• What is HACCP?
• Why HACCP?
• 7 Principles
• 12 Steps
• HACCP: Hazard Analysis Critical Control Points
• HACCP plan: The written document describing the
procedures to be used for controlling food hazards
using the HACCP method
• GMPs: Good Manufacturing Practices - One of the
foundations for food safety and required by the FDA
• Critical Control Point (CCP): A point during the food
manufacturing process where a food safety hazard
has to be controlled or the risk of injury becomes
• Critical Limit: This is the tolerance allowed before a
risk becomes unacceptable. May be regulatory or
What is HACCP?
HACCP was developed in the 1960’s by Pillsbury in
conjunction with NASA for the space program. The
current methods of food inspection were not adequate
to ensure that astronauts would not get sick in space
with no medical help.
HACCP is a science based process model for the
identification and prevention of food safety hazards
during manufacture. Although HACCP is designed only
for safety, the same risk based analysis is used as the
basis for many quality systems.
HACCP is required for certain industries under FDA and
USDA regulations. Breweries are not currently under a
regulatory HACCP requirement.
Food Safety Hazards
• Required under FSMA
• Sources can include equipment and well water
• FDA – While breweries are not required to have a
HACCP plan, they are required as food manufacturers
to produce safe food under CFR 21
• FSMA requires a written food safety plan
• Customers expect food they consume to be safe
• Recalls are costly and often result in businesses being
forced to close
• Reprocessing and repacking are extremely costly and
• Due diligence – In the case of a lawsuit, a well written
and appropriate plan that is followed can reduce
Designing a HACCP Plan
There are 5 preliminary steps to be completed before
actually developing a HACCP plan.
1. Assemble a HACCP team – should be as cross-functional
2. Describe your product
3. Identify the intended use – also include uses that
you can reasonably foresee consumers doing
4. Construct a process flow diagram
5. Verify the flow diagram by actually walking through
Designing a HACCP Plan
There are 7 principles to a HACCP plan.
1. Conduct a hazard analysis – determine hazards and
identify preventive measures
2. Identify Critical Control Points (CCP)
3. Establish critical limits for each CCP identified
4. Establish CCP monitoring methods
5. Establish corrective actions
6. Establish record keeping procedures
7. Establish verification methods
Conduct a hazard analysis for each step in your process.
Be sure to consider the 4 sources of potential contamination
and how they are controlled.
Example: Malt receiving. What possible contamination can
occur here? Some of the hazards will be different if you are
receiving it by railcar vs pallet.
How do you verify chemical hazards such as pesticide
residue? How about physical such as wood or metal?
Example: Bottling. The most obvious is physical and that is
Identify critical control points.
Depending upon your brewery setup, you may have only
one or two CCPs. If you have identified many CCPs, then the
monitoring, verification, and corrective action process can
There is no “right” number of CCPs to have in any plant but
if you seem to have a high number, you may wish to
reevaluate the hazard analysis to see if the hazard is
controlled by a pre-requisite program or if it is controlled
Establish Critical Limits.
Each CCP must have a critical limit associated with it.
A critical limit is either a minimum or maximum value that is
acceptable for preventing an identified hazard.
These limits can be based on experience, scientific
literature, or industry and governmental guidelines. Just be
sure to document your reasoning.
Establish CCP Monitoring Methods.
Monitoring can be done either automatically or manually by
If a non-continuous method is used, the sampling program
must be statistically valid.
A written SOP for the monitoring method must be
developed and maintained.
All employees responsible for HACCP checks should be given
training and that training needs to be documented
Establish Corrective Actions.
Now that you have your CCPs and monitoring taken care of,
what do you do if you fail your CCP limits?
You must have documented procedures for corrective
actions each time there is a deviation from your HACCP
These corrective action records must be complete and
maintained for a designated time period.
A HACCP deviation log lets you easily track and trend failures
of the system for evaluation in the future.
Establish Record Keeping Procedures.
A written policy or SOP defining how you will maintain your
records is required.
These records include the HACCP plan itself, risk
assessments if separate from the plan, CCP monitoring
records, deviation records and verification records along
with anything else associated with the plan.
Establish Verification Procedures.
A written plan on the methods use to verify and validate the
HACCP plan is required.
Verification is the process used to ensure the HACCP plan is
working as intended. For example – are records complete,
including monitoring and corrective action documents?
Validation is the process to make sure the plan does what it
is supposed to do i.e. make safe food.
HACCP is a strong tool but it cannot work effectively by itself.
A strong HACCP program also requires effective pre-requisite
programs and management commitment. Without all three
components, a food safety system will fail.
Pre-requisite programs typically control hazards early in the
process and minimize the possibility of contamination so
that the HACCP plan can focus on those things that can’t be
controlled prior to product release.
Management commitment is required to maintain these
programs and supply the resources necessary.
Pre-requisite programs include items such as material
receiving, chemical control, allergen control, GMPs, audits,
pest control, preventive maintenance, and traceability. This
is not an all inclusive list and each plant has to make its own
decisions on what programs are needed and how to
implement and maintain them. That however is another
Information provided by:
Notes for Food Safety in the Brewery
Slide 7: Designing a HACCP Plan
1.In a small brewery, you may only be able to have 2 people on your team. Large
breweries can supply more but an ideal team size should in most cases be limited to 5-7
2.Don’t just say beer. You have an alcoholic beverage made from malt and hops with an
alcohol range from 4-12% perhaps. Do you use fruit or flavorings in your product? Be
3.Beer is not just for drinking you know. Consumers sometimes do things you do not
reasonably expect but that does not mean you need to address all of them. As an
example, a certain national brand of aerosol whipped cream gets a large influx of
questions every year in February asking if it is safe to use their product in an intimate
manner. This is not to be expected but people do cook with beer.
4.You can do this at the table
5.Walk the process and note any equipment such as pumps, filters, etc that were not
included in your table top construction of the flow diagram.
Slide 9: Principle 1
Some possible preventive measures at receiving may be temperature if you are dealing
with a sensitive material or a COA or letter of guarantee from a supplier that the malt is
free of pesticide residue. There are many possible measures for each step along the
process flow diagram and there is no need to list every single one as long as what you
list is adequate.
Slide 12: Principle 4
Examples of continuous monitoring include temperature recorders, flow rate or pressure
recorders, etc. Manual sampling may be recording regulated substances onto a batch
sheet or sampling 30 cans an hour or similar.
Slide 13: Principle 5
State or Federal regulations that pertain to your business may determine how long you
are legally required to maintain these records. In the absence of those regulations, a
quick attorney consultation will give you an idea of best practices.
Slide 15: Principle 7
Verification methods may include audits of records, periodic record review by
management, and review/revision of the HACCP plan itself.
Validating the plan can be done by challenging the system such as using test cans with
foreign material to see if rinsers will remove it. Validation overlaps to a degree with
verification because if the record review and data trends indicate multiple failures, your
plan probably is not stringent enough and needs better control before the CCPs