Principle 2: Determine the Critical Control Points (CCPs)
What does this mean?
A Critical Control Point (CCP) is a step at which control can be applied and is essential to prevent or eliminate a food safety hazard, or reduce it to an acceptable level.
How is this stage achieved?
The correct determination of CCPs is vital to ensure that there is effective management of food safety. The number of CCPs in a process will depend on the complexity of the process itself and the scope of the study (for example, whether there are just a few types of hazard, or lots of different hazards).
CCPs should be determined through experience and judgement; this may be aided by the use of a decision tree.
If you decide to use a decision tree
There are many different decision trees to choose from. The MyHACCP tool shows you the Codex decision tree or Campden BRI decision tree, but you are not restricted to using these. You can use a decision tree of your choice, some businesses devise their own.
Using the Campden BRI decision tree, Process steps where hazards are effectively controlled by prerequisite food hygiene requirements will not be identified as CCPs. Using this tree will therefore typically generate fewer CCPs than the Codex decision tree. Your prerequisite food hygiene requirements will need to be well developed, implemented and maintained to ensure continued safe production of food. For example, if you take the physical hazard glass and run it through both decision trees, the Codex tree will identify it as a CCP whereas the Campden BRI decision tree will not, as long as effective prerequisite requirements are in place to control it.
Using MyHACCP to work through a decision tree (Codex or Campden BRI’s)
Apply the HACCP decision tree (whichever one you use) to each hazard at each process step. You will be prompted to record responses to the questions (yes or no). Campden BRI decision tree has 6 questions: Q1,Q2,Q2a,Q3,Q4,Q5 whereas the Codex decision tree has 5 questions: Q1, Q1a (N.B. Q1a 'Is control at this step necessary for safety?' is not identified by a number on the tree), Q2,Q3,Q4.
If using the Codex Decision Tree the following guidance to each question may help.
- Q1. Do control preventative measure(s) exist? This refers to control measures.
- Q2. Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level? This refers to the process step (not the controls).
- Q3. Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable levels? Think about this in terms of 'if you lost control'.
- Q4. Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level? This refers to whether there is another process step further on in the process flow diagram that will eliminate identified hazard(s) or reduce likely occurrence to an acceptable level.
You should keep a record of the decision tree you use and the reasons for your answers to each of the questions asked.
If in doubt over the answer to a question, assume the worst situation until you have evidence to say otherwise.
If no CCPs are identified, you should look again at the decision tree you used and check your answers to the questions, in case you have missed anything. However, if you are using Operational Pre-Requisite Programmes (OPRP), these may be controlling some significant hazards in your process. Operational Pre-Requisite Programmes are broad controls (for example, temperature control) which may be critical to food safety.
Documentation and Records
You should keep evidence of how you determined whether control of each hazard is a CCP or not. If your decisions are based on the experience and judgment of HACCP team members, you should document their experience and the reasons for the judgments made, for every hazard you considered.
If you are using a decision tree to help with this decision-making process, you should keep a copy of the decision tree you use.