Can a Warehouse HACCP Plan Have No CCPs?

Hi everyone,

We are a food warehouse and storage company handling ambient temperature products. Our operation includes receiving, storing, and distributing. Some of the products contain allergens, but we do not open, process, or repack anything, just storage and distribution.

We are currently preparing our HACCP plan for certification, and after conducting the hazard analysis, we’ve found that all potential hazards (like pest control, allergen cross-contact, damaged packaging, etc.) are being effectively managed through prerequisite programs (PRPs).

My questions:

1. Is it acceptable to have a HACCP plan with no CCPs in this kind of warehousing setup?

2. Would anyone be willing to share an example HACCP plan summary or template for a similar warehouse environment (ambient temp, allergens present, no food handling)?

3. Any recommendations for how to justify the absence of CCPs clearly in the HACCP documentation?

Any help or shared experience would be greatly appreciated. Thanks in advance!

Hi fqsknh,

It quite possible to have no CCPs in your HACCP Plan if all identified hazards are controlled by prerequisite programmes. Relevant info below including what should be in your control plan for those hazards that are controlled by PRPs and evidence of how you came to your decision.

CODEX GENERAL PRINCIPLES OF FOOD HYGIENE CXC 1-1969 2022 Revision

13. CONTROL OF OPERATION

13.1.3 Consideration of the effectiveness of GHPs

Having considered the product and process descriptions, an FBO should determine (using information relevant to hazards and controls from various sources as appropriate) whether the GHPs and other programmes they have in place are sufficient to address food safety and suitability or if some GHPs need greater attention. For example, a cooked meat slicer may require specific and more frequent cleaning to prevent the build-up of Listeria spp. on its meat contact surfaces, or a conveyor belt used in direct contact with the food, such as in sandwich production, may require an increased frequency of cleaning or a specific cleaning programme.

13.1.4 Monitoring and corrective action

The FBO should monitor the hygienic procedures and practices as relevant to the business and as applicable to the hazard being controlled. Procedures could include defining methods of monitoring (including defining responsible personnel, frequency, and sampling regime if applicable) and monitoring records to be kept. The frequency of monitoring should be appropriate to ensure consistent process control.

13.1.5 Verification

The FBO should undertake verification activities as relevant to the business, to check that GHP procedures have been implemented effectively, monitoring is occurring, where planned, and that appropriate corrective actions are taken when requirements are not met. Examples of verification activities could include the following, as appropriate:

-       review of GHP procedures, monitoring, corrective actions, and records;

-       review when any changes occur to the product, process and other operations associated with the business; and

-       assessment of the efficacy of cleaning.

Records of GHP verification activities should be kept, where appropriate.

You can also use Annex IV – Tools to determine the critical control points (CCPs) - Figure 1: Example of a CCP decision tree – apply to each step where a specified significant hazard is identified

HARA 2.6.1 Color Decision Tree WHO UN.jpg   115.66KB   1 downloads

See Q1 Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?

* Consider the significance of the hazard (i.e. the likelihood of occurrence in the absence of control and the severity of impact of the hazard) and whether it could be sufficiently controlled by prerequisite programs such as GHPs. GHPs could be routine GHPs or GHPs that require greater attention to control the hazard (e.g. monitoring and recording).

Kind regards,

Tony

Hi fqsknh,

 

It quite possible to have no CCPs in your HACCP Plan if all identified hazards are controlled by prerequisite programmes. Relevant info below including what should be in your control plan for those hazards that are controlled by PRPs and evidence of how you came to your decision.

 

CODEX GENERAL PRINCIPLES OF FOOD HYGIENE CXC 1-1969 2022 Revision

 

13. CONTROL OF OPERATION

13.1.3 Consideration of the effectiveness of GHPs

Having considered the product and process descriptions, an FBO should determine (using information relevant to hazards and controls from various sources as appropriate) whether the GHPs and other programmes they have in place are sufficient to address food safety and suitability or if some GHPs need greater attention. For example, a cooked meat slicer may require specific and more frequent cleaning to prevent the build-up of Listeria spp. on its meat contact surfaces, or a conveyor belt used in direct contact with the food, such as in sandwich production, may require an increased frequency of cleaning or a specific cleaning programme.

 

13.1.4 Monitoring and corrective action

The FBO should monitor the hygienic procedures and practices as relevant to the business and as applicable to the hazard being controlled. Procedures could include defining methods of monitoring (including defining responsible personnel, frequency, and sampling regime if applicable) and monitoring records to be kept. The frequency of monitoring should be appropriate to ensure consistent process control.

