Food Control 12 (2001) 209±215

www.elsevier.com/locate/foodcont

How to make HACCP really work in practice

Sara Mortimore *
Pillsbury Europe, Harman House, 1 George Street, Uxbridge, Middlesex UB8 1QQ, UK
Received 11 September 2000; received in revised form 9 January 2001; accepted 9 January 2001

Abstract
A HACCP system that really works in practice will depend on the competency of the people who both developed it and who
operate it, and the prerequisite programmes, which support it. If it is to be truly successful then there must be an overriding internal
belief in the HACCP approach and what it can do for the business once properly implemented. There are fundamental issues
concerning the Training and Education which need to be considered, such as the variable quality of education and training available
on a global basis, impinge on the ability of HACCP teams to conduct a Hazard Analysis. Compounded with this is the general weak
understanding of the HACCP and prerequisite programme relationship and of the implementation and maintenance phases . . . on
how to make it really happen. These elements are considered against four key stages to the application of HACCP principles. Ó 2001
Elsevier Science Ltd. All rights reserved.

Keywords: Training; Prerequisites; Implementation

1. Introduction Stage 3 is the implementation of the HACCP study

output.
The HACCP technique itself is a straightforward and Stage 4 is the ongoing maintenance of the HACCP
logical system of control based on the prevention of system.
problems ± a common sense approach to food safety Each of these four stages will brie¯y be considered in the
management. In reality, the use of the HACCP ap- context of making HACCP really work in practice.
proach may well o€er a practical and major contribu-
tion to the way forward in food safety management, but
only if the people charged with its implementation have
2. Stage 1 ± preparation and planning
the proper knowledge and expertise to apply it e€ec-
tively.
The key to it all is the ®rst stage (Fig. 1) ± proper
This paper is aimed at examining what we have
preparation and planning prior to the application of the
learned over the last 40 years with regard to making it
HACCP principles (Codex, 1997) through the HACCP
work in practice ± particularly in more recent times as
study. Preparation can be more than putting the per-
the use of HACCP has increased. It will also take a
son(s) charged with implementing HACCP on to a 2-
broad look at the practicalities of making HACCP work
day training course which is what will typically occur in
to best e€ect.
many organisations both large and small.
With these thoughts in mind let us now look at what
A few words on training: a trained HACCP team is
is required to make HACCP work within a food busi-
essential, yet we should question the quality and e€ec-
ness. In broad terms there are four stages to the appli-
tiveness of the training which is generally available.
cation of HACCP (Mortimore & Wallace, 1998):
Training is often provided by people who are not
Stage 1 is e€ective preparation and planning.
HACCP practitioners ± who are, instead, lecturers; ac-
Stage 2 is the application of the 7 HACCP principles.
ademics; regulators or former hygiene trainers who have
jumped onto the HACCP ``bandwagon'' (Mortimore &
Smith, 1998). There are trainers who have both real
practical knowledge and who have been properly trained
*
Tel.: +44-1895-201193; fax: +44-1895-202509. in delivery of training (not lecturing or presentation
E-mail address: smortimore@pillsbury.co.uk (S. Mortimore). techniques) ± but they are probably in a minority.

0956-7135/01/$ - see front matter Ó 2001 Elsevier Science Ltd. All rights reserved.
PII: S 0 9 5 6 - 7 1 3 5 ( 0 1 ) 0 0 0 1 7 - 2
210 S. Mortimore / Food Control 12 (2001) 209±215
One of the ®rst preparation activities is to gain an
overall understanding of what is involved in using
HACCP. In order to do this properly it is essential to
gain commitment at senior level and ensure proper al-
location of resources. An introductory HACCP training
course can provide such information as needed at this
stage and only after this should the HACCP team be
con®rmed. Selection of team members should be based
on knowledge of raw materials, products, processes and
hazards. In a small company the likelihood of having
someone who already has the ability to conduct a
Hazard Analysis may be low. This is a skill that could be
sourced externally and it is important that the company
acknowledges how vitally important it is to have access
to this if the HACCP study is to be meaningful.
