The 7 HACCP principles, explained by an operator.

If you're not sure what HACCP is yet, start with the pillar — the plain-English version of what the framework is, who needs one, and what it costs. This article goes deeper on one specific question: what are the seven principles, and what does each one look like in a real facility?

01The short version

The seven principles, in one paragraph.

HACCP stands for Hazard Analysis and Critical Control Points. It's a way of writing down where your food process can go wrong, and what you're going to do about it. The whole framework boils down to seven principles. They were finalized by the U.S. National Advisory Committee on Microbiological Criteria for Foods (NACMCF) on August 14, 1997, and codified internationally by the Codex Alimentarius Commission in standard CXC 1-1969. They have not materially changed since.

Here they are in order. The rest of this article walks through each one with a real worked example.

1. 01

   Conduct a hazard analysis

   List everything that could go wrong at every step of your process. Decide which ones are serious enough to control.

2. 02

   Determine the Critical Control Points (CCPs)

   A CCP is a step where you can apply a control that stops a dangerous hazard from reaching the customer. Most plans end up with two to six.

3. 03

   Establish critical limits

   For every CCP, pick the exact measurable number that separates safe from unsafe. A temperature, a time, a pH, a salt percentage.

4. 04

   Establish a monitoring system

   Decide what gets measured, how, how often, and by whom. The point is to catch a loss of control while you can still fix it.

5. 05

   Establish corrective actions

   Write down — in advance — what happens when a critical limit is missed. Who decides what to do with the food. Who fixes the cause.

6. 06

   Establish verification procedures

   Separate from monitoring. This is how you prove the plan is still working. Calibration, record review, internal audit, annual reassessment.

7. 07

   Establish documentation and recordkeeping

   The plan, the worksheets, the monitoring logs, the corrective action records, the verification records. The proof that any of this happened.

02The history

Where the seven came from.

NASA had a problem, Pillsbury solved it, the FDA noticed, and forty years later it became the global food safety standard.

In 1959, NASA hired Pillsbury to develop space food "absolutely free of any disease-producing bacteria and toxins." A Pillsbury microbiologist named Dr. Howard E. Bauman, working with the U.S. Army's Natick Laboratories, borrowed an industrial reliability framework called FMEA (Failure Mode and Effects Analysis) and adapted it for food. The insight: don't test the finished product. Identify the points in the process where contamination could happen and build a control at each one. The first public presentation of "Hazard Analysis and Critical Control Points" was in 1971.

The FDA picked it up after the 1972 commercial canned soup botulism outbreaks. Codex formally adopted HACCP in 1993. The FDA seafood rule landed in 1995, the USDA "Mega-Reg" for meat and poultry in 1996. Then on August 14, 1997, NACMCF published the current version of "HACCP Principles and Application Guidelines" — later reprinted in the Journal of Food Protection 61(9):1246-1259. That 1997 list is what auditors still cite.

Codex updated the wrapping in 2020 (CXC 1-1969 Rev 5 — new definitions for "good hygiene practices" and "prerequisite programme," plus an emphasis on food safety culture). The CCP decision tree was revised in November 2022 at CAC45. The seven principles themselves? Still the 1997 version.

“

HACCP is a systematic approach to the identification, evaluation, and control of food safety hazards based on the following seven principles.

”

NACMCF 1997, Journal of Food Protection 61:9, 1998

03Principle 1

Principle 1 — Conduct a hazard analysis.

A hazard is "a biological, chemical, or physical agent in, or condition of, food with the potential to cause an adverse health effect." That's the Codex definition, copied word-for-word into NACMCF 1997. The FSMA Food Safety Plan rule added radiological as a fourth category (21 CFR §117.130), but classic HACCP still uses three. Shorthand: B/C/P.

The principle has two halves. First, identification. At every process step, brainstorm everything that could go wrong: Salmonella in poultry, allergen cross-contact, glass from a broken sight glass, mycotoxins in incoming corn, cleaning chemical residue. Be exhaustive. The worksheet is meant to look long and ugly at this stage.

Second, evaluation. For each hazard, ask: is it reasonably likely to occur in my process, and how severe is the outcome? NACMCF and Codex call a hazard "significant" when, absent control, it will likely cause illness or injury. Significant hazards get a control measure. Non-significant hazards get dismissed with a written reason.

A worked example from my facility.