 

13.1.5 Verification

The FBO should undertake verification activities as relevant to the business, to check that GHP procedures have been implemented effectively, monitoring is occurring, where planned, and that appropriate corrective actions are taken when requirements are not met. Examples of verification activities could include the following, as appropriate:

-       review of GHP procedures, monitoring, corrective actions, and records;

-       review when any changes occur to the product, process and other operations associated with the business; and

-       assessment of the efficacy of cleaning.

Records of GHP verification activities should be kept, where appropriate.

 

You can also use Annex IV – Tools to determine the critical control points (CCPs) - Figure 1: Example of a CCP decision tree – apply to each step where a specified significant hazard is identified

 

HARA 2.6.1 Color Decision Tree WHO UN.jpg

 

See Q1 Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?

 

* Consider the significance of the hazard (i.e. the likelihood of occurrence in the absence of control and the severity of impact of the hazard) and whether it could be sufficiently controlled by prerequisite programs such as GHPs. GHPs could be routine GHPs or GHPs that require greater attention to control the hazard (e.g. monitoring and recording).

 

Kind regards,

 

Tony

Thank you very much !!!! That’s really helpful !!!

Just to clarify and build on our situation:

We’ve gone through the hazard analysis step-by-step and assessed each potential hazard (pest activity, allergen cross-contact, packaging integrity) in our ambient storage and distribution warehouse. Based on our assessment, all hazards are effectively controlled through PRP, including documented pest control, allergen management policies, receiving inspections, cleaning schedules, staff training, and segregation practices.

From what I’ve gathered, it seems that having no CCP is acceptable as long as we can justify that all significant hazards are controlled through PRP that are effectively monitored and verified. I just want to confirm I'm interpreting that correctly?  :helpplease:

Yes you're interpreting it correctly.  CCPs are normally very low in number even in plants taking in raw ingredients containing pathogens and producing ready to eat or reheat foods.  I'd see it as completely acceptable in a warehouse.  In most sites I've worked at where there are on site warehouses there are no CCPs.  If you work to an ISO based standard you might consider oPRPs but even they are remote.  I'd be happy with PRPs.

Remember though that PRPs don't mean no control or no verification.  In fact if anything they're often harder to control.  It's rare a recall or audit finding is on a CCP in my experience, it happens but it's normally a sign of a very crap site.  Most issues are in PRPs because they're more diffuse across your site and require more discipline to adhere to.

We are a 3PL ambient storage facility that has finished product ready for retail and we store ingredients and raw materials that will be processed later at other facilities.  Our HACCP is fairly simple and no CCP's.  

1. Is it acceptable to have a HACCP plan with no CCPs in this kind of warehousing setup? Yes

2. Would anyone be willing to share an example HACCP plan summary or template for a similar warehouse environment (ambient temp, allergens present, no food handling)? My "HAACP Plan Summary" just says "No critical control points identified."  It felt weird so I did add a summary of our flowchart, including non-conformance/damage disposal (all exposed foods are disposed of, we do not do recoup) as well as a summary on "known potential hazards" including allergens, chemical, pests, foreign material and included statements on trailer inspections, food defense, and training.

3. Any recommendations for how to justify the absence of CCPs clearly in the HACCP documentation? We have that all products are shelf-stable and sealed by the customer, but we do not own any of the product we store.

Quite simply, yes it is acceptable not to have any CCP's in your warehouse HACCP Plan providing you have followed the HACCP process including assessing all micro, chemical including allergens, and physical hazards at each step.   You should also have pre-requisite programs in place to support your HACCP plan,  including but not limited to, pest control, cleaning, transport and storage practices,  personnel requirements, traceability, etc.

Your HACCP plan is your justification.  I actually have a justification column as part of my Hazard Analysis Table.  It makes it visible and helps to explain to others how I have arrived at my ratings / decision.  I have attached an example of a warehouse receival step with the justification column (the ratings and questions are linked to an internal risk matrix but just wanted to show you the format).

Hope this helps.

Yes, I previously worked in a storage and distribution company handling ambient, frozen and chilled product and we had our HACCP plan with no CCPs, we risk assessed it on the basis if we had any temperature issues we would be rejecting this product at the door therefore it never came on site to us out of temperature, so any temperatures on site were due to refrigeration issues etc. got through all BRC, STS, Yum audits and more with this.