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1. Process 2. Identify potential 3. Are any of 4.

Justify your Control Measures

Step hazards and their the potential decision for column
source or cause at food safety 3
this Process Step hazards

Receiving Physical: No.

(sugar, salt, Foreign
wheat particles,wood, sand
powder) Chemical: No.
Impurities, heavy
metal contamination

Biological: Yes. Column 3 is true Quality assurance

Contamination by because the raw ( certificate of analysis)
spoilage/pathogenic from suppliers.
m.o. materials may
contain harmful
microorganism such
as bacteria , yeast ,
molds etc.

Storage (sugar, Physical: Yes. Column 3 is true Proper storage condition

salt, wheat insects because raw ( dry , clean ,
fumigation ) , sealed
flour,cocoa materials may be packaging of the
powder) affected by insects ingredients .
during storage and
cause damage .

Chemical: No.

Biological: Yes. Growth of harmful Proper storage condition

Contamination by microorganism maintain .
m.o. during storage.

Physical: Yes. This is true because Proper inspection of

Eggshell (Cracked / egg shell may be incoming eggs.
Receiving egg broken eggs)
cracked or broken
during handling or
may have
mechanical injury
from suppliers.

Chemical: No.

Biological: Yes. This is true because Quality assurance from

Presence of raw egg surface may suppliers.
pathogenic bacteria
contain harmful

Physical: No.
Egg shell cracked.
Storage of egg Chemical: No.

Biological: Yes. This is true because Proper storage condition,

Growth of pathogenic unsuitable storage refrigerated storage ( 5-
bacteria. 150C ) , label expired
condition can cause
date .
growth of harmful

Physical: Yes. This is true because Inspection of the

Insects, bone pieces, impurities from air , ingredients.
Weighing of dirts, personal items. SOP for production area.
contact surface may
be introduced to the
raw materials.

Chemical: No.

Biological: Yes. Microorganism from SOP for production area.

Microorganism contact surface,
personal items .
Ingredients Biological Chemical hazards. Physical Control or prevention
hazards. hazards. measures.

Unsalted Presence of Unapproved color , Foreign Product must met

butter. pathogenic / additives etc. particles , dirt established purchase
spoilage etc. specifications.
Visual inspection of
such as –
lactis , Inspection of
lactococcus , temperature.

Brown sugar. Presence of Unapproved color , Foreign Product must met

pathogenic / additives etc. particles , dirt , established purchase
spoilage sand , wood , specifications.
microorganisms bagasse etc.
such as – lactic
acid bacteria ,
bacillus cereus,
*insert raw materials ccp decision tree ( block diagram)

Raw materials CCP decision:

Q1: Is there a hazard associated with this raw material?

Q2: Are you or the customer going to process this hazard out of the product?

Q3: Is there a cross contamination risk that cannot be controlled?

Ingredients Q1 Q2 Q3 CCP? HACCP team notes

Butter Yes Yes No No Q1 is yes because of lactobacillus but

later heat processing will control ,
this is why Q2 is yes too. So, this is
not a CCP.

sugar Yes Yes No No Q1 is true because raw sugar may

contain bacillus cereus bacteria and
unapproved color & additives but
later heat processing will eliminate
this hazard , that’s why Q2 is yes too.
As there is no cross contamination
risk that’s why Q3 is true and this is
not a CCP.

Process step ccp decision:

Q1: can this significant hazard be controlled?

Q2: Is this step specifically designed to eliminate the hazard?

Q3: Could contamination occur or increase to unacceptable levels?

Q4: Will subsequent processing eliminate the hazard?

Process step Potential Q1 Q2 Q3 Q4 CCP? HACCP team notes


( P/C/B)

Receiving ( sugar, B N - - - N Quality assurance from

salt,flour, cocoa ) suppliers required.
Biological hazards will be
eliminated in further
heat processing.

