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Thursday, 28 November 2013

Ready-to-Eat Meat HACCP and Candid Candice

What would you do if you faced a situation similar to the following?

In this examined case, Candid Candice, one of the QC technicians, was assigned by a ready-to-eat meat processing company to verify the cooking/cooling CCP operations. She had just joined the company 3 months prior. She worked on a three-shift rotation with 2 other QC technicians who had been at this company for longer. As the newest technician, Candid Candice mostly got the night shift (10:00 p.m. to 6:00 a.m.)

All of the QC technicians including Candice were trained to conduct on site verification of the CCPs (metal detector, nitrite cure level, oven cooking/cooling temperature). The training included checking the oven cooking temperature using properly calibrated and verified thermometers and according to the determined heat distribution profile with particular attention paid to the coldest points.

The company had implemented its HACCP program with the help of a consultant three years ago. At the end of the first year of HACCP implementation, the operation gained an external certification of the program. Although the company had been operating under a certified HACCP program nearly 2 years prior to the employment of Candid Candice, she was the first to discover a flaw that had not been previously identified. Some of the cooking operators did not like the “inconvenience” of waiting for the temperature of the coldest point in the cooking oven. So they inserted the probe that was supposed to monitor that point at another point that reached the end temperature much quicker. This was clearly contrary to the established protocol. As stated, the QC technicians, during their on-site verifications, routinely checked the temperature readouts of the individual probes that were marked to identify the coldest points

Candid Candice once thought to check the temperature readouts but also checked the actual locations of the probes during one of her verification rounds. This meant she had to wait right there on the line to physically check as the racks were off-loaded from the oven. In this first instance, the probe of the coldest point happened to have been “mistakenly” inserted at a hot point. The incidence was treated as a mistake but corrected by re-cooking the product from the coldest points to the desired temperature. The findings and corrections were duly recorded and reported to the QA manager.

After a reasonable review of the situation by the QA and production managers, all cooking operators were re-trained and the QC technicians were instructed to also occasionally check the locations of the probes during their verification shifts. Consequent CCP monitoring records thereafter showed acceptable readings except some of the records prepared by Candid Candice during some of her verification rounds. Several batches went through the cooking process during each shift and it was not possible for the QC technicians to observe the off-loading of every batch. The deviating instances detected by Candice also did not pertain to a particular cooking operator. Different operators appeared to favor the deliberate probe misplacement “mistake” tactics and continued the practice at strategic times to elude discovery except Candid Candice caught some of those times.

Although every instance reported by Candice was corrected and noted in the verification records with appropriate reminders/warnings to the cooking operators, the problem was sufficiently evasive. A requirement for QC to always be physically present during the off-loading of each cooked batch was supposedly time-consuming. It was also seen by the company as cost-prohibitive since it requires the hiring of more QC manpower. Therefore it was not done as a routine. The QC technicians, at random frequency, were to do spot checks as Candid Candice did. The HACCP system was clearly not functioning as it should but management determined to do nothing further than was already done since “there was no recorded consumer or regulatory complaint that was linked to under-cooked product”.

During the annual HACCP certification audit later that year, the auditor examined all of the HACCP records including the cooking/cooling CCP records. All of the records sampled for examination appeared to be in order. They showed that CCP monitoring verification was done and required corrective actions for recorded deviations were completed. At the audit closing meeting attended by the managers and the QC technicians, the auditor reported, from his findings, that significant concerns were not found with the HACCP system. He indicated that the result of the audit was a pass and a re-certification would be recommended to the certification body. At this point Candid Candice raised a question about the sufficiency of the current cooking temperature verification process. The auditor was forced to investigate further. From the ensuing discussion, a further review of verification records prepared by Candice and other QC technicians, equipment setup review, more interviews, etc., the findings forced the auditor to revise the final judgment. A failure to properly monitor and verify the cooking CCP was assigned which meant that the audit was rated as a failed audit. How do companies in similar situations, perhaps with other hazard control measures, deal with such situations? How should they deal with such situations?
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Posted By Felix Amiri
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Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

4 comments:

  1. She did a brave job indicating the failure. But doing it in front of the auditor to make her company fail the audit is not appreciable. She could have done the same during internal audits and rectify the flaw through proper corrective actions.

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    1. Unfortunately I think the answer to Pragash is in the text "management determined to do nothing further than was already done since “there was no recorded consumer or regulatory complaint that was linked to under-cooked product”. Absence of evidence is not evidence of absence.

      Given this sort of attitude I have a low level of confidence that the management understood or wanted to understand there was a fundamental problem. I feel that if Candice continued to protest they may have decided to remove her. There were other people aware of the problem - Candice was professional enough to decide not to be associated with it any longer.
      Interestingly it also demonstrates how that audits only cover what is seen on the day

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    2. Great comment Andy, particularly the part about: "Absence of evidence is not evidence of absence."

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  2. Andy is right. If QA people protest they get removed by the management or the management convinces them. But it is normal in the life of a QA person. He is supposed to educate the management on the problems. I am taught to do so all the time. To educate people on the problems, make them aware, try to find the proper solution which can convince the management also etc., But never let the company down on an audit since it is not the failure of the management. It is the failure of that QA person.

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