Once selected, this team must then be prepared with
more detailed training in the principles of HACCP and
with additional training and understanding of the spe-
cial skills and topics which underlie the application of
these principles. For example, additional skills may in-
clude:
· Project planning and management
· Hazard analysis and risk assessment
· Critical limit validation techniques
· Process capability assessment
· Data administration and trend analysis
· Problem solving skills
· Auditing
· Training skills
Having gained commitment from senior management
and understood the desired outcome of adopting the
HACCP approach, the next task is to begin planning to
get there. This may take longer than simply launching
into a HACCP study, but to do this can o€er a real
bene®t to making the system work in practice.
HACCP is not a stand-alone system ± it is supported
by other programmes that are, increasingly, becoming
known as prerequisites (NACMCF, 1997). Early on, the
Fig. 1. Stage 1 ± preparation and planning.
team will need to determine what elements are already in
place and what is required in addition. Essentially, this is
a baseline audit and gap analysis, conducted in order to
determine those prerequisite operating standards that
are needed to control food safety in the business under
consideration. The di€erence between what is available
and what is not is the gap, which must be closed. Suc-
cessful food safety management will depend upon clos-
ing that gap. This work can be done alongside the
HACCP studies and can often be an early visible bene®t
of using HACCP.
When identifying the de®ciencies it is important to be
clear about what forms part of the HACCP study and
what is, or should be, in place as a foundation or sup-
port to HACCP implementation otherwise it can be
confusing for those who are not on the actual HACCP
team. HACCP is a tool for product safety management
and, in practice, links with many other management
systems (Fig. 2). It can be helpful to communicate this
relationship to other employees early on in the pro-
gramme.
It is unlikely, in a large, or even a small organisation,
that a HACCP system could be e€ectively implemented
in the absence of some of these other management sys-
tems, for example hygiene.
This phase of information gathering, and under-
standing of the relationship with other systems, is likely
to lead to a more structured and systematic approach. It
will also aid understanding of what HACCP is really
designed to do ± identify the critical control points
whilst providing a clear understanding of where addi-
tional control points can be e€ectively set up. This
simple relationship between CCPs and CPs must be
understood if HACCP is to be used to best e€ect.
In planning the HACCP project the HACCP team
leader will need to ensure that the team has a complete
understanding of the project vision and knows clearly
where they are starting from and what the end result will
look like (Fig. 3). This is most easily accomplished if the
team is appointed early and participates in the baseline
audit and gap analysis so that they fully appreciate the
Fig. 2. Food safety within a quality management programme.
 S. Mortimore / Food Control 12 (2001) 209±215
Fig. 3. HACCP project vision.
current capabilities and the size of the task. It can also
be helpful to honestly acknowledge what the initial
drivers behind the initiative are ± for example, customer
demand or legal compliance as opposed to being a self-
driven quality improvement project. This can also be a
very motivating period for the organisation if the project
is well communicated. ``Too little time to complete the
task'' is often cited as one of the reasons for failure.
Often in these situations a manager is told to put in a
HACCP system and is then left to get on with it. Un-
derstanding properly what additional bene®ts the or-
ganisation can gain, such as clarity of CCP location,
prerequisite improvements and a more motivated and
skilled workforce can sometimes help to ensure that
realistic and less pressured timescales are set. Also that
appropriate skills and resources are made available at
the start and during the project.
Another reason for failure is that the system becomes
over complicated. A planning session at the start that
considers the structure of the HACCP system can pre-
vent this from happening (Fig. 4). For example, will it be
a linear system where the HACCP principles are applied
straight through from raw materials to each individual
end product, or a modular system where the process is
split down into distinct parts covering all product op-
Fig. 4. HACCP system structure.
211
tions? The former is more common in simple operations
such as vegetable canning whilst the latter works well
both in larger, more complex, facilities like pizza man-
ufacturing sites and in catering or foodservice opera-
tions.
Once the structure of the HACCP system has been
agreed, the HACCP team leader can more properly es-
timate the resources and time required to complete the
task. This will help to ensure that the programme stays
on track and that problems are discussed as they are
identi®ed.
