Corrective action plan in food safety

• Corrective action is any procedure applied to a critical operation where deviation has occurred.
• In a HACCP plan, corrective actions are based on the established critical control points and critical limits.
• A corrective action plan is a set of instructions on how to identify and properly address the root cause of a deviation.

In the food industry, 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. Despite this, the HACCP system is not a zero-risk program. Breaches of standards may happen at times as a result of human error, equipment malfunction, and others. This is where the fifth principle of HACCP plan-making comes into play - establishing corrective action. In making a corrective action plan, appropriate tasks are prepared to address operations that may have potential deviations.

Food operations will never go without the risk of foodborne illnesses. As a food business owner or a food safety manager, it is part of your duties and responsibilities to protect your consumers from potential food safety threats. A part of this responsibility is to establish corrective actions to foreseeable problems related to the critical control points of your operations. 

To properly perform these tasks, you need to learn the basics of a corrective action plan and how to make one.

What is corrective action?

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.

What is corrective action in the workplace?

Particularly in a food industry workplace, a corrective action process can be any operation performed to control the critical limit back to an acceptable level. An example of a food processing establishment would be cooking meat to the correct internal temperature. Critical limits for the internal cooking temperature of meat such as for chicken are set to ensure that the dominant microbiological pathogen is properly removed.

For chicken, the target temperature is 165°F (74°C). Temperatures significantly below this target temperature, such as 160°F (71°C), could enable target pathogens to survive. As such, corrective actions must be applied. The appropriate corrective action process to this hazard is to reprocess the product for a shorter time using gentle heating. If this corrective action is not applicable, products can be disposed of based on the decision from the corrective action plan.

For common corrective actions outside the context of the HACCP system, simple operations such as mandating employees to file a sick leave when not feeling well can be an important corrective action. Additionally, other operations such as providing better protection gear for employees are effective corrective actions.

What is a HACCP corrective action plan?

A corrective action plan is an outline of steps needed to resolve errors or non-compliance. 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.

• Specific
• Measurable
• Attainable
• Relevant
• Time-based

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.

At what point in a HACCP plan should corrective actions be identified?

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:

• Corrective action step
• Assigned employee to perform corrective action
• Appropriate corrective action documentation

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.

Corrective action and Preventive action (CAPA)

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:

• Production and process controls
• Service reports
• Equipment and facility
• Materials
• Design
• Records, documents, and change controls

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, (1) correction, (2) corrective action, and (3) preventive action procedures. 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. 

How to write a corrective action 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:

1. Identify all deviations from critical limits. 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.
2. Appropriate corrective actions to resolve non-compliance. 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.
3. Determine the cause of deviation. 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. 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.
4. Decide on a disposition for the non-compliant food products. For manufacturing companies, non-compliant 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. 
5. Validation methods for the effectiveness of the corrective action and record. 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 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.

Corrective action plan example

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.

1. 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)?

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.

2. 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?

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:

• Disposing of spoiled foods.
• Increasing the holding temperature above the temperature danger zone.
• Rejecting supplies with observable major defects.

What is an example of a weak corrective action?

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:

• Double-checking the process
• Warning signs
• New regulations
• Repeated employee training
  
  

How can FoodDocs help you set a corrective action plan?

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. As such, a corrective action plan process is established accordingly to address any potential deviations from critical limits. Identifying these corrective actions can be very tricky. Each action must be based on an established critical control point as well as on their corresponding critical limit. Your team must then produce a comprehensive plan on how to address any deviations on these critical limits.

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 that you will automatically get comprehensive and intuitively suggested corrective actions for any potential breach in your operations. 

How? 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:

• Accurately identified and analyzed food safety hazards in your operations.
• Complete critical control points and corresponding critical limits.
• Corrective actions for any deviation on each critical control point. These corrective actions are intuitively set to automatically pop up from our mobile application as choices whenever a breach of standards occurs. This feature can easily guide food employees with which corrective action to perform.
• Automatically set monitoring procedures and forms for all significant operations.

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.