What is a HACCP plan, and which text is it based on?

A HACCP plan sets out, for a given product and process, the significant hazards, the steps where they are controlled, the limits to respect, monitoring, corrective actions and verification. It applies the HACCP method (Hazard Analysis and Critical Control Point) described by the Codex Alimentarius, the joint FAO and WHO food standards commission.

The reference text is the General Principles of Food Hygiene, CXC 1-1969, last revised in 2022, listed among the Codex texts. It has two chapters. The first covers good hygiene practices (GHPs): premises and equipment, cleaning and disinfection, pest control, personal hygiene, control of operations, transport and training. The second covers the HACCP system and its application. The substantive revision dates from 2020, and the text was revised again in 2022; it can be read in the Codex codes of practice list. The principles and steps below are summarised in our own words: only the Codex text is authoritative.

GHPs come first. A HACCP plan built on poorly cleaned premises or uncontrolled water does not hold: it ends up classifying basic hygiene as CCPs. For a buyer, this is the first thing to read in a supplier’s file.

Element

What it is

Where we cover it

Good hygiene practices (prerequisite programmes)

Basic conditions: premises, water, cleaning, pests, personnel

This page; food safety programmes

HACCP plan

Significant hazards, CCPs, critical limits, monitoring, corrective actions, verification

This page

ISO 22000:2018

Food safety management system standard that includes HACCP and distinguishes CCPs and OPRPs

ISO 22000 certification

FSSC 22000, BRCGS, IFS

GFSI-recognised certification programmes, all built on a HACCP plan

FSSC 22000, BRCGS certification, IFS certification

ONSSA approval or authorisation

The plant’s legal obligation in Morocco under Law 28-07

Further down this page

What are the 7 Codex HACCP principles?

Conduct a hazard analysis, determine the CCPs, set validated critical limits, monitor, take corrective action, validate then verify, and document. The table shows what an inspector, a buyer or an auditor will ask you to show for each.

Principle

What it requires

What you will be asked to show

1. Hazard analysis

Identify hazards at each step, retain the significant ones, define control measures

A justified hazard analysis and its sources: site history, complaints, scientific data, destination-country regulations

2. Critical Control Points (CCPs)

Determine the steps where a measure is essential to control a significant hazard

The written reasoning behind each classification

3. Validated critical limits

Set for each CCP a criterion that separates acceptable from unacceptable, and prove it works

The validation file: studies, trials, literature, regulatory limits

4. Monitoring

Measure or observe each CCP often enough to react in time

Records completed at the time of the check and signed

5. Corrective actions

Plan what happens when a limit is missed: restore control, isolate and assess the product

Deviation records and the fate of each affected batch

6. Validation and verification

Validate the plan before applying it, then verify it works as intended

The verification programme: record review, calibration, testing, internal audits

7. Documentation

Keep documents and records proportionate to the size of the business

The list of current documents and record retention times

Two points make the difference in an audit. Validation: a critical limit borrowed from another plant, with no evidence that it controls your hazard in your product, is not validated. Management commitment: the auditor reads it in the resources given to the HACCP team and in the decisions taken after a deviation.

How do you work through the 12 Codex steps?

The first five steps prepare the study; the last seven apply the seven principles one by one. Skipping the preliminary steps is the costliest mistake: a hazard analysis built on a wrong flow diagram is wrong. The step names below follow the sequence in the FAO good hygiene practices and HACCP toolbox.

Step

What it produces

Common gap we find

1. Assemble the HACCP team and define the scope

A multidisciplinary team, a written scope

The team is the quality manager alone

2. Describe the product

Composition, safety-relevant characteristics, packaging, shelf life, storage and distribution

A sales sheet instead of a safety description

3. Identify intended use and users

Target consumers, vulnerable groups, foreseeable misuse

Use in the destination market is not considered

4. Construct the flow diagram

All steps, inputs of materials, water and packaging, rework, outsourcing

Water and rework are missing

5. Confirm the flow diagram on site

A diagram checked during production, dated and signed

A diagram drawn in the office

6. Conduct the hazard analysis (principle 1)

Significant hazards and their control measures

A generic list, identical for every product

7. Determine CCPs (principle 2)

The classification of each measure

Everything is a CCP, or nothing is

8. Establish validated critical limits (principle 3)

One limit per CCP with its validation evidence

Limits copied from a template

9. Monitor each CCP (principle 4)

Method, frequency, responsibility, record

A frequency that cannot trace the affected product

10. Establish corrective actions (principle 5)

What happens to the process and the product after a deviation

“Inform the supervisor” as the only action

11. Validate the plan and set verification (principle 6)

A validated plan and a verification programme

Verification reduced to signing records

12. Documentation and record keeping (principle 7)

The system’s documents and records

Documents with no version or date

How these steps map to the clauses of ISO 22000:2018 is covered on our ISO 22000 certification page.

