J-6 HACCP Manual 2014 FINAL. 080314.pdf

HACCP

Hazard Analysis & Critical Control Point

Planning to Prevent the Spread of Invasive Species

N62742-21-R-1800 Attachment J-6

Edited by David Britton, Paul Heimowitz, Susan Pasko, Matthew Patterson, and Jonathan Thompson

June 2014 i USFWS-NCTC

Table of Contents

Acknowledgements ........................................................................................................ ii Chapter 1: Invasive Species Impacts Chapter 2: What is HACCP?

Chapter 3: Case Studies: When HACCP Could Have Helped Chapter 4: HACCP Planning

Step 1 – Activity Description Step 2 – Activity Flow Chart Step 3 – Potential Non-Targets Step 4 – Non-Target Analysis Worksheet Step 5 – Non-Target Risk Action Plan (NTRAP)

Chapter 5: Implementing HACCP Chapter 6: Glossary Chapter 7: References Appendix A: Blank HACCP Forms Appendix B: Example HACCP Forms (Completed) Appendix C: Risk Assessment Diagrams Appendix D: Critical Control Point Decision Tree

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Acknowledgements

This course manual was adapted from “Aquatic Nuisance Species—Hazard Analysis and Critical Control Point (ANS—HACCP) Training Curriculum,” which was developed by the National Sea Grant College Program. In particular, the U.S. Fish and Wildlife Service thanks Jeffery L. Gunderson, Ronald E. Kinnunen, Patrice M. Charlebois, Douglas A. Jensen, Mike R. Klepinger, Eric C. Obert, and Fred L. Snyder for their efforts in adapting the use of HACCP for prevention of aquatic invasions.

Many people have contributed to the current version of this manual and associated training curriculum. Key partners include the State of Arizona Game and Fish Department, the State of Wyoming Game and Fish Department, and the National Oceanic and Atmospheric Administration. Valuable feedback from past course participants has also enhanced refinement of this manual over time

Thank you to the following sources of photos within this manual:

- Bob Pitman, USFWS

- Stewart Jacks, USFWS

- Steve Sharon, WGFD

- Roger Sorenson, AZGFD/USFWS

- June McIlwain, USFWS

- Robert Lindsey, USFWS

- Peter Pattavina, USFWS

- Paul Nelson, USGS

- Gordon H. Rodda, USGS

- John Hollingsworth, USFWS

- Karen Hollingsworth, USFWS

- Steve Hillebrand, USFWS

- Jay Troxel, USFWS

- Stuart Leon, USFWS

- April Fletcher, USFWS

- Dan Dinkler, USFWS

Chapter 1: Invasive Species Impacts HACCP Planning to Prevent the Spread of Invasive Species

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Chapter 1 Invasive Species Impacts

Learning Objectives:

At the end of Chapter 1, participants will be able to:

Identify invasive species impacts.

Define invasive species (and synonyms).

Define target, non-target, pathway, and vector.

Identify local and global invasive species pathways.

List key invasive species legislation

Invasive Species Defined

Several terms are used to describe organisms living outside their native range including invasive, non-indigenous, exotic, non-native, alien, and nuisance. The Nonindigenous Aquatic Nuisance Prevention and Control Act (NANCPA) of 1990 defined ‘‘nonindigenous species’’ as any species or other viable biological material that enters an ecosystem beyond its historic range.” The term is often used interchangeably with “alien”, which was defined by Executive Order 13112 as “any species, including its seeds, eggs, spores, or other biological material capable of propagating that species, that is not native” to the particular ecosystem in which it is found. The terms are also synonymous with non-native, and exotic.

NANCPA further defines an aquatic “nuisance” species as a nonindigenous species that “threatens the diversity or abundance of native species or the ecological stability of infested waters, or commercial, agricultural, aquacultural or recreational activities dependent on such waters.” Similarly, Executive Order 13112 defined invasive species as an alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health. Thus, invasive and nuisance species are synonymous and can be used interchangeably.

Key Definitions:

Invasive Species – a non-indigenous organism whose introduction does or is likely to cause economic or environmental harm or harm to human health.

Non-indigenous Species – an individual, group, or population of a species that is introduced by human intervention into an area or ecosystem outside of its historic native geographic range. Synonymous with “alien,” “non-native,” “exotic,” and “introduced.”

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Invasive Species Impacts

No matter what you call them, invasive species are a growing problem. In 2010, Sam Hamilton, former Director of the U.S. Fish & Wildlife Service, said that invasive species are “probably the single greatest threat in our country to our native wildlife.”

Invasive species impact our environment and the diversity of life on our planet in many ways. The ecosystems into which these organisms are introduced often lack the conditions that limit range expansion in their natural habitats (e.g., predators, pests, or diseases). This factor, accompanied by characteristics such as high reproductive rates, the ability to utilize a variety of resources, and wide tolerance to a range of environmental conditions, allow invasive species to spread quickly following introduction, often resulting in serious impacts to the environment. Consequences of invasion include the extinction of native species and alteration of ecosystem processes.

