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PAPER

HACCP implementation: a
practical guide to the
implementation of the HACCP
plan
S. S. Khandke and T. Mayes

Hazard Analysis Critical Control Point (HACCP) is widely acknowledged as the

best method of assuring product safety and is becoming internationally recognized
as a tool for controlling food borne safety hazards. There is much activity in the
field of HACCP but this is focused primarily on the generation of a HACCP plan
(principles l-5). Alth ough generation of the IIACCP plan is a vital part of the
HACCP process it is just the beginning and must be implemented on the factory
floor to become a working system. This implementation can be a dificult and
time consuming part of the It4 CCP process and is an area many food businesses
struggle with. In this paper we break down this implementation process into three
distinct elements, transfer of ownership of the IIACCP plan, training to imple-
ment the plan and maintenance of the plan. The transfer of ownership of the plan
is important because it is unlikely that the HACCP study team will be responsible
for the day to day running of the HACCP plan in the factory This will normally
be done by line operators or supervisors and it is important that they understand
the role of IIACCP and are committed to it. Training of personnel is essential to
ensure supervisors, managers and operators are able to efficiently implement the
HACCP plan. Training should cover topics such as the sources of hazards, the
role of CCPs, the controls and monitoring procedures for which the individuals
are responsible, and the documentation requirements. The final element is the
maintenance of the ILACCP plan. A system to pick up changes to the product
and the process should be in place which triggers a review of the HACCP plan
before changes are made. This allows the change to be evaluated to ensure it does
not introduce uncontrolled, or uncontrollable, hazards to the line. 0 1998 Else-
vier Science Ltd. All rights reserved

INTRODUCTION first reported in the early 1970s (Bauman, 1974).

Hazard Analysis Critical Control Point (HACCP) is a
management tool aimed at controlling food borne
safety hazards, and has been widely acknowledged as
the best approach to achieve this. (Ehiri et al., 1995;
Anon, 1993a). HACCP is not a new concept, but was
Unilever Research Laboratory, Colworth House, Sharn-
brook, Bedfordshire MK44 ILQ, U.K.
However, with the development of the seven prin-
ciples (NACMCF, 1992) and the international stand-
ardization of approach (Codex Alimentarius, 1993,
1997) the HACCP concept has been gaining
increasing international acceptance. Food processors
have not fully taken up the implementation of
HACCP, but legislation is being introduced in many
countries, for example the EU (EC Directive 93/43)
(EC, 1993) and the FDA in the USA (FDA, 1995)

