HACCP: hazard analysis and critical control points

Definition and purpose

HACCP stands for Hazard Analysis and Critical Control Points. It is a food-safety management system that shifts the focus from testing the finished product to preventing hazards along the whole process: instead of sampling the ready food, the operator anticipates where and how a hazard may arise and sets measures to prevent it, eliminate it or reduce it to an acceptable level. It is a method, not a document: the food safety management manual is merely the form in which the procedures are described and demonstrated.

History: from the space programme to the Codex

HACCP emerged in the late 1960s in the United States. The Pillsbury Company, together with NASA and the US Army laboratories at Natick, developed the method to ensure that food for astronauts was free of contamination: in space a foodborne illness would have been unmanageable, and statistical testing of the finished product offered insufficient assurance. The system was first presented publicly at the 1971 National Conference on Food Protection. From a corporate tool HACCP gradually became a regulatory benchmark: the Codex Alimentarius Commission (a joint FAO/WHO body) adopted its principles in the 1990s and embedded them in the General Principles of Food Hygiene (CXC 1-1969), updated in the 2020 revision. It is from this international codification that the EU legislator drew Article 5 of Regulation (EC) 852/2004.

The seven principles

Article 5(2) lists the seven principles that the permanent procedures must incorporate Article 5(2) of Regulation (EC) No 852/2004:

The twelve Codex steps

The Codex Alimentarius translates the seven principles into twelve application steps, the logical sequence for building a HACCP plan:

1. assemble the HACCP team;
2. describe the product;
3. identify the intended use and expected consumers;
4. construct the process flow diagram;
5. confirm the flow diagram on site;
6. list hazards and control measures (Principle 1);
7. determine the CCPs, aided by the decision tree (Principle 2);
8. establish critical limits for each CCP (Principle 3);
9. establish the monitoring system (Principle 4);
10. establish corrective actions (Principle 5);
11. establish verification procedures (Principle 6);
12. establish documentation and records (Principle 7).

The first five are preliminary tasks; the remaining seven coincide with the seven principles.

HACCP, prerequisites and flexibility

HACCP does not operate in a vacuum: it presupposes the prerequisite programmes (PRPs) — cleaning, maintenance, pest control, personal hygiene — required by Article 4 and Annex II Article 4(2) of Regulation (EC) No 852/2004. Without prerequisites under control, hazard analysis has no foundation. Recital 15 and Commission Notice 2022/C 355/01 also acknowledge that some businesses cannot identify CCPs: there, good hygiene practices may replace their monitoring. Those who develop and manage the procedures must have received adequate training Annex II, Chapter XII, point 2 of Regulation (EC) No 852/2004.