Food Manager HACCP — The 7 Principles, Critical Control Points, and Limits

THE 7 HACCP PRINCIPLES in sequence: (1) CONDUCT A HAZARD ANALYSIS: Identify all potential hazards (biological pathogens, chemical contamination, physical objects) that could reasonably occur at each step of production; (2) IDENTIFY CRITICAL CONTROL POINTS (CCPs): Steps where control is essential to prevent or eliminate a hazard; (3) ESTABLISH CRITICAL LIMITS: The maximum or minimum values at each CCP; (4) ESTABLISH MONITORING PROCEDURES: How CCPs will be monitored; (5) ESTABLISH CORRECTIVE ACTIONS: What to do when a limit is not met; (6) ESTABLISH VERIFICATION PROCEDURES: Confirm the HACCP system is working; (7) ESTABLISH RECORD-KEEPING AND DOCUMENTATION. The hazard analysis MUST come first — you cannot identify CCPs until you know what hazards exist.

HEPATITIS A is a REPORTABLE DISEASE — the food manager is legally required to notify the local health department immediately upon learning of a confirmed case in a food worker. NEXT STEPS: EXCLUDE the employee from work immediately (CDC requires 7 days from jaundice onset); CONTACT HEALTH DEPARTMENT: They will guide the investigation including: identifying exposure window (typically 15-50 days incubation); notifying exposed customers if the worker handled ready-to-eat foods; assessing post-exposure prophylaxis options for exposed workers and contacts; FULL COOPERATION: Document the employee's work schedule, duties, and food items handled; the health department investigation protects public health; PREVENTION: Hepatitis A vaccination for food workers is strongly recommended and required in some jurisdictions.

TWO-STAGE COOLING REQUIREMENT (FDA Food Code): Stage 1: Cool from 135°F to 70°F within 2 hours; Stage 2: Cool from 70°F to 41°F or below within the next 4 hours; TOTAL: From hot to 41°F in 6 hours maximum. WHY SHALLOW PANS: Heat dissipates from surface area — a 4-inch deep pan has much more surface area relative to volume than a 5-gallon pot; a full pot of soup can take 8-12 hours to cool in a refrigerator, sitting in the danger zone the entire time; APPROVED METHODS: Shallow pans (max 4 inches); ice baths with stirring every 15 minutes; blast chiller; ice paddles (containers filled with ice that are stirred through food); cooling wands; NEVER: Cool in deep pots with lids; cool at room temperature; place large pots in walk-ins that raise the refrigerator temperature.

COOLING AS A CRITICAL CONTROL POINT: In a cook-chill or cook-serve-later process, COOLING is a critical control point because: cooking destroys vegetative bacteria but NOT all bacterial SPORES; as food cools through the danger zone, surviving spores can germinate and bacteria multiply rapidly — especially if cooling is too slow; CRITICAL LIMITS for cooling: 135°F to 70°F within 2 hours, then 70°F to 41°F within 4 more hours; MONITORING: Check temperatures at intervals during cooling; CORRECTIVE ACTION: If food doesn't cool fast enough, reheat to 165°F and restart, or discard; HAZARD: Clostridium perfringens and Bacillus cereus are spore-formers strongly associated with improper cooling of cooked foods (the 'cafeteria germ'); identifying cooling as a CCP and controlling it is essential in any operation that cooks food in advance; food managers conducting hazard analysis must recognize cooling as a high-risk step requiring control.

HACCP is the foundational science-based food safety system. The seven principles (FDA, USDA, NACMCF): (1) Conduct a Hazard Analysis — identify biological, chemical, and physical hazards in the operation and at each process step; (2) Determine Critical Control Points (CCPs) — points where control can be applied to prevent, eliminate, or reduce hazards to acceptable levels (typically cooking, cooling, hot holding); (3) Establish Critical Limits — measurable parameters at each CCP that must be met (e.g., chicken to 165°F internal); (4) Establish Monitoring Procedures — who, what, when, how to monitor each CCP; (5) Establish Corrective Actions — what to do when monitoring shows a CCP is not under control; (6) Establish Verification Procedures — activities other than monitoring that determine the HACCP plan is working (calibration, audits, testing); (7) Establish Record-Keeping and Documentation. HACCP plans are operation-specific; a plan that works for one restaurant may not work for another. Managers should lead HACCP plan development with team input. Documents to maintain: hazard analysis worksheets, CCP decision logs, monitoring records, corrective action records, verification records, training records. State and local regulators may require HACCP for high-risk operations (sushi, seafood, vacuum-packaging, modified atmosphere packaging).

TCS foods (formerly called Potentially Hazardous Foods/PHF) require strict time and temperature controls because their characteristics support pathogen growth or toxin formation. Characteristics that make foods TCS: (1) High water activity (Aw > 0.85); (2) Neutral or slightly acidic pH (4.6-7.5); (3) Protein-rich. Specific TCS foods per FDA Food Code: animal-based foods (meat, poultry, fish, shellfish, eggs, dairy); cooked plant-based foods (rice, beans, vegetables, pasta — once cooked, the matrix supports growth); cut leafy greens; cut tomatoes; cut melons; raw seed sprouts; garlic-in-oil mixtures (anaerobic, supports Clostridium botulinum); soy-protein products (tofu, soy milk); untreated garlic-in-oil; certain plant foods that have been heat-treated. Non-TCS foods: low Aw (dry foods, jam), low pH (most pickles, mayonnaise), or with effective preservation. Why important: Temperature Danger Zone is 41°F to 135°F (5°C to 57°C); TCS foods cannot be in this zone more than 4 hours total (or 6 hours per FDA Food Code if temperature monitored). Cold holding ≤41°F; hot holding ≥135°F. Time as a Public Health Control (TPHC) — using time alone instead of temperature — requires written procedures, marking, and 4 or 6 hour maximums.

