Seafood video resources

Hi my name is Amy and I am one of the department’s Seafood Export Facilitators! In this video I will cover why you need to have a HACCP plan in your Approved Arrangement, why it is important, what documents it should include, and what you need to do to maintain it. In case you weren’t sure, HACCP stands for Hazard Analysis Critical Control Point and it focuses on the activities you undertake specific to your product.

You need to include a HACCP plan in your AA because it is the key for safe food production, and it is what the Export legislation requires. In the previous video in this series called ‘What is an Approved Arrangement and what does it need to document?’, you will remember that we talked about documenting the activities that you undertake at your establishment to prevent your product being cross contaminated. These controls are the ones that need to be in place no matter what kind of export products are being prepared, or for that matter, what kind of food is being prepared. Think of it as being the same as what you would do at home. For example, washing your hands after you have been to the bathroom, or before you start preparing food, and not storing cleaning chemicals in the fridge! HACCP is where we get specific. You now have the general controls in place, HACCP is about having a closer look at the product you are preparing or storing for export.

HACCP has been around for a long time. our export rules, recommend that you look at the CODEX requirements for HACCP plans. CODEX has been around since the 1960s and refers to food safety standards that have been agreed to on an international level, and this includes general agreement to using HACCP as a tool for managing food safety worldwide. There is a lot of information available online about developing HACCP plans, including where you can attend training courses to help you understand HACCP and how it effects your business. We aren’t going to duplicate what is already out there, and this isn’t a training course. Instead, what we will do in this video is cover the minimum requirements for a HACCP plan that needs to be included in your AA. Even if you are going to get external help with this part of your documentation, or if you have trained Quality Assurance staff working for you, it will be helpful for YOU to understand how it works.

HACCP describes a process used to have a very close look at the product you are making for export, this includes considering all of the things that could possibly go wrong while you are making the product, or even just storing it. As you can see already, depending on what you are making or just storing, this process can be complicated or it can be simple. Either way, unless you are a sole operator, you will need a team to get this done. This is not because it is a huge task, it is because you need information from all parts of your business to do it properly. You may find that you require external assistance to document or develop your HACCP plan, this assistance may be in anything from simply typing up the document, through to seeking help from someone trained in developing HACCP plans. All of that is fine! BUT REMEMBER, they will only be ONE member of your whole HACCP team!

So, remembering that today we are only going to touch on the minimum requirements you need in your HACCP plan, we will now break down the documents that you need to provide to us.

• ONE – A fully documented product specification for the product or products that you are making or storing. If you are just storing frozen seafood that has been prepared by someone else, you would probably be tempted to DESCRIBE the product as ‘frozen seafood’. However, we do need you to think a little bit more about it, is your ‘frozen seafood’ a product that needs to be held at a specific temperature? Or handled in a particular way? Is this something that you need to add to your description so that it is clear? For example, is the product you are actually storing better described as ‘Pre-packaged frozen seafood, to be stored at colder than -180C’. Adding this additional detail turns your product DESCRIPTION into a product SPECIFICATION. So now you have documented not only what you are storing, but also the conditions it needs to be stored under. You can now demonstrate and document (prove!) that you are complying with your product specification by taking the temperature of the product with a probe or by referencing the refrigeration gauge.
  Obviously, product specifications for the products that you are MAKING are going to be more detailed because there are more things to consider. For example

• What does my customer want?
• What size boxes am I going to put it in?
• What temperature does it need to be stored at?
• Are there any legal requirements that the product has to meet? This could include considering things like the kind of ingredients you are allowed to use under the food standards code, through to meeting requirements for export labelling.

Consider that you may need more than one product specification if you are making more than one type of product. A detailed product specification will mean you have something you can measure your product against when you have finished making it. You can now PROVE that you have made exactly what you set out to make. 

• TWO – A description of all of the steps in the process for making or storing your product. If you are only storing frozen product, this can be as simple as:
  Step 1) receive frozen product into the establishment,
  Step 2) store in the freezer at below -300C,
  Step 3) select stock,
  Step 4) load refrigerated transport.
  
  OR, if you are processing your product it can be complex. For example, the steps that would be included in a process where frozen abalone is received and processed for export into cans. Simple or complex, it is important to get the steps right. We are happy for these steps to be presented in a diagram, HACCP calls this a ‘flow diagram’. So I think that a diagram is a good place for your HACCP team to start. To make sure that you have included all of the steps, it helps to walk through the actual process while it is happening, or if it is a new process, involving your HACCP team to test the diagram together. They will think of things that you don’t, or even steps that you have missed!
  
