HACCP plan review checklist

Preliminary steps (Codex steps 1 to 5)

• A HACCP team is named in writing, with the skills the product needs (production, QA, engineering, microbiology or an outside specialist) and a trained team leader (SANS 10330:2020; Codex CXC 1-1969).
• The scope states which products, lines and sites the plan covers and where it starts and ends.
• Each product or product group has a written description: composition, physical and chemical properties (pH, water activity, preservatives), processing, packaging, shelf life, storage and distribution conditions.
• The intended use names the consumer, including vulnerable groups (infants, the elderly, pregnant women, the immunocompromised) and any foreseeable misuse.
• The flow diagram shows every step from receiving to dispatch, including rework, waste, water, air and packaging inputs, delays and returns.
• The flow diagram has been confirmed on the floor, on every shift, and the confirmation is signed and dated.

Hazard analysis and CCPs (principles 1 and 2)

• Every step lists the biological, chemical (including allergens), physical and radiological hazards that are reasonably likely, with the source of each.
• Each hazard is scored for likelihood and severity using a documented method, and the score is defended with evidence (literature, history, complaints, test results).
• Control measures are named for each significant hazard, and each one is a prerequisite programme, an operational PRP or a CCP, with the reasoning recorded.
• CCPs are determined with a decision tree or an equivalent documented method, and the decision for each step is kept on file.
• Allergen cross-contact has been assessed as a hazard at receiving, storage, scheduling, changeover and rework.

Limits, monitoring and corrective action (principles 3 to 5)

• Every CCP has a measurable critical limit with a documented basis (regulation, standard, validated study or supplier data), not a borrowed figure.
• Where an operational limit is tighter than the critical limit, both are written down and staff know which one triggers what.
• Monitoring states what is measured, how, how often, by whom and on which record, and the frequency is enough to catch a deviation before the product leaves control.
• The instruments used for monitoring (thermometers, metal detectors, pH meters, timers) are on the calibration schedule and the last calibration is in date.
• Corrective action for each CCP covers the product (hold, evaluate, rework, reject), the process (bring it back into control) and the record, with the person authorised to release product named.
• Deviations in the last twelve months were handled as the plan says, and the records show it.

Verification, validation and records (principles 6 and 7)

• Each control measure has been validated: evidence that it achieves the limit in your process, before it was relied on (SANS 10330 and ISO 22000 both require this).
• Verification activities are scheduled: record review, calibration checks, internal audit, product and environmental testing, and complaint trends, with the results reviewed by the team.
• The plan has been reviewed within the last twelve months and after every change to product, process, equipment, supplier, layout or regulation, and the review is minuted.
• Records are legible, signed, dated, kept for the period the scheme or customer requires, and can be produced within the time a recall needs.
• Operators at each CCP can explain the limit, the monitoring and what they do when it fails, without reading it off the wall.
• Where the business is designated under R908 of 2003, the HACCP system meets that regulation; otherwise the plan is held to SANS 10330:2020 and the scheme or customer requirement.