Stop HACCP becoming a paper exercise
How to keep HACCP practical: hazard analysis (principle 1), common implementation mistakes, honest risk scoring, reviews and the team.
Many HACCP studies start as practical tools and slowly become large documents updated only for audits. Our trainers and a certification body Head of Technical discussed how to keep HACCP alive.
Q: How do we know HACCP has become a paper exercise?
Warning signs include:
- the plan is only opened for the annual review or when an auditor visits
- the hazard analysis records the benefit of a process but not the hazards it creates. Vacuum packing is a classic: it doesn't eliminate microbial growth, it changes the environment, and can increase the significance of anaerobic microbiological hazards such as Clostridium botulinum if temperature, shelf life and product factors aren't managed
- scoring that works backwards from the answer you want, for example giving the same microorganism a different severity later in the study. Most controls reduce likelihood; they don't change how severe the outcome would be for the consumer
Q: How do we keep it meaningful on the factory floor?
- Make sure operators can explain why each control exists, what could go wrong and what to do if a control fails.
- Spend less time teaching paperwork and more time teaching people to think about hazards and risk.
- Let the team follow the evidence wherever it leads, rather than justifying the process.
- Include a production operative on the HACCP team, not just the production manager.
- Keep it simple: the strongest plans are rarely the longest.
Q: What are the most common mistakes when implementing HACCP?
- lack of management commitment (HACCP becomes a one-person job, usually the technical manager)
- incomplete hazard analysis
- wrongly identified CCPs, and unclear critical limits
- inconsistent monitoring and record-keeping
- not enough staff training HACCP, especially incomplete flow diagrams and hazard identification, is a recurring theme in BRCGS Food Safety non-conformities.
Q: Principle 1 (hazard analysis) is the hardest step. Any tips?
- Get the multidisciplinary team right first (step 1). It makes or breaks everything after it, and a new team leader inheriting a team should check whether any expertise is missing.
- Give people "thinking time" on their own before group discussion; they contribute far more.
- List all hazard types at every step so the team is prompted to consider each one. The hazard list in BRCGS Packaging Materials Issue 7 is particularly detailed. "N/A" or "no perceived hazard" with no list makes it look like the team didn't bother. Our STC HACCP & Food Safety Intermediate Level 3 works through hazard analysis step by step.
Q: How often should the HACCP plan be reviewed?
At least annually, and whenever processes, products or regulations change. It needs to be a team effort, not one person's job. BRCGS Food Safety Issue 9 sets this out in section 2.14 (review the HACCP plan).
Q: Does HACCP or HARA only matter for food?
No. On packaging, storage and distribution, and consumer goods sites, teams often take workplace health and safety very seriously but haven't considered how their product could harm the customer. HARA is a tool for exactly that: health and safety once the product leaves your four walls. When you score severity, score the real-world impact on the user or consumer. BRCGS Packaging Issue 7 uses HARA in its section 2 in place of HACCP.
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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 3, Level 4, BRCGS HACCP and BRCGS HARA. See the course calendar, or ask QTC for a HACCP review.