Critical Control Points and Risk Assessment
Cooking chicken to the right core temperature kills Salmonella. Missing that temperature, even on a busy shift, can put pathogens in thousands of meals before anyone notices. Points in a process where control decides whether food is safe are critical control points, and finding them correctly — not too many, not too few — is the heart of HACCP and a heavily tested part of any IFS Food audit.
IFS Food, owned by IFS Management GmbH and benchmarked by GFSI, requires a HACCP system based on Codex principles. Monitoring of critical control points carries knock-out weight: a D grade on that requirement fails the audit. Risk assessment, however, reaches wider than HACCP alone, covering allergens, suppliers, fraud, and the prerequisite programmes that keep hazards low enough for critical points to manage.
Risk assessment basics
Risk assessment starts with hazard identification. For each raw material and process step, list biological hazards such as Listeria and Salmonella, chemical hazards including allergens, cleaning chemicals, and contaminants, and physical hazards such as metal, glass, and plastic. Then judge likelihood and severity honestly, using your own data, supplier information, legislation, and known outbreak history for similar products.
Controls follow from that judgement. Some hazards are controlled by prerequisites: supplier approval keeps chemical hazards in approved materials low; cleaning controls cross-contamination; maintenance prevents equipment fragments entering food. Only hazards that remain significant after prerequisites, and that a specific step can control, move forward to critical control point determination.
Deciding critical control points
Codex provides a decision tree to work through step by step. Does a control measure exist for the hazard at this step? Does the step eliminate the hazard or reduce it to an acceptable level? Could contamination occur or increase to unacceptable levels? Will a later step remove it? Answering truthfully, with the team, step by step, produces a defensible set of critical control points.
Common examples include cooking or pasteurisation for pathogen kill, chilling for growth control, and metal detection or X-ray inspection as a last removal step for physical hazards. Too many critical points dilute attention and suggest the team did not trust its prerequisites. Too few leave a significant hazard controlled by nothing stronger than a general procedure. Auditors challenge both errors, so keep your decision tree records and be ready to explain each outcome.
Critical limits must be measurable and validated
Each critical control point needs a critical limit separating safe from unsafe: a time and temperature, a maximum storage temperature, a detector sensitivity for defined test pieces. Validation means evidence the limit works — legislation, published science, or your own challenge studies. Monitoring then checks the limit at a frequency that catches failure before much product is affected, by a trained person, using a calibrated instrument.
When monitoring shows a failure
Write corrective actions before failures happen, because a pressured shift is the wrong time to improvise. Actions cover the product — hold everything since the last good check, assess, rework only if safety can be restored, otherwise reject — and the process: restore control, find the cause, and record everything. IFS treats monitoring and correction as a pair; monitoring without action is observation, not control.
- Hold and identify affected product since the last acceptable check
- Assess safety with competent authority inside the company
- Restore control and identify root cause
- Decide disposition: release, rework under control, or destroy
- Record the event, verify the fix, and trend repeat events
Verification, review, and wider risk tools
Verification proves the system works: review of monitoring records by a supervisor, calibration checks, microbiological testing, internal audits, and analysis of complaints and deviations. Review the whole HACCP plan at least annually and whenever something changes — new product, new supplier, new equipment, a complaint pattern, or an incident in the wider industry involving a similar product.
Use the same likelihood and severity discipline for allergen risk assessments, fraud vulnerability, and food defence threat assessment, known as VACCP and TACCP in many workplaces. Methods differ in detail, but the pattern repeats: identify, assess, control, monitor, review. Auditors reward that consistency and question assessments that score every hazard low with no reasoning. A risk assessment that never finds a significant risk is not reassuring; it is unfinished.
Record design can make or break monitoring in practice. A critical control point record should show the limit, the measured value, the time, the person, and space for action taken, all on one line that takes seconds to complete at line speed. If completion takes minutes, operators under pressure will batch entries later from memory, and the record stops being evidence. Pilot new records on the hardest shift, not the easiest, and adjust layout, wording, or instrument placement before rolling them out. Supervisors reviewing records should initial and date the review itself, so verification is visible rather than assumed.
Keep the team behind the assessment competent and cross-functional: production, engineering, quality, and purchasing each see hazards the others miss, and a plan written by one person at a desk rarely survives contact with a real process.
Key points
- Assess hazards by likelihood and severity for every material and step; control most through prerequisites.
- Use the Codex decision tree to identify genuine critical control points, and keep the reasoning on record.
- Every critical control point needs a validated, measurable critical limit and monitoring frequent enough to catch failure.
- Pre-write corrective actions covering product hold, disposition, root cause, and verification.
- Verify through record review, calibration, testing, and audit; review the plan annually and after any significant change.
