Hazard Analysis Verification (HAV)

Question 1

What is the hazard analysis verification (HAV) task?

Answer 1

• A work method that provides IPP with a powerful approach to verifying compliance with certain requirements of 9 CFR 417, particularly foundations of the plant HACCP plan

Question 2

What are the foundational elements of the HAV?

Answer 2

• A flow chart that mathces the acutal produtciotn processes
• A hazard analysis that considers applicable food safety standards that are reasonably likely to occur (RLTO)
• CCPs for hazards that are reasonably likely to occur
• Documentation supporting decisions that hazards are not reasonably likely to occur
• Evidence supporting HACCP
• Reassessment of the HACCP system annually and anytime hazards occur

Question 3

What are examples of scientific support for the establishment for decision making?

Answer 3

• Regulations, pathogen modeling program, processing authority, challenge studies, etc

Question 4

What are examples of support for the establishment for decision making for hazards that are reasonably likely to occur?

Answer 4

• Letters of guarantee, certificates of analysis, microbial testingg,

Question 5

What is the first step in the HAV process? What regulation covers this?

Answer 5

• Review flow chart and compare to production process
• Reg: 417.2(a)(2)
• e.g. does the flow chart represent the actual production process?
• Must accuratley refelect actual production practices and contain required information for entire production process

Question 6

What is the second step in the HAV process? What regulation covers this?

Answer 6

• Review the hazard analysis and consider guidance in the FSIS Meat and Poultry Hazards and Controls Guide (HCG)
• Reg: 417.2(a)(1-2)
• Does flow chart identify the intended use
• Does it consider relative food safety
• For each hazard, is it considered RLTO or NRLTO

Question 7

What is the third step in the HAV process? What regulation covers this?

Answer 7

• For each hazard the establishment considers RLTO, verify that the HACCP plan includes one or more CCPs to control it. If no hazards are reasonably likely to occur, skip to step 4
• 417.2(c)(2), 417.5(a)(2)
• Does the establishment have >1 CCP for hazards for each product when RLTO
• Does the establishment have info to support CCPs, CLs, monitoring, verification?

Question 8

What is the fourth step in the HAV process? What regulation covers this?

Answer 8

• For each hazard the establishment considers NRLTO, determine what evidence the establishment uses to support the decision, including prerequisits programs and other supporting programs
• 417.5(a)(1)
• ## Does hazard prevention implementation have a supporting program

Question 9

What is the fifth step in the HAV process? What regulation covers this?

Answer 9

• Review other supporting documents
• Reg 417.5(a)(1)
• Are there copies of the documents referenced to hazard analysis
• Do the documents apply to the current process?

Question 10

What is the sixth step in the HAV process? What regulation covers this?

Answer 10

• Review establishment validation documents, including scientific supporting documents and validation data
• 417.4(a)(1)

Question 11

What is the seventh step in the HAV process? What regulation covers this?

Answer 11

• Verify reassessment requirements. Check most recent signature date for each HACCP plan
• 417.4(a)(3), 417.3(b), 417.4(a)(3)(i)

Question 12

What is the eighth step in the HAV process? What regulation covers this?

Answer 12

• Document your findings in PHIS