Developing a HACCP Program

• Should you be using HACCP?
• Creating a HACCP plan takes time, work and commitment. However, done correctly, HACCP is a system that will help prevent food safety problems.
• In addition, as HACCP spreads through the food industry, your customers might be asking if you have a HACCP system in place. Your competitors might say yes.

Some tips for the farmstead cheesemaker

Heading for HACCP?

You may find it oppressive, confusing, and time consuming but if you are reading this then you must be interested in learning more about HACCP, or Hazard Analysis Critical Control Points. Like Tang™, cordless drills, and biomedical lasers, the HACCP system got its start in the space program. The U. S. Army Natick Laboratories, along with NASA (National Aeronautics and Space Administration) and the Pillsbury Company, designed the HACCP system to produce safe foods for the astronauts. They didn’t start out to develop a new system, initially they focused on 100% assurance of safe foods. Once they realized standard quality control methods wouldn’t be enough, this group developed a logical system focused on identifying and controlling potential hazards to prevent foodborne disease. Within two years of the 1969 Apollo missions, Pillsbury began to apply HACCP in plants producing food for the rest of us. Since then, HACCP has gone international—from Europe to the far East, HACCP is recognized as an effective tool to produce the safest food possible.

Should you be using HACCP? Creating a HACCP plan takes time, work and commitment. However, done correctly, HACCP is a system that will help prevent food safety problems. In addition, as HACCP spreads through the food industry, your customers might be asking if you have a HACCP system in place. Your competitors might say yes.

HACCP is a safety program

As you explore the HACCP system remember that HACCP is a safety program. Keep in mind the distinction between safety and quality and realize that HACCP is one part of your total program. After all, it is possible to produce a very safe product that just doesn’t meet your quality standards.

Several resources are available to help you plan and implement HACCP. Consider starting with the Dairy Product Safety System, a technical manual published by the International Dairy Foods Association (IDFA).This comprehensive manual will take you from defining HACCP all the way through the steps needed to implement a program, including model programs for dairy plants. They are currently working on an updated
edition, which should be ready in 2001.

This document is specifically adapted for the farmstead cheesemaker, although much of the information comes from the IDFA publication, which is a more thorough book that also covers manufacturing butter, ice cream and processing fluid milk.

Take the task apart

One of the challenges that farmstead cheesemakers face as they develop a HACCP plan is carving out the time. Most cheesemakers already have too much to do, and, of course, many are doing it alone. It is unrealistic to think you can sit down and work out an entire HACCP plan. Instead, consider breaking it into parts. Annie Lamott, novelist and writing instructor, in her book “Bird by Bird” relates a story about her brother, frustrated and overwhelmed because he had a term paper due and he had procrastinated so long the task was feeling impossible. Desperate and tearful, he couldn’t imagine finishing his entire paper, which was about birds. Lamott’s father’s advice was to “Just take it bird by bird.” So, to paraphrase Lamott, you should take the task apart, approach it curd by curd and work on one cheese at a time.

Don’t get hung up on the critical control points, or CCP’s. Before starting a HACCP program, IDFA suggests that you evaluate and review existing programs. You might not have any formal program, but you probably already do some of these tasks informally. “Prerequisite programs” are the universal procedures, like GMP’s (Good Manufacturing Practices) that control environmental conditions in a dairy plant in order to produce safe products. The name is deceptive, it doesn’t have any key words like critical or hazard in it but don’t be fooled—a prerequisite program is the foundation of every HACCP plan.

The IDFA manual outlines six prerequisite areas, including details to check and forms you can use to evaluate your program. The prerequisite areas include physical premises, receiving and storage, equipment performance and maintenance, personnel training programs, sanitation, and recall programs. See Appendix A for a chart adapted from IDFA which you can use to evaluate what you are already doing and what you might need to work on. Consider focusing on one prerequisite area each week, or each month, using IDFA’s Prerequisite Programs Evaluation Form.

Start by describing each product

You might want to start your plan by describing each product you make. You’ll eventually need a separate plan for each of your products, but just pick one cheese to start with. Consider composition, structure, processing, packaging systems, storage, and shelf-life. To keep on track, keep asking yourself, “Is this a hazard or a quality issue?”