Food Control 1998 Volume 9 Number 2-3 103

HACCP implementation: S. S. Khandke and T. Mayes
have included the requirement to apply the principles
of HACCP to varying degrees. Although this can be
viewed as a negative driver, forcing companies to
carry out HACCP, it will inevitably speed up the
progress of HACCP in the food industry.
In recent years there has been much activity in the
field of HACCP, and there are many publications on
the application of the principles of HACCP to a wide
range of food areas (Bryan, 1991; CFDRA, 1992).
Many of these papers deal with HACCP implementa-
tion (Ehiri et al., 1995; Mortimore and Wallace, 1994)
and give a detailed walkthrough of the seven prin-
ciples and numerous working stages of HACCP. The
focus of these papers is the generation of the
HACCP plan (principles 1-5, Codex Alimentarius),
that is, the identification of hazards, control
measures, CCPs and appropriate limits, monitoring
procedures and corrective actions. The above papers
give some information on principles 6 and 7 and
beyond but there seems to be very little published on
the practical implementation of the HACCP plan on
the ‘factory floor’.
The generation of the HACCP plan, correctly
identifying safety hazards associated with the product
and process, and the correct identification of the
CCPs is of vital importance in the HACCP process.
However, if the findings outlined in the HACCP plan
are not fully implemented in practice in the food
chain the benefits of HACCP will not be realized,
and the foods business will have incurred unnecessary
additional costs for very little gain.
In this paper we will look at the key stages in the
implementation of the completed HACCP plan, and
try to illustrate how HACCP can become a part of
the day to day operation of a process.
PRACTICAL IMPLEMENTATION OF
HACCP
The successful practical implementation of HACCP
on the factory floor has three key elements:
l Transfer of ownership of HACCP plan to opera-
tives, supervisors and managers
l Training of operatives, supervisors and managers
to implement HACCP plan
l Maintenance of HACCP plan
It is important to realize at the outset that there is
not just One successful approach to HACCP imple-
mentation, there may be many. The specific route(s)
chosen should reflect the culture/views/attitudes of
the personnel involved, and the structure of
communication and management in the factory. An
approach that proves successful in one company may
not work well in others. The following represent the
general principles that should be adhered to although
it is recognized that the precise details will vary in
different companies and sectors of the food industry.
104 Food Control 1998 Volume 9 Number 2-3
l’kansfer of ownership of HACCP plan from HACCP
study team to operatives, supervisors and managers
Prior to the assembly of a HACCP study team and
the development of a HACCP plan, a Company
should allocate the responsibility for overall manage-
ment of HACCP implementation within the
Company to a member of the management team,
(the HACCP Implementation Manager), who should
report on progress directly to senior management.
The HACCP Implementation Manager manages all
aspects of implementation, e.g. preparation of an
overall plan, ensuring supply of relevant documenta-
tion and tools, facilitating teams if required, moni-
toring timetables and costs, supporting local QA
manager and co-packers where necessary. The Imple-
mentation Manager role would normally be tempo-
rary, once implementation is complete, responsibility
for everyday use of HACCP should transfer to a
Production/QA partnership. It is recognized that
support and commitment of senior management is an
essential prerequisite of any HACCP study and it is
worth re-emphasizing here that continued support
and commitment is also essential throughout the
HACCP implementation phase (Anon, 1993b).
Where good manufacturing practices/codes of prac-
tice exist, it is essential that they are already imple-
mented, where they do not exist HACCP
implementation will have to be more extensive. It is
also important to realize that in some cases major
customers and/or regulatory authorities may wish to
be involved in the HACCP implementation process.
During the development of the HACCP plan a
multi-disciplinary team approach is used whereby a
number of persons from different departments contri-
bute their skills and experience to the decision
making process in the HACCP plan development.
This multi-disciplinary approach is known to improve
the quality of decision making, and, in addition,
provides for a wider degree of commitment and
ownership of the HACCP plan from the multi-disci-
plinary team than would be possible from a single
discipline team.
It can generally be assumed that the HACCP
Implementation Manager and the members of the
study team responsible for the development of the
HACCP plan are committed to the plan and feel a
sense of ownership towards it. However it is not the
HACCP Implementation Manager or HACCP study
team that will have the responsibility for the everyday
practical implementation of the HACCP plan. That
responsibility lies primarily with the line operatives
and supervisors working on the factory floor, together
with the relevant production management. In order
to have confidence in the smooth implementation of
HACCP it is important that these individuals are
encouraged to quickly take ownership of the HACCP
plan. Experience from within the foods industry has
shown that it is beneficial to have operatives, super-