The team should, now, also be able to provide the rest
of the organisation with a picture of what the ®nal
system will look like. This will include an indication of
the documentation format, how it will link with other
systems such as sanitation programmes or ISO9000, and
an indication of the people who will be involved as the
project gets underway.
When the project plan has been completed and au-
thorised, the HACCP team can move on to Stage 2 with
the knowledge that the required foundations for an ef-
fective HACCP system have been identi®ed and will be
built into the overall food safety system.
3. Stage 2 ± application of HACCP principles
This is where the HACCP study work is done (Fig. 5).
Without getting into too much detail, in applying HA-
CCP Principle 1, the team will typically start with de-
scribing the product. This involves an evaluation of
what is making it safe by considering intrinsic factors
such as pH and Aw , as well as extrinsic factors such as
thermal processing, packaging and storage temperature.
Fig. 5. Stage 2 ± HACCP studies and HACCP plan development.
212 S. Mortimore / Food Control 12 (2001) 209±215
Next, or alongside, there will be documentation of the
Process Flow that should then be established as correct
during all stages of the operation. Potential hazards can
be missed through working practices, or variations upon
them, such as holding times and temperatures not being
properly understood. In order to do this it is best to take
the ¯ow diagram into the process area and observe each
step. It is astonishing how often both this and the
product understanding phase is not done prior to
moving on to the Hazard Analysis.
The stage of the Hazard Analysis can begin once the
Process Flow in con®rmed. In doing so the team should
be clear on what types of hazards are likely to occur.
The Hazard Analysis is a very important element of the
HACCP process and must be based on sound science.
The team should consider the identi®ed hazard in terms
of the type, point of entry and growth and/or survival
potential of any microbiological hazards.
It should be remembered that a ``hazard'' is ``a bio-
logical, chemical or physical agent in, or condition of,
food with the potential to cause an adverse health e€ect''
(Codex, 1997). Hazard Analysis, therefore, requires that
both the likelihood of occurrence and severity of that
hazard are considered, in e€ect an assessment of risk
(Fig. 6).
A successful HACCP team must have a clear under-
standing of the signi®cance of identi®ed hazards and
which therefore require speci®c control measures as
opposed to being managed through prerequisite pro-
grammes. Validation of the Hazard Analysis is an im-
portant element of Principle 1, probably the key
principle in the whole HACCP system and the one
which many ®nd dicult to apply (Mayes, 1999). The
measures used to control the identi®ed hazards must
also be validated as being e€ective. This is another area
that can cause diculties for inexperienced HACCP
practitioners or those with limited technical back-
ground. There is much information available, formally
published and through the internet, but it is wise to get
advice at this stage or the study will either end up in-
Fig. 6. Hazard Analysis.
cluding many issues which are not food safety hazards
including some which are not relevant for the ingredi-
ents or process under consideration. There have been
many examples of this including some in published ac-
ademic papers so this is an area that needs further
practical understanding as, conceptually, it is actually
straightforward.
Following the Hazard Analysis the team will move on
to Principle 2 and identify the critical control points
(CCPs). Again, at this time knowledgeable and experi-
enced people are an essential resource for the team.
Identifying where the CCPs should be a question of
separating CPs from CCPs (Fig. 7). It can be a mistake
to ``choose to manage'' some prerequisites as CCPs to
``be on the safe side''. This can undermine the system
when operatives see that control measures at these ad-
ditionally selected ``CCPs'' are not always adhered to. A
common example of this is handwashing in a high care
area ± it is dicult to enforce to the level at which a CCP
should be operating and is best managed through a
prerequisite hygiene programme. Principle 3 then fol-
lows which is to set valid critical limits for safe man-
agement of the CCPs. This often requires some
experimental activity and the use of reference data.
Again, it is an area that can be problematic for inex-
perienced practitioners who sometimes resort to the use
of process control parameters as critical limits, failing to
see that operating on the limit of acceptable safety does
not make sense.
Principle 4 requires that monitoring procedures are
established and it is important to ensure that the fre-
quency set will detect loss of control in a timely manner.
