SANS 10330 Hazard Analysis: Product Description Guide (Stage 2)

Understanding Stage 2: Why Product Description Matters for Hazard Analysis

You cannot conduct meaningful hazard analysis without first documenting what you are actually making. Each product characteristic influences potential hazards. Fresh versus shelf-stable mayonnaise have dramatically different hazard profiles despite similar base ingredients, due to variations in processing, pH levels, water activity, and storage conditions.

The Seven Essential Elements of Product Description

1. Composition: Cataloguing Every Ingredient and Additive

Requires a complete inventory of raw materials, ingredients, additives, and potential allergens — not merely copying a recipe but identifying hazard sources.

• List every ingredient by name and specify its function
• Be explicit about allergens rather than assuming their presence
• Document processing aids even if they don't remain in the final product
• Identify allergen presence in compound ingredients

2. Physical and Chemical Properties: The Science Behind Safety

Document pH and water activity — fundamental controls determining whether harmful microorganisms can survive and multiply.

• Products with pH below 4.6 and water activity below 0.85 are generally low-risk for pathogenic bacteria
• Products above these thresholds provide ideal conditions for pathogens like Clostridium botulinum and Listeria monocytogenes
• Measure actual values using calibrated equipment rather than estimating
• Document testing methods and equipment used

3. Safety Treatments: Documenting Your Kill Steps

Safety treatments include cooking, pasteurisation, freezing, salting, smoking, and fermentation.

• Specify parameters making treatments effective (cooking temperatures and times, freezing rates, fermentation duration)
• Include scientific justification demonstrating adequate hazard control
• Provide references supporting treatment parameter adequacy

4. Packaging Systems: Your Product's Protective Barrier

Packaging prevents recontamination after processing and controls oxygen availability, which affects which microorganisms can grow.

• Describe packaging materials and methods completely
• Document target gas compositions for modified atmosphere packaging
• Include verification methods for packaging integrity
• Address food-contact compliance of packaging materials

5. Storage Conditions: Maintaining Safety from Production to Consumption

• Be specific about temperature ranges rather than vague terms like "keep refrigerated"
• Justify requirements scientifically
• Document how cold chain maintenance is verified
• Consider storage conditions in hazard analysis

6. Shelf Life: Time as a Food Safety Factor

• Base shelf life on scientific evidence, not marketing preferences
• Conduct challenge studies or shelf life studies testing for pathogen growth
• Document methodology for shelf life determination

7. Distribution Methods: Controlling Hazards Beyond Your Facility

• Specify required distribution conditions explicitly
• Document target temperature ranges and monitoring methods
• Include transport hygiene requirements

Connecting Product Description to Hazard Categories

Biological Hazards

Product characteristics revealing relevant biological hazards include composition, physical and chemical properties, safety treatments, packaging, storage conditions, and distribution methods. Relevant hazards in South Africa include:

• Salmonella species in poultry and eggs
• Listeria monocytogenes in refrigerated ready-to-eat products
• Staphylococcus aureus in manually handled products
• Clostridium botulinum in low-acid canned foods
• Pathogenic E. coli in ground meat and fresh produce

Chemical Hazards

Chemical hazards include naturally occurring toxins, environmental contaminants, processing chemicals, and allergens. Relevant South African chemical hazards include:

• Pesticide residues on fresh produce
• Mycotoxins (especially aflatoxins) in groundnuts and maize
• Heavy metals in fish and spices
• Veterinary drug residues in meat and dairy
• Histamine in fish products
• Allergens across product categories

Physical Hazards

Physical hazards include metal, glass, hard plastic, stones, wood, bone, and personal items. Common South African physical hazards include:

• Metal fragments from processing equipment
• Glass from broken containers
• Stones from agricultural products
• Bone fragments in deboned products
• Plastic pieces from packaging

Common Mistakes in Product Description

Mistake 1: Using Vague or Generic Descriptions

Avoid overly general descriptions. Instead, specify product name, ingredients with percentages, processing steps, and target parameters.

Mistake 2: Omitting Allergen Declarations

Explicitly identify all allergens. South African regulations require declaration of cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame seeds, sulphites, lupin, and molluscs.

Mistake 3: Failing to Document pH and Water Activity

Measure using calibrated instruments and document results. These values are critical for your hazard analysis and cannot be estimated.

Mistake 4: Inadequate Treatment Descriptions

Specify time-temperature parameters or other treatment criteria making steps effective. Vague descriptions like "cook until done" are insufficient for HACCP purposes.

Mistake 5: Ignoring Distribution Temperature Requirements

Specify exact temperature ranges required during transport and storage. Cold chain breaches are a common source of food safety incidents.

Moving Forward

Product descriptions are living documents requiring updates when products are reformulated, suppliers change, processing parameters are modified, or packaging is updated. Establish procedures for reviewing and updating descriptions at least annually.

Product description is not a one-time task — it is the foundation every other HACCP stage builds on. Get it right and the rest of your hazard analysis becomes significantly more straightforward.

FAQs

What is the purpose of product description in SANS 10330 hazard analysis?

Product description provides detailed information needed to identify all relevant biological, chemical, and physical hazards, documenting characteristics that influence which hazards are present and how they must be controlled.

How detailed must my ingredient list be?

Include every raw material, ingredient, additive, and processing aid used. List percentages or ranges, specify functions, and explicitly identify all allergens including those in compound ingredients.

How often should product descriptions be reviewed and updated?

Review at least annually as part of HACCP plan verification. Update immediately when reformulating products, changing suppliers, modifying processing parameters, altering packaging, or extending shelf life.