Why HACCP Is the Foundation of BRC V9 Food Safety Compliance
If there’s one part of BRCGS that auditors take incredibly seriously, it’s the HACCP plan. And honestly, that makes sense. HACCP is where science, risk assessment, and real-world production meet. Over the years supporting food manufacturers and distributors preparing for audits, I’ve seen HACCP plans that protect companies flawlessly—and others that crumble under scrutiny because they were outdated, generic, or built just to “tick a requirement.”
If you’re reading this, you probably want clarity—not theory. You want to know:
What BRCGS Version 9 expects from your HACCP plan.
How to structure it in a way that’s audit-ready.
What common mistakes derail certification—and how to avoid them.
By the end of this guide, you’ll know exactly how to build, refine, and maintain a HACCP plan that genuinely protects consumers and satisfies auditors.
HACCP Team Requirements — Competence, Training & Cross-Functional Expertise
A strong HACCP plan starts with a strong HACCP team. One person writing everything alone rarely works—not because they lack skill, but because HACCP requires different perspectives. Production sees risks differently than Quality. Engineering catches control failures Operations never thinks about. Purchasing understands raw-material variation and supplier risk.
BRC V9 expects your team to:
Have documented HACCP training.
Represent multiple functions.
Understand the process—not just theory.
Have clearly defined responsibilities.
A simple but effective tool is a HACCP Competency Matrix. It immediately shows an auditor that you didn’t randomly assign names—you built a capable team.
Common mistake: Using someone on the HACCP team who’s never seen the actual process flow.
Quick win: Have every HACCP team member complete a floor walk before reviewing the plan. You’ll be shocked how many missed risks surface when people see the reality—not the paperwork.
Hazard Analysis Done Right — Risk Identification, Categorization & Assessment
A compliant hazard analysis isn’t a copy-paste from a training textbook—it needs to reflect your product, your equipment, and your process.
BRC V9 focuses on whether you’ve identified relevant hazards considering:
Physical risks
Chemical contamination
Biological pathogens
Allergen cross-contact
(If relevant) Radiological contamination
The best approach is structured: define the hazard, decide if it’s significant, and support that decision with real evidence—scientific references, historical data, or regulatory requirements.
Pro tip: If your risk-scoring method doesn’t clearly explain why a hazard is high or low risk, auditors will question it.
I once worked with a site where every hazard was scored “moderate” simply because “it felt safe.” The auditor didn’t agree—and they failed Stage 1.
Evidence matters.
CCP Identification & Controls — Practical Decision-Tree Use and Verification
Not every control step is a CCP—and not every CCP is obvious. BRC requires a logical justification, which is why decision trees exist. They help avoid two extremes:
Declaring everything a CCP “just in case.”
Declaring no CCPs because “PRPs cover it.”
Both fail.
A proper CCP is a step where failure will almost certainly result in an unacceptable safety risk—and no further step can fully correct or detect the issue.
Metal detection, cooking, pasteurization, sieving, and allergen control are common CCPs—but the justification must fit your process.
Common pitfall: Using a decision tree but never explaining how you reached the final decision.
Auditors don’t want to see the tree—they want to see the thinking.
Once you define a CCP, the next question is: How do you prove it works?
Critical limits must be:
Based on regulations, science, or validated safety data—not assumptions.
Clear enough that anyone monitoring understands the threshold.
Measurable and recorded in real-time when possible.
Monitoring and corrective action procedures should be written in plain language. If a new employee can’t follow the instructions confidently during an audit, the system isn’t robust enough.
Real example: A site had a cooking CCP but didn’t specify where the temperature probe should be inserted. Results varied, the CCP wasn’t truly controlled, and they received a Major.
Small details matter.
Validation, Verification & Review — Keeping the HACCP Plan Alive
A HACCP plan is never “finished.” It evolves every time something changes—equipment, ingredients, suppliers, processes, regulations, or even customer requirements.
If it’s not recorded, in BRC’s eyes, it didn’t happen.
Your HACCP documentation should be:
Organized and easy to navigate.
Version controlled.
Complete and signed by the HACCP team and senior management.
Digital systems are fantastic when used well—but printing a record five minutes before the audit isn’t documentation… it’s decoration.
Mistake to avoid: Having procedures that describe one thing and operators doing another. Auditors always notice.
FAQs
Q: How often does the HACCP plan need reviewing under BRC V9? At least annually—or sooner if there’s a process change, incident, or trend indicating risk.
Q: Can we use a generic HACCP plan as a base? Yes—only if you fully modify, validate, and document it for your own process.
Q: Is having no CCPs acceptable? It can be—but only if the risk assessment clearly supports that outcome.
Conclusion — A Strong HACCP Plan Builds a Strong Audit Outcome
A well-built HACCP plan protects your customers, your brand, and your certification. When your team is trained, your hazard analysis is evidence-based, your CCPs are justified, and your records tell a clear story—audits become far less stressful.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