In addition to the severe and permanent damage to the habitats they invade, invasive species also hinder economic development. Nationwide the cost to manage invasive species has exceeded billions of dollars. Cost estimates are often underestimated as they usually do not consider ecosystem health or the aesthetic value of nature, which can influence tourism and recreational revenue. Estimating the economic impact associated with invasive species is further complicated as monetary values are difficult to estimate for the extinction of species or loss of native biodiversity and ecosystem services.

Additionally, invasive species may serve as vectors of human disease.

Throughout recorded history, epidemics such as malaria, yellow fever, typhus, and bubonic plague have used non-indigenous organisms as vectors. Waterborne disease agents, such as cholera bacteria (Vibrio cholerae), are often transported in the ballast water of ships. The effect of invasive species on public health extends beyond the immediate effects of disease and parasites, as chemicals used to control invasive species can pollute soil and water. Other invasive species, including invasive mussels, may increase human and wildlife exposure to organic pollutants such as polychlorinated biphenyls (PCBs), as these toxins accumulate in their tissues and are passed up the food chain.

Zebra mussels attached to a native freshwater mussel. Photo Credit: USFWS

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Pathways

Invasive species can arrive through many different pathways and vectors, but most species considered invasive in North America arrived as a direct result of human activity. For example, it is widely accepted that zebra mussels, Dreissena polymorpha, were introduced to the Great Lakes through ballast water discharge by ships arriving from foreign ports. Shippers did not intend to move zebra mussels when using ballast water to safely cross the ocean and manage cargo loading/unloading. Unfortunately, many species can survive transoceanic trips in ballast water, essentially “hitchhiking” to new ports. Likewise, the horticultural industry has inadvertently provided pathways by which plant pests have been imported to the United States, causing problems in agricultural and natural areas. Some of our worst insect invaders, such as the Formosan termite (Coptotermes formosanus shiraki) arrived in packing and crating materials. These are just a couple of examples of how species are moved around the planet unintentionally. However, the problem is ubiquitous and all too common.

Pathway – an activity or process through which a species may be transferred to a new location where it could become invasive (e.g., shipping, air travel).

Vector – the specific means by which an invasive species moves within a particular pathway (e.g., a ship, agricultural products, boots).

On a local scale, invasive species can be spread unintentionally to new habitats through a wide variety of human activities, including work in natural resource management. For example, the tiny size of the New Zealand mud snail (Potamopyrgus antipodarum) and its ability to clone itself help this species hitchhike to new habitats on targets such as waders, boats, and other aquatic gear. Similarly, terrestrial species can be moved via field or farm equipment, clothing, and/or native species that are moved to new areas for conservation purposes. Species monitoring, collections, natural resource surveys, and stocking of fish are all potential pathways for moving invasive species during natural resource management activities. Because invasive species are not the “target” of these activities, we can refer to them more generally as “non-targets.”

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Target – anything that is intentionally moved. For example, if your management activity calls for you to stock largemouth bass, then your targets would be largemouth bass and any equipment and personnel used to carry out this activity.

Non-target – anything, including any organism, that is not intentionally moved. For example, if your management activity calls for you to stock largemouth bass, then any other species of fish (or other organism) would be a non-target. Your intent would be to only move largemouth bass.

The use of “target” and “non-target” in HACCP can be confusing to those involved in control of weeds and other invasive species. For pesticide applications, invasive species are the “targets,” and “non-targets” are the beneficial species to be avoided. Confusion over these overlapping terms can be reduced if you remember that HACCP focuses on preventing invasions before they happen. From a prevention standpoint, we only want the targets of an activity to be moved.

HACCP Spotlight: Target vs. Non-target

Invasive purple loosestrife at Montezuma National Wildlife Refuge. John and Karen Hollingsworth, USFWS.

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Invasive Species Legislation

The invasion of zebra mussels in the mid-1980s caused a surge of invasive species awareness and prompted federal legislation in the form of the Non-indigenous Aquatic Nuisance Protection and Control Act of 1990. This act was reauthorized and amended to the National Invasive Species Act in 1996. Under these federal programs, specific regulations and national management plans are dedicated to research and management of numerous species such as the Chinese mitten crab, New Zealand mud snail, killer sea weed Caulerpa, Asian carp, and purple loosestrife.

