So you operate a chocolate chip cookie plant. You have all of your prerequisite programs in place (sanitization, packaging, new equipment checklist, etc.), a strong HACCP plan and your plant functions safely, smoothly, and efficiently. The good news: Your chocolate chip cookies are so popular that you decide to add a new line of cookies!
The challenge: You have to determine if you need to create a new HACCP plan when you introduce a new product?
The short answer: Not necessarily.
It depends on whether the new product line is considered as a SIGNIFICANT CHANGE or NOT within your existing HACCP plan.
For example, if you’re adding an oatmeal cookie line that introduces no new allergens or hazards, you may not need to create a new HACCP plan.
You do have some work to do but it might not be a new HACCP plan. First investigate and ask and answer some key questions: Are you making the cookies with the same ingredients like flour and sugar and eggs. Will you be using the same equipment and controls as your original product? This may be a big change for your plant, but it may NOT be considered a SIGNIFICANT CHANGE in terms of HACCP.
See if the new product fits in an existing HACCP plan. If it does, you may be pleasantly surprised at how little you have to change. You will need to follow your Label Approval procedure for the new label, approve new ingredients, add any new equipment to your preventive maintenance program and to your sanitation program. But in this case you don’t have to write a new HACCP plan.
So, when do you need to write a new HACCP plan?
The short answer: When you’re making a SIGNIFICANT CHANGE.
If you’re going to start making chocolate chip and macadamia nuts cookies and none of your other cookies contain nuts, you’re adding a new high-risk ingredient which, would indeed, constitute a SIGNIFICANT CHANGE. You will need to analyse the risks that come with handling new allergens, and decide which new controls are required. Then you will have to decide if any are CCPs (or CPs). You might have to add CCPs to your Master Plan and implement the appropriate changes. Then train your people , keep it simple and make sure they understand their role.
Since the purpose of HACCP is to ensure adequate control for all big hazards, when you have a new significant hazard, such as a new allergen profile, you will need to draft a new HACCP plan.
The good news is, if you already have a HACCP plan for your original chocolate chip cookies, to draft a new plan should not be a daunting or overwhelming process.
Does your HACCP plan define Significant and Insignificant Changes?
Look at your HACCP plan and make sure it includes a broad description that covers a family of products and processes and clearly defines what would be considered SIGNIFICANT CHANGES. This will help you determine if and when you need to draft a new HACCP plan when introducing new products.
If you need help with HACCP or any other food safety questions, don’t sweat it. We’re here to help you Navigate your way through the everyday challenges of making safe food.
Image by Erika Varga
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