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Issue Number: Council II 037


HACCP Training

Issue you would like the Conference to consider

The 2009 FDA Food Code allows establishments to obtain variances to the Code and under certain circumstances requires those establishments to submit Hazard Analysis Critical Control Point (HACCP) plans to the regulatory authority.

The preface to the 2009 Code states "Retail processors may be given the same opportunity as federally-regulated establishments to use innovative techniques in the production of safe foods. Retail establishments may apply to the regulatory authority for a variance to use a specific federal food safety performance standard for a product or a process in lieu of compliance with otherwise applicable specifications in the Food Code. However, to show compliance with the federal performance standard, the retail processor must, like a federally inspected establishment, show that processing controls are in place to ensure that the standard is being met. Thus, a request for a variance based on a federal performance standard must be supported by a validated HACCP plan with record-keeping and documented verification being made available to the regulatory authority."

However, in establishments that operate under federally mandated HACCP plans, the regulations that require the HACCP plan also require TRAINING. Retail establishments, operating under the food code, may attempt to submit a HACCP plan as part of a variance application; however, the Food Code contains no specific HACCP training requirement.

The current language in Section 2-102.11 of the Food Code, dealing with the Person in Charge (PIC) being able to demonstrate application of the HACCP principles, simply is not sufficient to prepare an individual to perform a hazard analysis, prepare a HACCP plan, or successfully implement a HACCP program.

Public Health Significance

The Food Code allows regulatory authorities to grant variances to the Code and then requires the establishment to operate in a HACCP environment. The production of safe food cannot be assured if the operator does not understand the program.

The fact that a variance has been required shows that the process being used has more risk (because it would not be allowed without the special permission of a variance). When the HACCP plan is improperly followed, unsafe food may be the result.

Taking the logical step of requiring the operator to be trained in the food safety system that is being used at the establishment will help mitigate the risk of foodborne illness due to system failure.

Recommended Solution: The Conference recommends...

that a letter be sent to the FDA requesting the agency to:

  • Establish a HACCP Curriculum based on the 7 principles of Hazard Analysis and Critical Control Point principles developed by the National Advisory Committee on Microbiological Criteria for Foods. or
  • Designate a national organization to establish the above curriculum, and
  • amend the 2009 Food Code (as modified by the Supplement issued in 2011) as follows (new language shown with underline):

Section 2-102.30 Persons engaged in HACCP Plan Development and Application

A person responsible for developing a hazard analysis and HACCP plan and reviewing the HACCP records, must have successfully completed training in the application of HACCP principles.

Submitter Information

Name Sean Dunleavy
Organization Great Lakes Conference on Food Protection
Address P. O. Box 16082
Lansing, MI 48901
Telephone (517) 243-8895
Fax (517) 373-3333
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