Principle 5 is to establish Corrective Actions that are to
be taken when a deviation occurs. The procedures
identi®ed must both correct the non-conformity and
deal with any product produced when the process was
out of control. In Principle 6 the team will ®nd it helpful
to document how they plan to verify that the HACCP
plan is working. Typically veri®cation activities will in-
clude periodic testing of samples, auditing the HACCP
plan, and evaluation of consumer complaints in addition
to regular review of CCP monitoring records. The ®nal
Fig. 7. Control point di€erentiation.
 S. Mortimore / Food Control 12 (2001) 209±215
Principle 7 requires that records are kept ± this will
obviously include not only the HACCP plan itself and
CCP monitoring records, but also training records of
CCP monitors, CCP record reviewers, veri®cation ac-
tivities and records of any amendments to the system
along with the justi®cation.
Principles 4±7 are often easier for the team to estab-
lish as more of their practical knowledge of the business
can be utilised and it is, perhaps, easier to understand
and apply the requirements of these principles. How-
ever, if the monitoring systems are not relevant and the
corrective actions are not properly followed at the im-
plementation stage, then this can be one of the reasons
why the HACCP system may fail (Mitchell, 1998).
Getting it right during the plan preparation is important
for later gaining credibility with the workforce.
After completing the HACCP study the team should
achieve a fully focused documented system, usually
known as the HACCP plan, or in a modular system a
comprehensive set of smaller HACCP plans, which is
ready for implementation and ongoing maintenance. It
is at this point, in some larger companies, that the
HACCP study team may hand over to an Implementa-
tion Team that includes representatives from the Human
Resources department.
The requirements of the HACCP principles can also
be used for structured management of the prerequisite
programmes and some companies are doing this. The
HACCP team may want to consider this option during
the preparation of the HACCP plan or they may ®nd it
easier to address this separately.
4. Stage 3 ± implementation
Unless the HACCP plan is properly implemented its
real bene®ts will not be realised. This is such a vital stage
and yet the relief at having completed the HACCP study
phase can sometimes mean that organisations see only
the documentation as the end point and not the ongoing
management and control of food safety. To make HA-
CCP work in practice, however, it does need to get into
the workplace and become part of the company's oper-
ating practices. Prior to implementing the HACCP plan
it can be useful to have it critically reviewed by a third
party. This applies to both large and small companies.
Inevitably, the implementation of HACCP will have
to take place within the existing constraints of the or-
ganisation with regard to time and resources. This
usually results in a phased implementation, particularly
in the case of a modular approach when the imple-
mentation process can be broken down into a number of
key tasks for better management and understanding
(Fig. 8). Control of budget can be maintained by not
reinventing vast amounts of paperwork and record
keeping systems but by concentrating on how the
213
Fig. 8. Stage 3 ± implementing the HACCP plan.
HACCP plan can be brought together within existing
systems using current monitoring sheets, data charts and
electronic systems if available.
A structured approach to implementation might also
include the construction of a table (Khandke & Mayes,
1998) where each CCP, and associated hazard, is listed
against speci®c implementation requirements such as
how often the monitoring is undertaken and where the
data are recorded.
Given the potential for changes in working practice, all
personnel throughout the organisation will bene®t from
having a basic understanding of the HACCP concept and
how it a€ects their particular working environment.
Compliance with essential prerequisite programmes, such
as adherence to good hygiene practices will mean that it is
necessary for personnel to understand how their com-
mitment to such programmes links through to both
HACCP and overall food safety management. At this
time, the e€ectiveness of operator level training in food
handling and hygiene should be reconsidered.
Training is essential but it does not have to be ex-
pensive as some of the HACCP study team members,
after appropriate trainer training, will be able to train
other personnel and conduct brie®ng sessions. If the
programme is to work to best e€ect it is important that
they do receive the proper training to enable them to do
this. Often HACCP team members are simply told to go
forth and ``train'' without any concept of the various
learning styles and barriers to learning that they may,
unknowingly, encounter.
