The 7 principles of HACCP, on one short rib

The 7 principles of HACCP at a glance

The seven HACCP principles are: (1) conduct a hazard analysis, (2) determine the critical control points, (3) establish critical limits, (4) establish monitoring procedures, (5) establish corrective actions, (6) establish verification procedures, and (7) establish record keeping and documentation procedures. Below, each one is applied to a single dish, so you can see what it actually looks like on paper and on the line.

The first principle of the HACCP plan is: conduct a hazard analysis

Annex 4 of the Food Code puts the purpose in one line:

FDA Food Code 2022, Annex 4, Principle #1

The purpose of hazard analysis is to develop a list of food safety hazards that are reasonably likely to cause illness or injury if not effectively controlled.

If you came here from a ServSafe or food handler question, that is the answer. If you came here because you have to write a plan, keep reading: the other six principles turn that list into numbers, checks and logs.

Where the seven principles come from

To be straight about it: the seven principles are not a Food Code invention. They come from the National Advisory Committee on Microbiological Criteria for Foods (NACMCF), which wrote them for the whole food industry and later checked them against the international Codex guidance. The Food Code's Annex 4 tells the story:

FDA Food Code 2022, Annex 4, 2.B

In November 1992, the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) defined seven widely accepted HACCP principles that explained the HACCP process in great detail.

FDA Food Code 2022, Annex 4, 2.B

In 1997, NACMCF reconvened to review the 1992 document and compare it to current HACCP guidance prepared by the CODEX Committee on Food Hygiene.

The Food Code then ties a restaurant HACCP plan back to those principles in its definitions:

FDA Food Code 2022, 1-201.10(B)

"HACCP plan" means a written document that delineates the formal procedures for following the HAZARD Analysis and CRITICAL CONTROL POINT principles developed by The National Advisory Committee on Microbiological Criteria for Foods.

What the Food Code adds is the layout. A restaurant plan is written to section 8-201.14, parts (A) to (G), not to a numbered list of principles. The principles are the thinking; 8-201.14 is the form your plan reviewer holds it against. They fit together closely, and the table further down maps one onto the other. For the full layout, read the HACCP plan for restaurants.

The dish: a 72-hour sous vide short rib

One dish, all seven principles. Bone-in short rib, seasoned, sealed raw in an oxygen-barrier bag on a chamber sealer, cooked in a circulator on the 72-hour recipe, cooled in the bag in an ice bath, held cold, then seared to order. Under 3-502.12(D) that is a sous vide process, and it needs a HACCP plan before the first bag goes in the bath. Here is its flow, which is where principle 1 starts:

Principle 1: Conduct a hazard analysis

Two stages: list every hazard you can think of at each step (biological, chemical, physical), then keep only the ones reasonably likely to cause illness or injury if not controlled. For the short rib:

In the plan: the food category goes in 8-201.14(B), the flow in (C), and the significant hazards next to each CCP in (E)(2). The hazards you decided are handled by everyday procedures show up in (D) as procedural controls. See more worked examples on critical control points.

Principle 2: Determine the critical control points

FDA Food Code 2022, Annex 4, Principle #2

A critical control point (CCP) means a point or procedure in a specific food system where loss of control may result in an unacceptable health risk.

The test that works in a kitchen: is this the last step where this hazard can be stopped, and would a failure here make someone sick? For the short rib:

• Cook is the only step that kills the bacteria on the raw beef. Miss it and nothing later fixes it.
• Cool is where spores that survived the cook can grow. Searing to order does not undo it, because some toxins survive heat:

  FDA Food Code 2022, Annex 4, Principle #1

  The toxins produced by the vegetative cells of Bacillus cereus, Clostridium botulinum, and Staphylococcus aureus may not be destroyed to safe levels by reheating.

• Cold hold is what keeps the sealed bag safe for days or weeks, the only barrier left once the bag is cold.

Receiving is not a CCP here, because the cook step takes care of what comes in on the meat. Neither is first-in first-out rotation:

FDA Food Code 2022, Annex 4, Principle #2

CCPs are only used to address issues with product safety.

In the plan: the CCPs are marked on the flow diagram (8-201.14(C)(2)) and each gets a row in the CCP summary (E)(1).

Principle 3: Establish critical limits

FDA Food Code 2022, Annex 4, Principle #3

A critical limit is a prescribed parameter (e.g., minimum and/or maximum value) that must be met to ensure that food safety hazards are controlled at each CCP.

For a restaurant, the limits come from the Food Code, with the section printed next to each so a reviewer can check them in seconds. Here are the short rib's:

Two things that are not critical limits: the circulator set point (that is an operating target; the limit is what the meat reaches) and a word like "chilled". If a kitchen has no unit that holds 34°F, the cold hold limit changes to option (ii): 41°F or less, used within 7 days. The sous vide guide lays out all four storage options.

In the plan: 8-201.14(E)(3), one or more limits per CCP.

