required by the Pasteurized Milk Ordinances (16) to have
no more than 50 bacterial colonies per 8 square inches. By
our interpretation, this would be a quality specification
and not a HACCP CCP, if historical data show that these
are spoilage microorganisms rather than pathogens that
are likely to cause illness.
End use of the packaging materials may lead to an
exception to the above rule that HACCP is not needed in
package manufacture. Some examples follow:
. Active packaging is now a very viable area of re-
search, and much of that research has focused on
incorporating into the material types of antimicro-
bials that are efficacious against microorganisms.
If such a compound/product is used in commercial
packaging and is itself an allergen to some popula-
tions, the labeling step may become a CCP, if the
HACCP team concludes in their hazard analysis that
the undeclared allergen is a hazard likely to occur.
In this case, the CCP is the label, the hazard is
the undeclared allergen, and the critical limit is
the proper notation on the label with visual monitor-
ing by the label operator or label scanner for the
correct label each time the labels are loaded. In some
cases, the HACCP team may conclude that the
hazard of an undeclared allergen is not reasonably
likely to occur due to a labeling prerequisite program
in place; in this case, no CCP would be needed.
. Gas combinations in modified atmosphere packaging
(MAP) may also prove critical in outgrowth of patho-
gens because oxygen concentrations below 2–3%
allow or enhance the growth of anaerobic organisms
such as Clostridium botulinum. Oxygen concentra-
tion would be a CCP in the MAP-packaging of mush-
rooms where growth of Clostridium botulinum is a
hazard reasonably likley to occur, for example. A
special case in fresh seafood packaging is vacuum
packaging. As noted in the Seafood Hazards Guide
(13), packaging material with an oxygen transmis-
sion rate (OTR) of 10,000 cc/m
2
/24 h has permeability
sufficient to allow aerobic spoilage to occur before
toxin can be produced. Selection of proper gas com-
binations and OTRs are CCPs in the cases of certain
commodities, where growth of anaerobic pathogens
such as Clostridium botulinum is a hazard reason-
ably likely to occur in the absence of control.
SUMMARY
HACCP is a systematic approach to assuring the safety of
food products based on the concept of prevention. The
HACCP program is widely used in the food industry in the
United States as well as worldwide. Although the seven
HACCP principles are well-developed and application
guidelines have been developed and revised based on
experience gained during HACCP implementation in the
last several decades, there is no universal formula for
putting together the specific details of a HACCP plan. The
plan must be specific to each facility and be dynamic,
allowing for modifications to production, substitution of
new ingredients and new materials (including specialized
packaging materials and packaging steps), and develop-
ment of new products. The plan is participatory at all
levels of management, both in formulating and managing
the plan. The strength in an HACCP program is in
providing a risk management framework that a company
can use effectively to organize and manage the safety of
the products which are produced.
BIBLIOGRAPHY
1. D. A. Corlett, Jr., HACCP User’s Manual, Aspen Publishers,
Gaithersburg, MD, 1998.
2. DHEW, Proceedings of the 1971 National Conference on Food
Protection, U.S. Dept. Health, Education, and Welfare, Public
Health Service, Washington, DC, 1971.
3. Pillsbury Company, Food Safety through the Hazard Analysis
Critical Control Point System, Contract No. FDA 72-59, Re-
search and Development Department, The Pillsbury Company,
Minneapolis, MN, 1973.
4. National Academy of Sciences, An Evaluation of the Role of
Microbiological Criteria for Foods and Food Ingredients, Na-
tional Academy Press, Washington, DC, 1985.
5. M. D. Pierson and D. A. Corlett, Jr., eds., HACCP, Principles
and Applications, Van Nostrand Reinhold, New York, 1992.
6. NACMCF (National Advisory Committee on Microbiological
Criteria for Foods), HACCP Principles for Food Production,
USDA, FSIS, Washington, DC, 1989.
7. NACMCF, ‘‘Hazard Analysis and Critical Control Point Sys-
tem,’’ Int. J. Food Microbiol. 16, 1 (1992).
8. NACMCF, ‘‘Hazard Anlaysis and Critical Control Point Prin-
ciples and Application Guidelines,’’ J. Food Prot. 61, 762–775
(1998).
9. Codex, ‘‘Hazard Anlaysis and Critical Control Point (HACCP)
System and Guidelines for Its Application,’’ Annex to the
Recommended International Code of Practice General Princi-
ples of Food Hygiene, FAO/WHO Codex Alimentarius Commis-
sion, Rome, 2003.
10. U.S. Department of Agriculture/Food Safety and Inspection
Service (FSIS), ‘‘Hazard Analysis and Critical Control Point
(HACCP) Systems; Final Rule,’’ 9 CFR Part 417, Federal
Register 61, 38868 (July 25, 1996).
11. U.S. Department of Health and Human Services/Food and
Drug Administration (FDA), ‘‘Procedures for the Safe and
Sanitary Processing and Importing of Fish and Fishery
Products; Final Rule,’’ 21 CFR Part 123, Federal Register
60, 65197 (December 18, 1995).
12. U.S. FDA, ‘‘Hazard Analysis and Critical Control Point
(HACCP); Procedures for the Safe and Sanitary Processing
and Importing of Juice; Final Rule,’’ 21 CFR Part 120, Federal
Register 66, 6197 (January 19, 2001).
13. U.S. FDA/Center for Food Safety and Applied Nutrition,
Fish & Fisheries Products Hazards & Controls Guidance,
3rd edition (online), Chapter 13, http://www.cfsan.fda.gov/
~comm/haccp4.html, 2001.
14. V. N. Scott and K. E. Stevenson, eds. HACCP: A Systematic
Approach to Food Safety, A Comprehensive Manual, 4th
edition, Food Products Association, Washington, DC, 2006.
15. U.S. FDA, Thermally Processed Low-Acid Foods Packaged in
Hermetically Sealed Containers, Title 21, Code of Federal
Regulations, Part 113, U.S. Government Printing Office,
Washington, DC, 1992.
572 HAZARD ANALYSIS AND CRITICAL CONTROL POINTS