Now, you’ll need to organize a flow diagram. This is not an engineering feat, instead use words in boxes to illustrate the steps used to produce each product, like the example shown on page 17.

When you have a good, simple flow diagram you are ready to conduct a hazard analysis. Now you are getting to the core of the HACCP experience. For this purpose, a hazard is any microbiological, chemical, or physical property that threatens the safety of your product. Analyzing hazards involves asking a series of questions to get at the varied factors that influence the safety of food. For example, you might ask about the chances that your product could be contaminated with hazardous substances. Or the likelihood that your product will contain viable spore-forming pathogens. You also need to consider what preventive measures, if any, are available. When you are finished, you should be able to list the significant hazards of each step in the flow chart, along with the severity of the risk and preventive measures.

Identifying critical control points

Next, you can identify critical control points, or CCP’s. They originate from the hazard areas you already identified and include things like the temperature of incoming milk, or pasteurization times and temperatures. Many hazard areas may already be controlled by your prerequisite programs, the ones that aren’t must be identified as CCP’s. Now that you have a list of CCP’s you need to set some parameters for them. Start by setting critical limits for each CCP, the limit that must be met to assure safety. Use regulatory standards, literature searches, experimental studies and your experiential knowledge to set your critical limits. Monitoring these critical limits is also built into your HACCP plan and you use it to determine and record when a CCP has exceeded the critical limit. Ideally, monitoring should be 100% accurate and quick. That’s why physical and chemical methods, like measuring pH and temperature, are more effective tools than microbiological testing.

Documentation and verification are built into HACCP plans. Corrective action plans for dealing with deviations from CCP’s need to be documented and recorded. Your documentation should also include all records for CCP’s, the monitoring systems, a list of the team, the flow diagram, etc.

Like many other systems and processes, HACCP is really never finished. You should conduct a full review at least annually. In addition, new product development, new hazards, and manufacturing changes are all situations that prompt a HACCP evaluation. Employee training and education is another ongoing process. Your entire staff needs to become familiar with the overall principles of HACCP and their part in the HACCP system.

Resources

The USDA/FDA Foodborne Illness Education Information Center is an excellent source of information about foodborne illness and how to prevent it. Two databases are maintained: The Foodborne Illness Educational Materials Database and the Hazard Analysis Critical Control Points (HAACP) Training Programs and Resources Database. Start at their website and follow the links.

http://www.nal.usda.gov/foodborne/about

Mary Falk’s Prerequisite Program

Chapter:

Milk receiving Milk storage Dry ingredient receiving/storage Cheese vat Starter Rennet Water Forms Drain table Aging Packaging Shipping Rodent and insect control Diagram

Milk receiving

Milk is stored in sterile disposable milk bags and stored in ice water in a chill tank that is kept below 35ºF. The temperature of the chill tank is charted twice a day. The temperature chart is hanging on the milk house wall.

The milk is screened for antibiotic residue and sampled for plate count and SSC on a “per vat “ basis. If milk is verified as “positive “ for drug residue, the milk is discarded. Test results of antibiotic screening are charted. The chart is on the shelf in the cheese make room. Tests results for PLC and SSC are dated and filed in “Milk History” folder. If tests results violate LoveTree’s milk receiving guidelines, patron is notified and receives a warning. If milk is again received from same patron that violates LoveTree’s receiving guidelines, milk will be refused from patron until tests prove that problem has been resolved.

Milk equipment is washed in accordance with good dairy hygiene practices after every milking. Twice a week the equipment is washed in dairy grade acetic acid, and twice a week the equipment is washed in a chlorinated alkaline cleanser. The rest of the washings use a food grade detergent. After every washing the equipment is sanitized with a food grade chlorine sanitizer using no less than 100ppm. The chlorine level is tested with chlorine test strips and charted. When the milk “bucket “ is full, it is immediately strained and placed in disposable bags in the chill tank.

Dave Falk starts the cheesemaking process by milking the sheep at Lovetree Farm

Mary´s Notes Dave and I realized that it was necessary to demonstrate to our customers (and ourselves) that we produce a safe and wholesome product. In order to achieve this, we needed to implement a HACCP plan for Lovetree Farmstead cheese.

