The Food Safety Update section of Food Manufacturing is
designed to offer our readers insight into the state of food
safety concerns across the industry. We received hundreds
of responses to this month’s survey on HACCP Planning.
Holly Henschen, Editor
The Hazard Analysis and Critical Control Point (HACCP) system was developed in the 1960s by the Pillsbury Corporation, the
National Aeronautics and Space Association (NASA)
and the U.S. Army to provide safe foodstuffs for the
first manned space missions. The food manufacturing
industry began implementing HACCP widely since the
1970s to ensure food safety. HACCP is now endorsed
by the Food and Agricultural Organization and the
World Health Organization of the United Nations.
With the signing of the Food Safety Modernization
Act in early 2011, the Food and Drug Administration
mandated preventative controls closely modeled after
the HACCP plans that meat, poultry, seafood and juice
facilities have been required to use since the late
1990s. Many food manufacturers along the product
spectrum are developing HACCP plans at the request
of their customers, often grocery chains, and to meet
third-party certifications. Deadly pathogen outbreaks
and food allergies in the ever-widening food supply
system have encouraged manufacturers to get their
data in line should they be called upon to prove they
Nearly 68 percent of respondents to a Food
Manufacturing survey said a commitment to food
safety prompted the development of a HACCP plan in
their facility, followed by 53 percent who were cued
by regulatory requirements. Nearly 40 percent of
respondents said customer demands were a major
motivator in HACCP development.
Instituting a new system can be a challenge in
an often constant production environment. Forty-five
percent of respondents said they faced confusion
over determining what constitutes a critical control
point (CCP). A critical control point is a specific point,
procedure or step at which control can be exercised
to reduce, eliminate or prevent the possibility of a
food safety hazard.
The second most-frequent challenge in HACCP
planning was confusion over regulatory requirements, cited by 36 percent of respondents. Another
24 percent had difficulty justifying the expense of
HACCP plan development. Roughly 20 percent noted
difficulty with employee buy-in. Twenty percent also
encountered conflicting advice from consultants.
Several respondents said that the time required
to develop, document and to implement the plan
was a challenge. Others noted that determining
the hierarchy in implementing CCPs was oner-
ous. Alternate exacting tasks in HACCP planning
included satisfying all the customers that audit
the company, as well as varying CCP require-
ments from different customers.
Nearly half of respondents said they initially
consulted internal QA/QC experts when developing their HACCP plan. Almost 43 percent
employed consultants in the process. Thirty-seven
percent inquired with government agencies.
Respondents also named employees, customers,
universities and equipment vendors as resources to
a lesser extent.
Dedicating time to develop a HACCP plan can
save effort down the road in case of a recall or to
assure customers, as well as consumers, that food
from a plant is safe.
One-third of respondents said they spent three to
six months developing a HACCP plan. Nearly 27 percent spent zero to three months on the process and
nearly 23 percent spent six to nine months on HACCP
plan development. Just 17. 5 percent took nine
months or more to develop a plan for their facility.
But HACCP planning doesn’t end once a strategy
is initially developed. Nearly 52 percent of respondents said that HACCP plans are a living document
that is constantly open to revision. Thirty percent of
respondents said they revise their plan once a year.
Just more than eight percent revisit the plan less
than once annually. Six percent revise HACCP twice
a year and three percent revise it quarterly.
Input from various sources helps survey respondents shape their ongoing HACCP plans.
Fifty-seven percent of respondents said that
internal QA/QC experts were key to effective HACCP
planning in their facility. Government agencies were
also vital resources for nearly 47 percent of respondents. Customers supplied support to roughly 48
percent of respondents. Employees aided 38 percent
in revision, while consultants assisted 25 percent of
It seems that the effort respondents put into
HACCP construction and revision is well worth it.
Approximately 56 percent said they were satisfied
with their facility’s HACCP plan. Another 32 percent
considered themselves very happy with their plan.
However, roughly 9 percent said the plan needs
adjustment/improvement, and four percent were
skeptical of the HACCP planning process in general.
The facilities of most respondents to the sur-
vey, 65 percent, did not develop HACCP plans
that required more tailored HACCP planning
guidance, like those that produce poultry, meat,
seafood or juice. However, 35 percent of respon-
dent’s facilities did.
The passage FSMA had a mixed effect on facili-
ties’ HACCP plans. Fifty-three percent of respondents
said FSMA did not cause them to change or update
the plan, while 47 percent said it prompted revisions.
Food defense and emergency response, which is
designed to protect food from intentional adultera-
tion by biological, chemical, physical or radiological
agents, is a vital aspect of FSMA. Food defense runs
the gamut from physical plant and information secu-
rity to restricting access to ingredients and chemi-
cals and hazardous materials on site. Nearly 51 per-
cent of respondents said they already incorporated
food defense vulnerabilities into their plans. Another
26 percent are evaluating the incorporation of these
vulnerabilities into their plan. About 21 percent said
they plan to incorporate them, while almost seven
percent said they will not.
The majority of respondents, 34 percent, were
operating facilities with fewer than 50 employees.
Twenty-two percent operated facilities with 101-250
employees, and roughly 17 percent each operated
plants with both 50-100 employees and 251-
500 employees. Just 5. 3 percent of respondents
employed more than 1,000 at their locations, and
roughly five percent had 501-1,000 employees. ◆
What challenges did you face in
developing a HACCP plan?
0 10 20 30 40 50
Confusion over determining what
constitutes a critical control point 45.4%
Confusion over regulatory requirements
Difficulty justifying expense
of plan development