Principle 4: Establish monitoring procedures

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.

Monitoring answers four questions per CCP: what is measured, how, how often, and by whom. For the short rib:

• Cook: each batch, the cook checks the bath with a probe when the bags go in, then probes the thickest bag through foam tape at the end of the cook.
• Cool: the cook probes the thickest bag at the start, at 2 hours and at 6 hours.
• Cold hold: the unit records time and temperature continuously and someone checks it by eye twice a day, as 3-502.12(D)(2)(f) requires. Every bag is labeled with the product name and date packaged.

On the log, one cooling entry looks like this:

In the plan: 8-201.14(E)(4), which says monitoring is done by the designated food employee or the person in charge. Print the free cooling log and cooking log, or run them on a phone with ClearHACCP logs.

Principle 5: Establish corrective actions

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.

Write them before you need them, so a cook at the end of a double shift does not have to decide. For the short rib:

• Cook missed: keep cooking until the core meets a row of the chart. If the circulator failed and nobody knows for how long, discard.
• Cooling missed: still above 70°F at the 2-hour check, reheat and start again with a faster method. Found above 70°F after 2 hours, or above 41°F after 6 hours, discard. The reheat comes from FDA's inspection guidance:

  FDA Food Code 2022, Annex 5, section 7 (Assessing Cooling)

  Cooked hot food may be reheated to 165 ºF for 15 seconds and the cooling process started again using a different cooling method if the food is:

• Cold hold missed: unit above 34°F, move the bags to a working unit. Bags still at or below 41°F switch to storage option (iii): no more than 7 days at 41°F, never past day 30. Bags above 41°F, or past day 30, discard.

On the log, every corrective action gets its own line: date, bag, what was found, what was done with the food, who did it, and who reviewed it. Use the free corrective action log.

In the plan: 8-201.14(E)(5), the action the designated food employee or person in charge takes when a limit is not met.

Principle 6: Establish verification procedures

FDA Food Code 2022, Annex 4, Principle #6

Verification includes those activities, other than monitoring, that determine the validity of the HACCP plan and show that the system is operating according to the plan.

Verification is the person in charge checking that the system works, not repeating the cook's job. The Food Code's own wording for a restaurant plan:

FDA Food Code 2022, 8-201.14(E)(6)

The method and frequency for the PERSON IN CHARGE to routinely verify that the FOOD EMPLOYEE is following standard operating procedures and monitoring CRITICAL CONTROL POINTS,

For the short rib: the person in charge reviews and signs the cooking, cooling and cold holding logs every day, watches one cooling check each week, checks every probe thermometer reads accurately (within ±2°F, 4-203.11(B)) and logs it, and pulls the unit's temperature record when reviewing the cold hold. Validation, the part that asks whether the limits really work, is mostly done for you here: the limits are the Food Code's own. It becomes real work only when you go outside them, which is when 8-201.14(F)(3) asks for scientific data.

On the log: a weekly line on the HACCP verification log (logs reviewed, gaps found, thermometers checked, signed), plus the thermometer calibration log.

Principle 7: Establish record keeping and documentation

FDA Food Code 2022, Annex 4, Principle #7

Records provide documentation that appropriate corrective actions were taken when critical limits were not met.

Annex 4 names the kinds of records worth keeping: prerequisite program records, monitoring records, corrective action records, verification and validation records, and calibration records. For the short rib that means the cooking, cooling, cold holding, corrective action, verification and calibration logs, plus the cold unit's continuous record. For sous vide the Food Code sets a minimum:

FDA Food Code 2022, 3-502.12(D)(3)(b)

Hold such records for at least 6 months

Your state or county may set a longer period, so check yours. The records have to be real, filled in at the time, by the person who took the reading. A week of identical readings in the same pen tells a reviewer more than any plan.

In the plan: 8-201.14(E)(7) lists the records, and (F)(2) asks for blank copies of every form.

The 7 principles mapped to Food Code 8-201.14

Your plan reviewer reads the plan against 8-201.14. Here is where each principle lands, and the three parts of 8-201.14 that are not principles at all.

That last block matters. A plan that nails all seven principles but skips the recipe and equipment (D) or the training plan (F)(1) still comes back. ClearHACCP builds the plan in 8-201.14 order with every principle inside it, so nothing falls between the two.

Where restaurant plans get the principles wrong

• Every step is a CCP. Ten CCPs means ten things to log at every batch, and the important three get lost. Most steps belong in procedures.
• The set point is used as the limit. A bath setting is not what the meat reached. The limit is on the food.
• Monitoring with no frequency. "Check cooling" is not a procedure. "Probe the thickest bag at 2 and 6 hours" is.
• The cook verifies their own log. Verification is a second set of eyes: the person in charge.
• Corrective actions that only notify. "Tell the chef" does not say what happens to the food.
• Records filled in later. A log written at the end of the week is not a record of anything.

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