A food safety system changes with time. Periodic reanalysis is needed to verify that the whole system works. The rule requires that you reanalyze your plan:
- At least every three (3) years. Even if your plan has not identified any preventive controls, at least every three years you must review your plan to ensure it accurately reflects your operations.
- New information becomes available about potential hazards associated with the food. This requirement recalls the need to keep up to date on the levels of Mycotoxins in grains across growing seasons, Changes may require you to increase the frequency of testing and may allow for a decrease in the frequency of testing. Keeping up to date with industry recalls and incidents of illness or injury will allow you to quickly respond to new threats.
- Corrective action and correction, when appropriate. One thing is sure in this industry is that everyday something unexpected will happen. A mill manager once described his job as that of a “short order cook”. When things change frequently you must have processes in place to adjust, fix and repair things when they go wrong. But when this is normal, when things are usually going wrong, it is time to reanalyze your plan and validate and verify its effectiveness.
- Preventive control ineffective. If you have put a preventive control in place to prevent a feed safety issue and the issue to still occurring or is recurring, it is necessary to reanalyze the plan to validate and verify it is appropriate.
- Significant change in product or process. You must reanalyze your plan if you decide to make feed for a new species of animal, a feed for an animal in a lifecycle you have not previously produced. Reanalyze your plan if you decide to start pelleting feed or if you install a new piece of equipment that operates differently than the previous equipment.
When you are implementing a preventive control or having issues with its effectiveness…
When you identify corrective actions or are constantly making corrections…
There are two things you need to ask…
Am I doing the right thing? Perform Validation that the process or preventive control is the right thing to do to prevent the problem. Validation requires the use of solutions that are scientifically based and proven solutions.
Am I doing it correctly? Verification requires that you prove the hazard is being prevented. If a process is put into place to prevent a hazard, you must prove that the hazard is not present. Merely trust it is working is not acceptable.