Corrective action is any procedure applied to a critical operation where deviation has occurred.
One of the most well-known systematic approaches to food safety is the Hazard Analysis Critical Control Point (HACCP). This program helps control and prevent the risk of food hazards from causing any foodborne illness.
Breaches of standards may sometimes result from human error, equipment malfunction, and others. This is where the fifth principle of HACCP plan-making comes into play: establishing corrective actions. In making a corrective action plan, appropriate tasks are prepared to address operations that may have potential deviations.
When food safety systems break down, the consequences cascade beyond health impacts. Businesses face devastating financial losses, damaged reputations, and potential legal action. Yet many food companies still treat corrective action plans as mere paperwork. But this is a critical mistake.
Corrective action is an immediate and intended step taken to address non-compliance of allowable critical limits at any operation. This operation is performed within a reasonable time frame in an attempt to return the breached parameters to acceptable limits.
In the food industry, non-compliance and deviations in critical limits may mean that the risk of causing foodborne illnesses will significantly increase. Corrective action can be a simple step, such as recalibrating a piece of equipment to highly technical operations that involve recomputing for alternative working parameters.
In a food establishment, including other industries, corrective action must be established in anticipation of any potential non-compliance. This step does not mean that employees can relax with their food handling practices because appropriate corrective actions are in place.
The application of corrective action can cause an increase in material and labor costs. Sometimes, corrective action can land on a decision to dispose of non-compliant products to protect the consumers from damages.
A corrective action plan is an outline of steps needed to resolve errors or non-compliance and to keep them from happening again. In terms of the HACCP principles, a corrective action plan is created in preparation for any deviations from established critical limits. This plan is created to prevent hazardous foods from reaching potential customers and causing foodborne illnesses or customer complaints.
A corrective action plan is an essential part of your HACCP plan. It is your food business team's defense in case of uncommon deviations. As such, your team must be able to fulfill all steps to ensure an effective corrective action plan.
In any other industry, a corrective action plan employs having SMART goals. This acronym describes the desirable qualities of an effective corrective action plan.
In a HACCP plan, corrective actions are dependent on the identified critical control points and their corresponding critical limits. Conducting corrective action must always be monitored for corrective action reports.
This step produces review records that can serve as proof that the products are either safe, or a just cause was identified to dispose of them. In addition, particular metrics are established to identify whether a corrective action plan is successful in containing deviations.
To monitor the application of this operation, a HACCP corrective action plan template such as the one shown below from the Food and Drug Administration must always be prepared.
The main benefits of an effective corrective action plan which can significantly enhance operations within a food production or handling environment are:
HACCP corrective actions are established for every critical control point and its critical limits. A HACCP corrective action plan is made particularly for specific operations. They are designed to control potential deviations on a food safety task and, therefore, must be related to a critical control point operation.
Under this principle, the following are identified for a corrective action plan:
Members of your HACCP team who are well-versed with the HACCP plan, the process, and the nature of the product are the most ideal candidates to perform a corrective action procedure. Once corrective actions are applied, the expertise of the food safety manager must be sought to collect a corrective action decision for the products affected by the deviation.
Apart from the corrective actions applied in the fifth principle of the HACCP system, a different system called the Corrective and Preventive action or CAPA system exists. The CAPA process is used to address issues at any part of your food business management controls including:
The main objective of a CAPA process is to collect and analyze information and to predict and foresee food safety and quality management to establish actions that can prevent or control them from occurring. Remember that correction and preventive action procedures are two different operations. They are applied in different sections of the operating system but are equally important. Appropriate monitoring techniques and verification procedures must always be implemented together with these actions.
A CAPA process consists of three different operations:
Although these may seem all similar, these operations are very distinct. Here is a summary of their differences:
Based on the Quality Management System Regulation FDA 21 CFR 820 in the United States, it is a regulatory requirement for manufacturers to establish procedures for corrective and preventive actions. The CAPA is a system under the prerequisite program Good Manufacturing Practices and contributes to the effectiveness of a HACCP plan.
A corrective action plan is used to resolve systemic problems and any core issue. As such, it tries to target the root cause of potential problems. An important essence of corrective action steps is the foresight of potential industry issues. Sufficient and reliable details are major keys to making an effective corrective action plan.