When I built the Preventive Control Plan (Canada's HACCP-equivalent under SFCR §86) for my Brantford mushroom facility, my first hazard analysis worksheet had about 30 candidate hazards across receiving, hydration, sterilization, inoculation, incubation, fruiting, harvest, dehydration, and packaging. Some obvious: spore-forming bacteria surviving substrate sterilization (biological). Some less obvious: aluminum residue from a leached pot (chemical), pieces of broken thermometer probe (physical).

For each, I wrote a one-line rationale in the "significant Y/N" column. Spore-forming bacteria on substrate — significant, controlled at sterilization. Glass from a broken sight glass — not significant, no glass in the production area by design (a prerequisite program controlling it, not HACCP). Allergen cross-contact — not significant, single-ingredient facility. That last one mattered to the inspector even though the answer was "no" — he wanted to see the analysis, not just the conclusion.

04Principle 2

Principle 2 — Determine the Critical Control Points.

A CCP — Critical Control Point — is defined by Codex as "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." The word that matters is "essential." A step where control is helpful is a control point. A step where control is essential is a critical control point. Every CCP generates monitoring, corrective action, verification, and recordkeeping work. More CCPs is not safer — it's just more paperwork around the same controls.

The 2022 Codex four-question decision tree.

The most-used CCP determination tool is the Codex decision tree. The original 2003 version is still common in older plans and some SQF (Safe Quality Food) and BRCGS audit templates. Codex adopted a redesigned four-question tree in November 2022 at CAC45:

1. 01

   Q1: Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs?

   A GHP is a Good Hygiene Practice — sanitation, pest control, employee hygiene. If YES, this step is controlled by prerequisite programs and is not a CCP.

2. 02

   Q2: Do specific control measures for the identified hazard exist at this step?

   If NO, modify the process so a control measure does exist.

3. 03

   Q3: Will a subsequent step eliminate the hazard or reduce it to an acceptable level?

   If YES, this step is not a CCP — the next step does the job.

4. 04

   Q4: Can this step specifically prevent, eliminate, or reduce the hazard to an acceptable level?

   If YES, this step IS a CCP.

Codex CXC 1-1969 explicitly says operators can use "a decision tree or other approach." Any structured method with documented reasoning is acceptable.

Common CCPs by industry.

A worked example from my facility.

My first draft of the Brantford PCP flagged dehydration as a CCP. The reasoning was lazy — "we use temperature, so it must be critical." When I ran it through the decision tree, I got stuck on Q3 (will a subsequent step control the hazard?). Dehydration reduces water activity, which controls microbial growth during storage. But the actual pathogen kill happens upstream at sterilization. Dehydration is a control point — important, monitored, scheduled — but not a CCP. Demoting it cut the monitoring burden in half without weakening the food safety story. Most first-draft hazard analyses overstate the CCPs. The decision tree exists to talk yourself back down.

05Principle 3

Principle 3 — Establish critical limits.

A critical limit is, in Codex's words, "a criterion which separates acceptability from unacceptability." Every CCP needs one. The limit must be three things: measurable, science-based, and actionable in real time.

Measurable means a number or a yes/no you can verify on the floor — temperature, time, pH, aw (water activity, on a scale where pure water is 1.00), salt percentage, chlorine ppm. "No Salmonella present" is not a critical limit — you can't measure it in real time. Use a surrogate parameter like cook temperature plus dwell time.

Science-based means it traces back to a published source: USDA-FSIS Appendix A, the FDA Food Code, the FDA Fish & Fishery Products Hazards & Controls Guide, peer-reviewed JFP studies, 21 CFR Part 114, or your own validation study. "We've always done it at 165" is not a science basis.

Actionable in real time means the operator can act on it during the shift. A 24-hour lab plate count is not actionable — the food is already shipped. A pH reading at the batch is actionable.

Examples from NACMCF and the regulations.

1. 01

   Ground beef cooking

   Internal temperature ≥ 71.1°C (160°F) for 15 seconds. From USDA-FSIS Appendix A.

2. 02

   Poultry cooking

   Internal temperature ≥ 73.9°C (165°F) for 15 seconds. FDA Food Code §3-401.11.

3. 03

   Acidified foods

   pH ≤ 4.6, scheduled process under 21 CFR Part 114, controls C. botulinum.

4. 04

   Shelf-stable dry foods

   aw ≤ 0.85 — above this, pathogens can grow; below, they can't.

5. 05

   Two-stage cooling

   135°F → 70°F within 2 hours, then 70°F → 41°F within 4 more. FDA Food Code §3-501.14.

6. 06

   Food-contact sanitizer

   50-200 ppm chlorine, or 200-400 ppm quaternary ammonium.

Operational limits vs. critical limits.

