Critical control points and critical limits, with examples

What a critical control point is

A critical control point (CCP) is a step where you can stop a food safety problem, and where getting it wrong could make someone sick. Cooking chicken is one: miss the temperature and Salmonella survives. Cooling a braise is another: cool it too slowly and spores that survived cooking wake up and grow. The Food Code defines both terms you need in its definitions section.

FDA Food Code 2022, 1-201.10(B)

"Critical control point" means a point or procedure in a specific FOOD system where loss of control may result in an unacceptable health RISK.

FDA Food Code 2022, 1-201.10(B)

"Critical limit" means the maximum or minimum value to which a physical, biological, or chemical parameter must be controlled at a CRITICAL CONTROL POINT to minimize the RISK that the identified FOOD safety HAZARD may occur.

Read those together and the idea is simple. A CCP is the where. A critical limit is the number at that step: a minimum cooking temperature and time, a maximum cooling time, a maximum pH. If the food is on the right side of the number, the hazard is under control. If not, you act.

In a HACCP plan for a special process, the CCPs are not optional prose. Section 8-201.14(E) says the plan must include a CCP summary for each food or category that clearly identifies:

FDA Food Code 2022, 8-201.14(E)

A CRITICAL CONTROL POINTS summary for each specific FOOD or category type that clearly identifies:

1. each critical control point;
2. the significant hazards at each one;
3. the critical limits for each one;
4. how and how often the designated food employee or the person in charge monitors it;
5. what they do when a critical limit is not met;
6. how and how often the person in charge verifies that staff follow procedures and monitor the CCPs;
7. the records kept to show the plan is working.

That list is the backbone of every CCP table, including the ones ClearHACCP builds. Plan reviewers read it column by column.

Critical control point examples in a restaurant

Annex 4 of the Food Code, FDA's guide to applying HACCP at retail, names the usual suspects:

FDA Food Code 2022, Annex 4, Principle 2

Common examples of CCPs include cooking, cooling, hot holding, and cold holding of ready-to-eat time/temperature control for safety foods.

Special processes add a few of their own. Here is where CCPs typically fall for the processes that need a plan:

Notice what is missing: receiving, washing hands, cleaning boards. Those matter, but they are controlled everywhere, every day, by procedures. The next two sections show how to tell the difference.

The CCP decision tree

Annex 4 suggests a tool for sorting steps into CCPs and everything else:

FDA Food Code 2022, Annex 4, Principle 2

One tool that can be used to assist each facility in the identification of CCPs unique to its operation is a CCP decision tree.

The Food Code prints its own diagram, labeled CCP Decision Tree 1 and noted as adapted from NACMCF, the National Advisory Committee on Microbiological Criteria for Foods. The version below is the common four-question decision tree used in Codex and NACMCF HACCP training, in plain words. Run it once for each significant hazard at each step.

The tree, run on a sous vide short rib

Here is how the questions fall for a sous vide short rib that is bagged raw, cooked in a circulator, chilled in an ice bath and held at 34°F.

If the same short rib were reheated and held on a steam table, reheating would answer Q2 "yes" and become a CCP with the limits in 3-403.11.

Hazard analysis example: sous vide short rib

The decision tree only works on hazards you have already found. That is the hazard analysis: walk each step and list what could go wrong, biological, chemical and physical, then decide which hazards are significant. The Food Code's definition is broad on purpose:

FDA Food Code 2022, 1-201.10(B)

"Hazard" means a biological, chemical, or physical property that may cause an unacceptable CONSUMER health RISK.

And Annex 4 is clear about what to leave out:

FDA Food Code 2022, Annex 4, Principle 1

Hazards that are not reasonably likely to occur are not considered in a HACCP plan.

Here is a worked hazard analysis for the same short rib. B is biological, C chemical, P physical.

Why are spores the big one? Annex 4 explains that cooking does not finish them:

FDA Food Code 2022, Annex 4, Principle 1

spores of spore-forming bacteria such as Bacillus cereus, Clostridium botulinum, and Clostridium perfringens survive cooking and may germinate and grow if food is not properly cooled or held after cooking.

That one sentence is why cooling and cold holding are CCPs in every cook-chill and sous vide plan.

Real critical limits for restaurant CCPs

A critical limit must be a number you can measure. Annex 4 says so directly:

FDA Food Code 2022, Annex 4, Principle 3

Critical limits may be based upon factors like temperature, time, moisture level, water activity (aw), or pH. They must be scientifically-based and measurable.