Hazard analysis works step by step and hazard by hazard, estimating the likelihood of occurrence without control and the severity of the effects. Four families are reviewed: biological (pathogens and their toxins, viruses, parasites, and substances such as histamine formed in some fish), chemical (residues, contaminants, cleaning chemicals, migration from packaging), allergens (in the recipe or from cross-contact) and physical (metal, glass, hard plastic, wood, bone). A hazard is significant when it is reasonably likely to occur at an unacceptable level without control, given the intended use. Food fraud and food defence are assessed separately, as the GFSI standards require: see our food safety programmes.

CCP, OPRP or good hygiene practice: how do you classify a control measure?

By the significance of the hazard and the role of the measure. Ordinary GHPs maintain basic conditions, an enhanced measure controls a significant hazard without a critical limit, and a CCP is the step where an essential measure is applied with a validated critical limit. The Codex and ISO 22000 describe the same ladder with different words.

Level of control

Codex term (CXC 1-1969)

ISO 22000 and FSSC 22000 term

When the measure fails

Basic conditions

Good hygiene practices

Prerequisite programmes (PRPs)

Correction, no significant hazard targeted

Enhanced measure

GHPs that need greater attention

Operational prerequisite programme (OPRP), with a measurable or observable action criterion

Correction and assessment of the effect on the product

Critical point

CCP, with a validated critical limit, measurable or observable

CCP, with a measurable critical limit

Product treated as potentially unsafe: isolated, assessed, then released, reprocessed or destroyed

BRCGS Food Safety and IFS Food work with Codex CCPs and prerequisite programmes; check the vocabulary of your own standard. A decision tree helps, but it is a tool, not a requirement, and its answer must stay consistent with the hazard analysis. The errors we see most often are a plan where every step is a CCP, “monitoring” that arrives after dispatch (that is verification), critical limits with no validation, OPRPs with no action criterion, and corrective actions that fix the machine but forget the product made since the last good check.

What does a HACCP plan look like for a fish cannery?

Short on CCPs and precise on their evidence. The example below is generic: it illustrates the method for a Moroccan sardine, mackerel or tuna cannery, with no figures. Your limits, frequencies and classifications must come from your own hazard analysis and validation.

The typical flow runs from receipt of fresh or frozen fish through chilled or iced storage, thawing, heading and gutting, brining, pre-cooking, filling, oil or sauce addition, seaming, can washing, sterilisation, cooling, labelling, storage and dispatch, including the water and empty-can circuits.

Step

Main hazard

Control measure

Typical classification, to be justified

Monitoring

If a deviation occurs

Fish receipt

Histamine formed during a cold-chain break upstream, in the species concerned

Assessed suppliers and vessels, temperature at receipt, sensory check, testing to a sampling plan

CCP or OPRP depending on the site’s analysis

Temperature of each delivery, results per lot

Lot rejected or isolated, then assessed

Chilled or iced storage

Bacterial growth, histamine formation

Control of temperature and storage time

OPRP, or GHP needing greater attention

Temperature record

Exposed lots assessed

Seaming

Seal failure, then recontamination after sterilisation

Seamer set-up, regular visual checks, seam teardown

CCP or OPRP depending on the site’s analysis

Checks per seamer and per head at a set frequency

Output held back to the last good check, seamer reset, product assessed

Sterilisation

Survival of Clostridium botulinum and other spore-formers

Scheduled process validated per can format and recipe, retort loading and operation

CCP

Record of each cycle, reviewed before release

Off-schedule cycle: batch isolated and assessed by a competent thermal process person

Cooling

Recontamination by water through a seam defect

Treated cooling water, residual chlorine checked

OPRP, or GHP needing greater attention

Residual chlorine at a set frequency

Water corrected, batches cooled during the deviation assessed

Labelling

Undeclared allergen in a sauce, wrong lot or date

Label check at start-up and at each changeover

OPRP, or GHP needing greater attention

Documented check

Labels removed, product reworked

The scheduled process is never copied: a person or body competent in thermal processing establishes and validates it for each format and recipe, and any change of format, fill or retort calls it into question. Seaming and cooling water protect what sterilisation achieved. Fish is itself a declarable allergen, and sauces may add others. The Codex sector codes of practice on fish and fishery products and on low-acid canned foods support this analysis; they are in the Codex list of codes of practice, where their latest revision should be checked before citing them in a plan.

