HACCP cheat sheet

Codex HACCP is delivered in 12 steps: 5 preliminary tasks (assemble the team, describe the product, identify intended use, construct the flow diagram, verify the diagram on site) followed by the 7 principles.

The 7 principles in fixed order: hazard analysis; determine CCPs; establish critical limits; establish monitoring; establish corrective actions; establish verification procedures; establish documentation and recordkeeping.

PRPs are the environmental and operational conditions needed for a hygienic operation - potable water, cleaning and sanitation (SSOPs), pest control, personnel hygiene, training, maintenance, allergen control, supplier approval, traceability and recall - and are managed separately from the HACCP plan.

A HACCP plan is site-specific: it must match actual equipment, layout, formulation and process flow; generic or copied plans fail verification and are a common audit finding.

Decision rule: a hazard reliably controlled by a PRP generally needs no CCP; where PRP control is variable, unmonitored or unverifiable, the step becomes a candidate CCP in the hazard analysis.

Hazard categories in scope: biological (pathogens, viruses, parasites, toxins), chemical (residues, allergens, mycotoxins, packaging migrants, process-induced chemicals) and physical (glass, metal, bone, hard plastic); radiological and allergen hazards are frequently tracked as separate categories.

Management commitment is a documented system requirement: a food safety policy, defined responsibilities and authority, allocated resources, and a designated HACCP team leader with cross-functional membership.

HACCP is not a zero-risk tool: it targets the significant hazards identified in the hazard analysis and depends on validated control measures plus functioning PRPs for everything else.

Hazard analysis produces two outputs: a list of hazards reasonably likely to occur at each step, and a written justification of significance for each hazard that names the control measure applied.

Significance decision rule: a hazard is significant when it can occur at an unacceptable level with reasonable likelihood and cause illness or injury; purely hypothetical hazards are excluded, but the exclusion must be justified in writing.

Risk characterization = likelihood of occurrence × severity of outcome; severity weighs dose, pathogen virulence and the susceptibility of the intended consumer.

Sources for hazard identification: peer-reviewed literature, outbreak and epidemiological data, regulatory limits and guidance, historical recalls, customer complaints, supplier specifications, and challenge or inactivation studies.

Analyze raw materials and inputs, every process step, equipment surfaces, personnel, rework, packaging, storage and distribution; consider pathogen survival, growth and cross-contamination routes at each point.

Consider intrinsic factors (pH, water activity, salt, preservatives, redox potential), extrinsic factors (time, temperature, atmosphere) and process steps (heating, chilling, acidification, drying, fermentation).

Intended use and consumer must be explicit: ready-to-eat foods, foods for vulnerable groups, and foods likely to be temperature-abused after purchase carry higher assigned risk.

The documented hazard analysis is the audit trail: it must support every CCP decision, including documented reasons why steps were not designated as CCPs.

CCP definition: a step at which control can be applied and is essential to prevent, eliminate or reduce a significant hazard to an acceptable level.

Codex decision tree applies four questions in sequence: are control measures in place? does the step eliminate or reduce the hazard to an acceptable level? could contamination occur or increase above acceptable levels? will a later step eliminate the hazard or reduce it to acceptable levels?

Critical limits must be objective, measurable and validated - for example 72 °C for 15 s pasteurization, pH ≤ 4.6, water activity ≤ 0.85, a defined retort time-temperature schedule, or metal detection at 1.5–2.0 mm ferrous.

Operating limits are set tighter than critical limits (for example a 75 °C target against a 72 °C critical limit) so process drift triggers adjustment before a deviation occurs.

Monitoring may be continuous or discontinuous; continuous records (temperature charts, metal detectors) capture every excursion but still require periodic verification against a calibrated reference instrument.

A critical limit must rest on validated science - challenge studies, published D- and z-values, regulatory standards or recognized process authorities; unvalidated limits fail verification.

Minimize the number of CCPs by strengthening PRPs; an excessive CCP count dilutes resources and usually signals incomplete prerequisite programs or an unfocused hazard analysis.

Each CCP requires a written monitoring procedure stating what is measured, how, when, where and by whom, plus the record that the measurement generates.

Monitoring determines whether a critical limit is met at a CCP; frequency must be sufficient to detect loss of control before product is affected, or the measurement must be continuous.

Monitoring record content: CCP identity, date and time, measured value or observation, equipment ID, the person performing the check, and the reviewer's signature.

Corrective action has four elements: restore control, determine and eliminate the root cause, decide disposition of affected product, and record the action with evidence of verification.

Deviation handling: hold and segregate all product produced since the last compliant check (or throughout the deviation), evaluate its safety, then release, rework, reprocess or destroy with documented justification.

Out-of-calibration monitoring equipment invalidates prior readings: trace back to the last successful calibration and evaluate all product produced in that window.

Corrective action records must be signed, dated and verified by someone other than the operator; a repeated corrective action triggers reassessment of the HACCP plan.

Monitoring must be performed by trained, named personnel who hold documented authority to stop the line and place product on hold.

When monitoring is continuous, records must still show operator verification checks at defined intervals (for example hourly or per batch) against a calibrated reference.

Validation answers "will this work?" - it collects scientific and technical evidence, before or during implementation, that the control measures and critical limits achieve the intended hazard reduction.

Verification answers "is it working?" - record review, calibration, audits, environmental and product testing, and deviation review confirm the system operates as designed.

Verification activities include review of monitoring and corrective action records, calibration records, direct observation of CCP monitoring, sampling and testing, and internal audits.

Record review must be independent: a trained person other than the record's originator reviews and signs at a defined frequency.

Reassessment triggers: change in raw material, formulation, process, equipment, packaging, supplier or intended use; new hazard information; a recall; a trend of deviations; and at minimum an annual review.

Retention periods: records are generally kept beyond product shelf life; US 9 CFR 417.5 sets 1 year for perishable and 2 years for shelf-stable product records, and EU rules require retention beyond shelf life.

Core documents: hazard analysis, CCP and critical limit rationale, monitoring and corrective action records, verification logs, calibration records, training records, supplier approvals, and the recall/traceability plan.

Records must be dated, signed by the responsible person, legible, and stored so they can be retrieved within the timeframe regulators or customers require during a recall (commonly 24 hours).