Establishing Critical Limits for Each CCP

Aligned with HACCP Principle – Codex Alimentarius / 21 CFR 117.135(c)(3)

Requirement Overview

HACCP Principle 3 requires that critical limits be established for each Critical Control Point (CCP). A critical limit is a specific, measurable value (e.g., temperature, time, pH) that must be achieved to ensure a hazard is effectively controlled.

Exceeding or failing to meet a critical limit indicates a loss of process control, requiring immediate corrective action to protect food safety.

Critical limits are validated boundaries, not targets, and must clearly define the difference between safe and unsafe conditions.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • Identify measurable limits that control hazards effectively

    Ensure all CCPs have scientifically validated critical limits

    Document the basis, source, and method for each limit

    Maintain monitoring, verification, and corrective action records

Step-by-Step Compliance Implementation

1. Identify the Hazard at Each CCP

  • Clarify which hazard (biological, chemical, or physical) is controlled. Example: Pathogen destruction during cooking; allergen cross-contact prevention.

    Evidence to Maintain:

    • CCP decision tree results

      Hazard analysis documentation

2. Determine the Appropriate Critical Limit

  • Establish measurable values or ranges that guarantee hazard control.

    Examples of Critical Limits:

    • • Time/Temperature: 165°F (74°C) for 15 seconds

      • pH or Water Activity (Aw): pH ≤ 4.2, Aw ≤ 0.85

      • Concentration: Sanitizer ≥ 200 ppm

      • Physical Parameters: Metal detector sensitivity ≥ 2.0 mm Fe

    Evidence to Maintain:

    • Scientific or regulatory references (FDA, USDA, NACMCF)

      Validation studies (in-house or third-party)

3. Document the Monitoring Method

  • Detail how the limit will be measured and by whom.

    Monitoring Parameters:

    • What is being measured (temperature, pH, sanitizer level, etc.)

      Who is responsible

      Frequency of monitoring (continuous, batch, hourly, etc.)

      Tools used (calibrated thermometer, pH meter, strips)

    Evidence to Maintain:

    • Monitoring logs/forms

      Equipment calibration records

4. Set Clear, Measurable Values

  • Avoid vague or subjective limits.

    Examples:

    • Acceptable: “Product must reach ≥165°F for ≥15 seconds.”

      Unacceptable: “Product must be adequately cooked.”

    Evidence to Maintain:

    • Signed CCP summary sheets

      Calibration SOPs

      CCP-specific work instructions

5. Link Critical Limits to Corrective Actions & Verification

  • Every CCP must have a corrective action plan for when limits are not met.

    Evidence to Maintain:

    • HACCP plan with critical limits and linked corrective actions

      Corrective action logs

      Verification records (review signatures, audits, trending reports)

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Vague or undefined critical limits Define specific measurable values with units and duration
Critical limits not scientifically justified Reference regulatory/scientific sources or conduct validation
Monitoring lacks assigned personnel or frequency Assign responsibility and set monitoring schedules
Critical limit not tied to corrective action Link every CCP limit directly to corrective response procedures

Auditor Verification Checklist

During audits, expect review of:

  • CCP summary tables with defined critical limits

    Scientific/regulatory references supporting each limit

    Monitoring logs with staff responsibilities

    Calibration records for monitoring equipment

    Corrective action history and resolution

Implementation Roadmap

Build Your CCP Framework

  • Identify hazards and define CCPs

    Assign validated, measurable critical limits

Train and Equip Your Team

  • Provide monitoring tools and role-specific training

    Maintain calibration of instruments

Monitor and Record

  • Use standardized forms for tracking compliance

    Record deviations, corrective actions, and verifications

Improve Continuously

  • Revalidate limits if processes, products, or equipment change

    Trend deviations to identify systemic improvements

Why This Matters?

  • Prevents unsafe food from reaching consumers

    Demonstrates compliance with Codex and U.S. regulations

    Strengthens traceability and accountability

    Enables timely corrective action to protect public health

Support Tools Available

Food Safety Systems provides:

  • CCP critical limit templates

    Monitoring and corrective action log sheets

    Validation reference libraries

    HACCP personnel training modules