PROCESS CONTROL
By Richard F. Stier and John G. Surak
Verification: Making
Sure Your Food Safety
Management System
Is Working
Principle 6, Verification, as defined in the harmonized Hazard Analysis and Critical
Control Points (HACCP) principles from
Codex Alimentarius1 and the National
Advisory Committee for Microbiological
Criteria for Foods (NACMCF), 2, 3 may be the most complicated
HACCP principle. From audits that we have conducted, this is the
one principle that many companies do not quite seem to grasp. Significant gaps in food safety management systems (FSMS) are often
found when one examines how different processors define verification activities even among companies with “certified” HACCP plans.
The National Food Processors Association (now now Grocery Manufacturers
Association) felt that the concepts of verification and validation were complex
enough that they developed a two-day workshop with an accompanying text that
focused on these topics. “HACCP: Verification and Validation” was taught as an
advanced HACCP workshop for persons who had preferably completed the three-day program that focuses on basic concepts and implementation.
The concept of verification is a late
addition to HACCP. The original principles did not include verification activities (Table 1). Verification as a principle
first appeared in the seven principles
published in 1989 by the NACMCF.
1. The identification and
assessment of food hazards
2. Documentation of critical control
points (CCPs) to control
identified hazards
3. Establishment of a system to
monitor CCPs
Table 1: Original HACCP Principles4
The Role of Verification
In the past 20 years, verification activities have been expanded, definitions
have been modified and expectations
have increased, even though principle 6
reads “Establish verification procedures.” In
the original concept of verification, validation is classified as a subcomponent,
making things difficult since, in other
areas of the quality and food safety field,
experts define validation and verification
as separate activities.
The basic role of verification is to ensure that the FSMS or HACCP plan is
functioning as designed and is effective.
Gombas and Stevenson5 state that “
Verification is to the HACCP plan what monitoring is to the critical control point (CCP).”
Thus, CCPs look at individual points in
the system and verification looks at the
entire food safety system, including the
HACCP plan, prerequisite programs
(PRPs) and other system components.
PRPs are defined as the foundation
for HACCP in the harmonized
Codex Food Hygiene document, the
NACMCF document and ISO 22000.6
PRPs can be compared to the old Sunday school parable that talks of the wise
man who built his house upon the rock
and the foolish man who built his house
upon the sand. The “house”—in this
case, the food safety program—with the
strong foundation is more likely to do
its job, protecting public health. Additionally, there should be a program to
verify that the PRPs are effective.
In 2008, the Codex Alimentarius
Commission adopted a new position
with regard to validation and verifica-
tion. 7 Codex recognized that validation
and verification were separate activities
in developing food safety control meas-
ures. Codex now uses the following defi-
nitions for validation, monitoring and
verification:
• Validation is “obtaining evidence
that a control measure or combina-
tion of control measures, if properly
implemented, is capable of control-
ling the hazard to a specified out-
come.”
