What Is a Food Safety Plan and What Is It Doing on My Table?

Would you like that burger with a side order of 
food safety plan? If the restaurant doesn't 
have one, you might want to reconsider your order!
Whenever you go out to eat with your family, co-workers, or friends, you may be unaware that many of the restaurants (food service establishments) and retail food stores have some type of food safety plan in place.  Most of the chain restaurants have sophisticated food safety systems designed and implemented for their daily operations and as well as many of the larger, more established restaurants and retail food stores. The U.S. Food and Drug Administration encourages these retail food operations to implement food safety systems and use them throughout the everyday activities of the operations. 

Besides the encouragement to implement and use these food safety systems in everyday operations, the U.S. Food and Drug Administration has recommended to state and local regulatory agencies that Hazard Analysis Critical Control Point (HACCP) systems be mandated for food production activities that pose significant risk and hazards for the consumer. Later in this article, we discuss when these HACCP program activities are required in these retail food facilities.
In 1993, the Unites States Public Health Service, Food and Drug Administration (FDA) issued the first version of the modern day FDA Food Code.  Prior to 1993, the United States Public Health Service had issued previous editions of documents for regulatory guidance in food service and retail food store operations.  Two documents of note and examples that preceded today’s FDA Food Code are (1) the 1962 Food Service Sanitation Manual including a Model Food Service Sanitation Ordinance and Code, 1962 Recommendations of the Public Health Service and (2) Food Service Sanitation Manual including A Model Food Service Sanitation Ordinance, 1976 Recommendations of the Food and Drug Administration.

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The U.S. Public Health Service first began its activities in food protection at the turn of the 20th century. Issuing documents such as (which is now titled) Grade A Pasteurized Milk Ordinance – Recommendations of the PHS/FDA, initially published in 1924. Model codes were developed to assist and enable state and local governments in initiating and maintaining effective programs for the prevention of foodborne illness.

FDA’s mission today in retail establishment food protection is to assist all levels of government (federal, state, local, and tribal authorities) by providing sound technical advice in the regulation of retail food operations. U.S. Public Health Service assistance to state and local governments is authorized by the Public Health Service Act (42 USC 243).

How is HACCP used today with the FDA Food Code?

The latest version of the FDA Food Code was issued by FDA in 2013.  The FDA currently issues a new Food Code every four years with supplements to the Food Code issued as needed in the years following publication of the last version.

First references to HACCP in the Food Code appeared in the 1999 Food Code and most likely appears because of the beginning and use of the HACCP regulatory system for Meat and Poultry Products by the USDA’s Food Safety Inspection Service in the mid to late 1990 decade.  As newer versions of the Food Code have been issued by the FDA, more and various options for the use of HACCP has been included by the FDA in these versions.

One of the first options for the use of HACCP plans in the 1999 Food Code was provided for the production of foods by a reduced oxygen process (ROP) method.  Since then, other requirements for production of foods with a HACCP plan required have been incorporated into other Food Code versions. Today the retail food industry’s use of HACCP can be found primarily in the production of ROP (reduced oxygen process) foods such as cook-chill or sous vide’.

HACCP represents an important food protection tool supported by Standard Operating Procedures, employee training and other prerequisite programs. Many national companies and small independent food operations have implemented HACCP and the use of active managerial control of hazards to provide safe food for the consumer. Identification of critical control points and critical limits is important for the preparation steps they perform. Establishment management must also follow through by routinely monitoring the food operation to verify that management and employees are keeping the process under control by complying with the critical limits.

Many state and local regulatory food safety jurisdictions effectively promote the retail industry's use of HACCP and apply the concepts during inspections. The implementation of HACCP continues to evolve as hazards and their control measures as they are more clearly defined. 

The use of HACCP by the retail food establishment is voluntary, however, if the type of food and process as specified by the FDA Food Code requires a HACCP plan, the state or local regulatory agency will ensure that the operation complies with the HACCP requirements for the production of that food.

FDA has issued an excellent guidance document that the industry may use in implementing HACCP within their facilities.  The document entitled, "Managing Food Safety: A HACCP Principles Guide for Operators of Food Service, Retail Food Stores, and Other Food Establishments at the Retail Level" is discussed in Annex 2 and Annex 3 of the Food Code.