Storage ( sugar, P Y N Y - Y Introduction of insects

salt , flour , due to unsuitable storage
cocoa) condition. Proper storage
condition is required.

Receiving eggs B N - - - N Quality assurance from

suppliers required.
Biological hazards will be
eliminated in further
heat processing.

Cracked or broken egg

P Y Y - - Y shell may cause
contamination. Proper
inspection is required.
Follow established
purchase specifications.

Storage of eggs B N - - - N Bacteria and spores may

grow if present initially.
The raw materials from
Suppliers need to be well
controlled based on
safety and quality
aspects. Biological
hazards will be
eliminated in further
heat processing.

Weighing of P N - - - N Foreign particles

ingredients contamination may
occur. SOP Should be
followed properly.


Ingredient/ Hazard & Control CCP Critical Monitoring Corrective
cause measure No. limit action
Process step

How Where Who frequency

Receiving Chemical Established 1 (C) Antibiotic Check Receiving Receiving Every 1. rejection of
Eggs hazard due to purchase residue = 0 the site personnel receiving non-complying
antibiotic specification CoA. ingredient.
residue on Cracked/ Receiving Receiving Every
Proper 2 (P) broken egg Inspecti site personnel receiving 2. write a
inspection of = 0. on of report to
Physical incoming incomin warehouse
hazard due to eggs. g eggs mngr.
cracked or
broken egg

Storage Physical Proper 3 (P) Rh Measur Storage Warehous everyday 1. disposition

( sugar, salt, hazard due to storage e Rh, room/ e of
flour, cocoa) insect attack. condition. Time < 1 check warehouse manager contaminated
month storage ingredients.
Biological 4 (B)
hazard due to SSOP = 2. correct the
microbial applied. cause to
contaminatio applica prevent
n. tion of recurrences.
3. maintain

4. write a
report to
HACCP plan has to be validated before implementation. The objective of validation is to
ensure that the hazards identified is correctly controlled. Validation is concerned with
the evidence that the elements of the HACCP plan will be scientifically and technically
effective. Validation ensures the information supported the HACCP is correct. Hence,
we carried out the validation process of all CCPs to provide strong evidence for further

The validation activities would include:

Thermal evaluation trials

Temperature distribution trials
Challenge test
Mathematical modeling
Documental review of HACCP plan

For instance, a validation process is carried out in baking process as one of our critical
control point. In this process, doughs are baked in the oven at 1800C about 30 mins to
achieve a minimum internal temperature of 77℃. The characteristics of concerned
bacterial pathogens in our products such as Salmonella and some heat resistant spores
of Bacillus cereuses will be investigated with the aspects of the microorganisms survival
condition, how to destroy these pathogens and the technique used to indentified these

Salmonellas are responsible for many outbreaks of foodborne illness every year. It can
be commonly found from poultry materials such as eggs. Inadequate baking may allow
the bacteria survive and grow.
The survival condition is listed:
The growth temperature is 5-47℃. Optimum: 35-43℃.
PH value 7-7.5
Water activity range >0.98
Heat sensitive and can be easily destroyed by high temperature

The pH of our brownie products is around 7.5, a bit desirable for Salmonella growth (7-
7.5). The water activity of our products is 0.05-0.15, which is much lower than 0.98 and
not a suitable survival condition for Salmonellas. Most importantly, baking process at
180℃ can destroy these heat sensitive bacteria.

The microbiological testing is done every 6 months to 12 months, in order to ensure our
HACCP plan is effective in eliminating Salmonellas.
The isolation an identification of Salmonellas can be done by the traditional five stages

1. Pre-enrichment in a non-selective medium increases the recovery of salmonella.

Incubate 16hr to 20 h at 35 to 37 ℃.

2. Enrichment stage: increase the amount of salmonella cells by using the selenite-
cystine broth and RV medium. Incubate 18-48 hrs at 42℃.