visors and managers contributing to relevant aspects
of the study team wherever possible as this will help
in the subsequent transfer of HACCP plan.
The HACCP plan should be fully discussed with
the line operatives, supervisors and managers respon-
sible for practical implementation. The origin of the
plan, the reasons behind the HACCP exercise, the
personnel involved in the development of the plan,
and the continued management support behind the
HACCP concept should be outlined to all concerned.
The output from the HACCP plan should then be
clearly explained and the implications of the plan in
terms of roles and responsibilities should be openly
discussed. The use of simple tables, such as the one
shown in Table 2 (Streets, 1995) can be very useful
for this purpose.
Table I is based on the HACCP plan (Codex
Alimentarius, 1993) but differs in a number of ways.
The first main difference is that only the CCPs and
hazards associated with the CCPs are listed in this
table. The company would still have a HACCP plan
showing all hazards identified in the study but this
level of detail is not required for this table. The table
records the process step, hazard and control measure
in the same way as the HACCP plan, although the
terminology used may be different to facilitate imple-
mentation. However, the implementation form con-
tains specific information regarding the control and
monitoring requirements, including responsibilities.
For example, the control measure is listed in the
table but the monitoring procedure is subdivided
under different headings, ‘what to check’, ‘how to
check’, ‘how often the check should be made’, ‘Who
should carry out the check’ and ‘where to record the
check’. The corrective action is listed on the form
with a separate column giving specific detail of who
can take action. This type of table can be viewed as
one mechanism of transferring the output of the
HACCP plan into a user friendly format for opera-
tors, supervisors and managers.
It is recommended that the operatives, supervisors
and managers are given the opportunity to look over
the HACCP plan, and suggest modifications if neces-
sary, thereby allowing them to become involved in
the finalization of the HACCP plan (any modifica-
tions to the HACCP plan suggested should be
cleared with the HACCP study team). In a small
factory it may even be possible to publicize the
HACCP plan and actions arising to enable all
personnel to comment prior to implementation.
Some companies have successfully used a nominated
HACCP coordinator to answer queries on specific
HACCP related issues.
After such discussions those individuals respon-
sible for implementing the HACCP plan should be
fully aware of the HACCP plan background, object-
ives and output and will hopefully feel a sense of
ownership and commitment towards the HACCP
plan.
HACCP implementation: S. S. Khandke and T. Mayes
‘lkaining of personnel to implement the HACCP plan
In order that operatives, supervisors and managers
are able to implement the HACCP plan it is essential
that they are adequately trained. Training should
involve discussions with all concerned with implemen-
tation and should result in an agreed understanding
of the following (Mayes, 1994):
Identification of the possible sources of hazards in
the product for which they are responsible and the
effect of such hazards on product safety
An explanation of the role of CCPs and their
importance in food safety
The nature of control required at those points in
the process for which they are responsible
An understanding of the terms ‘critical limits’,
‘monitoring procedures’ and ‘corrective actions’
and the role of these in control of food safety
The specific monitoring procedures and corrective
actions for which they are responsible
The correct record keeping procedures required
The objective of verification procedures
Triggers for review of the HACCP plan
It is important that all operatives, supervisors and
managers understand their role in the implementa-
tion of HACCP, and are convinced that their role is
important.
In addition to the above training in the under-
standing of roles and responsibilities, it is important
to identify and agree where new skills/ways of
working will be required. Where new responsibilities
are involved they should be agreed with the per-
sonnel department and unions if necessary. Where
additional training is necessary (e.g. taking accurate
and relevant samples/readings for monitoring pur-
poses, increased operator interactions with computer
based control systems), such training must be
provided, and where new equipment is required, this
must be purchased. Whenever possible, training
should be combined with ‘hands on’ experience
(Mayes, 1994). All disciplines involved in HACCP
implementation, (operatives, supervisors, manage-
ment, maintenance staff, electricians, sanitation crew
etc), should be included in the training given.
Simple, clear work instructions should be pre-
pared, and agreed, for the monitoring of CCPs, and
these should indicate what, how, when and who
should act in all cases, including corrective actions.
The use of forms, such as the one shown in Table 2
can be used but in many cases more detailed work
instructions will need to be prepared. It is essential
that responsibilities are clearly defined indicating who
can initiate corrective actions.
Progress in agreement and understanding should
be by discussion and involvement, where training is
required this may be achieved by formal discussion or
by practical example on the process line, where
possible. Some companies have found it useful to
judge the level of understanding gained during
Food Control 1998 Volume 9 Number 2-3 105
Table 1 HACCP implementation table x
Z
Location: Product: Date: Authorised by: &
F
Process Hazard Control CCP What to How to check How often Who checks Target and Where Corrective action Who takes 2
a
step measures Yes/No check tolerance recorded action
-I
Refer to What can go What are the Is this What factor What How often Who (title) What is the Where is the What happens when Who (title)
flowchart wrong at measures process at this step methods or do you do does the ideal check the results of the is respon-
this point taken to step a do you tests do you this? checking? value? recorded? tests are outside the sible?
to affect prevent critical have to use or Sample size? What are the limits which you set? Is anyone
product these control control in conduct? maximum What do you do with else
safety? hazards point? order to What senses and the product? involved?
occurring? minimize do you use? minimum How do you adjust the
or What checks value for process?
eliminate do you do? this factor? What do you do to the
this How do you Use numbers. system to reduce the
hazard? minimize Is the process chance of the same
the chance capable of thing happening
that these again?
something values? Where is the corrective
will go action recorded?
wrong?