In February 1999, Presidential Executive Order 13112 created the National Invasive Species Council and the Invasive Species Advisory Committee in response to growing concern over all taxa, including aquatic and terrestrial invasive species. This Executive Order states that “each federal agency whose actions may affect the status of invasive species shall, to the extent practicable and permitted by law…not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.” This broad directive has implications for non-federal agencies as well, particularly those working in partnership with federal agencies. But, it also raises risk-management questions. What is

HACCP Spotlight: NANPCA and NISA

Congress passed the Non-indigenous Aquatic Nuisance Protection and Control Act (NANPCA) of 1990 in response to the invasion of the zebra mussel and other species that damaged the Great Lakes. That law brought much-needed attention to the global movement of aquatic species. It also established the federal interagency Aquatic Nuisance Species Task Force, which became a key resource for regional and state efforts. The 1990 law’s strictest and most detailed provisions required that ships headed for the Great Lakes exchange their ballast water at sea. The law was reauthorized, renamed the National Invasive Species Act, or NISA, and expanded in 1996. Then all ships arriving from outside the 200-mile U.S. Exclusive Economic Zone were encouraged to exchange their ballast water, but required to report whether they had. NISA also authorized important research and linked its results to decisions about whether further ballast water regulation was needed.

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“practicable”? What are “feasible and prudent measures to minimize risk of harm”?

HACCP can help provide the answers.

Understanding pathways and developing plans to remove non-target species and prevent biological contamination is necessary to prevent invasive species impacts.

When it comes to natural resource management activities, these introductions should not be considered simply “accidental.” It is our responsibility as resource professionals to strive to do no harm. Understanding invasive species pathways and developing plans to remove hitchhiking species are necessary to prevent unintended spread.

Remember, if you are not part of the solution, then you are part of the problem.

Chapter 2: What is HACCP?

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Chapter 2 What is HACCP?

At the end of Chapter 2, participants will be able to:

Explain why "planning is essential" Describe the five steps of HACCP Planning.

Explain the benefits of a strong HACCP Planning team.

What is HACCP?

Hazard Analysis and Critical Control Point (HACCP) Planning is about risk management. It features five integrated steps that can reduce the risk of spreading invasive species and other non-targets via human-based pathways. HACCP examines activities to determine if and when invasive species might be unintentionally moved.

Where this potential exists, the tool helps to identify the most effective opportunities during an activity to reduce that risk and the specific control measures that are needed. Safeguards are included through the use of Prescribed Ranges, Limits, or Criteria (PRLC, previously called a control limit) and corrective actions that ensure that control measures (also known as preventive measures) are operating as intended.

Control measures, PRLC, and corrective actions will be discussed in more detail in later chapters.

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Control Measure – an action that can be used to control a potential hazard (sometimes referred to as a preventive measure). Control measures are the first, and sometimes only, line of defense against the spread of non-targets. If control measures fail, corrective actions should be implemented.

Prescribed Range, Limit, or Criterion (PRLC) - (previously called a “control limit”) – a specific measureable attribute that can be used to determine if control measures are effectively minimizing the risk (e.g., a minimum dose of a disinfectant, a minimum exposure time, or an acceptable range of temperatures).

Corrective Action - a procedure that must be followed if a control measure fails at a critical control point. A corrective action is backup procedure used as a second line of defense that may be necessary to prevent the spread of a non–target if the first–line defense (a control measure) fails to control a non–target.

The Origins of HACCP

HACCP has been around for decades and has its roots in the food industry. The Pillsbury Company pioneered the HACCP concept in the early 1960s in partnership with NASA as a way to combat food contaminants in the food supply for the U.S. space program. Since then, HACCP has been recognized and used around the world as a proactive method to ensure product purity. HACCP planning is widely used and accepted by industry for good reason: It works!

The National Sea Grant Program first adapted HACCP to reduce the risk of spreading aquatic invasive species and help fish processors comply with federal regulations regarding seafood safety. The U.S. Fish & Wildlife Service has since widely adopted this method and has developed many HACCP plans for fish hatcheries, watershed surveys, fish passage projects, and other natural resource management activities. Use of HACCP to prevent the spread of invasive species has even become an American Society for Testing and Materials (ASTM) International standard under the Standard Guide for Conducting Hazard Analysis-Critical Control Point Evaluations (ASTM E2590- 09).

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Planning Is Essential

Like many plans, a large part of the value of developing a HACCP plan is the planning process itself. While examining their planned actions in detail, planners will reveal new questions and insights that can identify unrecognized prevention opportunities. The time and effort used to develop a HACCP plan will reduce the likelihood of unintended invasions that could negate any benefits from the original work. Therefore, through proper HACCP planning, natural resources will be better protected.

In order to be successful, HACCP planning requires commitment from agency heads, managers, and field staff. Involving this range of participants in HACCP plan development not only ensures a comprehensive analysis of a specific activity and its risks but promotes the “buy-in” necessary to assure effective implementation.

Planning is nothing new for biologists and managers, but applying HACCP planning to natural resource work may be a relatively new concept for some. Without appropriate planning, the management work that takes biologists, technicians, and their equipment to many different habitats could be pathways for invasive species spread. HACCP planning is a tool that manages the risk of moving non-targets in natural resource management activities.