3. Streaking stage: Streak out enrichment culture onto Brilliant Green Modified ager
and XLD ager. Incubation at 35°C or 37°C for 20-24 hours and further 18 – 24 hours
if necessary. The pH is neutral or slightly alkaline. Therefore, Salmonella species
can produce hydrogen sulphide from the reduction of thiosulphate.

4. Biochemical tests on the isolation: Salmonella from selective media should be

confirmed by biochemical testing. Incubate at 35°C or 37°C for 18-24 h.

5. Serological identification is applied by agglutination with polyvalent O antisera.

In addition, ELISA and gene probes are modern techniques generally used to detect

Bacillus cereus
Bacillus cereus is Gram positive, aerobic sporing-formed organisms. Those spores are
often found in cereals (starch), the spores can even survive baking and generate
bacteria under appropriate condition and grow to release toxin.

The survival condition is listed:

The growth temperature is 8-55℃. Optimum: 28-35℃.
PH value 5-6
Water activity range around 0.95
Heat sensitive and can be easily destroyed by high temperature.

Although the pH of Bacillus cereus is not suitable to brownie, the water activity of
brownie is 0.05-0.15, which cannot provide a suitable survival condition for Bacillus

The microbiological testing is done monthly, in order to ensure our HACCP plan is
effective in eliminating Bacillus cereus. Since Bacillus cereuses could release toxin and
have an adverse effect on human health, it is important to analysis the isolation and
identification of Bacillus cereuses. In the outbreak of Bacillus cereuses poisoning, the
blood agar is generally used for Bacillus cereuses identification. This is achieved by
incubating for 24hours at 37℃. Moreover, in order to ensure the identification of blood
agar isolation, a more selective diagnostic agar is applied.
As soon as Bacillus cereuses are detected, QA manager needs to deal with the food
products, for instance, held the batch or probably dispose of the products completely.

Critical limit:

Minimum internal temperature of 77 0C within brownie Temperature in oven is controlled

at 1800C and belt speed of conveyor is adjusted to control baking time for about 30 min.

Monitoring :

In order to build a good system to monitor the entire process, it is important to consider
the base of Good Manufacturing Practice (GMP) and Quality Control (QC) aspects to
ensure food products safety and quality.

Thermostat is installed in the oven connected to the conveyer belt constantly

monitoring baking temperature of 180℃, which is checked each batch from
temperature chart by baking operator. Thermostat is calibrated daily with recording
in the log book.
Core temperature of random samples in every batch is examined by QC technician.
Speed of conveyor belt and temperature of oven can only be changed by QA
manager. Any amended action need to be record in the log book with date and time.
Random sample is tested with PH meter daily to ensure the pH of the brownie is
around 7.5. Random sample size is detected to ensure the thickness of the brownie
is suitable to standard size. Water activities of the sample is also checked.

Corrective action :

Corrective action is performed when monitoring indicated deviation from critical limit,
which means the monitoring indicates that the CCP is out of control.
The line manager will be informed if the internal temperature of random sample is not
reach minimum 77 ℃. Then the product will be well treated through quarantine area and
the unexpected products are usually discarded.
In terms of problems treatment, the factory engineers have the responsibility to give an
analysis and rectify the wrong situation by the following action:

Change the equipment directly .

Carry out an experimental trial to observe the condition problems and amend the
setup of the equipment.
In order to confirm the HACCP plan of red velvet swirl brownie production is working
effectively once it has been implemented, the verification procedures, methods and
relevant verification activities must be developed and carried out. For example, the
verification of prerequisite program, critical control point (CCP) and HACCP plan must
be done at least annually, as it is extremely important.
However, for the critical control points (CCPs) identified, the key verification activities as
below constructed need to be implemented to verify that the HACCP plan was working
Key verification activities will include :

1. Review of all CCP records and HACCP system:

 CCP monitoring records
 CCP calibration records
 CCP corrective action records
 CCP critical limits records

2. Review of deviation and product disposition (including customer complaints)

3. Confirm the CCPs are under control :

 Verification of sample collection, testing and analysis randomly
 Verification of training

The person who is suitable to carry out the verification activities is very important, they
must have a good understanding of HACCP system principle and know essential CCPs
and their characteristics, as well as they can check the line or sample analysis, even
though it is not necessary to require them to play the role of experts. Thus, they could
be the supervisors, technical staffs or managers. The verification activities will be done
at least annually. When there are some changes such as hazards, processing
occurring, the verification need to be done monthly, if the plant is running without
problem, minimum verification will be carried out by record review.