How does ONSSA approval relate to the HACCP plan?

ONSSA sanitary approval (agrément) or authorisation (autorisation) is the plant’s legal obligation; the HACCP plan is the technical core of what it must be able to show; certification comes afterwards. According to ONSSA, food and animal feed businesses must be approved and/or authorised on sanitary grounds.

Text cited by ONSSA

Subject

What we check in a diagnostic

Law 28-07

Sanitary safety of food products

The plant holds its approval or authorisation number

Decree 2-10-473

Implementation of certain provisions of Law 28-07

The regime matches the plant’s real activities

Order 2768-12 of 1 August 2012

Activity code and prefecture or province code

Declared activities cover the whole future certification scope

Order 244-13 of 16 January 2013

Sanitary authorisation and approval

The file still describes current buildings, lines and products

Procedure code CP 05/DCPV/14

Granting, suspension and withdrawal of approvals and authorisations

Nothing in day-to-day practice exposes the plant to suspension

The application is filed with the ONSSA inspection service of the province where the plant is located, with an administrative part and a technical part, and separate files for approval and for authorisation. Issue leads to an approval or authorisation number, and ONSSA publishes lists of approved and authorised establishments. The split between the two regimes is set by Article 4 of Decree 2-10-473 (in French): activities in the categories of its annex require approval, such as meat and meat products, milk and dairy products, fishery products, chilled storage of products of animal origin, juices and nectars, or heat-treated canned vegetables; all others require authorisation. The process decides: olives in brine fall under authorisation, while the same olives sterilised in jars become a heat-treated canned product. If in doubt, have the ONSSA provincial service confirm the regime before filing.

The technical part of the file is set by Order 244-13 (in French):

  • a location plan at 1:1,000 and a general layout at 1:100 to 1:300, showing work and storage areas, drinking water, waste water, staff facilities, equipment, product flow, staff movement and waste removal;
  • a technical sheet with ten headings, from the nature of the activity to means of transport, including detailed production flow diagrams and capacities;
  • for approval, a manual describing the HACCP-based own-check programme; for authorisation, a procedures manual based on the good sanitary practice guide for the activity.

For a site elsewhere in Africa or in the Middle East, the starting point is the national approval or registration that applies there. The full roadmap from ONSSA to the choice of standard is on our food safety consulting page.

How does the HACCP plan prepare ISO 22000, FSSC 22000, BRCGS or IFS?

All of them require a HACCP plan in line with the Codex; each adds its own requirements. A well-built plan is reused as it is, which avoids paying twice for the same work.

Standard

What it adds to the HACCP plan

Our page

ISO 22000:2018

A management system, justified PRPs, CCP or OPRP classification

ISO 22000 certification

FSSC 22000 Version 7

ISO 22000, ISO 22002-x:2025 PRPs and additional requirements, GFSI-recognised

FSSC 22000

BRCGS Food Safety Issue 9

Detailed requirements on the HACCP team, validation and review, in a graded audit

BRCGS certification

IFS Food Version 8

HACCP requirements in a scored standard with KO requirements

IFS certification

All GFSI standards

Culture, food defence, fraud, allergens, traceability and recall, environmental monitoring

Food safety programmes

Some bodies issue a “HACCP” certificate based on the Codex. It may reassure a local customer, but it is not among the programmes recognised by GFSI: ask your buyer in writing what they accept before choosing.

Would your HACCP plan pass an inspection or audit tomorrow?

The checklist we use at the start of a diagnostic, and that a buyer can use to screen a supplier.

If more than three boxes are empty, the plan needs rework before any certification project.

What ACG does for your HACCP plan

For buyers, we run second-party supplier audits in Morocco, Africa and worldwide. Our food safety training covers HACCP for operators, supervisors and HACCP teams, on site, in public sessions or online, in English, French or Arabic; funding through OFPPT special training contracts is explained on our CSF funding page, with no promised amount. To test your plan before a deadline, describe your project.