If it is your first time making a corrective action program, it would be best to take things slowly and use this step-by-step instruction. Each step is important to make the plan effective.
A corrective action guide consists of these major steps:
To understand the appropriate action, sufficient information on the problem must be collected. Questions such as "What is the problem at hand?" and " How did the problem occur?" must be appropriately answered for proper assessment. At this point, the assigned employee can determine if the problem is a problem with quality standards or a safety issue.
Use gathering methods like employee interviews, regular inspections, and audits of existing records. Record every finding clearly, as thorough documentation is key throughout this process.
Use tools like checklists and digital reporting systems to ensure no potential hazard slips through the cracks. Documentation should capture every detail about what went wrong, including when it happened, who was involved, and any immediate impacts. The key to success in this step lies in capturing the full scope of the problem for better analysis and solution formulation.
Whether a product quality or a safety issue, the problem must be immediately dealt with. Especially in the food manufacturing company where products are sometimes produced by the second, immediate corrective action must be applied to prevent the problem from causing a bigger effect. Corrective actions must always be justifiable, measurable and can be applied in real-time to ensure their applicability at any point in food processing.
In contrast with correction, a corrective action involves determining the root cause of the deviation. Through this, the recurrence of the problem can be prevented. At this point, a comprehensive root cause analysis and data gathering from an objective investigation must be conducted.
As Abbie Llanes wrote for Safe Food Alliance:
Once a root cause is identified, make sure you find a solution that thoroughly addresses the issue. If you don’t, it is very possible the problem will happen again. CAPA investigators frequently identify non-conformity as a root cause, thus leading to develop an ineffective solution.
Root cause analysis can be enhanced by asking iterative "why" questions (i.e., the 5 Whys) or a Fishbone Diagram. This approach helps dig deeper into the underlying issues beyond the symptoms.
For example, if contamination occurred, ask why it happened, then ask why again based on the first answer, until reaching the root cause. Questions such as "What led to the problem from occurring?" may be asked to assess the situation. Remember that the lack of proper information can lead to an inefficient corrective action plan where the problems may still recur.
Decide on a disposition for the non-compliant food products. For manufacturing companies, non-compliant or defective products, although applied with corrective actions, can be insufficient for the company compliance standards. As such, dispositions such as whether to rework, reconstitute, or dispose of these must be made. In deciding what to do with non-compliant food products, the safety of consumers must always come first.
Implementing the plan requires proactive communication between departments. Inform all relevant staff of their roles. Use briefings, written instructions, and continuous training sessions to ensure everyone understands what's expected. Consider having regular check-ins to reinforce responsibilities and get feedback on progress.
To ensure that the corrective actions have been properly applied and that their purpose has been achieved, validation methods must be in place. These records serve as proof and reference if complaints on the affected products arise. Additionally, they can also be significant tools for traceability purposes.
Other information such as the responsible employee and the time needed to perform the corrective action must also be added. A corrective action plan is a versatile system. It can be applied for the prevention of quality problems and food safety issues. At times, it is also used to resolve management issues and employee programs.
Similar to other systems, adequate training materials and constant monitoring are important to achieve the maximum results of a corrective action plan. Additional training programs help teach employees how to create a corrective action plan and implement it in everyday and current operations.
In some cases in the industry, new operations would need their assessment and new hazards and critical control points can be identified. In such a case, a corrective action request can be filed for the creation of a new corrective action plan for this operation.
To better understand how to create this plan, here are some corrective action examples based on some of the most common critical control points in the food industry.
Perishable foods such as fresh meat and vegetables must always be kept in refrigerated conditions. Particular for meat, this raw material must be stored at 28°F to 32°F (-2°C to 0°C) to control the growth of microbial pathogens. How should a food employee address the situation if the refrigerator thermometer reads 59°F (15°C)?