A critical limit is the boundary between safe and unsafe. An operational limit is a tighter number the operator runs to in normal practice. Cook target: 165°F. Critical limit: 160°F. The line cook aims for 165 so normal process variation never crosses 160. Cross 165 → adjust the equipment, no formal deviation. Cross 160 → trigger corrective action. The mistake is setting your critical limit at your target. Now every minor variation becomes a formal deviation and the actual food safety signal gets buried in noise.

06Principle 4

Principle 4 — Establish a monitoring system.

Monitoring is, per Codex, "the act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control." Plain version: how you check, in real time, that the critical limit is being met.

A monitoring procedure has to answer four questions. NACMCF 1997 calls them the "what, how, when, who":

1. 01

   What is being measured

   Temperature. Time. pH. ppm. Visual condition.

2. 02

   How it's measured

   A calibrated thermometer. An in-line probe with chart recorder. A pH meter. A test strip. A visual inspection against a reference standard.

3. 03

   When and how often

   Continuous (chart recorder on a pasteurizer). Every batch. Every hour. Every shift. The frequency has to be defensible — frequent enough to catch a loss of control before product ships.

4. 04

   Who does it

   A named individual or position. Trained on the procedure. Authorized to take corrective action if needed.

Continuous vs. interval monitoring.

Continuous monitoring (a chart recorder logging every second on a pasteurizer) is the strongest form. Use it where equipment supports it. Non-continuous monitoring (probe checks every batch, hour, or shift) is the most common in small facilities and is acceptable — but the frequency has to be defensible. USDA-FSIS 9 CFR §417.2(c)(4) requires frequency to "enable the establishment to take corrective action in time to prevent the product from being adulterated." Translation: monitor often enough that a single deviation doesn't condemn a whole shift's worth of product.

The signature requirement.

Every monitoring record has to be signed or initialed by the person who did the observation, at the time of the observation. USDA-FSIS 9 CFR §417.5(a)(3) is explicit. Pre-printed forms with retroactive signatures are an FDA Form 483 finding waiting to happen. CFIA inspectors look for the same thing under SFCR.

A worked example from my facility.

Sterilization monitoring at Brantford: the autoclave has a chart recorder that logs internal temperature continuously over the cycle. After each cycle, the operator pulls the chart, compares the time-above-temperature against the validated cycle, initials and dates the chart, and logs the batch number in the sterilization log. Chart is the primary record; log is the index. Frequency: every batch. Who: any trained production employee. Inspector wants Tuesday's chart for batch 247 — two-tap retrieval, three minutes flat. That's the bar.

07Principle 5

Principle 5 — Establish corrective actions.

When monitoring shows a critical limit was missed, four things have to happen. USDA-FSIS 9 CFR §417.3 and Codex CXC 1-1969 are aligned on the list:

1. 01

   Identify and eliminate the cause

   Why did the limit get missed? Equipment failure, sensor drift, human error, raw material variation, ingredient change?

2. 02

   Bring the process back under control

   Restart, recalibrate, repair, retrain. Document the corrective action.

3. 03

   Determine disposition of affected product

   What happens to the food that was being made when the deviation happened? Options: hold and evaluate, reprocess, divert to a non-food use, destroy. Decided by a designated, qualified individual. Documented.

4. 04

   Prevent recurrence

   Root cause analysis. Adjust the plan if a systemic issue was found. Update the procedure, retrain, change the schedule, replace the equipment — whatever it takes.

Pre-defined, not improvised.

The single most important rule about corrective actions: they have to be pre-determined. Written into the plan, before the deviation. At the moment of a deviation, a line cook should not be making a creative judgment call about whether to hold or ship product. The plan should already say. The decision is yours, calmly, on a Tuesday morning when you wrote the plan — not theirs, under pressure, at 11 PM on a Friday with three trucks waiting.

A worked example from my facility.

Corrective action for a sterilization cycle that misses the validated curve: (1) batch is quarantined and labeled QUARANTINED. (2) Operator notifies me. (3) Substrate is reprocessed through a full additional cycle, then re-evaluated. (4) Cause is investigated — steam pressure, sensor calibration, gasket, load arrangement. (5) Root cause is logged with the corrective action. (6) If the cause is systemic (a sensor drifted), the calibration schedule is reassessed. Written once. Now any production employee can execute it without calling me. That's the point of pre-defined corrective action.

08Principle 6

Principle 6 — Establish verification procedures.

