Student Handout- Module Number Twenty-One (21) - Canning HAV and HACCP Plan 

Verification 

Canning HAV and HACCP Plan Verification 

All establishments must conduct a Hazard Analysis (HA). 

Some establishments may decide microbial hazards in thermally processed products are RLTO 

and address them in a HACCP plan. 

Other establishments may choose to use the regulatory exemption (in the slide) and omit 

microbial hazards from HACCP plan. In this case the decision in the HA is that microbial 

hazards are NRLTO because the product is produced in accordance with the canning 

regulations. The ongoing support for this decision is that the product is produced in compliance 

with the canning regulations. So, compliance with the canning regulations is a prerequisite for 

the decision in the HA. 

When operating under the exemption, failure to meet any canning regulation is noncompliance 

with 417.5(a)(1) and all noncompliances with canning regulations are to be associated. When 

there are repetitive noncompliances or a failure to prevent microbial hazards, the establishment 

does not have support for the decision in the HA that microbial hazards are NRLTO. 

Notice that this exemption only applies to microbial hazards. Any chemical or physical hazards 

deemed RLTO during the HA must be addressed in the HACCP plan. 

IPP will conduct the HAV task per Directive 5000.6 Revision 1 

Because compliance with the regulations is prerequisite for products under the exemption, IPP 

are to verify compliance with all canning regulations during the HAV task. To do this, they will 

review records and make observations. In the absence of existing documentation supporting 

compliance, IPP must gather additional information. For example, if a canning regulation has 

not been verified recently enough to determine compliance, IPP must verify that regulation. 

Once the additional information has been gathered, IPP will assess the information, and 

determine whether it provides overall support for the decision in the HA that microbial hazards 

are NRLTO. ..READ BULLET 3. 

Concerns about the adequacy of the food safety system should be discussed with Supervisor. 

An EIAO may be assigned to conduct an FSA. 

The HACCP Verification task is performed the same way for products produced under the 

exemption (ie not under a HACCP plan but through compliance with the canning regs). 

Expectation: Verify all canning regulations at least once during the year. If no changes, 311 

Recall and 310 Training would probably be done only once. Other regs could be verified much 

more often depending on the situation. Focus on regs with greatest potential public health 

impact. 

If on patrol, may not have time to do more than one requirement before going to other plants. 

Have a tracking system for regulations verified-could use Inspector Notes in PHIS. 

Specifications, procedures, and criteria for venting and IT must be met. 
Process times and temps are typical CLs at retort CCP. Time-temperature data is obtained 

from monitoring the CCP. Other canning regulations can be verified during processing such as 

simultaneous readings of the MIG and the chart temps. 

All canning regulations must be met in HACCP facilities. Many other regulations must be 

verified-recall plan, training, container closure examinations, posting processes, annual audits, 

etc. 

EIAOs have critical roles in canning establishments. They perform in-depth food safety 

assessments to determine the adequacy of the plant’s food safety system especially in 

response to illness outbreaks or spoilage incidents. 

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