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HACCP plan review

An independent technical review of your existing HACCP plan. Every element marked sound, weak or missing, with replacement wording for anything that would not survive an audit.

What is a HACCP plan review?

A HACCP plan review is an independent technical assessment of an existing HACCP plan, checking that the hazard analysis is complete and justified, that the critical control points are correctly identified, and that critical limits, monitoring, corrective action and verification would stand up to an audit. It is carried out against the seven Codex Alimentarius principles, against the requirements of the certification standard the business holds, and against the food law of the markets it sells into.

Most HACCP plans fail audits in the same small number of places, and almost all of them are visible on paper long before an auditor arrives. Hazard analysis without recorded justification, critical control points that should be prerequisite programmes, and critical limits lifted from guidance and never validated account for a large share of HACCP findings across BRCGS, IFS Food, FSSC 22000, ISO 22000 and SQF audits.

The review returns specific rewrites in place of general observations, so the plan can be corrected directly with no reinterpretation first. Plans are reviewed in any language, and the report is delivered in whichever language you need.

Summary

A HACCP plan review checks whether your existing plan would survive an audit, and tells you exactly which wording to change. It is delivered remotely from the documents you already hold, and is quoted on scope.

HACCP plan review at a glance

Assessed against
Codex CXC 1-1969 and your standard
Standards
BRCGS, IFS, FSSC 22000, ISO 22000, SQF, customer codes
Legislation
The food law of any market you sell in
Delivery
Remote
Coverage
Worldwide
Output
Findings plus replacement wording
Pricing
Quoted on scope
Languages
Any language, including English, Spanish, French, German, Italian and Portuguese

What a HACCP plan review covers

The review works through the seven Codex principles in order, then checks the plan against the additional requirements of the certification standard you hold.

Codex principleWhat is checkedMost common failure
1. Conduct a hazard analysisEvery hazard identified at every step, across biological, chemical, physical, allergen and radiological categories, with the significance decision justified in writing.Justification missing or asserted without evidence
2. Determine the critical control pointsDecision logic applied and recorded, with each control correctly classified as a CCP, an OPRP or a prerequisite programme.Controls made CCPs that should be prerequisites
3. Establish critical limitsLimits that are measurable, achievable in production, and supported by validation evidence that applies to your product and equipment.Limits copied from guidance with no validation
4. Establish monitoring proceduresWho monitors, how, how often, with what equipment, and where the result is recorded.Frequency set with no stated rationale
5. Establish corrective actionsWhat happens to affected product and to the process when a limit is breached, including who decides and who is informed.Action covers the process but not the product
6. Establish verification proceduresActivities confirming the plan works as intended, distinct from monitoring, with results reviewed by someone able to act on them.Verification confused with monitoring
7. Establish documentation and recordsRecords that prove each element operated, retained for the required period and retrievable on request.Records exist but cannot be found quickly

CCP, OPRP or prerequisite programme

Misclassifying a control is one of the most common structural fault in a HACCP plan, and it goes wrong in both directions. This is the distinction the review applies.

TypeWhat it isCritical limitMonitoringCorrective action
Critical control point (CCP)A step where control is essential to prevent, eliminate or reduce a significant hazard to an acceptable level.Yes, measurableContinuous or at defined frequency, recorded every timeImmediate, covering both process and affected product
Operational prerequisite (OPRP)A control measure that manages a significant hazard where a measurable critical limit and immediate product decision are not practical.Action criteria in place of a critical limitPlanned and recordedDefined, though not necessarily immediate product disposition
Prerequisite programme (PRP)A basic condition or activity maintaining a hygienic environment across the operation, not controlling one hazard at one step.NoScheduled verification in place of per batch monitoringCorrective action on the programme, not on a specific batch
Note

A control designated a critical control point must be monitored and recorded to CCP standard every time. Designating a prerequisite programme as a CCP therefore creates a nonconformity the moment monitoring lapses, without adding any food safety benefit.

The most common HACCP plan failures

These eight account for a large share of HACCP findings raised at certification audits. Each is checked explicitly during the review.

