Good Hygiene Practices along the coffee chain

Establish Corrective Actions(Task 10 / Principle 5)

Module 4.10

Slide 2Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Objectives and contents

Objectives To enable trainees to establish effective

procedures for corrective actions when there are deviations from critical limits

Contents What is ‘process deviation’ and ‘loss of

control’? Scope of deviation procedures / corrective

action Deviation and corrective action records

Slide 3Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Corrective action

Where loss of control is A deviation from a critical limit

Corrective action...any action to be taken when the results of monitoring at the CCP indicate a loss of control

Slide 4Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Proactive nature of HACCP

In HACCP plans deviation procedures are pre-determined and documented actions to be implemented in case of a deviation Control of non-compliant product Addressing source of problem within the

process Trend of deviation from operating limits

adjustments to prevent loss of control

Slide 5Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Corrective actions

Depending on the process, several deviations may be possible at a CCP More than one corrective action may be

required for each CCP Individuals responsible for

monitoring must be trained to adequately perform corrective actions when necessary

Slide 6Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Product deviation –controlling non-compliant product

Process deviation is ‘failure to meet critical limit’ A deviation implies that a safety breach has occurred

Immediate action Activates a system that identifies, marks and isolates

all product affected over the deviation period Producer must maintain control of suspect batch

pending evaluation

Deferred action The evaluation establishes the status of the batch

regarding safety - to release, reprocess, or destroy

Slide 7Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Deviation procedures –controlling cause of deviation

Investigation to determine the cause of deviation

Determine if measures can be taken to prevent recurrence of the deviation

Possible re-evaluation of aspects of the HACCP plan or related hazard analysis

Verify that the corrective action was effective

Slide 8Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Form 10 - documenting deviation processes in the HACCP plan

Process step

CCP No.

Hazard description

Critical limits

Monitoring procedures

Deviation procedures

HACCP records

6.Boia sun- drying

CCP1a (B)

Long residence time in a partially dried condition can allow development of mould and production of OTA

5 days or less between Aw 0.95 and 0.80

Aw / m.c. measurement nightly from day 3

Sequester; complete drying in mechanical dryer; OTA testing

Aw / m.c. records; lab reports;

CCP1b (B)

Reintroduction of water after drying mostly accomplished can lead to growth of mould

No exposure to condensation at night; No exposure to rain

Continuous visual assessment of weather conditions; inspection of covering of coffee in the evening

Continue drying; measure Aw / m.c. at end of day; apply CCP1a specification

Rainfall records; drying yard records

Slide 9Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Deviation records

Accurate records of deviations are essential Demonstrate effective control of affected products Facilitate system improvements

Deviation records include Product affected

• Product / code; date produced / held / released; reason for holding; amount of product affected; details of evaluation; signature of staff taking or approving action

Corrective action• Cause of deviation; action taken; follow-up

Slide 10Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Deviation records

RECORD OF DEVIATION PROCEDURES AND CORRECTIVE ACTIONS

DOMAIN OF APPLICATION (Area or stage of production line involved) CODE:

DESCRIPTION OF THE DEVIATION Reporting Staff:Date:Signature:

Confirmation: Yes / NoDate:Signature:

IMMEDIATE ACTIONProduct

Process

Responsible staff:Date:Signature:

Verified by:Date:Signature:

DEFERRED ACTIONEvaluation of affected product

Responsible staff:Date:Signature:

Analysis of the cause of the deviation Responsible staff:Time/Date:

Decision regarding action Approving staff:Date:Signature:

Implementation of action Responsible staff:Time/Date:

Efficacy of corrective action Confirmation: Yes / NoDate:Signature:

Slide 11Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Dealing with process deviations

Deviation procedures cannot be generalized - they depend on products and production methods

However, identification and isolation of affected product for evaluation is the first step

Deviations may arise from mechanical faults, procedural oversights or, in some cases, external specification violation

Follow-up might include plant renewal, staff retraining, education of suppliers

Slide 12Module 4.10 – Establish Corrective Actions

(Task 10 / Principle 5)

Summary

Deviation and corrective action procedures

Documenting corrective actions in a HACCP plan

Deviation records

Next module: Establish verification procedures