HACCP identifies high-risk activities and focuses attention on those actions needed to reduce the movement of non-targets. Plans documenting risks and methods used to remove non-target species give managers the opportunity to weigh such risks for species spread against benefits from natural resource actions. For some pathways, the risks may outweigh resource benefits until better procedures to detect and remove non-target species are identified. HACCP planning provides a systematic method to make consistent decisions based on identified risks. HACCP plans also create a reference source to document best management practices and standard operating procedures that can be shared with other offices, agencies, and the private sector to reduce the risk of species spread through pathways with similar characteristics.

First-time HACCP planners often identify only well-known invasive species as non-targets to remove from pathways. While these species deserve increased attention, biologists recognize that many local species could become invasive if introduced outside their native range. HACCP planning for natural resource pathways is intended to reduce the risk from all non-target species, following the precautionary principle.

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The precautionary principle states that if an action could plausibly cause harm, but there is not yet a scientific consensus that the action is actually harmful, the burden of proof that such an action is not harmful falls on those taking the action. The precautionary principle implies a social responsibility to protect the environment from exposure to harm when careful consideration has found a plausible risk. This protection can be relaxed only if scientific findings emerge that provide sound, convincing evidence that no harm will result.

Using the precautionary principle, HACCP focuses on potential or known invasive species, but also includes species not yet known to be invasive. History demonstrates that many invasive species do not reveal their invasiveness until long after an introduction occurs; therefore caution should be practiced in the context of uncertainty.

"Always have a plan and believe in it. Nothing happens by accident."

(Chuck Knox, Football Coach)

HACCP Spotlight: The Precautionary Principle

Invasive brown tree snake (Boiga irregularis). Photo credit: Gordon H.

Rodda, USGS.

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The Five Steps of HACCP Planning

1. Describe the activity: The activity description includes specific information such as the who, what, when, where, how, and why of the project. The description offers a historical, working reference to facilitate plan review and communication with the facility staff and other resource management agency personnel.

2. Chart the flow of tasks for the activity: This step provides an important visual tool that the HACCP team can use to complete the remaining steps of the plan. Here, a clear and concise, yet complete description of the tasks necessary to complete the overall activity is diagramed in a linear fashion.

3. Identify potential non-targets: Any species that has a reasonable potential to be moved or introduced to new habitats should be identified in order to implement appropriate control measures to prevent an unintended invasion.

These may include vertebrates, invertebrates, plants, or other organisms (e.g., diseases, pathogens, and parasites).

4. Analyze the risk of moving non-targets: It is crucial to identify significant non-targets with respect to each required task within a larger activity so that effective measures to control them may be employed. During the analysis, the significance of each potential non-target is assessed by considering its risk of being moved within each individual task.

5. Completing the action plan: The action plan addresses specific methods to control risks of non-target species. It lists specific information about controls, monitoring procedures, methods for evaluation, and corrective actions.

Each of the above steps corresponds to a specific form in the HACCP process, and each step builds on prior steps. Blank forms are included in Appendix A.

Starting Out in the Right Direction

A successful HACCP program depends on the firm foundation of management commitment, HACCP training, and assembly of an effective HACCP team. Attempting to implement a HACCP program without these components will likely lead to HACCP planning that lacks a thorough assessment of the potential non-targets and commitment to apply the plan in the field.

Management Commitment - For HACCP planning to work, it is considerably important to have the support of everyone in the agency, from management to the field technicians. Without support, the plan will not become an agency priority or be effectively implemented.

HACCP Training - Education and training are important elements in developing and implementing a HACCP program. Employees who will be responsible for the HACCP program must be adequately trained in its fundamentals. HACCP can be a fairly

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HACCP Team Assembly - Assembling a team is an essential step in building a HACCP program. Although one person might be able to analyze risks and develop a plan successfully, a team approach maximizes the breadth of expertise needed to comprehensively evaluate an activity, identify all potential non-targets, and brainstorm the full spectrum of available prevention options.

“But I already have this covered in my standard operating procedures…” A list of prevention measures in your standard operating procedures is a great way to reduce the spread of invasive species, but it is not the same thing as a HACCP plan. HACCP is a process that requires a team to think comprehensively about what invasive species might be introduced through all parts of an activity, analyzes the significance of those risks, identifies the most effective opportunity to reduce risks, monitors whether the risk reduction measures are working, and if they’re not, provides a back-up plan. HACCP will help you generate a list of prevention or control measures, but simply using a list without going through the HACCP process can be a shot in the dark. From this standpoint, HACCP isn’t something more comprehensive than a list of best management practices; it is a best management practice.

"Man often oppose a thing merely because they have no agency in planning it, or because it may have been planned by whom they dislike."

(Alexander Hamilton, American President)

HACCP Spotlight: SOP's vs. HACCP

Was an SOP in place to decontaminate this boat before launch? Photo Credit: Steve Hillebrand, USFWS.

Chapter 3: Case Studies: When HACCP Could Have Helped HACCP Planning to Prevent the Spread of Invasive Species

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Chapter 3 Case Studies: When HACCP Could Have Helped

Learning objectives:

At the end of Chapter 3, participants will be able to:

Identify target species and potential non-target species in example case studies.