Who a HACCP plan review is for

Any food business operating a HACCP plan, whether certified to a GFSI recognised standard or working to the legal requirement alone. It suits manufacturers, processors, packers, food supplement producers and catering operations, and it is particularly useful where the plan was written by someone no longer with the business or has never been independently checked.

Your plan was written years ago and the process has moved on since.

An auditor has said your hazard analysis lacks justification.

You are not confident your CCPs are correct, or you suspect you have too many.

Your critical limits came from a guidance document instead of your own validation.

You are moving to a new standard and the plan must meet a different expectation.

A new product, line or process step has been added without the plan being reassessed.

The person who wrote the plan has left and nobody can defend it.

A customer or a regulator has asked to see evidence of independent review.

How a HACCP plan review is carried out

  • 1

    Documents in

    You send the current plan, flow diagrams, the supporting hazard analysis and any validation evidence you hold.

  • 2

    Structural review

    The plan is checked against the Codex sequence and the documented requirements of your standard, so missing elements surface before content is assessed.

  • 3

    Technical review

    Hazard analysis and CCP determination are assessed on technical merit, hazard by hazard and step by step.

  • 4

    Evidence check

    Critical limits and control measures are checked against the validation evidence you hold, and gaps in that evidence are recorded.

  • 5

    Findings

    Every element is marked sound, weak or missing, with the reasoning stated in place of a general observation.

  • 6

    Replacement wording

    Specific wording is supplied for anything that would not survive an audit, so the plan can be corrected directly.

What is not included

The review assesses and corrects an existing plan. Building a plan from nothing is HACCP plan development, quoted separately.

Laboratory validation of critical limits is also separate, though the review identifies precisely which limits require it and what study would satisfy the requirement.

Where a process needs a recognised process authority, such as low acid canned food thermal processing, the review states that plainly and does not assess it.

What a HACCP plan review costs

Quoted on scope, never sold at a list price, because plan length varies enormously between businesses with the same nominal scope. These factors determine the price.

Number of product families

Number of process steps

Standard in scope

What this service is assessed against

These are the primary sources this work is built on. Where a market you sell into has its own requirement, that takes precedence and we assess against it.

CXC 1-1969, General Principles of Food Hygiene
The international reference for prerequisite programmes and for the seven HACCP principles. Codex Alimentarius
CXG 69-2008, Guidelines for the Validation of Food Safety Control Measures
What constitutes evidence that a control measure is capable of achieving its intended effect. Codex Alimentarius
Regulation (EC) No 852/2004 on the hygiene of foodstuffs
The general hygiene requirements and the duty to operate procedures based on HACCP principles. EUR-Lex
21 CFR Part 117, preventive controls for human food
The FSMA hazard analysis and risk based preventive controls requirements, including validation and verification. eCFR
BRCGS, IFS Food, FSSC 22000 and SQF published requirements
The clause your certification body audits against, which differs between schemes and between issues. BRCGS

HACCP terms used in the review

HACCP
Hazard Analysis and Critical Control Points. A systematic preventive approach to food safety set out in the Codex Alimentarius General Principles of Food Hygiene, CXC 1-1969, and adopted into food law in most jurisdictions.
Critical control point
A step at which control is essential to prevent or eliminate a food safety hazard, or reduce it to an acceptable level.
Critical limit
A measurable value separating acceptable from unacceptable at a critical control point. It must be measurable in real time by the person monitoring it.
Validation
Obtaining evidence that a control measure is capable of achieving the intended level of hazard control. It happens before the control is relied on.
Verification
Confirming, through methods other than monitoring, that the plan is operating as intended. It happens on an ongoing basis after implementation.
Operational prerequisite programme
A control measure applied to manage a significant hazard where the structure of a critical control point is not practical.
Prerequisite programme
A basic condition or activity necessary to maintain a hygienic environment suitable for producing safe food.
Hazard analysis
The process of collecting and evaluating information on hazards and the conditions leading to their presence, to decide which are significant to food safety.

