SQF Audit Tip #4 Monitoring

The monitoring of control points and critical control points can provide more information than just an indication that a deviation has occurred, leading to a risk of a hazard at a CCP. I think about this when I inspect walk-in coolers or freezers and I notice ice build-up or dripping condensation. Since, someone is checking the temperature two or more times per day, then why not including a quick inspection of the cooling unit as part of the monitoring activity.
It is smart to add to the monitoring activity the requirement that the person responsible for monitoring will look for “warning signs” that equipment is not operating properly. To do that properly, the monitoring document must include written instructions and have a space on it to prompt and encourage the employee to include those observations on the document right away.
There are really three objectives to monitoring.
1) The monitoring should help spot trends and identify warning signs that a loss of control could happen. By doing this, you are making the monitoring record into a powerful tool that can be used to correct a situation before a deviation occurs. This is why quantitative data (an actual number) is preferred over qualitative data (pass/fail). Quantitative data can provide trending data to show when recorded values are trending toward a critical limit. This is one of the reasons that continuous cooking charts can be so useful. They show with precision and accuracy detailed and easily comparable data.

2) All CCP monitoring must identify when a loss of control exists. This is why rapid analysis is used when taking CCP measurements. Examples of commonly used monitoring methods used to monitor CCPs are; visual inspections, metal detection, temperature measuring and water activity testing. These measurements provide fast results. Microbiological analysis can be used for a CCP, but it is usually considered too times consuming and difficult to manage because it requires holding product for two or more days until the results are ready.

3) Lastly, the monitoring activity must provide useful records to be used to prove that the monitoring activity is being conducted consistently. The records must also be useable as a tool to investigate. For example, when pest control inspection records are detailed on a trending sheet, the data is very useful for investigating pest issues. Many of the old fashion methods or recording activity is not as useful. Records, like hand written service reports and inspection cards are harder to trend and use to investigate pest control issues.

SQF Audit Tip #3 Corrective Actions

At the heart of HACCP is the effective application of corrective actions.  If the corrective actions are not proactively written into the HACCP plan and supporting procedures, the corrective actions may not be applied properly. In some cases the corrective actions may not be applied at all.

Take for example a receiving person who knows that the temperature of incoming product is supposed to be <41°F.  On this occasion, before receiving the load, he takes the measurement and reads it to be 46°F.  He looks around for his supervisor, but the supervisor is busy with something else. Then, the driver explains to him that the temperature was high because he opened the doors before backing in.   Anyway, the trucks temperature is set at 36°F and he shows the temperature setting to the receiver.  The product also looks good and feels cold.  The receiver finally decides that the product is okay.   He decides that the best thing to do is to write down that the product was 40F and then wheels it into the cooler as fast as possible to chill it down to 40°F.

The monitoring of all prerequisite programs and critical control points must be accompanied with an understanding and an expectation that the person responsible for the monitoring activity will know what the limit is and will know what to do if the limit is exceeded.

It is important to write the procedure well, and make sure that the responsibility for the employee’s part in the procedure when non-conformances are discovered is clearly written.  It is equally as important that the employee is trained on the prerequisite program and the rationale for the monitoring activity.  The employee must leave the training session with an understanding that the procedure must be literally followed.

Some corrective actions can be detailed directly on the monitoring document.  For example, if cooked product doesn’t meet temperature; the product can go back in again to continue cooking, but it is required that corrective action is documented.  This corrective action must be detailed so that the systemic problem of the oven not properly cooking the product can be understood and remedied.

From my example of the receiver receiving warm product; the monitoring procedure may require the receiver to put the product on hold and to “notify the supervisor”, who would then be called upon to perform a more detailed evaluation of the product. That evaluation method would be detailed in the procedure, and would be followed by the responsible person identified in the procedure and would then result in the proper disposition of the product.