HACCP the Codex way: seven principles, twelve steps, real records
Most weak HACCP plans fail before the first CCP: the flow diagram does not match the floor, or hygiene basics are missing. Start there.
In Short
- Good hygiene practices come first; HACCP sits on top.
- A CCP is essential to control a significant hazard, not every check.
- Corrective actions are decided before a deviation, not during it.
The Food Processing Operations Guide
Safe changeovers. Right labels. Every lot traceable.
- The rules and the plan
- Supplier to filled tray
- Allergen changeovers and pack checks
- Trace, recall and record review
Plus Evidence map and four worksheets.
Get the food processing guideWe ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.
UltimateFree guide
The Food Processing Operations Guide
Safe changeovers. Right labels. Every lot traceable.
The Codex Alimentarius General Principles of Food Hygiene (CXC 1-1969, revised in 2020 and amended since) set out good hygiene practices and the HACCP system. Codex texts are international standards adopted by FAO and WHO members; they become binding when a country writes them into law or a buyer writes them into a contract. Many food laws and certification schemes build on them. This guide explains how the system fits together. Check your own market's rules, such as FDA's seafood and juice HACCP rules or USDA FSIS rules for meat and poultry, which have their own requirements.
Good hygiene practices come first
The 2020 revision puts good hygiene practices (GHPs) at the base: premises, equipment, cleaning, pest control, personal hygiene, supplier control, training and food safety culture. Some GHPs need greater attention because they are important to food safety, such as allergen cross-contact controls.
More on good hygiene practices come first
HACCP is built on top of working GHPs, not instead of them.
Twelve Steps, Seven Principles
Codex lists twelve steps for applying HACCP: assemble the team and identify scope; describe the product; identify intended use and users; construct a flow diagram; confirm it on site; then the seven principles. The principles are: conduct a hazard analysis and identify control measures; determine critical control points (CCPs); establish validated critical limits; establish monitoring; establish corrective actions; validate the plan and establish verification procedures; and establish documentation and record keeping.
The Twelve Steps
- 1Assemble the HACCP team and identify scope
- 2–3Describe the product; identify intended use and users
- 4–5Construct the flow diagram and confirm it on site
- 6Principle 1: hazard analysis and control measures
- 7–8Principles 2–3: determine CCPs; validated critical limits
- 9–10Principles 4–5: monitoring; corrective actions
- 11–12Principles 6–7: validation and verification; documentation
Hazard Analysis and CCPs
The team lists biological, chemical (including allergens) and physical hazards reasonably likely at each step, considers their likelihood and severity, and identifies control measures. A CCP is a step where control is applied and is essential to prevent or eliminate a significant hazard or reduce it to an acceptable level.
More on hazard Analysis and CCPs
Not every control is a CCP; others may be managed as GHPs needing greater attention.
Limits, Monitoring and Corrective Action
Each CCP has validated critical limits, such as a time and temperature. Monitoring is planned so that a loss of control is detected in time to act, with records signed by the person who monitored.
Worked Example: a Cooking CCP Deviation
- 10:05Core temperature 68 °C against a critical limit of 72 °C for batch K-311Line operator
- 10:06Batch held; cooking extended per the predetermined corrective actionLine operator
- 10:20Recheck 74 °C recordedLine operator
- 10:45Oven probe found faulty; replaced and checkedMaintenance
- 11:30QA reviews records and decides batch dispositionQA
More on limits, Monitoring and Corrective Action
When monitoring shows a deviation, predetermined corrective actions bring the CCP back under control and deal with the affected product. People decide product disposition and record why.
Validation, Verification and Review
Validation checks before use that control measures can control the hazard. Verification checks during operation that the system works as planned: record review, calibration, sampling and audits.
More on validation, Verification and Review
The plan is reviewed when anything changes, such as a new ingredient, process or equipment, and periodically.
Also relevant: Food Safety Control & Traceability Buyer Guide (14-page PDF, on the Food Safety page).
Questions
Is Codex HACCP a legal requirement?
Codex texts are international standards. They become legal requirements when a country adopts them into law or when they are written into contracts or certification schemes. Many national food laws reference HACCP principles.
What changed in the 2020 revision?
The 2020 revision of CXC 1-1969 restructured the text, introduced the idea of good hygiene practices needing greater attention, added food safety culture and allergen management, and clarified validation and verification.
How many CCPs should a plan have?
As many as the hazard analysis justifies, and no more. Too many CCPs dilute attention; too few leave significant hazards uncontrolled.
Is HACCP the same as FSMA preventive controls?
No. FSMA preventive controls under 21 CFR Part 117 share HACCP's principles but are broader, covering allergen, sanitation and supply-chain controls and a recall plan beyond CCPs.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
Food CGMP Readiness: Daily Checks and Evidence
EU Acrylamide Regulation 2017/2158: Mitigation, Sampling and Benchmark Levels
BRCGS Food Safety Issue 9 Guide: Culture, HACCP, Traceability and Audits
Cronobacter in Powdered Infant Formula: Part 106 Testing and FDA's Prevention Actions
21 CFR 106 Infant Formula CGMP Guide: Release, Testing and Traceability
Food Allergen Control: US Labeling and Bakery Readiness