By Clare Sant - 2 May 2017

Your HACCP plan is there for a reason. Not complying with it is considered a non-conformance. Even though HACCP plans have been a requirement of the Food Safety Legislation since 2006, over the 30 years I have been auditing I see the same non-conformances cropping up time and time again.

HACCP systems are the basis for your company’s due diligence defence. HACCP systems protect businesses but they can also fail them if they are not correctly implemented. It's therefore critical to make sure your HACCP plan is effective. To help you improve your HACCP plan, here are the top 5 non-conformances I see when carrying out HACCP audits:

1. Validation

The HACCP plan is often validated prior to the current HACCP team as the line/ factory may have been in production for years and the team inherit the HACCP plan. This can make it difficult to find the validation information. Without validation a company will not know if their food manufacturing system is capable of producing safe food when challenged and therefore cannot guarantee that safe food will reach the consumer. Often a business will only discover the validation evidence isn’t available at a time a problem occurs - when it’s too late.

2. Hazard Analysis

Companies often group hazards together under the same banner, for example grouping physical hazards such as plastic, metal and glass. Just because hazards can be grouped together does not mean that they originate from the same source, or have the same control measures, or have the same implications for a business. Companies should separate different hazards.

3. Critical Control Point Determination

Often a company identifies the wrong decision tree within their HACCP plan, which can mean the company identifies the wrong Critical Control Points (CCP). Another issue is that the team can identify one decision tree in the HACCP plan but actually use another tree to get the answers they want. The auditor should and must use the decision tree named in the plan to ensure the company has understood the decision tree mechanism and identified the correct Critical Control Points.

4. Corrective Action

Often businesses become more concerned with dealing with the symptoms of a problem rather than finding and addressing the cause of the issue. Sometimes staff may deal with the symptoms by finding a temporary fix, hoping the problem goes away or if something happens it’s on someone else’s shift! This is a disaster waiting to happen. Root cause analysis is one tool that can be used to identify the correct cause so the problem can be resolved.

5. Scope

The scope of your HACCP plan should summarise your company’s intent with regard to food safety in a concise statement at the front of the HACCP plan. Often the scope will be lacking key statements so the auditor is unable to understand the company’s intent. A good scope will lay out for the business and the auditor what the HACCP plan aims to do.

Most food safety management systems look at all areas in the production of food and provide a holistic view of the food safety business. GFSI schemes are well known for looking throughout the food chain, but the auditors tend not to be HACCP specialists. Companies may need to employ an auditor who is able to focus solely on the HACCP plan to provide the company with complete confidence that their food safety management system can be relied upon to produce safe food.

Is your HACCP plan fit for purpose?

Our HACCP specialists can audit your HACCP system and highlight any corrective action or improvements needed. You will receive a certificate following a successful audit which you can use to demonstrate you meet industry HACCP standards that are required by BRC, SALSA, FSSC 22000 etc.

To find out about the Campden BRI HACCP Auditing Standard please contact

Clare Sant, Directorate Systems Coordinator
+44(0)1386 842129
clare.sant@campdenbri.co.uk