Determining CCPs

At step 7 the team considers which of the control measures listed at step 6 should be applied at a CCP. CCPs are determined only for hazards identified as significant. They are set at steps where control is essential and where a deviation could result in a potentially unsafe food. The control measures at CCPs should result in an acceptable level of the hazard being controlled.

A decision tree can help. Codex says one should be flexible, and that other approaches, such as a CCP determination worksheet or expert consultation, may be used. Annex IV, added in 2022, gives this example, to be applied to each step where a specified significant hazard is identified.

Question 1: can the significant hazard be controlled to an acceptable level at this step by prerequisite programmes such as GHPs? If yes, this step is not a CCP. If no, continue. Codex notes that you should consider the significance of the hazard, and that GHPs may be routine or may need greater attention, such as monitoring and recording.

Question 2: do specific control measures for the identified significant hazard exist at this step? If no, this step is not a CCP, and later steps should be evaluated. If yes, continue.

Question 3: will a later step prevent or eliminate the hazard, or reduce it to an acceptable level? If yes, that later step should be a CCP. If no, continue.

Question 4: can this step specifically prevent or eliminate the hazard, or reduce it to an acceptable level? If yes, this step is a CCP. If no, modify the step, process or product to implement a control measure, then return to the start after a new hazard analysis. Codex also notes that if a control measure works in combination with one at another step to control the same hazard, both steps should be considered as CCPs.

Older training uses a differently worded tree, so check which one your plan is based on. Whichever you use, record your answers. The tree supports judgement. It does not replace it.

Now apply the tree to the pies. Take Salmonella at goods-in for raw mince. Question 1: prerequisites such as supplier approval cannot control it to an acceptable level. Question 2: no specific control exists at this step that would deal with it. So goods-in is not a CCP for this hazard, although it is still an important check.

Take the cook step. Question 1: no. Question 2: yes, heat. Question 3: will a later step deal with it? The care home will reheat the pies, but the producer cannot rely on a step outside its control, particularly for food going to vulnerable people. So the answer is no. Question 4: yes. The cook step is a CCP.

Take cooling. Clostridium perfringens can form spores that survive cooking. Codex gives a similar example: the cook step may be the CCP for killing active cells, while the cooling step may be a CCP to prevent germination and growth of the spores. The cook step and the cooling step work in combination, so both are CCPs.

Take labelling. Undeclared milk is a significant hazard. Question 1: label control procedures help, but the team judges that they cannot control the hazard alone, because several pie recipes run on the same line. Question 2: yes, a check of the label against the product at the start of each run. Question 3: nothing later will correct a wrong label. Question 4: yes. Labelling is a CCP. Another business, making only one product with one label, might reasonably decide differently and treat this as a GHP that needs greater attention. That is why reasoning matters more than the answer alone.

Glass from a light fitting was not significant, so it does not enter the tree. It stays under prerequisites.

Be alert to two opposite failures. One is CCP inflation, where every check is called a CCP. Attention is spread thinly, and real CCPs lose their force. The other is avoiding CCPs to reduce the workload. Neither is acceptable. There is no correct number.

A plan may have no CCPs at all. Recital 15 accepts that this can happen in certain businesses. Codex says that where a business decides no CCPs are needed, a periodic review should check whether that has changed.

Summarise the results in a HACCP worksheet, as in Annex IV, Table 2, of the Codex text. Its columns are CCP, significant hazards, critical limits, monitoring (what, how, frequency and who), corrective actions, verification activities and records. Mark each CCP on the flow diagram.