Milk storage

The temperature of the chill tank is monitored twice a day and kept under 35ºF. The milk is stored in sterile disposable bags made specifically for milk storage. (The bags are purchased from General Film Inc.) The chill tank temperature is charted twice a day. The chart is kept hanging on the wall in the milk house. The chlorine is added to the chill tank water and monitored at 100ppm on a daily basis, and that chart hangs on the wall, too.

In accordance with the regulations of the state of Wisconsin and Mary Falk’s certification, all milk is screened for antibiotic residue utilizing the Penzyme test kit. The milk is tested on a “per vat” basis. If milk testing procedure validates positive drug residues in milk, then milk is discarded. The chill tank is cleaned out once a week with detergent and an acid wash

Dry ingredient receiving/storage

Salt is received in 50 pound bags and poured into a sealed tote that protects it from possible contamination. (water, dust, chemicals, etc) The lot number of the bag of salt is charted and dated and kept in the Dry Ingredient folder. Cedar boughs are washed and sanitized and air dried on sanitized racks in the cheese room. The sanitizer is monitored for 100 ppm by using chlorine test strips. The chart for monitoring the sanitizer is kept on the desk in the make room. Implementing a HACCP plan made us motivated to get organized. Even though we “knew” that the products we used in the plant were approved for use in food manufacture, HACCP showed us how to organize the ingredient information. Now, if we ever need to recall our product we simply need to follow the audit trail. 

Cheese vat

The cheese vat is washed after every make of cheese. The vat is also cleaned weekly with a chlorinated detergent and an acid wash. The vat is sanitized using a chlorine sanitizer of no less than 100ppm. The chlorine level is monitored using chlorine test strips and charted no less than twice per production day, and/ or whenever a new solution is made. The chart is kept on the wall in the cheese make room. The cleaning chemicals are kept on the bottom rack of the storage shelf next to the sink in the cheese make room and are measured out according to manufacturers directions.  

Mary´s Notes When you order your chlorine test strips, order as many as you can afford. That way they will be always be in stock. It is easier to get out of the habit of testing if you run out of supplies like the chlorine test strips.

Starter

The starter is a direct vat set purchased from a starter company. The lot number is charted and dated and kept in the Dry Ingredient section of the Ingredient Receiving folder. The starter is stored in the freezer, for long term storage (10ºF.), or in the cooler for short term storage (38ºF). The temperature of the refrigeration units are charted twice a day, and the chart is kept in the unit. All starters are stored in Ziploc bags to prevent contamination.

Rennet

Rennet is purchased from a reputable supplier. The lot number is charted and dated and kept in the Fluid Ingredient section of the Ingredient Receiving folder. Rennet is stored in a cooler at 38ºF. The temperature of the cooler is charted twice a day, and the chart is kept in the cooler.

Water

Water is tested according to the regulations in Wisconsin for dairy plant water testing. Test results are kept in my Regulatory file. of testing if you run out of supplies like the chlorine test strips. 

Mary´s Notes This is a good time to get in the habit of charting the lot numbers of your starter. The information can help you track down any problems in production quality along with helping you follow an audit trail in the event of a recall.

Forms

The cheese forms are food grade approved and washed and cleaned after each cheese make with an acid wash or a chlorinated alkaline cleanser. The forms are sanitized with no less than 100ppm. Sanitizer is tested no less than twice during a production day, and whenever a new solution is made.

Drain table

The pH of the cheese is monitored using pH test strips to check for proper acid development before salting (A sample of the cheese is pureed in an electric mill and then tested.) A pH of 5.10 is the target pH. The pH of the cheese is charted on the corresponding Cheese Make Sheet. If the pH is higher than 5.2, then the cheese is not salted and allowed to sit for another 12 hrs. If, after 12 hrs, the pH is still not at 5.1, then the cheese is salted and the information is charted on the Make Sheet for future reference. The cheese is dry salted and the whey allowed to drain off. The whey is disposed of by feeding to livestock. 

Mary´s Notes I used to routinely use a pH meter but since I had chronic problems with my meter, I switched to pH test strips. I compared test strip readings to pH monitor readings and was pleasantly surprised to see how accurate the strips are.

