Engineering Expert Witness Blog

      The FDA’s Hazard Analysis Critical Control Point (HACCP) seeks to accomplish the same with regard to food production.  As discussed last week with regard to HACCP Principle 1, those involved in designing food processing equipment must proactively analyze designs to identify potential food safety hazards.  Now let’s see how common sense is once again employed through Principle 2, guiding design engineers to take control of situations where hazards have been identified through Principle 1.

     HACCP Principle 2:  Identify critical control points.  A critical control point (CCP) is a step in the design process at which a control can be most effectively introduced to prevent or eliminate hazards.  In this context a “control” would be a design revision to eliminate hazards identified during the Principle 1 stage.  We will once again use the two examples introduced in last week’s blog discussion on Principle 1.

     In our first example, hazard analysis revealed that food can accumulate in a food processing machine in areas where cleaning is difficult or impossible.  This accumulation would eventually rot and fall into uncontaminated food passing through production lines.  Design engineers would work to address this contamination hazard by identifying a CCP within the design process, that is, the best place where a preventative measure can be added to the machine setup to facilitate removal of the accumulation.  At that CCP, measures can be taken to change the machine’s design.  Perhaps all that is needed to correct the situation is to include easy to remove access covers.

     In our second example hazard analysis revealed that the metal tooling as designed for our food production machine was too fragile and would not withstand the repeated forces imposed on it by the mass production process.  This design flaw presents a strong possibility that metal parts will break off and enter food on the line.  To correct this situation, design engineers must once again identify the juncture within the design process at which a CCP is identified.  There, a preventative measure can most effectively be introduced, enabling more robust metal to be used in the tooling.

     The previous two examples illustrate CCPs being utilized within the design process.  CCPs can also be introduced outside the design process, as when they are identified during the course of training procedures involving the operation, cleaning, and general maintenance of equipment and production lines.  And an excellent way of implementing this approach is to have design engineers collaborate with operating and maintenance staff.  Working together, they are best able to identify key elements to be addressed and make note of them within written procedures.

     Now that we have identified some examples of CCPs within the design process, we can move on to HACCP Principle 3 and how it guides design engineers to establish critical limits for each CCP.
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