The HACCP Plan That Wasn't Followed
A small restaurant has a written HACCP plan for its cook-chill soup operation. The plan identifies cooking (165°F for 15 seconds), cooling (135→70°F in 2 h; 70→41°F in 4 h), and cold holding (≤41°F) as CCPs. The plan specifies monitoring every batch, corrective actions, and weekly verification by the manager. In practice: the cook records cooking temperatures only 'when he remembers,' cooling is not logged, and the manager signs the verification sheet without reviewing it. On Tuesday, a batch of soup was cooked to 168°F, cooled in a 5-gallon pot on the counter overnight, and served Wednesday. No one became ill, but an inspector is due next week.
1. Is this a HACCP plan failure, an implementation failure, or both? Explain.
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Both.
- Plan failure: The plan itself is incomplete or unrealistic. It requires monitoring every batch and weekly verification, but it does not specify who monitors, how the cooling is done (5-gallon pots on the counter are not a validated cooling method), or what equipment is used. A plan that cannot be executed as written is a plan failure.
- Implementation failure: The cook does not record cooking temperatures, cooling is unlogged, and the manager signs without reviewing. The CCPs are not being monitored, so the plan is not being followed.
The inspector will look for records that demonstrate the CCPs were met. There are none for cooling, and the cooking records are incomplete. The manager's signature on an unreviewed sheet is worse than no signature - it is falsified verification.
2. What are the CCPs here, and what monitoring and corrective action should each have?
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| CCP | Critical limit | Monitoring | Corrective action |
|---|---|---|---|
| Cooking | 165°F for 15 s | Probe thermometer in the thickest part of each batch; record time/temp/initials | Continue cooking until 165°F is reached; re-check; document |
| Cooling | 135→70°F in 2 h; 70→41°F in 4 h | Record start time; check at 2 h and 6 h; use shallow pans/ice bath | If >70°F at 2 h, reheat to 165°F and restart, or discard; if >41°F at 6 h, discard |
| Cold holding | ≤41°F | Check and log at least every 4 hours (or continuous monitoring) | Discard if >41°F for more than 4 h; repair unit; move product |
Each record needs date, batch, time, temperature, initials, and a verification signature by the manager who actually reviewed it.
3. What should the manager do before the inspection, and what should they NOT do?
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Do:
- Conduct a mock inspection and walk the CCPs.
- Fix the cooling method - shallow pans, ice bath, or blast chiller - and validate it.
- Retrain the cook and manager on monitoring and corrective actions.
- Start accurate records immediately; do not backfill.
- Review the HACCP plan and update it to be executable: assign responsibility, specify equipment, and set a realistic monitoring frequency.
- Document the corrective actions taken for the Tuesday batch (it should have been discarded, not served).
Do NOT:
- Fabricate or backfill records - this is falsification and a serious violation.
- Sign verification sheets without reviewing - that is the exact failure being corrected.
- Serve the Tuesday soup - it should be discarded; if it was served, document the assessment.
- Hide the problem from the inspector - be honest and show the corrective action plan.