This one trips up almost every new HACCP writer because it sounds like monitoring but isn't. NACMCF and Codex draw a sharp distinction between two activities:

Validation answers "is the plan correct?" Verification answers "is the plan being followed?" Both are required. Both go into the documentation. They are not the same activity.

What verification includes.

USDA-FSIS 9 CFR §417.4 breaks verification into five activities:

1. 01

   Calibration

   Every monitoring instrument on a defined schedule, against a traceable standard, with records.

2. 02

   Direct observation

   A trained person watches the monitoring being done. Confirms the procedure is followed.

3. 03

   Record review

   Someone reviews every monitoring record for completeness and signature, before product ships. FSIS specifies "prior to shipping" or "within a week of preparation."

4. 04

   Periodic testing

   Finished-product testing, environmental swabbing, in-line sampling. Frequency depends on product and hazard.

5. 05

   Annual reassessment

   At least once a year, plus whenever raw materials, process, equipment, packaging, distribution, intended use, or the hazard landscape change. Required under 9 CFR §417.4(a)(3).

A worked example from my facility.

My pH meter calibration: every batch where pH is measured, the meter is calibrated using pH 4.0 and pH 7.0 buffer solutions before use, logged with signature, date, and buffer lot. That's verification — proof the instrument was accurate at the moment of measurement. My early draft said "monthly calibration check, no record." The inspector spotted it on the first audit. Rebuilding the procedure took two hours. Every subsequent inspection has been airtight.

09Principle 7

Principle 7 — Establish documentation and recordkeeping.

If the first six principles are the plan, this one is the proof. Two parts: the plan itself (what you're going to do) and the records (what you actually did).

A complete HACCP plan includes the written hazard analysis (every step, every hazard, the significant Y/N rationale, the control measure, the references), the written plan (CCPs, critical limits with science, monitoring, corrective actions, verification, recordkeeping), validation records (scientific basis for each critical limit), and training records.

Daily operations generate the rest: CCP monitoring records signed at the time of observation; corrective action records with cause, action, product disposition, and sign-off; verification records (calibration logs, record review sign-offs, audit reports, reassessment); receiving and shipping records for traceability.

Retention.

Each regulation sets its own retention requirement:

The retention clock runs from creation, not from when you last looked at the record. If a record is from January 2024 and the rule says 2 years, you can dispose of it in January 2026 — not later, but not earlier either.

A worked example from my facility.

My CFIA inspector pulls a random month of records every six months. He walks the production area with the PCP in hand and asks "show me the entry that matches what I'm looking at." First time, I was paging through three-ring binders and it took 90 minutes. Now everything is indexed by batch number — any record in under two minutes. Same paperwork, different organization. That's the audit-trail mindset Principle 7 is trying to teach.

10HACCP vs. FSP

How the seven sit inside the FSMA Food Safety Plan.

The biggest source of confusion for U.S. operators in 2026 is "do I have a HACCP plan or a Food Safety Plan?" Same DNA, different wrapper. The seven principles run through both.

USDA-FSIS (meat, poultry, processed egg) follows HACCP under 9 CFR Part 417. FDA seafood under 21 CFR Part 123. FDA juice under 21 CFR Part 120. Everyone else FDA-regulated follows the Food Safety Plan under 21 CFR Part 117. Differences worth knowing:

1. 01

   The author

   HACCP is written by a HACCP team. An FSP must be written or overseen by a PCQI — Preventive Controls Qualified Individual, trained through a 2.5-day FDA-recognized course.

2. 02

   The hazard bar

   HACCP uses "reasonably likely to occur." FSP uses "known or reasonably foreseeable" — a slightly broader bar.

3. 03

   The control point

   HACCP has CCPs. FSP has Preventive Controls — includes CCPs plus broader allergen, sanitation, and supply-chain controls.

4. 04

   The recall plan

   HACCP recommends; FSP requires under 21 CFR §117.139.

5. 05

   Reassessment cadence

   HACCP annual plus change-triggered. FSP every-3-years plus change-triggered.

If you can write a HACCP plan, you can write an FSP — add the allergen, sanitation, and supply-chain control sections, plus the recall plan, and get a PCQI to sign off. For Canadian operators: the SFCR PCP (Preventive Control Plan) is HACCP-equivalent with extra sections on traceability, labelling, and food fraud.

11Common myths

What operators get wrong about the seven.

1. 01

   The seven changed in 2020

   No. Codex updated definitions and the decision tree in Rev 5 (2020) and CAC45 (2022). The principles themselves haven't changed since NACMCF 1997.