Please note that in the above document, there are differences between using a HACCP plan in retail food establishments and food manufacturing plants. The FDA Food Code and the above document provides a framework for the retail food industry to develop and implement a sound food safety management system. 

When a HACCP Plan is Required

Using the 2013 FDA Food Code, let’s look at when a HACCP plan is required by the Food Code.

Submission of a HACCP PLAN may be required by a state or local health regulatory agency when:

  • Smoking food as a method of food preservation rather than a as a method of flavor enhancement;
  • Curing FOOD; 
  • Using FOOD ADDITIVES or adding components such as vinegar: 
    • As a method of FOOD preservation rather than as a method of flavor enhancement, 
    • To render a FOOD so that it is not TIME/TEMPERATURE CONTROL OF SAFETY FOOD; 
  • Packaging TIME/TEMPERATURE CONTROL FOR SAFETY FOOD using a REDUCED OXYGEN PACKAGING method except where the growth of and toxin formation by Clostridium botulinum and the growth of Listeria monocytogenes are controlled as specified under § 3-502.12 (Food Code); 
  • Operating a MOLLUSCAN SHELLFISH life-support system display tank used to store or display shellfish that are offered for human consumption;
  • Custom processing animals that are for personal use as FOOD and not for sale or service in a FOOD ESTABLISHMENT; 
  • Preparing FOOD by another method that is determined by the REGULATORY AUTHORITY to require a VARIANCE; 
  • Sprouting seeds or beans. 

Contents of HACCP Plan – Food Code Requirements

The Food Code specifies the following documents will be a part of the HACCP plan for the food or foods that will be produced under the HACCP plan requirements. Section 8-201.14 of the Food Code specifies the following:

(A) A categorization of the types of TIME/TEMPERATURE CONTROL FOR SAFETY FOODS that are specified in the menu such as soups and sauces, salads, and bulk, solid FOODS such as MEAT roasts, or of other FOODS that are specified by the REGULATORY AUTHORITY; 

(B) A flow diagram by specific FOOD or category type identifying CRITICAL CONTROL POINTS and providing information on the following:

  • Ingredients, materials, and EQUIPMENT used in the preparation of that FOOD, and
  • Formulations or recipes that delineate methods and procedural control measures that address the FOOD safety concerns involved;  
(C) FOOD EMPLOYEE and supervisory training plan that addresses the FOOD safety issues of concern;  

(D) A statement of standard operating procedures for the plan under consideration including clearly identifying:

  • The method and frequency for monitoring and controlling each CRITICAL CONTROL POINT by the FOOD EMPLOYEE designated by the PERSON IN CHARGE, 
  • The method and frequency for the PERSON IN CHARGE to routinely verify that the FOOD EMPLOYEE is following standard operating procedures and monitoring CRITICAL CONTROL POINTS, 
  • Action to be taken by the PERSON IN CHARGE if the CRITICAL LIMITS for each CRITICAL CONTROL POINT are not met, and 
  • Records to be maintained by the PERSON IN CHARGE to demonstrate that the HACCP PLAN is properly operated and managed; and
  • Additional scientific data or other information, as required by the REGULATORY AUTHORITY, supporting the determination that FOOD safety is not compromised by the proposal. 
(CAPs above = Food Code definition)

The use of a HACCP system by the retail food industry has greatly expanded in the last few years. State and local regulatory agencies of today are more aware of the Food Code requirements for HACCP plans and these HACCP plans help to ensure that safe food is produced and sold to the consumer.

When you visit your favorite restaurants or purchase that food item in the delicatessen from your retail food store (grocery) you may want to consider asking the management about their food safety plan. As consumers, we want our food to be safe and management of these operations also wants to be sure to provide safe foods to their customers.

W. Lynn Hodges has worked in food safety for more than 37 years with local, state, and Federal regulatory agencies, including the U.S. Food and Drug Administration and the USDA/Food Safety Inspection Service.  He has held positions as food program supervisor on the state and local levels, FDA food safety specialist, and USDA/FSIS regional trainer in meat and poultry inspection.  He currently works as a consultant with HACCP Consulting Group, LLC in Fairfax, Virgina.  He may be reached at wlh@hodges-hacg.com or 972-268-5243.

The HACCP Consulting Group, LLC performs food safety consulting activities and training that includes USDA/FSIS meat and poultry operations, US FDA food processing operations, USDA and FDA imported food products, and retail food protection activities for food service, institutions, and retail food store operations.