Drain table, continued

Each wheel of the raw milk cheese is permanently identified with it’s corresponding lot number etched into the wheels with a hot brand. The lot numbers are printed on the cheese Make Sheets and stored in the Make Sheet folder where the date of each lot number of cheese is also recorded. The drain table is washed after every make of cheese using a chlorinated detergent at least once a week, and an acid wash at least once a week. The drain table is sanitized using a chlorine sanitizer of no less than 100ppm. The chlorine level is monitored using chlorine test strips and charted no less than twice during a production day, and/ or whenever a new solution is  made. The chlorine test chart is kept on the wall in the cheese make room.The cleaning chemicals are kept on the bottom rack of the storage shelf next to the sink in the cheese make room and are measured out according to manufacturers directions.  

Mary´s Notes By permanently identifying each wheel of cheese I retain flexibility in the aging room. I can now shuffle my cheeses around without worrying aboutlosing track of “who they are!”

Aging

The cheese is carried to the cave in clean, sanitized and sealed totes. The cheese is place on top of sanitized cedar boughs which are place on waxed boards in the fresh air aging cave for no less than 2 months at no less than 38ºF. The cheese is aged at an average temperature of 55ºF. The temp of the cheese “cave “ is charted daily and the chart is kept in the aging cave. The cheeses are turned and inspected no less than twice a week.  

The cheese shelves are washed on a weekly basis with a mixture of acetic acid and water. The cedar boughs are disposed of after the aging cheese has been removed, or if the integrity of the cedar starts to degrade. 

Mary´s Notes By charting the aging temperatures, I can track fluctuations in temperature. This helps me to evaluate cheese  characteristics and/or defects while also showing that we are meeting the legal temperature  requirements.

Aging, continued

The floor of the cave is washed and swept at least twice a week. Worn boots are left at the door of the cave, and clean boots that are designated for cave use only are put on when entering the cave. 

Mary´s Notes I absolutely LOVE the smell of a good, moldy, clean cave! When we wash the floors, we help the humidity level in the cave at that same time that we disrupt any nasty bacterial activity. We prefer using manual acid cleaners on the floor  and only occasionallyuse chlorine. (NEVER use chlorine and acid together!!!!)

Packaging

Cheese that is at least 61 days old is transported in clean, sanitized and sealed totes to the cheese make room where the cheese is readied for shipping. The cheese is placed in clean and sanitized racks and washed with a 50/50 solution of apple cider vinegar and allowed to air dry. The cheese is then weighed and wrapped for shipping/delivery. The customer’s name ( and store location if required), lot number and the weight of the cheese is charted and kept in the Customer Log folder. When not being used, the Customer Log folder is kept in the sealed tote in the storage room. The packaged cheese is then stored in the cooler to chill overnight before being shipped.  

Mary´s Notes By disciplining yourself to follow through on this step, you will greatly simplify yourbilling and improve communication with your customers. When a customer calls with a  question on a shipment of cheese, I can readily track which lot of cheesethey received. This  obviously simplifies anyrecall issues or product  quality issues.

Shipping

Cheese is wrapped and taped in freezer paper and then placed inside of paper bag or covered a second time in freezer paper. The product is then placed in a thick cardboard box that is packed with large curl pine shavings and or clean hay, and freezer packs (in hot weather). Typically, an 8 pound wheel of aged cheese will require two one pound freezer packs. All cheese is shipped by 2nd day air if the temperature upon departure is over 60ºF, or if the temperature of the destination point is over 60ºF. All freezer packs are first wrapped in white butcher paper before being placed in packaging material.

All packages are transported to a UPS Authorized Shipping Station since Love Tree currently does not have a area that is separated from the cooler for the courier to retrieve packages from. To prevent possible contamination of product storage area (from courier) transporting packages to a Designated Shipper is now necessary.

Rodent and insect control

Rodent control for premises: Ferrets are used in the outside per meter (non cheese make and non cheese  aging and storage facility)
In ferret absentia, bar bait is placed in the outside perimeter in bait stations. All open air vents are screened for insects and also screened with hardware cloth for rodents. The walls of the milk house and cheese room are washed with Shaklees Basic H for fly control, and selective “swatting” is also used.   