Review of all CCP records and HACCP system

A reviewer who should have a good understanding of HACCP system, e.g. supervisor
or manager will verify the CCP records at least annually to make sure whether the
CCPs are under control in accordance with plan and if the records are properly.
Specifically, the managers should check all the staffs whether or not to finish their own
records correctly at the time intervals based on plan and operating process properly in
accordance with critical limits plan. On the other hand, the reviewers will have to verify
all the records related to the CCP daily, such as monitoring records (temperature,
baking time, labeling, metal detection records), corrective action records, and calibration
records etc to confirm the records are prepared and implemented based on the plan,
through review of all CCP records. Furthermore, evaluate the monitoring records and
corrective action taken via using reasonable methods at least annually or monthly,
confirming the individual responsibility is reasonable identified and the relevant
documents are checked and signed properly in every shift.
Verifying the calibrations of processing equipments and monitory devices are performed
properly by record review. For example, through review of temperature or time
monitoring device calibration during the baking processing and corrective action
reports, supervisors will confirm critical limits for CCPs are met or not. They will also
need to check whether the control system calibration is specified and maintained as
plan frequently. If possible, in this case, it can be checked that whether or not the CCPs
are adequate and effective to control and identify the finding hazards.

Review of deviation and product disposition (including customer complaints)

The reviewers will verify the corrective actions are performed and recorded effectively
whenever there is deviation from critical limits occurring when monitoring is out of
critical limits by record review. The corrective actions should be properly prepared,
signed and dated; meanwhile, it should report the individual responsibility for each
corrective action. However, when any CCP is still out of control, even if the actions have
been taken as plan, the supervisors will need to evaluate if the CCP is still working well
and the CCP still necessary or another CCP needed so as to make the plan work
correctly, because probably some unclear instructions for the CCP confused the
HACCP study teams, and also too many CCPs identified may make it more difficult to
guarantee resources are focused effectively, which needs to be verified and updated.
Meanwhile, verify if critical limits, control measure, and latest document have been
followed. If there are some changes in new safety information, foodborne illness
outbreak, customer use or recurring deviation etc, the CCPs may need to be updated to
make sure the HACCP plan is working effectively.

Similarly, supervisor needs to verify the records of product disposition, and processors
have to review of consumer complaints to ensure the HACCP plan is working
correctively. They will frequently confirm and evaluate how the products were identified
and whether the product disposition is properly done as plan where necessary.
Regarding to the consumer complaints, the manager should verify carefully at a fixed
frequency. Through review of the trending of complaints data, it can give the information
that indicated where the problems occurred, which CCP is out of control. This will be
very useful to control any trends or problems during the processing in the aspects of
both updating the control measure successfully and giving confidence for the
effectiveness of CCP in the future.
Confirm the CCPs are under control