Explain how HACCP could have helped reduce the risk of invasive species introductions in two case studies.

Case study: Inks Dam National Fish Hatchery (NFH)

Inks Dam NFH is a warm-water facility operated by the U.S. Fish & Wildlife Service (Service) in central Texas. It is used for raising sport-fish for stocking throughout the Service’s Southwest Region. One of the programs at Inks Dam NFH is the production of largemouth bass, which are stocked in tribal waters of Arizona. The facility pumps raw water from nearby Lake Buchanan to fill their ponds. Lake Buchanan contains a suite of warm-water fish species native to central Texas. Annually largemouth bass brood-stock are spawned in ponds. The fry from the spawning adults are separated and reared in ponds, and eventually loaded into the stocking truck and transported to Arizona or New Mexico.

Prior to the implementation of HACCP at Inks Dam NFH, shipments of largemouth bass sometimes contained non-target organisms including fish, invertebrates, and plants that were inadvertently spread to receiving waters. This caused fish-management challenges and possibly led to the establishment of invasive species in Arizona and New Mexico. In 1998, a shipment of largemouth bass from Inks Dam NFH was determined to be the source of the introduction of gizzard shad to Morgan Lake in New Mexico, an important largemouth bass sport fishery on the Navajo Reservation. Later shipments of bass transported to Morgan Lake from the hatchery were found to have as many as nine different species besides largemouth bass including Guadalupe bass, logperch, gizzard shad, white bass, bluegill, and dollar sunfish. These shipments were refused but gizzard shad were already firmly established in Morgan Lake. Morgan Lake provides water to the APS power plant near Shiprock, as a result logistics prevent shad from being chemically removed from the 1200 acre lake... Lowering the lake would require a power-plant shut-down for an extended period. Poisoning the water without lowering the lake would block intakes with dead fish and effectively shut down the power plant. Since 1998, gizzard shad have spread significantly within the Colorado River system. In 200 the invasive fish was found in Lake Powell; however the source of this introduction has yet to be officially connected to the actions of the Ink Dame NFH.

At Inks Dam NFH, the pathways identified as potential sources for introduction of non-target species included the water in which the largemouth bass were raised. Water from Lake Buchanan is directly supplied to the hatchery with the possibility of moving

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June 2014 14 USFWS-NCTC numerous fish, invertebrate, and plant species as well as disease and pathogens. .

Another potential pathway for non-targets was the water used to fill the stocking truck, which also directly from Lake Buchanan.

The HACCP plan for stocking of largemouth bass from Inks Dam NFH identified an opportunity to fill trucks with well water instead of raw lake water (a practice that continues today). Additionally, hatchery personnel now use flow-through holding tanks to remove non-target plants and invertebrates. Large-mesh dip nets are used to collect the largemouth bass while allowing the smaller non-target fish to pass through. Finally, hatchery personnel inspect all holding tanks to ensure that non-targets are removed prior to loading the fish in the stocking truck.

As a check on the effectiveness of these control measures to remove non-target species from shipments of largemouth bass, service biologists on the receiving end inspect every shipment of fish prior to the bass being stocked. Since the HACCP plans have been implemented at Inks Dam NFH, unintended shipment of non-target organisms has effectively been minimized.

Case study: Ridgefield National Wildlife Refuge (NWR) Ridgefield NWR, located in southwest Washington State, has a total of 5,218 acres of marshes, grasslands, and woodlands. Management objectives include preserving the natural Columbia River floodplain and providing habitat for waterfowl and other wetland wildlife. In particular, the refuge was established to secure vital winter habitat for dusky Canada geese and other wintering waterfowl. As part of wetland creation and restoration projects undertaken at Ridgefield NWR, rice screenings from the Sacramento Valley of California were spread and harrowed within borrow areas of eight wetlands that had been scraped to mineral soil during September 1999. This activity was performed in order to establish a seed source for moist-soil vegetation in areas where the seed bank was removed as a result of the scraping. Rice screenings are composed of seed and other non-rice vegetation remaining after cleaning and processing of harvested rice. These screenings are primarily composed of moist-soil plants seeds (e.g., wild millet, smart weeds) that are considered high-quality food for aquatic, migratory birds. The seed mixture applied to the refuge contained predominately wild millet, smartweeds, and an unidentified bulrush.

Inks Dam National Fish Hatchery is located 60 miles northwest of Austin, Texas. Photo Credit - Bob Pitman & Robert Lindsey/USFWS

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During the spring/summer of 2000, the unknown bulrush germinated in refuge wetlands and was subsequently identified as Eurasian ricefield bulrush, a known invasive. In the Sacramento Valley, this species has become ubiquitous in wetlands and rice fields and is considered a nuisance weed. Beyond the original eight wetlands contaminated in 1999, the invasive bulrush has since infested six additional wetlands at the refuge.

Because this bulrush had not been previously recorded in the Pacific Northwest, the infestation at the refuge represented an introduction of a new invasive species.

