HACCP Recommendations

Here is some key information that applies to various areas of HACCP.

The Key to Food Safety

What is Food Safety?

  • Identifying potential hazards surrounding the safety of food; and the controls to keep food safe.

How is a Food Safety Plan Developed?

  • Through controls found in the Prerequisite Programs or in a HACCP Plan.

Where and When?

  • Have your controls actively in place of the potential hazard; not just documented.


  • Management. 


There are different controls that may be utilized to control potential hazards surrounding the safety of food. 

For instance, through

1.  Prerequisite Programs such as the following:

  • GMP's - Good Manufacturing Practices
  • SOP's - Standard Operating Procedures
  • SSOP's - Standard Sanitation Operating Procedures

The Prerequisite Programs must be actively followed. This is most effectively accomplished with the correct utilization of "logs & record keeping" which is vital to Food Safety. 

2.  HACCP CCP's (Critical Control Points)

  • (Critical Control Points) are placed at the place of the potential hazard.


As with the Prerequisite Programs, a concentrated effort must be made to actively follow the CCP's; and, this again is most effectively accomplished through the utilization of "logs & record keeping." 

The more actively the company practices the Controls, the safer the food products are. 

Corrective Action, along with the Audits & Non compliant Records, if applied, brings the HACCP Program into greater control.

The question is, if the above Prerequisite Programs effectively control the hazards, what is the need for large numbers of CCP's? The goal is to limit your CCP's, while enlarging your ability to control the hazards.

HACCP Upgrades

It seems the corner stone of HACCP is one of the most neglected.

A new yet basic concept of HACCP: Through compliance with government agencies a proactive food-safe program may be accomplished.

  • This concept is difficult to develop and implement.
  • Commitment is required by everyone from CEO/Owner to the janitor in order to develop a food safety system.
  • Rather than delegation of responsibility, one's own commitment must be taken by each person at every level in the company.

Results of food safety system unimportance:

  • Ruins company
  • Excessive non-compliance
  • Crisis, failure, confusion

The HACCP System

Developing and implementing food safety:

  • In food preparation
  • In cooking
  • Holding at room temperature
  • Training in record keeping

All of the above leads to "Inspection Approval". See letter below:

HON KEE Restaurant (Chinese Barbeque)

Chicago, IL


In the past, barbeque duck, pork, whole pigs and steamed chicken products, were processed until "crispy".

The finished "crispy" products where then held at room temperature until sold. The "inspectors" would consistently condemn any product held at room temperature, dispose of it, and then write a "ticket" which would cost anywhere from $500.00 to $2,000.00.

Billy G. Nolen Associates, INC., wrote a "Food Safety Program with a HACCP Plan" for the room temperature held product. It was approved by the city of Chicago.

Recently, a "ticket" was given to HON KEE restaurant by a city inspector for "room temperature held product". The restaurant, through Billy G. Nolen Associates, INC., contested the ticket. The ticket was cancelled; no fines were paid.

They stated at the court, if their were records concerning the "cooked, crispy, room temperature held products". There would be no more tickets issued.

HACCP for Reduced Oxygen Packaging

Reduced oxygen packaging should have a HACCP plan with safeguards for food safety in practice

  1. Proper cleaning & sanitizing
  2. Temperature control
  3. Labeling requirements
  4. Hygiene (hand washing)

With a fixed set of barriers there are general barriers and there are specific barriers. Some barriers include:

  • pH 4.6
  • W. A. .91
  • Sanitation
  • Temperature
  • Cure (Restricted ingredients)
  • Product Sanitizers
  • Hygiene
  • Dedicated Area (Product separation)
  • Listera & Botulinum are killers

Watch out for:

  • Temperature abuse
  • Poor sanitation & hygiene
  • Cross contamination
  • Use by date/expiration date/lot codes

Keys to Food Safety Inspection

  1. Excel in sanitation and hygiene (can't find problems)
  2. Keep concise records (first to observe, first to write, first to correct)
  3. Any deviation to be corrected immediately
  4. Question answered immediately (you're the expert)
  5. QC continuous training (employing consultant trainer)

I Want To Know · I Need To Know

Your customer is not your test kitchen, or quality control department. The company should install a sensory control (testing with records).

Using an organoleptic system

Appearance · Smell · Feel · Taste · Comments recorded


With periodic testing/sampling

Our goal is to know my product quality and to control the parameters of the product quality.


Sensory Committee

1.  Form your quality control committee

  • Select committee from available staff
  • Example (select committee with specific qualifications)
  • Mexican person (salt)
  • Inspector (trace spices)
  • Owner (consistency)
  • Supervisor (texture)
  • Polish person (appearance)
  • Secretary (notes)

2.  Our lab in a small company is a circle around a frying pan

3.  Record finding by impression


Note: The larger the company, the more sophisticated the committee and your lab · The committee fine tunes your quality

Food Safety True-isms

Trouble Shooting Class 101

  1. Have honest advisors.
  2. You can't make a silk purse out of a pig's ear.
  3. Fresh-in products means products will be fresh.
  4. You can't sanitize dirt.
  5. Failure not my fault.

A man drove his car two times a day, and ran a red light each time for 20 years. One day, he had an accident and questioned, "Why did I have this accident?! I never had one before!" Foodborne illnesses don't just happen; they are a direct result of faulty programs and operation.

The Greatest Deficiency in a Food Safety Plan

The food safety auditor or inspector knows more about the process in your facility than you do. (Shame, shame.)

The Quality Control Manager should know the secrets. The method is to measure, observe, and record with proactive energies. One method is to organize your discoveries.

  1. Write a room-by-room inventory.
  2. Inventory all equipment in each room.
  3. Inventory each facility feature (lights, ceiling, wall, electric box, sewer).
  4. Inventory all of the rooms in the facility.
  5. Inventory the outer perimeter of the facility.
  6. Prioritize:
    • A. Record deviations in each room.
    • B. In each room, prioritize greatest to smallest deviations.
    • C. Correct major deviations in each room.
    • D. Then, correct minor deviations in each room.
    • E. Don't overload; just correct one room each week.
  7. Estimated time — three months


Oh-no — I must begin again, coordinating this with a long-range cleaning schedule. Now I know more!

Congratulations — You're the man (woman) who knows.

Dueling Flashlights

Your flashlight extends your eyesight in sanitation inspection before operation begins. Here's an illustration from my experience:

I inspected with a flashlight. The inspector came in with a bigger flashlight. Now the duel was on. Next day I had the larger flashlight. Next the inspector had the largest one. This went on for a week. At the end of this time we both saw very well with our flashlights.

For a year we laughed about our duel.

Remember the flashlight is a great inspection tool.

Talk to a food safety expert today!

Do you have any questions? Do you need more information about something? Get in touch with a food safety expert at Billy G. Nolen Associates today.  Over-the-phone consultations are always free of charge! 

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