Monthly verifying if the random sampling plan is able to detect confidently any loss of
control at CCPs to confirm the CCPs are under control. Moreover, confirming the data
of testing, analysis from the relevant staffs is organized and clear to read, and also the
managers will evaluate whether the CCP is adequate and effective to control the
identified hazards in accordance with the plan. If not, for example, a forborne illness
occurs, it must has a reassessment, and also it is necessary to check the adequacy of
monitoring via additional sampling and testing as well as visual inspection of operation
frequently to confirm the CCPs are under control.
However, it is important to re-evaluate employee training frequently (at least annually)
so as to confirm the CCPs are under control effectively. Managers will have to confirm
the operators still have a good understanding of knowledge about the CCPs, the critical
limits, the monitoring records keeping. An updated training program can be set up by
verifying the staffs whether can take corrective actions in the case of a deviation and
observing the operator’s performing activities.
In a word, through the effectively review of all the CCP records, deviation and product
disposition, and verify the random sampling collection, testing and analysis, and
verification of training correctly, it can be confirmed that the CCPs will be under control,
and with the help of a verification schedule set up, the HACCP plan was working
correctly once it had been implemented.
Prerequisite Programmes
Good manufacturing practices (GMP) and standard operating procedures (SOP) are
constructed in this program to ensure the safety of our red velvet swirl brownies in the
Hazard Analysis and Critical Control Point (HACCP) system. The relevant aspects
including hygiene, training, pest and other foreign body control, cleaning, and facility will
be established, implemented and maintained.


Hand hygiene

As personnel hands are frequently contacting with food stuffs directly, therefore, hand
hygiene must be more noticed in order to ensure food safety; relevant rules are
constructed as below:

Completely and effectively hand washing

Always keep the effectively hand washing frequency to prevent the potential risk of
cross contamination.

The complete and effective ways for hand washing are recommended for all the staffs,
managers and visitors: hands with liquid soap or wetted must be rubbed for 20 seconds
and any person needs to last minimum 10 seconds for the washing under the clean
running water and keep dry.

Relevant additional personnel hygiene

 All staffs must not taste food including hand-to-mouth.

 All staffs must not have nail varnish and any perfume and keep short finger
nails .
 All staffs must not have rings, jewellery or watches to be
 All staffs must not reuse the wasted gloves.

Work clothing hygiene:

 All the work clothing must be standardized and sterilized once a month.
 All staffs must wear work clothing, gloves, hats and shoes each time before
getting in working area, and also need to clean the shoes in a disinfecting

Personnel health hygiene :

Any person (including staffs, managers, and even some visitors) who is ill must be
reported and noticed. Particularly, the staff with open injures including some boils and
infected wounds are not allowed to because this can be as a source for microbial
contamination to food surfaces


All staffs, especially the new employees should have an intensive training session on
the professional knowledge of HACCP to make sure the food safety, this will cover the
areas of personnel hygiene, cleaning plan, standard operating procedures and
foodstuffs formulation etc, and the training courses are conducted seasonally.

Pest and other foreign body control

All staffs should keep all the open equipments closed after production or equipment
washing in order to prevent the potential physical hazards such as pests and dusts.


A plan about when, who and what need to clarified during the cleaning. The production
staffs and cleaning staffs need to keep correct cleaning frequency after each
operational time daily and weekly. All the rooms including equipments and surfaces,
particularly the hands clean points, door, and electric switch buttons need to be cleaned
or sterilized completely by each component member of working groups at cleaning site.
Use non-toxic cleaning agents to wash food contacting machine every time.


EU “machinery directives” highlights that food-processing machinery should be

designed and constructed as to avoid any risk of contamination which can cause safety

 Transport equipment: The pump should be design as smooth and avoid blocking
by some food obstacles. The pipeline system should be easily disassembling and
cleaning regularly by CIP system. In addition, pipe hangers should be sterilized
as well to reduce the risk of contamination.
 Metal detection equipment: Metal detector used to reduce physical hazards
requires checking by each hour and calibrating in every 3 month to achieve high
sensitivity. The equipment should be designed to eliminate all loose metal items
to avoid the risk of machine blocking and human eating safety risk.
 CIP system: The design of the CIP systems aims to clean the machine and
ensure the hygiene processing environment.

Finished products
Ensure that products are packed and transferred to the storage room as soon as
possible to reduce the risk of microbial growth. The temperature in storage room is
monitored automatically on a computer that alerts the QA if the temperature changes
significantly. Before distribution, stuffs should check each product and make sure the
integrity of packaging boxes.