15.2 HACCP Seven Principles
Key Takeaways
- HACCP’s seven principles in order are: hazard analysis, determine CCPs, establish critical limits, monitoring, corrective actions, verification, and record-keeping.
- Cooking poultry to 165°F is a typical restaurant critical control point and critical limit; “cook until done” is not a critical limit.
- Prerequisite programs — GMPs, SSOPs, and supplier control — support HACCP but are not a substitute for CCPs on a special process.
- A formal HACCP plan is required for Food Code special processes such as most ROP, curing, and smoking for preservation; ordinary cook-serve operations usually run on AMC without a submitted plan.
Hazard Analysis and Critical Control Point (HACCP) is a science-based system that identifies significant hazards and controls them at steps where control is essential. FDA and USDA use it in manufacturing. The Food Code requires a HACCP plan for certain retail special processes. Most ordinary restaurants do not need a bound seven-principle plan for a grilled chicken sandwich. They still need the thinking: what can go wrong, where you must not fail, what the number is, who checks it, and what you do if you miss.
Memorize the seven principles in order. The exam will scramble them.
The Seven Principles in Order
Principle 1 — Conduct a Hazard Analysis
Walk the process step by step and ask which biological, chemical, or physical hazards are reasonably likely. For a grilled chicken sandwich: Salmonella and Campylobacter on raw poultry; norovirus from bare hands on the bun or lettuce; allergen cross-contact if the same grill press just cooked a sesame bun; metal from a worn blade. Significance depends on severity and likelihood. A hazard that cooking will kill is still listed; you will assign the kill step as a critical control point in Principle 2.
Do not invent exotic hazards to look thorough. Do not skip the obvious ones because “we have always done it this way.” The analysis is about this menu and this equipment.
Principle 2 — Determine Critical Control Points
A critical control point (CCP) is a step where control can be applied and is essential to prevent, eliminate, or reduce a hazard to an acceptable level. Not every important control is a CCP. Washing hands is essential, but it is usually a prerequisite sanitation procedure, not a CCP, because it is not a single measurable process step with a critical limit on that sandwich. Cooking the chicken is a CCP: if it fails, surviving pathogens go onto a sandwich that will not be recooked.
A common exam trap is calling every SOP a CCP. Receiving, cold holding, and cleaning matter. They become CCPs only when they are the last essential control for a significant hazard in that process. On a cook-serve sandwich, the cook step is the classic CCP.
Principle 3 — Establish Critical Limits
A critical limit is the measurable boundary that separates safe from unsafe at that CCP. For poultry, FDA Food Code 3-401.11 is 165°F (74°C) for less than 1 second (instantaneous). “Cook until done,” “until juices run clear,” or “until it looks white” is not a critical limit. For cook-chill chili, cooling has critical limits: 135°F to 70°F in 2 hours, then 70°F to 41°F in 4 more hours (6 hours total from 135°F). Reheating that chili for hot holding has another limit: 165°F within 2 hours.
If you cannot measure it with a calibrated thermometer, a timer, a pH meter, or another specified device, it is not a critical limit.
Principle 4 — Establish Monitoring Procedures
Who measures what, where, when, and how. For the chicken CCP: the cook checks the thickest part with a calibrated thermometer on every batch (or a statistically valid frequency the plan specifies) and records the temperature, time, and initials. Watching color is not monitoring. Spot-checking “when we remember” is not a procedure.
Monitoring must be frequent enough to catch a failure while the food can still be recooked, cooled, or discarded. A log filled in at close from memory is not monitoring.
Principle 5 — Establish Corrective Actions
If the chicken is 158°F, continue cooking until 165°F; do not plate. If chili is still 80°F at the 2-hour mark, reheat to 165°F and restart the cool, or discard. Write who decides and what happens to the food. “Tell the manager” is incomplete if the sandwich still leaves the window. Corrective action also includes fixing the process so the next batch does not fail — a broken oven, an overloaded pan, an uncalibrated stem.
Principle 6 — Establish Verification Procedures
Verification asks whether the plan is working. Calibrate thermometers. Review logs every shift. The PIC or a designated person checks that cook temperatures were actually taken. Periodically confirm that 165°F is still the right limit for this process. An inspector or third-party auditor reviewing the plan is also verification.
Monitoring is the cook’s check. Verification is the check on the checker. Do not confuse the two on the exam.