  The other important consideration is to think about when a step is a step. To keep this process simple and accurate, think about the product and what happens to it at each step in your process. A common mistake is to combine too many activities into one step. For example, ‘packing and weighing’ may be an accurate description of the step if one person is packing product into a box on a scale and weighing it at the same time. But, this is not an accurate description if one person packs the product into the box on one side of the factory, and another person weighs the product in a different area or on a different day. The important thing to focus on is what is happening to the product at each step of the process. Is it just sitting in the freezer waiting to be processed at the next step? Are you doing something to the product during this step such as cooking it or freezing it? Each step is about the product and what is happening to it during that step. It is NOT about cleaning the factory before you start processing, or training your staff in how to operate the cooker. It is too late to do these things, because right now you are in the middle of processing!!
• THREE – Documenting the hazard analysis. This may be the part where you may need external help. In summary, this is where you consider each step individually in more detail and document what could possibly go wrong, and what you are going to do about it. In HACCP language you are now ‘conducting a hazard analysis’. This might seem like a huge task, I mean for example the roof could cave in!! ANYTHING could happen!! It isn’t actually about ANYTHING that could possibly go wrong. It is about what would be “reasonably expected to occur”. This is where your knowledge of your product and your business comes into play. You have already documented in your Approved Arrangement how you will control the obvious things like cross contamination of the product by pests, people, or poor cleaning. AND you know that the roof isn’t going to cave in because you have control of this through your maintenance program. Other things you already have under control should include: the approval of suppliers of your raw material, the operation of your refrigeration system, and your staff training. To remind you of what you already have under control you might want to have another look at our video called ‘What is an Approved Arrangement and what does it need to document?’.

So, now your HACCP team can focus on each step in your flow diagram, using your knowledge of the product and the process to document what you do. There are several commonly used formats for this, we don’t mind what format you use, as long as your document clearly shows that you have considered what can go wrong at each step. By ‘wrong’ we mean go wrong in such a way that the product you are preparing could cause physical, chemical, or biological harm to the end consumer. To complete this analysis correctly it is important to think about what could CAUSE things to go wrong, and detail the controls that you have, or will put in place to PREVENT this from happening. If you are already operating a successful business and produce a good product (or intend to!), chances are you already have the required controls in place. It’s just that you may not have looked at the things you do as ‘controls’ before, or documented them in this way.

Conducting and documenting a hazard analysis will allow you to work out if there are any steps in your process that are critical for making sure that the product you produce is safe. These are called Critical Control Points, or CCPs for short. These typically include steps in a process where you may be actively trying to destroy harmful bacteria by cooking or canning the product. This can include the step where you receive the product, as this may be the only step in the process where you can prevent unsafe product entering your premises. For example, you don’t want to receive fish that contains toxins that cooking or even canning will not destroy. It is safe to say that not having the right CCPs can be bad for business!

If your hazard analysis indicates that there are no critical steps in your process, and that you can produce a safe product under your more general controls, then this is where you can celebrate because you can skip the documents required in step 4!

• FOUR – Documenting the HACCP table. If critical control points are identified, you will need to document these in a new table usually called a ‘HACCP table’. Again, there are lots of different formats that you can use for this. BUT, at a minimum your HACCP table needs to include each step in your process that includes a CCP. You will need to detail how you monitor each CCP to make sure it is always under control, including what ACTION you will take if something goes wrong. The HACCP plan also needs to include details of who is responsible for monitoring, how and when they will monitor, and where they will document the results of their monitoring. Make sure when you read through your hazard analysis and HACCP plan that this all makes sense to YOU! This is your product, your process, your people, and you know it best! If it doesn’t describe what you do, the document is not going to help you to ensure your food is safe!

It is important that you and all of your staff understand what their role is, why it is important, and what they need to do if something unexpected happens. You do this by having documented work instructions, and by training staff in processes that have been identified as critical. This includes: training in monitoring, record keeping, and confirmation that they understand the action to take if something goes wrong at a step in the process. You will also need documented procedures showing how your HACCP plan is going to be maintained, and how you will PROVE it works. That is, if you follow your HACCP plan the product that you prepare continues to be safe to eat and is able to be exported. We will talk about maintaining your AA (including the HACCP plan!) and checking that your whole system of controls works in our next video called ‘Maintaining your Approved Arrangement and documenting corrective action’.

Hopefully this video has helped you to understand a bit more about what we require to be in your HACCP plan. You should think about HACCP plans as your “working out” documents. It’s the process behind what you are going to make, how you are going to make it, and documents that you have taken due care in making sure that the product is safe to eat. This means that it is VERY important to make sure that all of the details in your HACCP plan, including product specifications and flow diagrams, are up to date and accurately reflect what you are doing NOW. Your whole HACCP plan must be reviewed at least annually even if you have been doing the same thing for years! AND you need to document this process! I can’t stress this enough, it is incredibly important that you revisit your HACCP plan prior to making any changes to your products or processes because a small change, when analysed properly, could turn out to be critical!