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What is the problem? |
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Significant deviation from the critical limit 28°F to 32°F (-2°C to 0°C). |
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What should be done? (Corrective action) |
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Check if the refrigerator is malfunctioning. If yes, evaluate all wholesome food and transfer them to a functioning refrigerator and send the malfunctioning fridge to maintenance. Discard foods that have been spoiled because of the deviation. |
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Why should this action be done? (Justify corrective action) |
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Food spoilage is time-sensitive. If the raw materials are left at an unsafe temperature, the risk of causing foodborne illness increases. To prevent this from happening again, the refrigerator must be sent to maintenance for proper repairs. |
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Who will do it? |
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Food handler assigned with monitoring storage temperatures. |
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Where will it be done? |
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Storage area. |
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When will it be done? |
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Immediately upon detection. |
In this corrective action plan example, the immediate corrective action is to ensure that the raw meats are stored at proper storage temperatures to prevent spoilage. To prevent this from happening again, the refrigerator can be sent for recalibration or total maintenance to determine the root problem.
In this example, it is important to identify the critical limits that have been breached to ensure that there is a deviation. This deviation can help point out a few reasons for the cause of the deviation.
In food processing, reaching the recommended internal temperature is one of the most important criteria to ensure food safety. For foods such as chicken or poultry meat, the recommended internal temperature is very strict. Poultry meat must always be cooked to an internal temperature of 165°F (74°C). What would be the corrective action if the oven cannot process chicken dishes to this internal temperature?
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What is the problem? |
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The oven cannot process chicken dishes to 165°F (74°C) internal temperature. |
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What should be done? (Corrective action) |
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Stop processing. Separate affected batches. Adjust cooking parameters to achieve the target internal temperature. Send oven for recalibration and maintenance. |
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Why should this action be done? (Justify corrective action) |
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To continue restaurant service, increase the oven temperature to reach the target internal temperature. The problem may be because of an uncalibrated thermometer. Use a manual thermometer to verify cooking temperatures. |
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Who will do it? |
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Food handler assigned with cooking the poultry dishes. |
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Where will it be done? |
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Kitchen area. |
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When will it be done? |
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Immediately upon detection. |
Corrective actions do not always have to be a single operation. Sometimes, to address a problem, a set of additional actions must be applied. In this corrective action plan example, the production of chicken dishes cannot be stopped since service is still ongoing. If the problem is with the thermometer reading, applicable actions can involve food handlers switching to a manual food thermometer for accurate results. Soon after service, the oven can be sent for recalibration and maintenance work. This is part of the corrective action management.
Affected materials can either be reworked or disposed of depending on the disposition of the food safety manager.
In other situations, corrective action tasks can be any of the following:
Corrective action systems that depend on variable factors such as memory, recall, and memorization of written policies are considered weak. The actions must not depend on the employees but rather on the process itself, which is less variable than a human behaviour issue.
Some examples of operations that make a corrective action plan weak may include:
In the food industry, the HACCP program was established to significantly reduce the level of risk of foodborne illnesses because of food safety hazards. While this program is a systematic approach, it does not guarantee the total elimination of these risks.
At FoodDocs, we can help you take out the tedious process of identifying these corrective actions for all of your critical control points. Our built-in software HACCP plan builder can help you complete all 7 principles of HACCP in just an average of 1 hour by automatically generating a comprehensive HACCP plan based on your business operations.
This means you'll automatically get comprehensive and intuitively suggested corrective actions for any potential breach in your operations.
How? By using artificial intelligence and your answers to our basic questions, our system analyzes and generates a complete HACCP plan based on the nature of your food business. It can provide you with all of the most important HACCP documents that can help you attain HACCP food safety compliance.
Here are some of what our HACCP plan software offers:
What makes our system an even better fit even fitter for your food business is that we allow your food safety manager to customize the suggested corrective actions and other important documents. This feature will allow your team to add operations that are unique to your food business.
With our built-in digital HACCP plan builder, you can save up to 500x more time from your HACCP planning stage with no revisions. In addition, our system is powered by artificial intelligence and the guidance of food safety experts who have worked in the food industry for several years. Rest assured, our automatically generated HACCP plans for you can help you get compliant in no time.
Switching to a digital platform has never been this easy. Additionally, you can easily share your digital HACCP plan with food safety enforcement authorities for audit or inspection purposes. If they prefer the traditional way, you can always download your HACCP plan, print it, and submit it to your local food safety agency.
With our digital HACCP plan builder, you would never have to worry about whether your corrective action plan is appropriate for your operations or not. Get the guidance of food safety experts by joining us at FoodDocs. Start your HACCP plan-making journey with our free, 14-day trial.
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