Here are the limits restaurant HACCP plans use most, straight from the FDA Food Code 2022. Each one is pulled from a registry that quotes the Food Code sentence it comes from, so this table cannot drift from the source.

Two of these appear in Annex 4 as the textbook examples of a critical limit:

FDA Food Code 2022, Annex 4, Principle 3

Examples of critical limits are the time/temperature parameters for cooking chicken (165oF for <1 second (instantaneous)).

FDA Food Code 2022, Annex 4, Principle 3

The critical limit for the acidification of sushi rice, a pH of <4.2, sets the maximum limit for pH necessary to control the growth of spore- and toxin-forming bacteria.

CCP or prerequisite program?

The most common reason a plan comes back is a CCP list that is either too long or too short. Too long usually means handwashing, cleaning and receiving have been dressed up as CCPs. Those are prerequisite programs: the everyday procedures that keep the whole kitchen under control so the CCPs can do their job.

FDA Food Code 2022, Annex 4, Prerequisite Programs

When prerequisite programs are in place, more attention can be given to controlling hazards associated with the food and its preparation.

Annex 4 lists prerequisite programs such as vendor certification, training, allergen management, buyer specifications, recipe and process instructions, first-in first-out, and other standard operating procedures. It also lists facility-wide controls that apply to every process: no bare-hand contact with ready-to-eat food, proper handwashing, restricting or excluding ill employees, and preventing cross-contamination.

Quality checks are not CCPs at all:

FDA Food Code 2022, Annex 4, Principle 2

CCPs are only used to address issues with product safety.

Prerequisites still go in the plan. A special-process plan has to include the operational procedures and training program that 3-502.12(B)(5) and (B)(6) describe, and 8-201.14(F) asks for a training plan and blank record forms. They just do not go in the CCP table.

Monitoring and corrective action examples

A critical limit without monitoring is a wish. Annex 4 defines monitoring plainly:

FDA Food Code 2022, Annex 4, Principle 4

Monitoring is the act of observing and making measurements to help determine if critical limits are being met and maintained.

And when a reading is on the wrong side of the number:

FDA Food Code 2022, Annex 4, Principle 5

Corrective actions are activities that are taken by a person whenever a critical limit is not met.

Good monitoring says who checks, with what, how often, and where it is written down. Good corrective actions say what happens to this food and what you fix so it does not happen again. Here are six worked examples across processes, in the same shape as a CCP summary under 8-201.14(E).

For the cooling row, the reheat-or-discard split follows the guidance FDA gives inspectors in Annex 5. Your plan sets the exact rule and your regulator may want it written differently. The two-stage cooling guide walks through it with clock times.

Every probe reading above relies on a thermometer accurate to ±2°F if it reads in Fahrenheit only (4-203.11(B)). Calibrate it on a schedule and log it: free thermometer calibration log. Out-of-limit readings go on a corrective action log.

What plan reviewers send back

Health department plan reviewers read many CCP tables. These are the problems that come up again and again:

• A limit that is not a number. "Cook thoroughly" or "cool quickly" cannot be monitored. Write the temperature and the time, and cite the section.
• Half a limit. Reheating to 165°F without the 15 seconds and the 2-hour window. Cooling to 41°F without the 2-hour checkpoint at 70°F.
• Monitoring that cannot catch a failure. Checking a cooling batch only at the end tells you it failed hours too late to save it. Check at the first checkpoint.
• Corrective actions that skip the food. "Retrain staff" is verification. The corrective action must say what happens to the batch: keep cooking, reheat, move, or discard.
• The wrong storage option. Mixing a 7-day limit at 41°F with a 30-day date on the label. Pick one option from 3-502.12(D)(2)(e) and match the label to it.
• Handwashing listed as a CCP. Reviewers will ask you to move it to procedures and add the missing process CCPs instead.
• No thermometer accuracy or calibration. Every monitoring reading depends on it.
• Home cooking charts. A sous vide chart for home cooks is not a Food Code limit. If you want to cook below 3-401.11, that is a variance under 3-401.11(D)(4), with its own HACCP plan.

ClearHACCP builds the CCP table from your answers with every limit pulled from the Food Code and its section printed next to it, ready to submit. You sign it. Your health department decides. Check whether your process needs a plan, or see the flow charts that place each CCP in the process.

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