, or physical property that may cause a food to be unsafe for human consumption.

Principle 2: Identify critical control points. – A critical control point (CCP) is a point, step, or procedure in a food manufacturing process at which control can be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to an acceptable level.

Principle 3: Establish critical limits for each critical control point. – A critical limit is the maximum or minimum value to which a physical, biological, or chemical hazard must be controlled at a critical control point to prevent, eliminate, or reduce to an acceptable level.

Principle 4: Establish critical control point monitoring requirements. – Monitoring activities are necessary to ensure that the process is under control at each critical control point. In the United States, the FSIS is requiring that each monitoring procedure and its frequency be listed in the HACCP plan.

Principle 5: Establish corrective actions. – These are actions to be taken when monitoring indicates a deviation from an established critical limit. The final rule requires a plant's HACCP plan to identify the corrective actions to be taken if a critical limit is not met. Corrective actions are intended to ensure that no product injurious to health or otherwise adulterated as a result of the deviation enters commerce.

Principle 6: Establish procedures for ensuring the HACCP system is working as intended. – Validation ensures that the plants do what they were designed to do; that is, they are successful in ensuring the production of a safe product. Plants will be required to validate their own HACCP plans. FSIS will not approve HACCP plans in advance, but will review them for conformance with the final rule.

Verification ensures the HACCP plan is adequate, that is, working as intended. Verification procedures may include such activities as review of HACCP plans, CCP records, critical limits and microbial sampling and analysis. FSIS is requiring that the HACCP plan include verification tasks to be performed by plant personnel. Verification tasks would also be performed by FSIS inspectors. Both FSIS and industry will undertake microbial testing as one of several verification activities.

Verification also includes 'validation' – the process of finding evidence for the accuracy of the HACCP system (e.g. scientific evidence for critical limitations).

Principle 7: Establish record keeping procedures. – The HACCP regulation requires that all plants maintain certain documents, including its hazard analysis and written HACCP plan, and records documenting the monitoring of critical control points, critical limits, verification activities, and the handling of processing deviations.

 

[Rob Nash]

http://www.ctahr.hawaii.edu/oc/freepubs/pdf/FST-38.pdf 

 

 

[Earl ward]

 

Excellent material Rob, I personally believe in a commercial setting Haccp is essential along with SSOP (Standard Sanitation operating procedures)and also  an SPS plan (Sanitation  Performance Standards). The Haccp and SSOP deals With the Product itself the Sps is for the building and growing environment. I am developing all of these plans plus a food security plan for my commercial garden, haccp plans are a living document as the business evolves so does the Haccp Plan. The Government may not require you to have theses plans ; but, if you are going to sell to large retailers they will require it along with the food security plan.  P. S. As far as fish go catfish are under USDA FSIS and amenable to the meat act and tilapia are FDA

 

[DJ Bisson Jr]

Hi Gina,

Do you know where I can learn more information on HAACP. Is there any online classes. Is it commonly taught at local colleges?

[Earl ward]

There are several online courses in haccp. lots of information on the USDA FSIS site and FDA site

[DJ Bisson Jr]

Thanks Earl, I'll check them out.

Earl ward said:

There are several online courses in haccp. lots of information on the USDA FSIS site and FDA site

[Sahib Punjabi]

Good start...Point 7 being crucial "Document"

 

God bless,

 

[Molly Stanek]

Great resource, Rob - thanks for sharing it with us.  I agree completely that commercial growers should be devoting some time and effort into looking into this, Gina.  Sounds like Earl has a great start, maybe he'll be presenting at the next conference on this topic (hint, hint).

This issue kind of dovetails in with the worms and E.coli discussion in my mind.  Because aquaponics is such a young industry there seems to be so little concrete absolute hard-and-fast knowledge about what hazards are present. When you add in the diversity of aquaponic options (raft, media bed, tower, different media, fish and plant species) identifying them all almost seems like an impossible task.  I think we may need to agree on a starting point and direct our collective efforts and resources towards finding out what risks are present and what practices are recommended based on that information.

After we have gained that information on one setup, it will inform us all in how to best plan the next steps of research and also guide our decision making in food safety.

As others have said elsewhere(Raychel, I believe) - what university partnerships can we gain to make this happen? This might be a good issue for the association to address as we grow and gain some financial resources.   

[Chris Smith]

I think it is a shame things got so complicated!!! But that's the game we have to play to truly take aquaponics large.

[Chris Smith]

It may be helpful to look at some HAACP plans for hydroponics to learn by and adapt to aquaponics. I have alwayse found it helpful learn from others.

[Gina Cavaliero]

Great suggestion Molly!  I would love to hear Earl present on this next year.   I agree this topic definitely relates to the worms, E.coli and other food safety discussions and the relative infancy of our industry presents so many unknowns, but we have to start somewhere.   It seems until we have any definitive hazards of aquaponic systems identified, maybe the best approach or starting place is to address general food safety and GAP practices first and then as we have research and data available, apply specifics.   There is such a great need for research to be done at the university level and eventually I hope the AA will be able to support these kind of projects.  

I hear ya Chris, but even more important then taking it large, is just insuring that we are able to continue doing what we do.  I think this is more along the lines of being proactive.  I rather have these things in place and the research supporting what we all consider to be true regarding aquaponic food safety.   

[Gina Cavaliero]

I just found this.  It is "Steps in Developing your HACCP Plan" but is for fish and fisheries but looks like it could be easily adapted for other products or produce too.  

 http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/Gui...

Here is a blank HACCP form that can be filled out with the above directions and will create a HACCP plan.

http://www.fda.gov/downloads/Food/GuidanceComplianceRegulatoryInfor...

[Earl ward]

A HACCP Plan begins with Hazard analyses of the system it does not matter if you are using rafts media or hybrid system. You have to look at every step in the system and break it down to a process. What inputs you have and what effect they have on food safety. Here is guidance from USDA FSIS http://www.fsis.usda.gov/OPPDE/nis/outreach/models/HACCP-1.pdf. When I was doing the analysis for my garden I kept coming back to the water in the system. If you keep the water within acceptable food safety parameters you can keep the system in acceptable ranges. I’m now in the process of reassessing the analysis I plan on going to a hybrid system with gravel beds before the rafts. I really don’t think it will change much and yes they will have worms. I would love to do a presentation, but, im not a phd, just a guy with power tools