Machinery Lubrication magazine published by Noria Corporation
Issue link: https://www.e-digitaleditions.com/i/875060
www.machinerylubrication.com | September - October 2017 | 49 ML biological or chemical hazard must be controlled at a critical control point to prevent, eliminate or reduce to an acceptable level the occurrence of the identified food safety hazard." In the case of lubricants, the FDA has set this limit at zero parts per million for non-food-grade lubricant contamination. Monitoring Procedures Monitoring is essential to an HACCP system. It can warn of an impending loss of control so action can be taken before a critical limit is exceeded. Monitoring gener- ally will be more effective if the personnel responsible for monitoring understand its purpose and importance, and are clearly identified and properly trained. Monitoring procedures usually relate to online processes. Corrective Actions Once the HACCP plan is implemented, corrective actions must be taken any time a critical limit is not met. These actions should include determining the disposition of a non-compliant product, correcting the cause of the non-compliance to prevent a repeat, examining the process or product again at the control point to ensure the results are within the limits, and maintaining a record of the correc - tive actions and results of the applicable testing. Under HACCP, the actions to be taken in the event a critical limit is not met at a critical control point must be established in advance. Personnel responsible for monitoring the critical control points should understand the process and be trained on how to perform the corrective actions. All corrective actions should also be documented, with the respon - sible personnel signing an acknowledgement. If a corrective action is required that has not been previously identified in the HACCP plan, this should be documented as well. It may be necessary for the product to be held for further investigation. This investigation may include product testing, consultation with a third party or processing authority, or a thorough records review. Record-keeping Procedures Accurate and complete records are important because they serve as written docu- mentation of compliance with the HACCP plan. These records will allow you to trace the history of an ingredient, finished product or in-process operation should problems arise. They can also help you identify trends in an operation that could result in a deviation. HACCP systems should include records for critical control points, establishment of critical limits, how deviations were handled and the results of verification activities. These records must contain the product identification, crit - ical criteria, time and date of the observation, and the monitor's and reviewer's signatures. Verification Procedures The HACCP system should be assessed periodically to ensure it is working correctly. Among the points to evaluate would include the monitoring equipment's cali - bration process, any corrective actions, and obser vations of monitors and moni- toring activity. A periodic evaluation of employees is also recommended to ensure that corrective actions are performed and documented properly. Validation of the HACCP plan will demon- strate that it prevents, eliminates or reduces all identif ied microbiological, chemical and physical hazards to a regulated and/or commercially feasible level. The responsibility for this validation rests on the regulated industry. The validation assembles the data to prove that the HACCP plan developed and implemented by a company will control the process and prevent food safety hazards. A reassessment should be performed at least annually to determine if the HACCP system is adequate. A reassessment is also necessary any time new hazards have been identified or when changes have occurred in the process, ingredients, raw materials, vendor, product volume, personnel, pack - aging, distribution or any other factor that could affect the hazard analysis. In conclusion, as the FDA continues its efforts to fully implement the Food Safety Modernization Act, companies that manu- facture food and beverage products must prepare for the changing requirements. If they fail to comply, their plant managers could face hefty fines, criminal prosecution or even imprisonment. About the Author Loren Green is a senior technical consultant with Noria Corporation, focusing on machinery lubrication and maintenance in support of Noria's Lubrication Program Development (LPD). He is a mechanical engineer who holds a Machine Lubrication Technician (MLT) Level II certification and a Machine Lubricant Analyst (MLA) Level III certification through the Inter - national Council for Machinery Lubrication (ICML). Contact Loren at lgreen@noria.com.