HACCP plan review questions

A HACCP plan review is an independent technical assessment of an existing HACCP plan. It checks that hazards have been identified at every process step, that significance decisions carry written justification, that critical control points are correctly determined, and that critical limits, monitoring, corrective action and verification are adequate. The output marks every element as sound, weak or missing, and supplies replacement wording for anything that would not survive an audit.

At least annually under most certification standards, and additionally whenever something changes that could affect the hazard analysis. That includes a new product or recipe, a formulation or supplier change, new or modified equipment, a change to a process parameter, a new hazard identified in the sector, a customer complaint or recall, and any change to the applicable legislation. An annual review date with no change triggers defined is itself a common finding.

Someone with HACCP training and technical knowledge of the process, who is independent of the people who wrote the plan. Independence is the difficulty for small teams, because the person qualified to review the plan is usually the person who wrote it. An external reviewer resolves that, and standards accept an external reviewer provided competence is documented.

Evidence, never assertion. Auditors test whether the hazard analysis covers every step and category, whether significance decisions are justified, whether CCP determination followed a recorded logic, whether critical limits are validated for your process, whether monitoring records exist and were completed at the time, and whether the plan has been reassessed after change. A plan that reads well but cannot produce the evidence behind it will still attract findings.

A review starts from a plan you already have and corrects it, returning findings and replacement wording. Development starts from your process and builds the plan from the beginning, including flow diagrams and the full hazard analysis. If your plan is broadly sound but unverified, a review is the right service. If it is a template with your company name typed into it, development usually costs less than repairing it.

There is no correct number, and comparing against other businesses is misleading because CCPs depend on the process and not on the sector. What matters is that each CCP is genuinely a step where control is essential and a measurable limit exists. In practice, over identification is far more common than under identification, and both are findings.

In most countries, yes. The Codex Alimentarius principles have been written into national food law across the great majority of jurisdictions, so a documented HACCP based system is a legal obligation for most food businesses wherever they operate. The wording differs by country. In the European Union it comes through Regulation (EC) 852/2004. In the United States most registered facilities fall under FSMA preventive controls in 21 CFR Part 117, with separate HACCP rules for seafood, juice, and meat and poultry. Other markets impose it through their own food safety acts and sector regulations. The review is carried out against the law of the markets you sell in, which is confirmed at scoping.

It checks whether the hazard analysis relies on prerequisite programmes and whether that reliance is stated. It does not assess the programmes themselves in depth, which is a prerequisite programme review. This matters because hazards are routinely dismissed on the grounds that a prerequisite controls them, and if that programme is weak the justification collapses.

Yes. We work in any language, and the review is delivered in whichever language you need it in. Where the plan and the report are in different languages, both are handled on our side, so you receive findings and replacement wording ready to drop into the plan as it stands. Language is confirmed at scoping so nothing is assumed.

A written report marking every element of the plan as sound, weak or missing, with the reasoning stated for each finding, and specific replacement wording for anything that needs correcting. The report is written so it can be used directly to amend the plan, and so it can be shown to an auditor as evidence that the plan was independently reviewed.

A single product family with a straightforward process is quick. Multiple product families, long process flows or plans covering several sites take longer. The largest variable is plan length, which differs enormously between businesses with the same nominal scope. Turnaround is confirmed with the quote once the plan has been seen.

Yes, and it is one of the main reasons businesses commission it. Each control measure is assessed against decision logic, and the review states whether it should be a CCP, an OPRP or a prerequisite programme, with the reasoning recorded so the classification can be defended at audit.

Who carries out this work

Confi Food assigns work by subject. HACCP, labelling, certification standards, regulatory compliance, supplier assurance and monitoring are separate disciplines, and each piece goes to someone who works in that area. Every deliverable is reviewed internally by a second specialist before it reaches you.

Our technical positions are built from primary sources, meaning the legislation, the competent authority, Codex Alimentarius, the certification scheme owner or the relevant standards body. We set out how that works in our technical review and editorial policy, and what happens at each stage of an engagement in how Confi Food works.

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Request a HACCP plan review

Send the plan and receive a written quote covering the scope, the timeline and the price.