Determine Critical Control Points (CCPs)
Aligned with HACCP Principle – Codex Alimentarius & 21 CFR 117.135
Requirement Overview
HACCP Principle 2 requires the food safety team to identify Critical Control Points (CCPs) at steps in the process where control is essential to prevent, eliminate, or reduce a food safety hazard to an acceptable level.
The determination of CCPs is foundational to building a robust food safety plan. A CCP ensures that the process can consistently control significant hazards—and failure to manage it could result in unsafe food reaching the consumer.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Identify process steps where hazards must be controlled
✓ Use a decision tree or equivalent logic to confirm CCPs
✓ Justify and document CCP designations clearly
✓ Ensure consistency across all product/process variants
Step-by-Step Compliance Implementation
1. Conduct a Thorough Hazard Analysis
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Foundation for CCP Identification:
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• Start with a complete flow diagram of the production process
• Evaluate biological, chemical, and physical hazards at each step
• Identify significant hazards that require preventive control
Evidence to Maintain:
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• Hazard analysis worksheet with severity and likelihood ratings
• Team meeting records validating hazard significance
- • Start with a complete flow diagram of the production process • Evaluate biological, chemical, and physical hazards at each step • Identify significant hazards that require preventive control
- • Hazard analysis worksheet with severity and likelihood ratings • Team meeting records validating hazard significance
2. Apply a CCP Decision Tree
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Use a Structured Approach:
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• Use a codified CCP decision tree (e.g., Codex model or equivalent)
• Ask critical control questions:
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– Does a preventive control exist?
– Is control at this step essential for safety?
– Will a later step eliminate or reduce the hazard?
Evidence to Maintain:
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• Completed CCP decision tree for each significant hazard
• Justification summaries for each CCP vs. non-CCP decision
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• Use a codified CCP decision tree (e.g., Codex model or equivalent)
• Ask critical control questions:
- – Does a preventive control exist? – Is control at this step essential for safety? – Will a later step eliminate or reduce the hazard?
- • Completed CCP decision tree for each significant hazard • Justification summaries for each CCP vs. non-CCP decision
3. Identify and Confirm Each CCP
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CCP Characteristics:
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• Must control a significant hazard
• Must be measurable or monitorable
• Must include defined limits and corrective actions
Common CCP Examples:
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• Cooking to a minimum internal temperature
• Metal detection post-packaging
• pH adjustment in acidified foods
Evidence to Maintain:
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• List of identified CCPs by process step
• Annotated flow diagram with CCPs indicated
• CCP summary table with hazard linkage
- • Must control a significant hazard • Must be measurable or monitorable • Must include defined limits and corrective actions
- • Cooking to a minimum internal temperature • Metal detection post-packaging • pH adjustment in acidified foods
- • List of identified CCPs by process step • Annotated flow diagram with CCPs indicated • CCP summary table with hazard linkage
4. Verify CCP Designations
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Team-Based Review:
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• Confirm CCPs with cross-functional HACCP team
• Evaluate product/process variations
• Review annually or when process changes occur
Evidence to Maintain:
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• CCP verification checklist
• Meeting minutes from CCP confirmation sessions
• Updated documentation when changes are made
- • Confirm CCPs with cross-functional HACCP team • Evaluate product/process variations • Review annually or when process changes occur
- • CCP verification checklist • Meeting minutes from CCP confirmation sessions • Updated documentation when changes are made
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Missing or incomplete CCP decision logic | Apply structured decision tree and retain all documentation |
| Vague CCP justifications | Clearly link each CCP to specific hazard control requirements |
| CCPs not monitored or verified | Define measurable limits and monitoring procedures |
| Inconsistent CCPs across similar products | Standardize and document CCPs with rationale across variants |