Handbook of Herbs and Spices - Volume 3

QA and HACCP systems in herb and spice production 107

preventive measures at control points. For management practices, the critical limit

would be whether the preventive measure was complied with or not. A critical limit

requires 100% compliance or an acceptable explanation of deviation from the program.

For example, in our program one critical limit is the successful completion of the

Plant Identification Practice prior to the sale of the product. Less than 100% compliance

would be an unacceptable risk to anyone using the product.

Acceptable levels are defined as criteria that delineate a level of safety – whereas

outside this range would be critical in relation to food safety. Acceptable levels must

meet the criteria outlined in the monitoring procedure in an effort to minimize or

reduce a non-critical hazard. They may require less than 100% compliance, although

any deviation should be recorded. They must meet regulatory requirements. For

example, acceptable limits for pesticide application follow label requirements that

are set by law.

Monitoring the program

Monitoring procedures must be put into place to monitor the critical limits of a CCP

or the acceptable limit of the ‘must do’ GAP to ensure control. The frequency of

monitoring reflects regulatory requirements. For example, the monitoring procedure

for pesticide application involves keeping a record of what is applied the rate and

timing of application and the crop and pest that were targeted. The date of harvest of

that same crop must also be recorded. Label instructions must be followed.

Deviating from standard procedures

Deviation occurs when a procedure addressing either a critical or acceptable limit

does not follow the original program. Procedures that deviate from the original

program may have a potential impact on food safety. A deviation procedure must

clearly define the action taken to address the specific limit. It must reflect regulatory

requirements. For example, the original procedure for pesticide handling may be to

apply product immediately upon receipt and not to store it. A deviation procedure

may be to store the product and talk to a local crop specialist or product buyer for

recommendation. The deviation procedure does not alter the risk level. It does allow

the latitude of addressing limits in more than one way.

Verifying what is done

The verification procedure is a process with two aspects:

1. Reviewing records for completeness. For example, in this document the verification

procedure is to review sign-off documents relating to plant identification practice

and confirm that the appropriate sample has been retained.

2. Maintaining records to verify that the HACCP plan has been adhered to. This

procedure would identify the records to be in place for acceptable limits, monitoring

and deviation procedures.

Good agricultural practices (GAPs)

There are eight good agricultural practices (including good wildcrafting practices) in

this program:

1. plant/product identification


2. pest control products – purchase, storage, handling and application


3. purchasing


4. production – on farm and wild harvesting