Food Safety Magazine - April/May 2018

facility’s food safety plan.

Note: Example 1 is provided for illustration purposes only based on the guidance published in Fish and Fishery Products Hazards and Controls Guidance. 14 Manufacturing facilities must perform Hazard Analysis and identify preventive controls as appropriate to the nature of the applicable control and its role in the facility’s food safety system.

Example 2: Frozen bakery products in which a cooking process is used to significantly minimize or prevent Salmonella spp. survival and is managed as an OPRP in a facility’s food safety plan.

Note: The above example is provided for illustration purposes only based on the International Association for Food Protection (IAFP) poster presentations by Kottapalli et al. 15 and Kottapalli and Schaffner. 16 Manufacturing facilities must perform Hazard Analysis and identify preventive controls as appropriate to the nature of the applicable control and its role in the facility’s food safety system.

Advantages, Disadvantages, and
Limitations of Tools

The main advantage of using decision trees and/or risk matrices is that they provide a straightforward, easily documented approach to determining the type of control measure needed to address an identified hazard during risk analysis. For larger companies with multiple facilities, these tools are a good way to standardize the Hazard Analysis approach across the company. Codex Alimentarius recommends training in the use of the decision tree, 17 and in the Seafood HACCP guidance, FDA recommends that users “not rely exclusively on the decision tree, because error may result.” 14 Each facility and food safety plan is different and requires expert review to ensure the decision tree results are, in fact, appropriate to the Hazard Analysis. Some examples of this limitation are described below.

Earlier decision trees developed prior
to the introduction of the preventive
control concept have an inherently lim-
ited flexibility to consider OPRPs. These
early trees have only “CCP” and “Not
a CCP” options and do not describe
what needs to happen for those control
measures deemed “Not a CCP.” While
the assumption is that the “Not a CCP”
measure will be maintained as a Good
Hygiene Practice (GHP) or PRP, this is
not explicitly stated within the decision
trees themselves. Use of the modified
decision trees in Figure 1 could be more
helpful to facilities that have preventive
controls to be managed as OPRPs. The
Codex Committee on Food Hygiene
is considering adding the concept of
“Control Measures at Places other than
CCPs” or “Enhanced GHPs,” but this
terminology has not yet been final-
ized. 18 There is a proposed decision tree
(Figure 2) that accompanies this revi-
sion.
While the risk matrix approach may
seem a good quantitative technique,
the Hazard Analysis becomes more
difficult when it gets to the point of
assigning number rankings to certain
hazards. Questions can arise on how
much of a dose is considered a high
dose, what is really the difference be-
tween a consumer who is ill and one
who goes to the hospital, and what is
the difference between something that
occurs occasionally, occurs often, or is
a common occurrence? Another option
could be to take a more conservative
approach to risk analysis, and instead of
assigning number rankings to severity
and likelihood, the decisions are made
as to whether the hazard is or isn’t se-
vere, and whether the hazard is or isn’t
likely to occur. In this case, severity and
likelihood rankings are listed simply as
Yes or No. Combinations of Yes and
No will determine whether the hazard
is one that needs a preventive control
and what type of preventive control it
should be (Table 1).
Depending on the situation at the
individual facility, there are additional
HACCP