AFDO Streamlines Retail HACCP Approvals with Review Service

Developing a retail Hazard Analysis and Critical Control Point (HACCP) plan can be a complicated process not only for food establishments, but also for the regulatory jurisdictions that sign off on them — an issue the Association of Food and Drug Officials (AFDO) knew needed to be fixed.

So, in September 2024, AFDO launched the Retail HACCP Plan Review Service to nationally streamline and simplify the HACCP review process across multiple jurisdictions, which hasn’t been done before, said Deanna Copeland, AFDO’s retail food safety director.  

What Is a Retail HACCP Plan?

FDA Model Food Code requires retail food establishments (i.e., grocery stores, supermarkets and restaurants) to have approved retail HACCP plans before they can serve or sell food products using a specialized or novel process, or other non-standard preparation technique.

A retail HACCP plan is a systematic approach to identifying, evaluating and controlling food safety hazards. The overarching goal is for the plan to prevent foodborne illness.

The specialized processes that mandate retail HACCP plans are outlined in FDA Model Food Code and include processes such as reduced oxygen packing (ROP), preservation by acidification, fermentation, smoking or curing, and more.

Retail HACCP plans often require many resources to develop and to receive approval, presenting a potentially complicated process for companies that are trying to affirm their commitment to food safety.

“We know that this is a problem because regulatory agencies, they have those competing priorities, and sometimes HACCP approvals just get shifted to the back burner,” Copeland said. “We also have different food code versions in use across the U.S.”

The Review Service.

This is where AFDO comes in.

Some regulatory agencies and their health or agricultural departments share duties, including retail food safety programs. If one person wears multiple hats at an agency and is being asked to review, for example, a 100-page retail HACCP plan, it may present a challenge.

Instead, retail companies can submit their retail HACCP plans on AFDO’s website for review. The organization provides free templates for companies to develop their HACCP plans. Copeland said AFDO provides review and evaluation from scientific and regulatory experts, depending on what food process a company uses.

Businesses interested in using AFDO’s Retail HACCP Plan Review Service can follow these steps to start and complete the review:

1. Submission: A company submits their retail HACCP plan for a free initial review (this is where free templates and other tools can be used).
2. Clerical/initial review: AFDO accepts the plan and checks for completeness (if a part of the plan is incomplete, correct documentation will be requested and AFDO will provide guidance).  
3. Payment: To continue with the full review, a company pays for the service depending on number of establishments under review ($995 for one establishment, $2,495 for two to 10 and $4,995 for 11 or more).
4. Review and evaluation: The plan will be reviewed within six months, but the review could be longer depending on its complexity. However, AFDO will inform more on next steps in this case.

After AFDO completes its evaluation and deems that a retail HACCP plan meets FDA Model Food Code and is sufficient in protecting food safety, companies receive a final review letter.

“Once a business has this final review letter, stating that the plan meets all the minimum requirements, then that can go to the health department for their individual approval, because each jurisdiction is still required to issue their own approval according to FDA Food Code,” Copeland said. “But this AFDO review letter confirms that the plan is credible, meets all the minimum safety standards, and then that way, that regulatory agency doesn’t have to use their precious resources for an extensive review.”

A Mutual Benefit.

The Retail HACCP Plan Review Service is meant to support and benefit both retail businesses and health departments. AFDO works alongside local, state, territorial and tribal retail safety food jurisdictions during review processes, said Dr. Sally Flowers, scientific affairs director for AFDO.

“We work together from the very beginning,” Flowers said. “We talk with the establishment and get to know which jurisdictions we’re working with. We reach out to all of them, bring them all together on an opening call and just say, ‘This is what the review process looks like. This is what you’re in store for. We’re going to need your help to weigh in on this aspect of the review. Who wants to volunteer to be on the panel review calls?’”

Many experts have been happy to volunteer, said Flowers, resulting in thorough reviews to ensure HACCP principles and points and that food code requirements are being met by retail establishments.

Identifying which experts will be involved in the review of each retail HACCP plan depends on the processes businesses submit. If a plan under review includes a well-established food process, then AFDO staff and subject matter experts from regulatory agencies review it, Copeland said. AFDO also has university academics on hand to help with the scientific aspects of plans.

If a plan involves a new or novel process, AFDO will “start looking outside of what’s necessary to ensure that this science is sound,” Copeland said. And if a process is new, it helps everyone involved learn how to address it in regards to food safety.

Strong Retail HACCP Plan = Stronger Business.

A jurisdiction-approved retail HACCP plan demonstrates that an establishment is confident in its food safety measures. As AFDO provides a more efficient and streamlined opportunity to have HACCP plans reviewed, more businesses will be able to move forward with their specialized food processes across multiple jurisdictions.

“According to the food rules and all the regulations in place, it’s well established that there’s a relative risk in all foods, but some food processes do have greater inherent risks, and the FDA terms those specialized processes,” Copeland said. “We’re seeing more and more of these, because food preparation methods are advancing, new technology is coming into use. … So, having that strong HACCP plan, what it does is it sets the requirements to make sure that the process is conducted safely, and that sets up a business for success to make sure that they are serving safe products to their customers when they choose to use these specialized processes.”

For more information about AFDO’s Retail HACCP Review Service, visit https://www.afdo.org/haccp-plan-review/.