HACCP stands for "Hazard Analysis and Critical Control Points". It is a method for preventing problems before they reach the plate, instead of finding out when somebody falls ill.
What the law requires
Article 5 of Regulation (EC) 852/2004 says that the FBO must put in place, implement and maintain permanent procedures based on the HACCP principles. In Italy this is also called autocontrollo (self-control). The FBO must be able to show the inspection authority that it has done so. Administrative penalties for failing to do so are set out in Legislative Decree 193/2007.
Prerequisites first
Before the HACCP system you need basic good hygiene practices, also called prerequisites: suitable premises, cleaning and sanitation, pest control, staff hygiene, training, a potable water supply, waste management, traceability and the cold chain. For many small premises the prerequisites cover most of the risks.
The seven principles
Article 5(2) lists the seven principles:
- Identify the hazards to be prevented, eliminated or reduced to acceptable levels.
- Identify the critical control points (CCPs): the steps where the hazard can and must be controlled.
- Establish critical limits: the values that separate a safe product from an unsafe one.
- Establish monitoring procedures for the CCPs.
- Establish corrective actions for when monitoring shows that a CCP is not under control.
- Establish verification procedures to confirm that the system works.
- Prepare documents and records suited to the nature and size of the business.
An example
A kitchen prepares roast chicken.
- Hazard: Salmonella may be present in the raw meat.
- CCP: cooking.
- Critical limit: a core temperature set by the plan (for example +75 °C).
- Monitoring: the core temperature is measured with a probe.
- Corrective action: if it does not reach the value, cooking continues.
- Verification: the person in charge periodically checks the thermometer's calibration and the records.
- Record: the values are noted on the sheet.
Who makes the plan
The FBO is responsible for the plan. It can do it alone or with a consultant, but must know it and apply it. Whoever develops and maintains the HACCP procedures must have received adequate training in the HACCP principles (Annex II, Chapter XII). The plan starts from your own premises: the same foods in two different kitchens may need different controls.
Flexibility for small businesses
The law allows the method to be adapted to the size and risk of the business. Small, low-risk businesses can have simpler procedures, as long as they ensure safety. One help is the manuals of good hygiene practice (good practice guides, Articles 7 and 8 of Regulation 852/2004) prepared by trade associations and authorities. The European Commission guidance (notice 2022/C 355/01) explains how to apply prerequisites and HACCP proportionately, but is not binding.
Records
The most common records:
- temperatures of fridges, freezers and cooking;
- checks on incoming goods;
- cleaning and sanitation;
- staff training;
- maintenance and calibration of instruments;
- corrective actions and problems found.
A record must be true, legible and made at the time. Filling in the sheets afterwards, from memory, is a serious mistake: the plan exists to protect, not to fill in paperwork.
When to update the plan
Update it when the menu, recipes, suppliers, equipment, premises or the law change, and after a problem. A plan left in a drawer protects nobody.
Remember
- HACCP prevents problems with 7 principles.
- Prerequisites come before the HACCP system.
- The CCP is the point where control prevents the hazard.
- Records must be true and made at the time.