CCP Monitoring and HACCP Records from Your Control System

A critical control point (CCP) is a step in food production where a control is applied to prevent, eliminate or reduce a food safety hazard to an acceptable level. Many CCPs in a food plant are a temperature held for a time, or a check that product is free of foreign bodies, and the plant's control system already measures them. This guide explains which CCPs can be monitored automatically, what a monitoring record must show, how deviations should be handled, and what makes the records trustworthy.

It is written for QA and food safety managers, production managers and engineers in Australian food and beverage plants who want CCP records that are complete without manual transcription.

Where CCPs sit in a HACCP plan

Hazard Analysis and Critical Control Point (HACCP) is the internationally recognised system for managing food safety hazards. It is set out by the Codex Alimentarius Commission in its General Principles of Food Hygiene, and it rests on seven principles.

1. Conduct a hazard analysis.
2. Determine the critical control points.
3. Establish a critical limit for each CCP.
4. Establish a system to monitor each CCP.
5. Establish corrective actions for when monitoring shows a CCP is not under control.
6. Establish verification procedures to confirm the system works.
7. Establish documentation and record keeping.

A HACCP plan is the document that applies those principles to a specific product and process. The control system can do a great deal for principles 4, 5 and 7, and it supports principle 6. Principles 1 to 3 remain the job of the site's food safety team.

In Australia, food safety requirements are set by the Australia New Zealand Food Standards Code and enforced by state and territory regulators. Some sectors, such as dairy, have their own primary production and processing standards and regulators. Your food safety program and regulator set what your records must contain.

CCPs a control system can monitor

The CCPs best suited to automatic monitoring are those measured by an instrument the control system already reads.

Some limits are set by regulation. For example, the dairy processing standard in the Food Standards Code (Standard 4.2.4) requires milk to be pasteurised, commonly by holding it at no less than 72°C for no less than 15 seconds, or by an equivalent process. Others are set by the site's hazard analysis and validation. Either way, the limit belongs in the control system as a configured value with change control, not as a number someone remembers.

Checks that depend on a person, such as a visual inspection or a sensory check, can still be recorded electronically at the HMI against the batch and time, which removes the paper while keeping the human judgement.

What a monitoring record must show

A CCP monitoring record is evidence that the control was applied. For an automatically monitored CCP, it should show:

• the CCP and the equipment it applies to;
• the critical limit and any operating limit tighter than it;
• the measured value, at a frequency that suits the hazard, continuous where practical;
• the time of each reading, from a synchronised clock;
• the product, batch or run the reading applies to;
• the result against the limit, pass or deviation;
• who reviewed the record, and when.

The last point is often forgotten. Automatic logging does not remove the need for a person to review the record at the frequency the HACCP plan sets. It makes the review faster, because the record can show exceptions first.

Handling deviations

A deviation is any reading outside the critical limit. The HACCP plan sets the corrective action, but the control system can make it faster and more complete.

1. Detect. An alarm at the HMI and to supervisors as soon as the limit is crossed, with the CCP, value and time.
2. Act on the process. Automatic actions where the plan allows, such as a pasteuriser diverting product until temperature is restored.
3. Identify the product. The record shows which batch, run or time window is affected, so it can be held.
4. Record the corrective action. The operator or QA records what was done, against the deviation, at the HMI.
5. Sign off. A responsible person reviews and closes the deviation, and the record shows who and when.

Storing deviation records beside the monitoring record means an auditor sees the event, the product affected and the action taken in one place.

Verification and data integrity

Automatic records are only as good as the instruments and systems behind them. Verification activities that the control system can support include:

• Calibration: calibration dates and results for each CCP instrument, held beside its readings, with an alarm when calibration is due.
• Instrument checks: comparisons against a reference thermometer or test piece, recorded at the HMI.
• Record review: daily or per-batch review screens showing exceptions first.
• Clock synchronisation: one time base across PLCs, SCADA and servers so readings, batches and shifts line up.
• Access control and audit trail: only authorised users can change limits or acknowledge deviations, and every change is logged.
• Retention and backup: records kept for the period the food safety program requires, backed up and retrievable.

Replacing chart recorders

Many plants still record CCPs on paper or paperless chart recorders. They do one job well, and they are hard to search, easy to misplace and give no alarm. Moving a chart-recorder point into the control system gives a searchable record by batch, an alarm on deviation and no paper to file. A careful migration keeps the same channels, ranges and retention, runs the recorder in parallel until the new record is accepted, and updates the HACCP plan to name the new record.

CIP verification as a related record

Clean-in-place is not always a CCP, but it is usually a prerequisite program with records that auditors check closely. A CIP record should show each step's time, temperature, chemical concentration or conductivity, flow and return confirmation against the validated recipe. The same principles apply: capture it from the control system, alarm on failure, and make exceptions easy to review. Our guide to CIP automation for hygienic processing covers CIP design, and our work at McCormick and Lactalis covers CIP records and CIP set validation.

What this means

Most process CCPs in a food plant are measurements the control system already takes. Logging them continuously against the critical limit, alarming on deviation, identifying the affected product and recording the corrective action gives a more complete and more reviewable record than paper. The HACCP plan still sets the hazards, limits and verification; the control system makes monitoring and records reliable. Quality records beyond CCPs, such as checkweigher results and lot genealogy, are covered on our quality data and traceability page.

If you want your CCP and CIP records captured from the control system, speak with an engineer.