training by asking questions e.g. ‘who is responsible
for the corrective actions at this CCP?’ or by holding
a small exam at the end of training. Above all it is
essential that individuals clearly understand what their
roles and responsibilities are in the HACCP plan.
Once such training has been completed the
HACCP plan should be implemented within the
constraints of available resources and achievable
time-scales. Activities should be integrated into the
existing QA plan and changes to procedures (e.g.
sampling), agreed where necessary. During the initial
stages of implementation it is possible that problems
may occur, and those involved in implementation
should be encouraged to identify where adjustments
to the plan are required. This should not be seen as
a failure of implementation but rather as a modifica-
tion and improvement to the HACCP plan and
regular input from operatives, supervisors and
managers should be encouraged.
Maintenance of HACCP plan
Once the HACCP plan has been implemented there
is a need to maintain the efficacy of the plan. It is
recommended that the HACCP Implementation
Manager, or more probably a designated manager
from Production/QA with responsibility for HACCP
maintenance (e.g. the HACCP coordinator), utilizes a
number of techniques to ensure that the HACCP
plan is operating effectively.
These- techniques include:
Listening to the views of the personnel responsible
for implementation
Verification procedures (HACCP principle 7)
Regular review of record keeping and documenta-
tion activities
Development of a system of ‘change control’ to
take account of the daily/weekly/monthly changes
to processing that can occur and that may require
a review of the HACCP plan prior to implementa-
tion of any changes that may affect the safety of
the product
Formal internal and external auditing of the
HACCP plan
A review of critical limits arising from new
developments e.g. changes in legislation, new
scientific data on infectious dosage, emerging
hazards, new areas of risk, changes in consumer
profile, changes in product usage etc.
In addition to the above it is valuable to identify
the quantifiable benefits, (e.g. reduction in product
contamination, increase in line efficiencies), arising
from HACCP implementation.
Food processes are constantly changing with new/
improved equipment, changes to product formulation
or raw material supply and changes to the working
environment. It is therefore easy to let a HACCP
plan become out of date if it is not regularly reviewed
HACCP implementation: S. S. Khandke and T. Mayes
and updated. The HACCP system should therefore
have procedures in place to ensure it remains applic-
able to the current product/process.
An important part of an implemented HACCP
plan is a change control system to identify any
changes in the product or process which may affect
the HACCP plan, by adding, or removing hazards or
changing CCPs. The HACCP plan should therefore
be fully reviewed at least once a year to ensure it is
still valid for the line on which the study was carried
out, but more importantly, a system to capture
proposed changes should be put in place to trigger an
evaluation of the proposal before any changes can be
made to the product/process. Possible triggers
include:
A change to a new or different raw material
A change in processing procedures
A change or modification to the process or process
equipment
A change to the line layout or the factory
environment
Information concerning a new hazard which may
affect the safety of the product
Once a proposed change has been identified it
should be recorded and handled appropriately. The
type of change and specific details of the proposed
change are recorded on the form, signed and dated.
The change is then evaluated, the result recorded on
the form and the proposed change is either approved
or rejected.
During the implementation of the HACCP plan it
is important that everybody is trained in the import-
ance of the change control system, and understands
how the system works. They must know what should
trigger an evaluation and what to do to initiate the
evaluation.
The appointment of a HACCP coordinator, who
oversees all HACCP activities in the company can act
to focus the system, all change control forms can be
passed to the coordinator who takes the appropriate
action.
Once the HACCP coordinator receives a change
control form, he/she must make a decision as to the
extent of evaluation required. Not all changes will
require a review of the entire HACCP plan, or even
a review by the HACCP team responsible for the
initial study.
Once the type of the evaluation has been decided
the proposed change must be examined to see if it
introduces any new hazards to the HACCP plan. If
the change does not introduce a hazard it can be
authorized and the HACCP plan updated. Checks
should be carried out to identify if the change
removes an existing hazard and if so the HACCP
plan and any work instructions should be modified
accordingly. If the evaluation of the change identifies
one or more new hazards the first question to ask is
whether or not the change is actually necessary. If
Food Control 1998 Volume 9 Number 2-3 107
