Who should lead your HACCP team, and how well trained must they be?
Can a consultant be HACCP team leader? What training level is right? How small businesses without a trained leader can stay compliant.
Small sites often lean on consultants for HACCP. Our trainers and a certification body Head of Technical answered the questions this raises.
Q: Can a consultant be the HACCP team leader?
They can, but it isn't the best approach. If they are, they must take full ownership and have a deputy for their absence. Better: an internal team leader with the consultant as deputy, so in-house knowledge grows over time and the plan stays under the company's control.
From a certification point of view, the BRCGS standards require day-to-day management of the food safety system remains the site's responsibility, and the person doing that is in effect the HACCP team leader. UK law places responsibility on the food business operator; convincing a court that a consultant was the responsible person could be a real challenge. Auditors are sceptical when a consultant is documented as team leader, and especially so if the same consultant also carries out the HACCP internal audit. BRCGS Food Safety Issue 9 sets the HACCP team requirements in clause 2.1.
Q: What level of training does a HACCP team leader need?
Technical HACCP and food safety training is only part of the picture. A strong team leader also needs leadership skills, the ability to manage group dynamics, and awareness of how habits, overconfidence and "it's always been fine" thinking can skew food safety decisions. HACCP shouldn't fall on one person: build a competent team that shares the responsibility.
Q: We're very small and have no trained HACCP lead. What can we do?
- Get professional help: compare providers, ask other businesses for recommendations and read reviews.
- Use free resources such as the FSA's MyHACCP guidance as a starting point. These are a good basic model but not detailed enough for GFSI certification such as BRCGS.
- Make clear in any consultancy contract that the business still has its part to play.
Q: I've spotted a safety issue but there's no-one in charge of HACCP. What should I do?
Document it (a simple log of what's wrong and the risks), raise it with whoever is in charge, and suggest a fix. If it's a serious risk, push harder: point to legal requirements or get an external opinion.
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Reviewed by Chisala Ngandwe, Technical Manager & Trainer, STC · November 2026
These Q&As share general best practice from our trainers and auditors. They aren't consultancy advice for your site. For support specific to your site and systems, we can refer you to our sister company QTC.
Learn more: HACCP & Food Safety Level 4, the HACCP Refresher & Update, and the course calendar. For HACCP implementation support, contact QTC.