Definition and Purpose
A monitoring system for each CCP is necessary to demonstrate it is operating within a defined critical limit, which significantly reduces the risk of unsafe product reaching the consumer. Codex describes monitoring as “the act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control”1. Monitoring operational limits creates an opportunity to act before a deviation occurs at a critical limit. Recorded observations and measurements also provide documented evidence to support verification activities and legal compliance.
Measurements and Observations
Monitoring must provide rapid, accurate and repeatable results that relate back to critical and operational (target) limits. There are generally two ways to monitor a critical control point: measurement and observation. Measurements usually include temperature, time, pH, Aw, etc. Whereas observations may focus on colour change in food, visually checking operation of a metal detector, inspecting the integrity of a sieve, etc.
Methods of Monitoring
Monitoring procedures are dependent on three factors: critical limits, capability of the chosen method or device to detect a deviation and process throughput. Observations and measurements can be performed on-line or off-line. On-line systems may take measurements continuously or at intervals during the process1,2. Continuously monitoring systems may also require additional manual checks to verify accuracy. Off-line systems take samples for rapid testing elsewhere, using instruments such as calibrated pH or Aw meters1,2. Observational systems also check if a critical limit can be detected and control mechanisms in place for a CCP are working as expected.
Equipment used to monitor operational and critical limits must be maintained and calibrated to provide reliable results1,2.
The frequency of discontinuous monitoring should be enough to provide acceptable assurance that a CCP is under control1. It can be time based (e.g. hourly) or production based (e.g. each batch). The rate of frequency must permit enough time to regain control over the process and deal with affected product. This is determined by sound historical knowledge of the product and process. Factors to consider include:
- level of tolerance between operating limit and critical limit1
- amount of product at risk if a deviation should occur at a CCP1
- variations in process and product1,2
- automated or manual processes2
- history of previous checks2
A corrective action may also temporarily increase frequency of monitoring.
Consideration should be given in assigning responsibility for monitoring activities1. CCP monitoring is often associated with production personnel because they are familiar with the process. Production supervisors or managers and quality assurance personnel will usually verify the monitoring activity. Personnel assigned to monitoring CCP’s must be trained and demonstrate competency in relevant procedures. Records of training and competency assessment should be maintained2.
Documentation and Records
The monitoring system must be documented and outline the following:
- specify what control parameter(s) will be monitored
- state the frequency of measurements and/or observations
- specify who is responsible for performing and overseeing the monitoring activity
- define or refer to a procedure in how to conduct the monitoring activity, including details of equipment to be used2
- detail where the results of monitoring are recorded with specific reference to documents and/or online systems2
- List any supporting, procedures, work instructions and specifications2.
Accurate monitoring records show the process was under control or appropriate corrective action was taken. A record must state the date, time and result of the monitoring activity. All monitoring records must be signed by the person conducting the monitoring activity and countersigned by the person responsible for checking records, such as a supervisor or manager.
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Food Standards Agency (2020). Principle 5: Establish a Corrective Action Plan. [online]. Available at: https://myhaccp.food.gov.uk/help/guidance/principle-5-establish-a-corrective-action-plan%20Accessed%20on%2001/11/20#help-31 Accessed on 01/1120
Food and Agriculture Organisation of the United Nations (unknown). Section 3 – THE HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM [online]. Available at: http://www.fao.org/3/w8088e/w8088e05.htm#module%2010%20%20%20establish%20corrective%20actions%20%20%20task%2010principle%205 Accessed on 01/1120