FDA Food Code minimum internal cooking temperatures (food/seconds at temperature): (1) 165°F for 15 seconds: poultry (chicken, turkey, duck, goose); stuffed meats, poultry, pasta, fish; stuffing containing TCS food; food reheated for hot-holding; raw meat in microwave (covered, rotated, 2 min rest); (2) 155°F for 17 seconds: ground meat (beef, pork); mechanically tenderized or injected meat; ground or comminuted fish; ratites (ostrich); eggs to be hot-held; (3) 145°F for 15 seconds: seafood (fish, shellfish, crustaceans); pork, beef, lamb steaks/chops/roasts (intact, non-comminuted); commercially raised game; eggs for immediate service; (4) 145°F for 4 minutes (or other equivalent time-temperature combinations): roasts of beef and pork (longer time, lower temp acceptable); (5) 135°F: commercially processed, ready-to-eat foods being hot-held; fruits, vegetables, grains, legumes for hot-holding. Cooking temperatures destroy pathogens. Use calibrated thermometers; check temperature in the thickest part. Microwave cooking requires special handling — covered, rotated/stirred, 2 minute rest after cooking, then check temperature in multiple places.

Two-stage cooling per FDA Food Code: (1) From 135°F to 70°F: within 2 hours; (2) From 70°F to 41°F (or below): within additional 4 hours; (3) Total cooling time: 6 hours maximum from 135°F to 41°F. If the first stage (135°F to 70°F) takes more than 2 hours, the food must be discarded — it cannot be salvaged by faster cooling in the second stage. Why critical: temperature danger zone (41°F-135°F) supports rapid pathogen growth; cooling too slowly allows growth and toxin formation; pathogens like Clostridium perfringens and Bacillus cereus can produce heat-stable toxins that survive subsequent reheating. Effective cooling methods: (1) Shallow pans (food <2 inches deep) on top racks of cooler; (2) Ice baths with frequent stirring; (3) Ice paddles in liquid foods; (4) Blast chillers (rapid cooling units, can cool large quantities quickly); (5) Adding ice as an ingredient (e.g., to soup, then water is added); (6) Smaller portions in shallow containers. Don't: put hot food directly into cooler in deep containers; stack containers blocking airflow; rely on refrigeration alone to cool large hot batches. Monitor cooling with temperature checks — at 2 hours (should be ≤70°F) and at 6 hours (should be ≤41°F). Record temperatures.

FDA Food Code requires the Person in Charge (PIC) to manage employee illness. Reportable illnesses (employees must report; managers must notify regulators if confirmed): The 'Big Six' pathogens: (1) Salmonella Typhi; (2) Salmonella spp. (non-typhi); (3) Shigella spp.; (4) Shiga toxin-producing E. coli (STEC), including O157:H7; (5) Hepatitis A virus; (6) Norovirus. Symptoms requiring exclusion (cannot work at all): (1) Vomiting; (2) Diarrhea; (3) Jaundice (yellow skin/eyes); (4) Sore throat with fever (in establishments serving high-risk populations like daycares, nursing homes, hospitals); (5) Diagnosis of any Big Six pathogen. Restriction (cannot work with exposed food, utensils, or equipment but may work in other capacities) for: certain conditions and recovery periods. Infected open lesions: must be covered with impermeable bandage and glove (for hands) or otherwise excluded. Documentation: employees should sign written agreement understanding reporting obligations; managers maintain illness logs. Returning to work: requires being symptom-free, often 24+ hours after symptoms resolved; some pathogens require medical clearance or stool testing. Sick employees in food service is one of the leading causes of foodborne illness outbreaks. Norovirus, the most common cause, spreads easily through sick workers.

Person in Charge (PIC) requirements per FDA Food Code: (1) Always present during operating hours — a designated person responsible for food safety; (2) Demonstrate knowledge of foodborne disease prevention, application of HACCP principles, and Food Code requirements (typically demonstrated through certification); (3) Most jurisdictions require Certified Food Protection Manager (CFPM) certification — ANSI-accredited programs include ServSafe Manager, Prometric, NRFSP, ATF (Above Training and Food). Certification involves: (1) Coursework (online or classroom); (2) Proctored exam — typically 80+ questions, 75% passing; (3) Valid 5 years; (4) Renewal required. CFPM exam content: foundations of food safety, hazards, time/temp control, personal hygiene, cross-contamination, cleaning/sanitizing, regulatory authority, HACCP. PIC duties: (1) Train staff on food safety; (2) Monitor food safety practices throughout the operation; (3) Respond to issues and complaints; (4) Cooperate with regulatory inspections; (5) Manage employee illness and exclusions; (6) Ensure HACCP plan compliance if applicable; (7) Maintain documentation. Local regulations may add requirements. A facility without an on-site PIC during operating hours can be cited or shut down. PIC is responsible legally and operationally for food safety in their facility.