Accordingly, Ridgefield NWR has established an aggressive control program. The following are potential vectors by which this bulrush seed spread to new areas: water flow in drainage and delivery ditches, farm equipment and vehicles, and transport by wildlife and humans (e.g. refuge visitors, hunters, and refuge staff). Although the actual mechanism by which this bulrush has infested additional wetlands on the refuge is unknown, the likely vector was water flow between units.

Because drainage water is annually pumped from the refuge into the Columbia River, there are further risks of the bulrush escaping into additional sites within the Columbia River System.

Although it is not possible to determine with certainty whether a HACCP plan would have prevented the introduction of this invasive plant to Ridgefield NWR, HACCP would have facilitated analysis of threats from the source area and helped identify prevention measures such as seed purity protocols and quarantine procedures.

"The significant problems we face cannot be solved at the same level of thinking we were at when we created them."

(Albert Einstein, Nobel Prize Winner, Physics)

Ridgefield National Wildlife Refuge is located just north of Vancouver, Washington. Photo Credit – Friends of the Ridgefield National Wildlife Refuge

Chapter 4: HACCP Planning: Step 1 – Activity Description HACCP Planning to Prevent the Spread of Invasive Species

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Chapter 4 HACCP Planning

Step 1 – Activity Description

At the end of Step 1, participants will be able to:

Identify the essential components of a well-written Activity Description.

Write an Activity Description encompassing all six description components.

Once a HACCP team is established, the members first describe the activity, the method of accomplishing the activity, and the intended purpose and need for the activity.

Examples of activities include, but are not limited to the following:

Forest thinning operations

Raising and/or stocking of fish and other organisms

Wildland fire fighting

Field surveys (aquatic and terrestrial)

Habitat restoration projects

Research field work

Road construction and maintenance

Trail building and maintenance

Introducing an organism for biological control

Landscaping

Invasive plant removal

The HACCP Plan title and management objective should be clearly stated at the top of the Step 1 form. The management objective should state the overall goal of the activity or project to be performed. A contact person also should be identified. This person will be the point of contact for any questions regarding the HACCP plan; in most situations the contact person will be the HACCP team lead, project coordinator, or site manager.

The activity description should provide historical references and background information to help facilitate communication between staff members conducting the activity as well as other resource management agency personnel that may be involved. The activity

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June 2014 17 USFWS-NCTC description should be a narrative description that includes the “who, what, when, where, why and how” of a particular project:

Who: The individuals (e.g., project manager, site manager, or field staff) that are responsible for managing and conducting the activity.

What: A statement about what is done during the activity.

When: The timing and frequency of the activity (i.e., is it a one-time occurrence or does it occur repeatedly such as maintenance, annual surveys, or seasonal fish distribution?).

Where: The location(s) where the activity takes place.

Why: A statement about the need and the objective of the activity.

How: A general statement about the methods used to complete the activity

The Activity Description should be complete, accurate, and thorough, yet succinct. The objective is to provide enough information to allow someone unfamiliar with the activity to be able to understand the context and details of the HACCP plan, but not burden them with unnecessary details.

The form on the following page provides a consistent template for Step 1.

Fieldwork may involve intentionally moving a particular species. But, what else are you dragging along? Photo Credit: Peter Pattavina, USFWS.

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Chapter 4 will take you through the five steps of HACCP planning. At the end of each Step, this manual uses the following hypothetical example to demonstrate the application of HACCP concepts.

A Hypothetical Example

Throughout the year, staff members from the Cutthroat Trout National Fish Hatchery conduct monthly riparian habitat surveys to measure vegetation densities within the Thompson River Basin in Montgomery County, California. The purpose of the surveys is to gather data and information on riparian habitat to guide cutthroat trout recovery actions within the Thompson River Basin. When not in use, the specialized survey gear is stored in a warehouse on hatchery property. Surveys are begun by first retrieving all necessary gear from the warehouse at the beginning of the day. Once loaded into a pickup truck, staff members travel with the gear to the sampling site chosen for the day.

After the gear is unloaded, the staff conducts the sampling activity using the appropriate gear. At the end of the day, staff members load the gear back into the truck and return to the warehouse. The gear is then unloaded and put away until needed for the next survey. Within the Thompson Basin, several potential invasive species, parasites, and diseases have been determined to be of significant concern. These include bullfrogs (Rana catesbeiana), New Zealand mud snails (Potamopyrgus antipodarum), Eurasian milfoil (Myriophyllum spicatum), purple loosestrife (Lythrum salicaria), Chytrid fungus (Phylum Chytridiomycota), and whirling disease (Myxobolus cerebralis).

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HACCP Step 1 – Activity Description

Management Objective & Contact Information

HACCP Plan Title:

Management Objective:

Contact Person:

Phone:

Email:

Activity Description i.e. Who; What; Where; When; How; Why

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Here is an example Activity Description for the hypothetical example introduced in Chapter 4: Step 1 (page 16).