2. 02

   Every process step is a CCP

   No. A CCP is the last step where significant hazard control is essential. Most plans have two to six. If yours has 15, your decision tree is broken.

3. 03

   Prerequisite programs are part of HACCP

   Traditionally they sit underneath HACCP as a foundation — sanitation, pest control, employee hygiene, GHPs. Codex Rev 5 makes the layered model explicit. FSMA bundles allergen and sanitation controls into the plan itself.

4. 04

   You can copy a HACCP plan from another operator

   A template, yes. A finished plan, no. Hazard analysis must reflect your ingredients, equipment, process, consumers. Auditors catch copy-paste fast.

5. 05

   Critical limits should be as tight as possible

   No. A critical limit is the boundary between safe and unsafe. Operate above it. If your critical limit equals your operational target, every minor variation triggers corrective action.

12By scale

How the seven scale up and down.

The principles don't change with the size of the operation. The execution does.

Cottage operator. Generally exempt from formal HACCP under state cottage food laws. The discipline is still worth borrowing.

Small manufacturer (5-25 employees). The seven apply in full. The HACCP team might be two people. CCPs might be two or three. Records might be on paper. None of that is a violation. NACMCF and Codex both note HACCP must be scalable. Inspectors look for competence and honesty, not formality.

Restaurants. Most U.S. restaurants run under the FDA Food Code with no formal HACCP plan. "HACCP-Based" provisions kick in for specific high-risk processes — sushi rice acidification, sous vide, smoking for preservation, reduced-oxygen packaging, sprouting — where the local health authority requires a written plan before granting a variance.

Importers. FSMA's Foreign Supplier Verification Program (FSVP, 21 CFR Part 1 Subpart L) requires the importer to verify the supplier's controls. As an importer you don't write a HACCP plan; you verify your suppliers have one and follow it.

13What to do this week

How to actually apply the seven this week.

Reading about the seven is one thing. Building them into a working plan is another. The cheapest first steps:

1. 01

   Draw your process flow diagram

   Every step from receiving to shipping. Pencil and grid paper. Walk the floor with it. Fix what's wrong. Foundation for Principle 1.

2. 02

   Brainstorm hazards at every step

   B/C/P. Be over-inclusive. Aim for at least three candidate hazards per step.

3. 03

   Run each significant hazard through the decision tree

   Most fall out as "controlled by prerequisite programs" or "controlled at a later step." The ones that survive are your CCPs.

4. 04

   For each CCP, find the published reference

   USDA-FSIS Appendix A, the FDA Food Code, the Fish & Fishery Hazards Guide, 21 CFR Part 114. Save the citation with your critical limit.

5. 05

   Write the monitoring procedure

   What, how, when, who. Frequency tight enough that a missed limit doesn't condemn a full shift.

6. 06

   Pre-write the corrective action

   What gets quarantined, what gets reprocessed, who decides disposition. In writing, before any deviation.

7. 07

   Schedule calibration and record review

   Frequency for each monitoring instrument and record type. Plus annual plan reassessment.

8. 08

   Set up your records to be retrievable in two taps

   Indexed by batch number, date, CCP. Tuesday's cook log for batch 247 — under two minutes.

First time through, expect two to four months at a small operation. After that, you only revisit the hazard analysis when something material changes — new product, equipment, supplier, packaging, distribution.

Footnotes

1.NACMCF, "Hazard Analysis and Critical Control Point Principles and Application Guidelines," adopted August 14, 1997 — reprinted in Journal of Food Protection 61(9):1246-1259 (1998). FDA host page — fda.gov

2.Codex Alimentarius Commission, General Principles of Food Hygiene, CXC 1-1969 Rev. 5 (2020), HACCP Annex with 2022 decision tree (CAC45) — fao.org

3.9 CFR Part 417 — USDA-FSIS HACCP Systems — ecfr.gov

4.21 CFR Part 117 — FSMA Preventive Controls for Human Food — ecfr.gov

5.21 CFR Part 123 — FDA Seafood HACCP — ecfr.gov

6.21 CFR Part 120 — FDA Juice HACCP — ecfr.gov

7.FSIS HACCP Seven Principles Inspection Methods 16-1 (Mar 2016) — fsis.usda.gov

8.WHO/FAO CAC45 — Codex Alimentarius Commission 45th Session adopts new CCP decision tree, November 2022 — who.int

9.CFIA Safe Food for Canadians Regulations §86 — Preventive Control Plan — inspection.canada.ca

Andrew Langevin·CFIA-licensed facility, Brantford ON· Published 2026-06-04· 12 min read· Wikidata Q139112497