HACCP for Dairy

The 7 HACCP Principles

Codex Alimentarius General Principles of Food Hygiene (CXC 1-1969) defines the 7 principles that every HACCP plan must address:

Hazard Analysis — What to Look For

Hazards in dairy come in three categories:

Biological hazards

• Vegetative pathogens — Salmonella, Listeria monocytogenes, E. coli O157, Cronobacter sakazakii, Staphylococcus aureus
• Spore-forming bacteria — Bacillus cereus, Clostridium botulinum, Clostridium perfringens
• Viruses — norovirus, hepatitis A (food-handler transmission)
• Parasites — rare in dairy but relevant for raw milk
• Toxin-producing organisms — S. aureus enterotoxin, Bacillus emetic toxin, mycotoxins from Aspergillus

Chemical hazards

• Antibiotic residues from veterinary treatments not respecting withdrawal periods
• Cleaning chemicals — caustic soda, nitric acid residues from inadequate rinsing
• Allergens — milk allergens themselves, plus added ingredients (nuts, soy, eggs in some dairy products)
• Mycotoxins — aflatoxin M1 carryover from feed
• Heavy metals — from feed contamination or equipment corrosion
• Pesticide residues — from feed
• Lubricants — non-food-grade lubricants on processing equipment

Physical hazards

• Metal — broken machine parts, milking equipment fragments, broken needles
• Glass — broken laboratory glassware, light fixtures (where used)
• Plastic — broken packaging, equipment components
• Wood — pallet splinters
• Foreign matter — insects, dirt, hair from operators

Typical Dairy CCPs

The CCP Decision Tree

Codex provides a 4-question decision tree to identify whether a hazardous step is a true CCP:

1. Do preventive control measures exist at this step?
2. Is the step specifically designed to eliminate or reduce the hazard to acceptable levels?
3. Could contamination occur at or beyond acceptable levels?
4. Will a subsequent step eliminate or reduce the hazard to acceptable levels?

A step is a CCP if it's the LAST point where the hazard is controllable in the process. For example, pasteurisation is a CCP for vegetative pathogens because no subsequent step in fluid milk processing would destroy them.

Prerequisite Programmes (PRPs)

HACCP rests on a foundation of prerequisite programmes — the operational hygiene controls that make HACCP feasible. Without effective PRPs, HACCP doesn't work.

HACCP and Modern Certification Schemes

HACCP is the foundation; most modern dairy operations sit under one of the GFSI-recognised certification schemes:

HACCP Verification & Validation

Validation (Principle 6)

Validation proves that the HACCP plan is scientifically sound — that the critical limits genuinely control the hazards. For pasteurisation, this means demonstrating that 72°C/15s achieves the required log-reduction of Coxiella burnetii. Usually relies on published thermal-death data rather than plant-specific testing.

Verification (Principle 6)

Verification confirms that the plan is being followed and is working in practice. Activities include:

• Reviewing CCP monitoring records
• Calibrating monitoring equipment
• End-product microbiological testing
• Internal audits
• External certification audits
• Customer / regulatory inspections

Annual HACCP review

The HACCP plan should be reviewed at minimum annually, plus whenever:

• New products are introduced
• Process changes are made
• New equipment is installed
• Regulatory requirements change
• An incident or near-miss occurs
• Customer requirements change

Common HACCP Plan Weaknesses

Frequently Asked Questions

What does HACCP stand for?

HACCP stands for Hazard Analysis and Critical Control Points. It is a systematic, prevention-based food safety methodology that identifies hazards, determines control points, sets critical limits, monitors them, and verifies the system is working. Codified in Codex CXC 1-1969 General Principles of Food Hygiene.

What are the 7 HACCP principles?

(1) Conduct hazard analysis; (2) Determine Critical Control Points; (3) Establish critical limits; (4) Establish monitoring procedures; (5) Establish corrective actions; (6) Establish verification procedures; (7) Establish documentation and record-keeping. Every HACCP plan must address all 7.

What are the typical CCPs in a dairy plant?

Pasteurisation (biological hazards), metal detection or X-ray (physical hazards), UHT sterilisation (where applicable), filling/sealing integrity (post-process contamination), antibiotic residue screening at milk reception (chemical), and allergen segregation/changeover for plants making multiple products. Most dairy plants have 3–5 CCPs.

What is the difference between a CCP and a PRP?

A CCP (Critical Control Point) is a step in the process where a hazard is specifically controlled or eliminated — failure here means food safety failure. A PRP (Prerequisite Programme) is an operational hygiene control that creates the conditions for HACCP to work — cleaning, pest control, training, building hygiene. PRPs provide the foundation; CCPs are the specific control points.

Do I need HACCP if I have FSSC 22000?

FSSC 22000 includes HACCP as part of its requirements (via ISO 22000). The HACCP plan is the food-safety engine; FSSC 22000 wraps the broader management system around it (documentation, management review, supplier control, training, etc.). You need both; FSSC 22000 already requires HACCP.

How often should HACCP plans be reviewed?

At minimum annually, plus whenever: new products are introduced, process changes are made, new equipment is installed, regulatory requirements change, an incident or near-miss occurs, or customer requirements change. The change-management procedure should trigger HACCP review when any of these happen.

What is HACCP validation vs verification?

Validation proves the HACCP plan is scientifically sound — that the critical limits genuinely control the hazards (usually relies on published data, e.g. thermal death kinetics for pasteurisation). Verification confirms the plan is being followed and is working in practice — via monitoring records review, calibration, end-product testing, audits.

Further reading: John Watson publishes articles on dairy industry topics on LinkedIn. Browse all articles by John Watson on LinkedIn →

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