HACCP Step 1 – Activity Description

Management Objective & Contact Information

HACCP Plan Title: Hypothetical HACCP Plan

Management Objective:

Survey riparian vegetation habitat based on the recovery plan for the cutthroat trout

(CT).

Contact Person: Dave Britton

Phone: (800) LUV-FISH

Email: David_Britton@fws.gov

Activity Description i.e. Who; What; Where; When; How; Why

Who: Cutthroat Trout National Fish Hatchery personnel

What: Measurement of Riparian Vegetation Density

Where: Survey sites within the Thompson River Basin (Montgomery County, California).

Water bodies include the Thompson River, Patterson River, Britton Creek, and Pasko Creek. There are 20 sites within the basin (5 per river or creek). Survey sites are 100 meters in length.

When: Sites are sampled continuously throughout the year starting in April and ending in November. Only one site is sampled per day.

How: Retrieve the appropriate gear from a warehouse at the beginning of the day. Travel to the sampling site. Once at the site the survey is conducted by wading down the river and taking measurements on riparian vegetation density. Once activity is complete, return to the warehouse. Gear is unloaded and stored.

Why: To gather data and information on riparian habitat to help guide cutthroat trout recovery actions

Chapter 4: HACCP Planning: Step 2 – Activity Flow Chart HACCP Planning to Prevent the Spread of Invasive Species

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Step 2 – Activity Flow Chart

At the end of Step 2, participants will be able to:

Discuss the relationship between the Activity Description and the Activity Flow Chart.

Identify all of the tasks required to complete the activity described in Step 1.

Complete an Activity Flow Chart.

An Activity Flow Chart is a method for outlining the sequence of tasks that occur during the activity addressed by the HACCP plan. Information from the Activity Description (Chapter 4, Step 1), specifically the “how” from the narrative, is used and expanded upon to develop this sequence. The flow chart should contain a task number, title, and brief description. It is important to include all tasks within the activity, from preparation to project completion. If a task is missed, a significant non-target may not be addressed.

All tasks covered by a HACCP plan should be included in an Activity Flow Chart. If your activity includes any tasks that occur in parallel (simultaneously), then the activity is too general for a single HACCP plan. This is one of the most common mistakes made when people first start creating HACCP plans. In this case, break the activity into two or more sub-activities and create HACCP plans for each sub-activity. Each sub-activity should have its own Activity Flow Chart that contains only sequential tasks.

Tasks intended to prevent the spread of invasive species (e.g., decontamination procedures), should NOT be included in the Activity Flow Chart. The HACCP plan will be stronger if those tasks are not included as “tasks”, but instead are included as control measures for a related task. For example, consider a forest survey team that proactively decontaminates its vehicles upon entry and exit to a new site. Since it is part of their normal operations, the HACCP team may prepare a plan for this activity that includes the decontamination process as one of the tasks. However, the plan will be more effective if the team lists only the entry and exit to the site as tasks and later identifies the decontamination process as an associated control measure for these tasks. These two approaches may not seem much different, but only the latter allows the HACCP plan to provide valuable documentation, monitoring, and evaluation of the decontamination process and prescribed corrective actions should the decontamination process (control measure) fail. You will learn more about control measures and corrective actions in Steps 4 and 5.

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A Note on “Lumpers vs. Splitters” The number of tasks required to complete the activity will depend on the activity’s complexity and whether your HACCP team consists of “lumpers” or “splitters.”

If you have a team of "lumpers" (i.e. they define very broad tasks), you will have few tasks and it might be difficult to distinguish specific prevention opportunities. On the other hand, if your team identifies more than ten tasks, your team is probably splitting too much. Remember, a HACCP plan will not be effective if the tasks defined for your activity are too narrowly or too broadly defined. Be specific, yet concise.

The HACCP team should evaluate the entire activity or operation and make any changes required in the flow chart. The evaluation allows each team member to gain an overall picture of how the activity is conducted. The Activity Flow Chart is an important tool that the HACCP team will use to complete the remaining steps of the plan. In addition, an activity diagram based on the flow chart’s tasks, although optional, is a useful aide in visualizing the activity and completing the risk analysis in Step 4.

An Activity Flow Chart template is provided on the next page, followed by an Activity Flow Chart and an example activity diagram for the hypothetical example introduced in Chapter 4: Step 1 (page 16).

"A common mistake people make when trying to design something foolproof is to underestimate the ingenuity of complete fools."

(Douglas Adams, Author)

HACCP Spotlight: Lumpers vs. Splitters

Is this one task or multiple tasks? Photo Credit: USGS.

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HACCP Step 2 – Activity Flow Chart

Outline Sequential Tasks of Activity *

Task 1

Title:

Description:

Task 2

Task 3

Task 4

Task 5

* Add or remove boxes as needed

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Here is an example Activity Flow Chart that shows how the HACCP team completed Step 2 for the hypothetical example introduced in Chapter 4: Step 1 (page 16).