Principle 7 — Establish Record-Keeping and Documentation
Keep the hazard analysis, the plan itself, CCP logs, corrective-action reports, calibration records, and verification reviews. If it is not written, the system cannot be verified and cannot be taught to the next PIC. Records also show the regulatory authority that a special process is under control.
Worked Example: Grilled Chicken Sandwich
Process flow: receive raw chicken → cold store → prep (portion) → grill cook → assemble on bun with RTE lettuce and tomato → immediate service.
| Principle | Restaurant example on this sandwich |
|---|---|
| 1 Hazard analysis | Biological: Salmonella/Campylobacter in raw chicken; norovirus on RTE garnish. Chemical: sanitizer residue. Physical: bone or metal. |
| 2 CCPs | Cooking the chicken is the CCP for vegetative pathogens. Assembly is hygiene (prerequisite), not a cook CCP. |
| 3 Critical limits | 165°F instantaneous in the thickest part |
| 4 Monitoring | Calibrated probe in the thickest piece each batch; record time, temperature, initials |
| 5 Corrective action | If below 165°F, continue cooking; if contaminated after cook, discard |
| 6 Verification | PIC reviews the cook log each shift; ice-point calibration; watch the cook take a real reading |
| 7 Records | Hazard analysis, cook logs, calibration log, corrective-action notes |
Cook-Chill Chili Overlay
A large batch of chili that is cooked, cooled, stored, and reheated for hot holding has more than one CCP. Cooking is one (135°F minimum for plant foods for hot holding; 165°F if the chili contains poultry). Two-stage cooling is another. Reheating for hot holding to 165°F within 2 hours is a third. That is why cook-chill and reduced-oxygen packaging are where formal HACCP appears in the Food Code: the hazards hide in the cool and the package, not only on the grill.
If you vacuum-pack that chili or run a cook-chill bag, you have left “ordinary leftover chili” and entered a special process. Chapter 11 covered variances. This chapter is why the RA also wants the seven principles on paper.
Prerequisite Programs Versus HACCP
HACCP assumes the basics already work. Those basics are prerequisite programs:
| Prerequisite | Examples | Why it is not usually a CCP |
|---|---|---|
| GMPs (good manufacturing / retail practices) | Personal hygiene, pest control, facility condition, approved water | Broad, continuous conditions, not a single process step |
| SSOPs (sanitation standard operating procedures) | Warewashing, slicer cleaning every 4 hours, restroom stocking | Essential hygiene; monitored, but not the kill step |
| Supplier control | Approved sources, incoming inspection | First risk-factor control; often a prerequisite so HACCP can focus on in-house CCPs |
| Employee health | Exclusion and restriction policy | People control across every item, not one product CCP |
| Allergen program | Separation, labeling, communication | Critical for guests; usually a prerequisite unless a process claims allergen removal |
If prerequisites collapse — sewage on the floor, no hot water, an excluded cook on the line — HACCP logs will not save the food. Fix the prerequisite or stop service. The next section treats those collapses as crises.
When a HACCP Plan Is Required Versus When AMC Is Enough
Food Code 8-201.13 and 3-502.11 / 3-502.12 are the usual retail triggers. A formal HACCP plan is typically required for special processes: smoking for preservation, curing, using additives to render food non-TCS, custom animal processing, sprouting, most reduced-oxygen packaging (vacuum, MAP, cook-chill, sous-vide), molluscan shellfish tanks, and juice treatment that claims a 5-log reduction. Some limited ROP under 3-502.12 can skip a variance but still needs a HACCP plan.
Ordinary cook-serve operations — grill the chicken, hold the soup, cool leftover chili under 3-501.14 — run on AMC: SOPs, monitoring, correction, and records without a seven-principle plan submitted to the RA. If you invent a process that changes pH, oxygen, or shelf life, stop and ask the RA. Do not relabel AMC paperwork as a HACCP plan to justify sous-vide.
The exam trap: HACCP is not “whatever we write after an outbreak” and not “the binder we show instead of taking temperatures.” It is a specified seven-step system. AMC is the everyday retail version. Special processes need both AMC and a formal HACCP plan — and often a variance.
In the standard HACCP order, which task is Principle 3?
On a grilled chicken sandwich, cooking the chicken to 165°F is best described as:
When does a retail operation typically need a formal HACCP plan rather than Active Managerial Control alone?