Monitoring Procedures for Critical Control Points (CCPs)

Aligned with HACCP Principles – Codex Step: Establish Monitoring Procedures for Each CCP

Requirement Overview

According to HACCP guidelines (Codex Alimentarius and 21 CFR Part 117 Subpart C), each Critical Control Point (CCP) must have defined monitoring procedures to ensure that food safety limits are consistently met. Monitoring provides real-time assurance that preventive controls are functioning effectively to eliminate or reduce food safety hazards.

Consistent monitoring supports timely decision-making, helps prevent unsafe product release, and ensures regulatory and certification compliance.

Note: Monitoring procedures must be measurable, documented, and performed at a frequency sufficient to maintain control.

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

  • Ensure that CCPs remain within critical limits

    Detect process deviations before they impact food safety

    Assign qualified personnel to conduct accurate, timely monitoring

    Document all results and take immediate corrective actions when necessary

Step-by-Step Compliance Implementation

1. Identify Monitoring Requirements for Each CCP

  • Monitoring Plan Must Include:

    • What will be monitored (e.g., temperature, pH, time)

      How the monitoring will be done (method)

      Who is responsible (person or role)

      When and how often monitoring occurs (frequency)

    Evidence to Maintain:

    • CCP monitoring sheets

      Equipment calibration records

      Monitoring SOPs and job descriptions

2. Establish Clear Monitoring Methods

  • Examples of Monitoring Methods:

    • Manual checks (e.g., thermometer readings)

      Continuous monitoring (e.g., data loggers, sensors)

      Visual inspections (e.g., package integrity, seal verification)

    Evidence to Maintain:

    • Monitoring records with initials/signatures

      Equipment usage logs

      Visual inspection logs

3. Train Monitoring Personnel

  • Training Must Cover:

    • Proper monitoring technique

      Correct documentation

      Immediate steps to take if a deviation occurs

    Evidence to Maintain:

    • Training attendance sheets

      Competency verification records

      Updated SOPs reviewed by employees

4. Verify Monitoring Effectiveness

  • Verification Activities May Include:

    • Review of monitoring logs

      Supervisor observation of monitoring practices

      Cross-checking monitoring results with calibration records

    Evidence to Maintain:

    • Verified monitoring records

      Internal audit reports

      Review logs by food safety team or QA

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No documentation of CCP monitoring Implement and maintain daily monitoring logs
Monitoring done incorrectly Retrain personnel and document updated procedures
Inadequate frequency Adjust schedule based on process risk and HACCP plan requirements
Failure to take action on deviation Add escalation procedures and corrective action triggers

Auditor Verification Checklist

During an audit, be prepared to provide:

  • Documented monitoring procedures for each CCP

    Monitoring records with dates, times, and personnel signatures

    Evidence of timely corrective actions for deviations

    Verification records and internal audit findings

Implementation Roadmap

Build Monitoring Framework

  • Identify all CCPs and define specific monitoring methods

    Assign responsible personnel and establish schedule

Train and Empower

  • Provide monitoring SOPs and hands-on training

    Reinforce awareness of critical limits and corrective actions

Monitor and Record

  • Conduct monitoring consistently at required intervals

    Complete monitoring logs with clarity and accuracy

Verify and Improve

  • Regularly review records for trends or noncompliance

    Adjust monitoring practices based on audit findings and incidents

Why This Matters?

  • Ensures that food safety hazards remain under control

    Prevents unsafe product from reaching the consumer

    Strengthens audit readiness and traceability

    Builds confidence in regulatory and GFSI scheme compliance

Support Tools Available

Food Safety Systems offers:

  • CCP monitoring record templates

    Role-specific monitoring SOPs

    Real-time data capture tools and logbooks

    Training kits for QA and production staff