HACCP Principle 2 & 3: Identifying CCPs and Setting Critical Limits

HACCP Principle 2 & 3 Identifying CCPs and Setting Critical Limits
Food Safety

HACCP Principle 2 & 3: Identifying CCPs and Setting Critical Limits

Last Updated on December 2, 2025 by Melissa Lazaro

Why CCPs and Critical Limits Matter

When teams finish their hazard analysis, the next big question usually sounds like this:
“So… how do we know which step is a CCP?”

I hear that almost every time I guide a food business through HACCP or GFSI certification—whether they’re a startup bakery or a large export manufacturer.

Identifying Critical Control Points (CCPs) and setting Critical Limits isn’t just a paperwork step. This is where your food safety plan becomes real, measurable, and defensible. It’s where you start separating assumptions from controlled, proven actions.

In this guide, you’ll learn how to identify CCPs using a simple method, avoid the most common mistakes food businesses make, and set science-based critical limits that hold up during audits.

By the end, you’ll feel more confident defining CCPs and applying limits that actually protect consumers—not just tick boxes.

Understanding Critical Control Points (CCPs) — What They Are and Why They Matter

A Critical Control Point is a step in your process where a control must be applied to prevent, eliminate, or reduce a food-safety hazard to an acceptable level.

If control fails at this point, the product may no longer be safe. That’s why CCPs require measurable limits, documented monitoring, and corrective actions.

To give you a simple comparison:

  • PRPs: Foundation controls (cleaning, pest control, hygiene).
  • OPRPs: Important controls, but not as strict as CCPs.
  • CCPs: Your highest level of control—no room for compromise.

Example CCPs you might recognize:

  • Cooking poultry to destroy pathogens
  • Metal detection on packaged products
  • Confirming allergen labelling accuracy

Pro Tip: A CCP typically controls a significant hazard that isn’t fully handled anywhere else.

Common Mistake: Some teams turn everything into a CCP because they think “more is safer.” In reality, unnecessary CCPs create excessive monitoring work and increase the chance of human error.

HACCP Principle 2 & 3: Identifying CCPs and Setting Critical Limits Using the CCP Decision Tree — A Practical Method for Identifying CCPs

The most reliable tool for identifying CCPs is the HACCP decision tree. It’s a structured series of yes/no questions designed to help you evaluate each process step in a consistent way.

For example, you’ll ask questions like:

  • Is there a hazard at this step that requires control?
  • Is the step specifically designed to eliminate or reduce the hazard?
  • Can control at this step fully prevent the hazard?

Let’s look at two quick scenarios:

  • Cooking ready-to-eat chicken:
    The step is designed to eliminate pathogens → CCP.
  • Visual label check during packaging:
    It prevents undeclared allergens, but it’s not always the only control (software, barcode verification, supplier controls may exist).
    This may be CCP or OPRP depending on risk and evidence.

Pro Tip: Use the decision tree as a group—production, QA, technical, maintenance. Different perspectives reduce blind spots.

Common Mistake: Teams often jump straight to the answer instead of documenting why decisions were made. During audits, the justification is just as important as the conclusion.

Documenting CCP Identification — Making Decisions Traceable and Audit-Ready

Once CCPs are identified, document everything: the decision, the reasoning, and the evidence behind it.

Auditors expect to see:

  • The decision tree or equivalent method
  • Written justification (not one-word responses)
  • Links to hazard analysis and process flow diagrams
  • Any scientific or historical data supporting the decision

Here’s a simple example of justification language:

“This step is a CCP because cooking is required to destroy Salmonella and Listeria, and no further kill step exists downstream.”

Pro Tip: Keep documentation formats consistent across all HACCP sections—hazard analysis, CCP list, monitoring forms.

Common Mistake: Updating one document and forgetting to update other related records. This causes confusion and creates audit findings.

Setting Critical Limits — Turning Safety Requirements into Measurable Controls

Once a CCP is identified, the next step is setting a Critical Limit—a measurable, non-negotiable standard that must be met to ensure food safety.

Critical limits must be:

✔ measurable
✔ observable
✔ scientifically justified

Examples of valid critical limits include:

  • Temperature: Cook to ≥ 75°C for at least 15 seconds
  • pH: Maximum pH 4.4 within defined fermentation timeframe
  • Metal detection: 2.0 mm ferrous / 2.5 mm non-ferrous / 3.0 mm stainless
  • Allergen controls: Validated swab < limit of detection

Pro Tip: Use regulatory guidance, scientific journals, process validation studies, or challenge testing—not tradition or opinion—to set limits.

Common Mistake: Setting limits based on equipment capability instead of safety requirements. The process must match the science—not the other way around.

Examples of Critical Limits in Real Food Processes

Here are a few real-world examples I’ve used while supporting HACCP and certification clients:

  • A poultry facility validated its cooking step based on regulatory time-temperature tables.
  • A beverage manufacturer reduced spoilage risks by introducing a pH limit supported by fermentation science.
  • A bakery strengthened allergen verification by validating cleaning with allergen-specific ELISA swabs rather than visual checks.

These examples had one thing in common: evidence-based decisions.

Auditors rarely challenge well-supported limits. They often challenge undocumented assumptions.

Verification and Validation — Making Sure CCPs and Limits Actually Work

Setting limits isn’t the end—you need to prove they work.

  • Validation confirms the limit is scientifically effective (before implementation).
  • Verification confirms procedures are being followed (ongoing).

Examples of evidence:

  • Calibration records
  • Microbial challenge studies
  • Review of CCP monitoring logs
  • Trend analysis of deviations or incidents

Pro Tip: Validation documents should be easy to find—don’t bury them in unlabelled folders or emails.

Common Mistake: Treating validation as a one-time task instead of reviewing controls after process changes or incidents.

FAQs — CCPs & Critical Limits

Is there a required number of CCPs?
No. Some plants have one, others have several. The number depends on your hazards and processes—not certification expectations.

Can I use supplier documentation as justification for critical limits?
Yes—but only if it’s validated and applicable to your process.

Are CCPs and OPRPs the same thing?
Not exactly. CCPs require strict monitoring and corrective action. OPRPs are important controls but may not require the same intensity of monitoring.

Conclusion — Moving Forward with Confidence

Identifying CCPs and setting critical limits takes time, teamwork, and the right mindset. But once it’s done properly, it builds a HACCP plan that’s strong, defensible, and practical to use every day—not just during audits.

If you want help reviewing CCP decisions or validating your limits, now is a great time to get expert support before finalizing your plan or scheduling certification.

Share on social media

Leave your thought here

Your email address will not be published. Required fields are marked *