HACCP Step 2 – Activity Flow Chart Outline Sequential Tasks of Activity

Task 1

Title: Load Gear and Drive to site

Description: Arrive at warehouse and load appropriate gear for sampling activity. Drive to sampling site.

Task 2

Title: Unload gear and conduct survey

Description: Unload gear from vehicle. Prepare gear to conduct sampling.

Conduct survey by wading down river and taking measurements on riparian vegetation density

Task 3

Title: Reload gear

Description: Return to vehicle and pack up gear.

Task 4

Title: Return to warehouse and unload gear.

Description: Return to the warehouse in vehicle with gear. Put equipment away to store for next use.

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An Activity Flow Diagram like the one below is optional. Sometimes it is helpful to sketch the linear sequence of tasks, particularly when the tasks are conducted in more than one location. If this helps your HACCP team produce an Activity Flow Chart, then please consider using a diagram in addition to the Activity Flow Chart.

Example Activity Diagram

Jacks Parkway

Sharon Ave

Heimowitz Road

Warehouse

Sample Site

2 3

Road

River

# Task

North

"Proper preparation prevents poor performance" (Charlie Batch, Two-time Super Bowl Winning Quarterback)

Chapter 4: HACCP Planning: Step 3 – Potential Non-Targets HACCP Planning to Prevent the Spread of Invasive Species

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Step 3 – Potential Non-Targets

At the end of Step 3, participants will be able to:

Discuss the difference between a target and a non-target.

Identify the different non-target categories (Vertebrates, Invertebrates, Plants, and Other Organisms).

Identify non-targets that potentially could be moved during your activities.

Complete a form for HACCP Step 3.

In Step 3 of the HACCP planning process, the team needs to identify the potential non-targets that may be moved through the tasks identified in Step 2.

Remember that targets can include yourself, your gear, and/or a species that you intend to move. Non-targets are anything that you do not want to be moved from one area to another. Non-target organisms can be categorized into four general categories:

vertebrates, invertebrates, plants, and other organisms (e.g., fungi or microbial pathogens). Species considered non-targets vary from state to state, agency to agency, and biologist to biologist. Your HACCP team should consider ALL potential non-targets that have a reasonable probability of being moved through the tasks identified in Step 2.

In later steps of the HACCP planning process, you will have an opportunity to narrow down your list to the truly significant non-targets. For now, if your HACCP team is on the fence about whether something should or should not be listed as a potential non-target species, it probably should be listed (remember the precautionary principle). You may need to do some research or consult with local experts to determine which species should be considered non-targets (see Chapter 7 for helpful resources). Discussions about non-targets can help focus planning objectives and establish the basic foundation for each HACCP plan. In the end, the HACCP planning process may reveal non-target species that were not previously recognized as present in the activity area.

Individual species or general categories (e.g., all non-target fish species) can be used to develop this list. In general, it is acceptable to group taxa when numerous individual species have the potential to be non-targets. However, any species that are of high concern or require specific or additional control measures should be listed individually.

Remember our discussion about “lumpers” and “splitters” in Step 2? This concept also applies to potential non-targets. If you need a refresher, check out the HACCP Spotlight on page 22.

The form on the following page provides a consistent template for Step 3.

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HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

Invertebrates:

Plants:

Other Organisms (pathogens, parasites, etc.):

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Here is an example that shows how the HACCP team completed Step 3 for the hypothetical example introduced in Chapter 4: Step 1.

HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

Amphibians Bullfrog (Rana catesbeiana)

Invertebrates:

New Zealand Mud snail (Potamopyrgus antipodarum)

Plants:

Eurasian milfoil (Myriophyllum spicatum) Purple loosestrife (Lythrum salicaria)

Other Organisms (pathogens, parasites, etc.):

Chytrid fungus (Phylum Chytridiomycota) Whirling disease (Myxobolus cerebralis)

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"To be prepared is half the victory."

(Miguel de Cervantes Saavedra, Author, Poet and Playwright)

Sometimes non-target species are obvious and easily spotted. Sometimes they are not. What are you moving? Photo Credit - USGS

Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW) HACCP Planning to Prevent the Spread of Invasive Species

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Step 4 – Non-Target Analysis Worksheet (NTAW)

At the end of Step 4, the participant will be able to:

Describe the relationship between Steps 1, 2, 3 and 4 of the HACCP Planning Process.

Evaluate the significance and severity of each non-target using risk assessment.

Define control measure, control point, and critical control point.

Determine if a control measure action is a critical control point or an optional control point.

Complete a Non-Target Analysis Worksheet using information from Steps 1, 2, and 3.

The Non-Target Analysis Worksheet (NTAW) is a pivotal step in the HACCP planning process because it determines if an activity poses a significant risk for moving invasive species or non-targets, and if so, what control measures can be applied to eliminate or reduce this risk to an acceptable level. As such, Step 4 is more complicated than the first three steps.

The…