Mary´s Notes Don’t cut corners on shipping. Properly packaged cheese will greatly reduce any possibility of damaged or destroyed cheese and will help to ensure happy customers—and a healthy bank account.

Diagram

LoveTree’s HACCP for Trade Lake Cedar Production

Milk Receiving
Microbiological/Pathogens	Proper temperature is monitored to prevent bacterial growth /staph toxins CCP Each vat of milk is screened for PLC and SSC	CCP
Chemical -Animal Drug Residue	Milk is screened for presence of drug residues
Physical-any physical hazards	Prerequisite Program in place to prevent contamination
Milk Storage
Micro/Pathogens	Temp control is necessary to prevent bacterial CCP growth in fluid milk/staph toxins	CCP
Chemical -any hazardous chemical	Prerequisite Program in place to prevent contamination
Physical-any physical hazards	Prerequisite Program in place to prevent contamination
Dry Ingredient Receiving
Micro/Pathogens	Prerequisite Program in place for ingredient receiving and storage
Chemical -any hazardous chemical	Prerequisite Program in place to prevent contamination
Physical-any physical hazards	Prerequisite Program in place to prevent contamination
Dry Ingredient Storage
Micro/Pathogens	Prerequisite Program in place for ingredient receiving and storage
Chemical -any hazardous chemical	Prerequisite Program in place to prevent contamination
Physical-any physical hazards	Prerequisite Program in place to prevent contamination
Cheese Vat
Micro/Pathogens	Milk is heated to ripening temperature quickly to prevent pathogen growth. Starter is added as soon as milk is at ripening temperature
Chemical -any hazardous chemical	Prerequisite Program in place to prevent contamination
Physical-any physical hazards	Prerequisite Program in place to prevent contamination
Starter
Micro/Pathogens	Prerequisite Program in place for ingredient receiving and storage
Chemical-any hazardous chemical	Prerequisite Program in place for ingredient receiving and storage
Physical-any physical hazard	Prerequisite Program in place for ingredient receiving and storage
Rennet
Micro/Pathogen	Prerequisite Program in place for receiving and storage
Chemical- any hazardous chemical	Prerequisite Program in place for receiving and storage
Physical- Any physical hazard	Prerequisite Program in place for receiving and storage
Water
Micro/Pathogen	Prerequisite Program in place to prevent unwanted microbial/pathogen growth
Forms
Micro/Pathogen Pre	Requisite Program in place to prevent unwanted microbial/pathogen growth
Chemical/Any hazardous chemical	Pre Requisite Program in place to prevent contamination
Drain Table
Micro/Pathogens	Prerequisite Program in place to prevent contamination. Ph monitoring to check for CCP proper acid development before salting	CCP
Chemical/Any hazardous chemical	Prerequisite Program in place to prevent contamination
Physical/Any physical hazard	Prerequisite Program in place to prevent contamination
NACI
Micro/Pathogen	Prerequisite Program in place for ingredient receiving and storage
Chemical/Any Chemical Hazards	Prerequisite Program in place for ingredient receiving and storage
Physical /Any Physical	Prerequisite Program in place for ingredient receiving and storage
Aging
Micro/Pathogen	Prerequisite Program in place to ensure proper aging temperature and time
Cedar Boughs	Prerequisite Program in place to prevent contamination
Chemical/Any Chemical Hazards	Prerequisite Program in place for proper cheese storage
Physical/ Any Physical Hazards Insect /rodent control	Prerequisite Program in place for prevention of insect and rodent contamination/damage
Packaging
Micro/Pathogen	Prerequisite Program in place for purchasing packaging supplies Prerequisite Program in place to track product
Chemical/Any Chemical Hazards	Prerequisite Program in place for receiving and storage of packaging supplies
Physical/ Any Physical Hazards	Prerequisite Program in place for receiving and storage of packaging supplies
Storage	Properly packaged product contains no hazards
Distribution	Properly packaged product contains no hazards

If you download this article in a pdf-file there is an Appendix with a Prerequisite Program Evaluation. To download, Right click here and choose Save target as... >>