To make HACCP work in practice, speci®c training
will be required for CCP monitors, their deputies, their
supervisors and managerial sta€. They will need to un-
derstand not only what they are expected to do but also
why they are doing it and how it ®ts in with the rest of
the system. They will need to know how and when to
monitor CCPs and to take corrective actions and the
organisation needs to know that they are capable of
actually doing so. This type of training is unlikely to be
214 S. Mortimore / Food Control 12 (2001) 209±215
gained through a classroom approach alone and often
requires experiential learning. Additionally the supervi-
sory and management sta€ must have some idea of the
learning theory so that they can e€ectively continue with
reinforcement following the completion of formal
training both in hygiene and CCP monitoring. Overall,
the training process for all personnel should be regarded
as a motivating experience and should not be conducted
in a negative environment. Positive involvement will be
gained by the sharing of knowledge and by creating an
awareness of a particular individual's role within the
food safety management programme as a whole. A
teamworking culture is to be encouraged.
The successful implementation of a properly planned
and conducted HACCP study requires only a few spe-
ci®c actions:
· Training and education
· Monitoring of CCPs
· Taking action when required
· Recording results
This is when HACCP goes ``live'' and becomes the re-
sponsibility of the personnel within the day-to-day op-
eration and not the responsibility of a special team.
With proper preparation and planning, such an imple-
mentation should not be dicult.
5. Stage 4 ± HACCP maintenance
Last, but not least, the maintenance of the HACCP
system must be considered if the implementation is to
remain a success. This is an area, which if overlooked,
can be a likely reason for HACCP appearing to fail.
Ongoing application of Principles 6 and 7 is a strong
element of these activities (Fig. 9).
It is unlikely that the products produced, the process,
the environment, likely hazards or the people in the
facility will remain unchanged over time. It is, therefore,
Fig. 9. Stage 4 ± maintaining the HACCP system.
important to ensure that changes and their e€ect on
food safety management are properly evaluated.
There are a number of activities which ought to be
considered at this point which include:
· Record keeping
· Ongoing audit ± veri®cation
· Data analysis ± veri®cation
· Keeping abreast of emerging hazards
· Updating and amending the HACCP plan
· Ongoing training requirements
What is important is that both the HACCP plan and the
supporting prerequisite programmes are properly veri-
®ed as continuing to be e€ective through regular audit
activities. This is primarily the responsibility of the
company itself, though in many countries the role of the
regulatory agencies in assessing the HACCP system can
provide useful additional veri®cation (WHO, 1998).
6. Conclusion
In conclusion, a HACCP system that really works in
practice will depend on the competency of the people
who both developed it and who operate it, and the
prerequisite programmes, which support it. If it is to be
truly successful then there must be an overriding internal
belief in the HACCP approach and what it can do for
the business once properly implemented. The critical
success factors will thus be:
· Proper preparation and planning
· Trained and educated people
· Belief in the approach by all personnel
· A shared commitment to food safety
It will be successful only if it has been put together by
people with sucient technical ability, implemented
with enthusiasm and driven by forces within the or-
ganisation.
It is noticeable that some organisations grasp the
HACCP philosophy and emerge with evangelical zeal in
their mission to use the HACCP approach, not only to
control food safety, but also in some cases for all
manner of business improvement activities. But there
are other organisations who plod through the seemingly
endless round of tedious and, often, acrimonious
HACCP meetings to emerge with a weighty document ±
The HACCP plan ± but with no real appetite to
implement it nor any real insight or understanding of
what the concept really means.
The di€erences between the two organisations de-
scribed are likely to include the di€ering skill base of the
people who are involved in the HACCP implementation
programme and, more often than this, the culture within
which they work. This means not just their technical
expertise, attitude and approach to food safety man-
agement but the overall business culture including their
ethical approach, positive attitude to empowerment,
 S. Mortimore / Food Control 12 (2001) 209±215
training and management style. The dilemma is that
HACCP can be used to help stimulate that supportive
quality culture yet, perhaps without the culture change it
is more dicult to make it really work in practice. The
key to a successful food safety management programme
lies in resolving this problem.
References
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Mayes, T. (1999). How can the principles of validation and certi®ca-
tion be applied to hazard analysis?. Food Control, 10, 277±280.
Mitchell, R. T. (1998). Why HACCP fails. Food Control, 9, 101.
Mortimore, S. E., & Smith, R. A. (1998). Standardised HACCP
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Mortimore, S., & Wallace, C. (1998). HACCP: a practical approach
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