Writing a HACCP manual (food safety management plan): a practical guide

Before drafting: a system, not a certificate

Before writing a line, fix the nature of the document. Article 5 requires the FBO to put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles Article 5(1) of Regulation (EC) No 852/2004; point (g) of paragraph 2 asks for documents and records commensurate with the nature and size of the business, to demonstrate the effective application of the measures Article 5(2) of Regulation (EC) No 852/2004. The manual is that body of documents. It is neither issued nor endorsed by any body: the FBO draws it up under its own responsibility Article 17 of Regulation (EC) No 178/2002 and provides it to the competent authority in the manner that authority requires Article 5(4) of Regulation (EC) No 852/2004. Two practical consequences follow: a flawless but unimplemented manual still breaches Article 5 Article 5(1) of Regulation (EC) No 852/2004; procedures that are implemented but not documented do not discharge point (g) and are hard to prove during official controls Article 5(2) of Regulation (EC) No 852/2004.

Preliminary steps

The Codex Alimentarius HACCP method places a number of preliminary steps ahead of the seven principles, and the manual must make them traceable.

• HACCP team. Identify who develops and maintains the procedure. In micro-businesses this may be the owner alone; in every case those responsible must have received adequate training in the application of the HACCP principles Annex II, Chapter XII, point 2 of Regulation (EC) No 852/2004.
• Product description and intended use. Raw materials, ingredients, allergens, storage conditions, target consumers (including vulnerable groups). This is the precondition for identifying "any hazards that must be prevented" under point (a) Article 5(2) of Regulation (EC) No 852/2004.
• Flow diagram. It sets out every step of the process, from receipt to service or sale, and must be verified on site. A diagram that does not match reality corrupts the whole analysis from the outset.

Prerequisites as the foundation

The HACCP principles are built on prerequisite programmes: cleaning and disinfection, maintenance, pest control, personal hygiene, waste management, water supply, cold chain. These are the general and specific requirements imposed by Article 4 and Annex II Article 4(2) of Regulation (EC) No 852/2004. The manual describes them as programmes (PRPs) with their records: they are the condition for the hazard analysis to have a real footing. Commission Notice 2022/C 355/01 is explicit in placing PRPs upstream of HACCP.

The seven HACCP principles

The core of the manual applies, one by one, the seven principles of paragraph 2 Article 5(2) of Regulation (EC) No 852/2004:

Two textual points. Point (c), read with recital 15 of the Regulation, does not require a numerical limit in every case: for some CCPs an observable limit is enough. Point (f) — verification — must not be confused with monitoring: monitoring checks a single CCP in real time, whereas verification confirms that the whole system stays effective over time.

CCPs and PRPs: do not confuse them

The most common technical error is treating a prerequisite as a CCP, or the reverse. A CCP is the step at which control is essential to prevent, eliminate or reduce a hazard to acceptable levels, with a measurable, monitorable critical limit Article 5(2) of Regulation (EC) No 852/2004. A PRP is a basic, cross-cutting hygiene condition that is not tied to a critical limit of that kind. Cooking to a defined core temperature is a CCP; disinfecting work surfaces is a PRP. The decision tree exists precisely to decide, step by step, whether a CCP is present. Commission Notice 2022/C 355/01 recognises that in many businesses, once prerequisites are well managed, the actual CCPs are few or absent: the decision not to identify any must, however, be reasoned in the manual and withstand the authority's scrutiny Article 5(4) of Regulation (EC) No 852/2004.

Proportionate documentation

Point (g) builds proportionality into the text: documents and records "commensurate with the nature and size of the food business" Article 5(2) of Regulation (EC) No 852/2004. A small cafe's manual need not replicate that of an industrial plant. In practice, distinguish the documents describing the procedures (the stable part, to be kept up to date at all times) Article 5(4) of Regulation (EC) No 852/2004 from the records proving their implementation (temperature logs, cleaning records, non-conformities, training). Records must be retained "for an appropriate period", which the Regulation does not quantify Article 5(4) of Regulation (EC) No 852/2004: the practical benchmark indicated by Commission Notice 2022/C 355/01 is the shelf life of the product; detailed arrangements may specify the period Article 5(5) of Regulation (EC) No 852/2004.

Small businesses and guides to good practice

For simple operations, drafting becomes lighter. Guides to good practice, voluntary in use, help operators apply the HACCP principles Article 7 of Regulation (EC) No 852/2004: they are developed by the sectors Article 8(1) of Regulation (EC) No 852/2004 and may be assessed at Union level Article 9(1) of Regulation (EC) No 852/2004. A business writing its own manual can build on a validated sectoral guide, adapting it to its activity: it is an aid, not a substitute for the in-house document. Where no CCP can be identified, well-managed prerequisites and good hygiene practices can form the core of the plan, with reduced but traceable records: see flexibility for small businesses. A hazard analysis is still required.

Updating the plan

The manual is not static. The second subparagraph of paragraph 2 requires the procedure to be reviewed and the necessary changes made whenever the product, process or any step changes Article 5(2) of Regulation (EC) No 852/2004; paragraph 4 requires the documents describing the procedures to be kept up to date at all times Article 5(4) of Regulation (EC) No 852/2004. Updating is therefore event-driven: a new supplier, new equipment, a new menu, the start of delivery. The periodic verification of effectiveness — point (f) — is itself a moment of plan maintenance. For the other obligations of a food business, see the obligations section.