HACCP implementation: S. S. Khandke and T. Mayes
not, the change should not be authorized. If the
change is essential the hazards should be thoroughly
evaluated, e.g. by putting them through the CCP
decision tree (NACMCF, 1992; Codex Alimentarius,
1993) to identify whether or not the new hazard
makes the process step at which the change will
occur, or any other process step in the study, a CCP.
If not, the HACCP plan should be modified and the
change authorized. If the hazard does make the
process step a CCP it must be determined if the
hazard can be adequately controlled. If the hazard
cannot be controlled at this, or another process step,
the change must not be authorized. If a control can
be put in place to satisfactorily control the hazard the
change can be authorized. It is important that the
HACCP plan is modified to clearly indicate the
required controls and monitoring procedures, and
that all work procedures at the affected area are
updated.
The HACCP coordinator should take responsi-
bility for authorizing changes and ensuring all neces-
sary modifications to the HACCP plan and work
instructions are made. Old versions of the plan and
work procedures should be recalled and replaced
with the new versions. Where retraining is required it
should be carried out following the guidelines
described earlier in this paper.
Regular auditing is an important tool to ensure the
HACCP plan is up to date and is being implemented
on the factory floor. Some of the factors to be
assessed during these audits are listed below:
Is the flow diagram still an accurate representation
of the line?
Is the product formulation and raw material speci-
fication in line with the HACCP plan?
Has the line layout changed since the HACCP
plan was finalized?
Are all work instructions, checklists, log sheets etc.
which are required for control and monitoring
CCPs available on the line? Are they being used?
Are they up to date?
Have all operators working on the line been
adequately trained and do they understand the
role of HACCP and its. importance?
SUMMARY
HACCP is a common sense approach to identifying,
quantifying and controlling food safety hazards. It
sets up a framework allowing the detailed examina-
tion of a process to identify hazards and where the
hazards can be controlled. The application of the
principles of HACCP is accelerating in the food
industry around the world and the number of
different papers being published on HACCP is an
illustration of this international activity.
Much of the focus of this activity is on the genera-
tion of the HACCP plan (principles 1-S)(Codex
108 Food Control 1998 Volume 9 Number 2-3
Alimentarius, 1993). However, the HACCP plan is
only the beginning of an operational HACCP system.
The HACCP plan must be implemented on the
factory floor for it to work. This implementation
process is probably the most difficult and time
consuming part of the whole HACCP process and is
an area that many companies struggle with. This
paper has split this implementation process into three
separate phases:
0 Transfer of ownership of the HACCP plan
l Training
0 Maintenance of the HACCP plan
and has tried to present some practical advice on the
implementation process and the maintenance of an
effective HACCP plan throughout the regularly
changing manufacturing environment.
ACKNOWLEDGEMENTS
I would like to thank my colleagues at Streets Ice
Cream for the information and examples of the use
of change control in an operational HACCP system.
REFERENCES
Anon (1993a) Implementation of HACCP in a food processing
plant microbiology and Food Safety Committee of the National
Food Processors Association, Washington. Journal of Food
Protection 56(6), 548-554
Anon (1993b) HACCP implementation: a generic model for
chilled foods microbiology and Food Safety Committee of the
National Food Processors Association, Washington. Journal of
Food Protection 56(12), 1077-1084
Bauman, H. E. (1974) The HACCP concept and microbiological
hazard categories. Food Technology 28,30
Bryan, F. L. (1991) Teaching HACCP techniques to food proces-
sors and regulatory officials dairy. Food and Environmental
Sanitation ll( lo), 562-568
CFDRA (Campden Food and Drink Research Association) (1992)
HACCP: A Practical Guide Technical Manual 38. Campden
Food and Drink Research Association, Chipping Campden,
U.K.
Codex Alimentarius (1993) Guidelines for the Application of the
HACCP System, Alinorm 93/13A, Codex Alimentarius Com-
mission, Rome
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Point System and Guidelines for its Application, Alinorn 97/13A,
Codex Alimentarius Commission. Rome
EC (1993) Directive 93/43/EEC on Hygiene of Food Stuffs. Offi-
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1993
Ehiri, J. E., Morris, G. P. and McEwen, J. (1995) Implementation
of HACCP in food businesses: the way ahead. Food Control
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 HACCP implementation: S. S. Khandke and T. Mayes

FDA 1995. Seafood Processing and Importing Procedure. HACCP NACMCF (National Advisory Committee on Microbiological
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1st edn. Chapman and Hall. London Australia

Food Control 1998 Volume 9 Number 2-3 109