Verification & Validation of the HACCP Plan

Aligned with HACCP Principles – Codex Alimentarius

Requirement Overview

Verification and validation are essential components of HACCP to confirm that the food safety plan is both scientifically sound and effectively implemented.

• Validation ensures that identified control measures are capable of controlling hazards.

• Verification ensures that the HACCP system is applied correctly and continues to operate effectively on an ongoing basis.

Both steps provide assurance that the food safety plan is robust, protects consumers, and meets regulatory and certification expectations.

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

  • Validate control measures to demonstrate they are effective in preventing or reducing hazards

    Verify that HACCP procedures are implemented consistently and correctly

    Maintain records of validation studies, verification checks, and corrective actions

    Regularly review and update the HACCP plan to ensure it reflects current operations and risks

Step-by-Step Compliance Implementation

1. Validate the HACCP Plan

  • When to Validate:

    • During initial plan development

      After significant product, process, or equipment changes

      Following system failures, incidents, or recalls

    Validation Activities May Include:

    • Scientific literature or industry guidance supporting CCPs

      Internal testing or challenge studies

      Review of process capability and equipment performance

    Evidence to Maintain:

    • Validation data, scientific references, or expert opinion

      Internal or external test results

      Signed validation reports

2. Verify Ongoing Implementation

  • Verification Tasks:

    • Routine review of CCP monitoring records

      Calibration of instruments used in monitoring

      Internal audits of HACCP records and practices

      Tracking and reviewing corrective actions

    Frequency:

    • Daily/weekly: record reviews, instrument checks

      Monthly/quarterly: internal audits

      Annually: comprehensive HACCP system review

    Evidence to Maintain:

    • Verification logs and checklists

      Calibration certificates

      Audit reports and follow-up records

      Corrective action verification documentation

3. Review and Update the HACCP Plan

  • Triggers for Review:

    • Introduction of a new product, ingredient, or supplier

      Changes in process, formulation, or equipment

      Regulatory or scientific updates

      Audit findings or consumer feedback

    Annual Review Should Include:

    • Effectiveness of existing controls

      Analysis of non-conformances and trends

      Adequacy of staff training and competency

    Evidence to Maintain:

    • Updated HACCP plan with revision notes

      Revised hazard analysis and process flow diagram

      Training records and updated SOPs

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No validation evidence for CCPs Provide scientific or technical justification for control measures
Incomplete verification records Maintain logs of reviews, calibrations, and internal audits
HACCP plan not reviewed annually Conduct and document formal annual review with management sign-off
Corrective actions not verified Ensure all CAPAs are reviewed, signed off, and supported with evidence

Auditor Verification Checklist

Auditors typically review:

  • Validation studies and supporting documentation

    Monitoring records with signatures and checks

    Verification logs and internal audit schedules

    Corrective action records and closure evidence

    Annual review reports and updated HACCP documentation

Implementation Roadmap

Build and Validate

  • Use scientific data and process capability to justify CCPs and critical limits

    Document validation of key process steps

Verify and Monitor

  • Review CCP records and calibrate instruments

    Perform internal audits and track corrective actions

Review and Improve

  • Conduct annual HACCP reviews

    Update the plan as processes or risks change

Why This Matters?

  • Confirms the HACCP plan is not just documented but working in practice

    Reduces the risk of undetected hazards or ineffective controls

    Demonstrates compliance and audit readiness

    Builds trust among consumers, customers, and regulators

Support Tools Available

Food Safety Systems provides:

  • HACCP validation and verification log templates

    Internal audit schedules and forms

    Scientific reference sheets for common CCPs

    Training guides for food safety and QA staff