When to review your HACCP plan: the triggers and how to run the annual reassessment

Most HACCP plans are accurate on the day they are signed and start drifting the next morning. A new supplier, a moved conveyor or a recipe tweak from the sales team, and the plan no longer describes the factory you run. Knowing your HACCP plan review triggers, and running a proper annual reassessment, is what keeps the plan honest and keeps your auditor satisfied.

Why a HACCP plan goes out of date

A HACCP plan is a model of your process: the products, the raw materials, the steps, the hazards and the controls. The factory keeps changing while the document stays still. On audits we regularly find flow diagrams that are missing a step added two years ago, hazard analyses that do not mention a raw material now in daily use, and critical limits based on an oven that has since been replaced.

None of this happens through neglect alone. It happens because the people making changes, in production, engineering and procurement, do not see the HACCP plan as theirs. The fix has two parts: a list of triggers that force a review when something changes, and a full reassessment at least once a year to catch what the triggers missed. Both SANS 10330 and the Codex HACCP principles expect the system to be reviewed and kept up to date. Codex does not fix an interval for the full review; once a year is the common minimum, and your certification scheme or customer may set it for you.

The HACCP plan review triggers that require a review now

Write these into your HACCP procedure so that everyone knows a change is not finished until the HACCP team has looked at it.

• A new product or a recipe change. New ingredients, different proportions, a change in pH or water activity, or a new allergen.
• A new raw material or supplier. Even the “same” ingredient from a new supplier can bring a different hazard profile.
• Equipment, layout or process changes. New machines, moved lines, changed flow of people or product, new cleaning chemicals or methods.
• A change in packaging. A new pack format, gas mix or shelf life claim.
• A change in intended use or consumer. For example, starting to supply a hospital, an old age home or a school feeding programme.
• A CCP failure trend. Repeated deviations at the same CCP mean either the control or the critical limit needs to be looked at again.
• Complaints, incidents, withdrawals or recalls. Especially when the cause was a hazard your plan did not identify.
• New legislation, customer requirements or emerging hazards. New regulations, a customer code of practice, or an outbreak linked to a similar product.
• Verification findings. Laboratory results, internal audit findings or environmental monitoring that show the plan is not working as intended.

A review triggered by one change does not have to cover the whole plan. It covers the steps, hazards and controls the change could affect, and it is recorded in the same way as the annual review.

Change control: catching changes before they reach the line

The triggers only work if changes reach the HACCP team before they reach the production floor. A simple change request form does this. Whoever proposes the change completes it, and the HACCP team leader signs it before the change goes ahead.

The form should ask:

1. What is changing, and when?
2. Which products, lines and process steps does it affect?
3. Does it introduce a new hazard, including an allergen, or change an existing one?
4. Does it affect a CCP, an OPRP or a prerequisite programme?
5. Do documents, labels, training or validation need updating before start-up?
6. Who has approved it, and when was the HACCP plan updated?

A worked example

A meat processor in the Western Cape decided to launch a cheese-filled boerewors. Sales and production agreed the recipe in a week. Because the change request went to the HACCP team first, they picked up three things: a new allergen (milk) on a line that previously had none, the need for a cleaning validation between the cheese product and the plain product, and a new supplier for the cheese who had not yet been approved. Labels, the allergen matrix and the cleaning schedule were all updated before the first production run, not after the first complaint.

Running the annual reassessment step by step

The annual reassessment is a full, structured look at the whole plan. Block a day, or two half days, and work through it in order.

1. Confirm the team. Check that the HACCP team still covers production, engineering, quality and hygiene, and that members have current training.
2. Review the scope and product descriptions. Are all products in the plan, and are the descriptions, intended use and shelf life still correct?
3. Verify the flow diagrams on the floor. Walk each diagram during production, on more than one shift if possible. Note every rework loop, hold point and bypass that is not on paper. BRCGS Issue 9 requires this on-site check at least annually and whenever the process changes.
4. Rerun the hazard analysis. Go step by step through biological, chemical (including allergens) and physical hazards. Use the year’s complaints, deviations, lab results and industry alerts as inputs.
5. Check the CCP and OPRP decisions. Are the controls still in the right place, and is anything that was a CCP now better managed another way, or the other way round?
6. Review monitoring and corrective action records. Look at twelve months of deviations at each CCP. Trends matter more than single events.
7. Review verification results. Calibration, internal audits, record reviews, product and environmental testing.
8. Review the prerequisite programmes. Cleaning, pest control, maintenance, personal hygiene and supplier approval all support the plan.
9. Update, approve and communicate. Reissue the plan, retrain the people affected and withdraw old copies.

Checking that validation still holds

Validation is the evidence that a control measure, at its critical limit, actually controls the hazard. Verification checks that you are doing what the plan says. A plan can pass verification every day and still be invalid if the process has changed underneath it.

During the reassessment, ask for each CCP:

• What is the evidence for this critical limit? A scientific reference, a regulation, a supplier’s study, or your own trials?
• Was that evidence produced for the equipment, product size and loading we use now?
• Have batch sizes, container sizes, oven loading or line speeds changed since?
• For metal detection, are the test pieces still right for the current product and pack?

If a cooking validation was done with 5 kg trays and you now cook 10 kg trays, the old validation does not cover the new process. Revalidate before you rely on it. Our HACCP and GMP implementation consulting often starts with exactly this check.

Recording the review so an auditor can follow it

An auditor should be able to pick up your review record and see what was looked at, what was found and what changed. Keep:

• The date, attendance and the trigger (annual, or the specific change).
• A table with each item reviewed, the evidence considered, the conclusion and any action with an owner and date.
• A change log in the plan itself showing the version, the date, what changed and why.
• Superseded versions, retained and marked as obsolete.
• Sign-off by the HACCP team leader and senior management.

“Reviewed, no changes” is acceptable only if the record shows what was reviewed. A one-line entry with a signature tells the auditor nothing. If you need a consistent structure across the plan, the HACCP and PRP document templates toolkit (SANS 10330 and SANS 10049) gives you templates to adapt. An internal food safety audit before your certification audit is a good test of whether the review record stands on its own.

What to do this week

• Add the list of review triggers to your HACCP procedure.
• Introduce or relaunch a change request form, and tell production, engineering and procurement it exists.
• Check the date of your last full reassessment and book the next one.
• Pick one CCP and find the validation evidence for its critical limit.
• Walk one flow diagram on the floor during production.

For HACCP team leaders who own the system and need to defend it at audit, our Advanced HACCP System Implementation course goes deep into hazard analysis, validation, verification and keeping the plan current.