Start with the basics: good hygiene practices
HACCP sits on top of good hygiene practices, sometimes called prerequisite programmes: clean premises, pest control, trained staff, maintained equipment, safe water. In the 2020 revision of the Codex general principles, these good hygiene practices are given more emphasis, and some of them are recognised as needing greater attention than others.
For cold storage, the prerequisites include a refrigerator that is correctly sized and maintained, a working calibrated thermometer, a cleaning schedule, and staff who know the temperature limits. Without these, a HACCP plan is paperwork.
The seven principles applied to cold storage
| Principle | Cold-storage example |
|---|---|
| 1. Conduct a hazard analysis and identify control measures | Bacterial growth in chilled high-risk food; cross-contamination from raw meat; control by temperature and separation |
| 2. Determine critical control points (CCPs) | Decide whether chilled storage of ready-to-eat food is a CCP or managed as a good hygiene practice |
| 3. Establish validated critical limits | For example, high-risk chilled food at 5 °C or below; frozen at −18 °C or below |
| 4. Establish a system to monitor control of each CCP | Readings at fixed times, or continuous data logging with alarms |
| 5. Establish corrective actions | What staff do if food is found above the limit: assess, move, use or discard, then fix the cause |
| 6. Validate the plan, then establish verification procedures | Check limits are scientifically sound; review logs, calibrate thermometers, audit |
| 7. Establish documentation and record keeping | Signed logs, corrective-action records, calibration records, plan reviews |
Is cold storage a critical control point?
It depends on the food and the process. For ready-to-eat chilled food that won't be cooked again, such as salads, desserts, cut fruit or cooked meats, refrigeration may be the last control between a hazard and the customer. Many plans treat that as a CCP with a critical limit and formal monitoring.
For raw meat that will be cooked thoroughly later, the cooking step is often the CCP, and storage temperature is managed as a good hygiene practice. Codex provides a decision tool for identifying CCPs. The point is not to label everything a CCP, but to know which steps you cannot afford to get wrong and control them tightly.
Setting critical limits you can actually measure
A critical limit must be measurable at the moment of checking, so staff can act on it. Food temperature is ideal: a probe reading takes seconds. Use limits that are supported by recognised guidance, such as 5 °C for chilled food and −18 °C for frozen, unless you have validated evidence for something different.
Distinguish between the critical limit and an operating target. You might run the cabinet at 3 °C as a target so that you have a margin before the 5 °C limit is reached. Many plans also add a time element, for example how long food may be above 5 °C before it must be discarded.
Monitoring and corrective action that staff will follow
- Name who checks, when, with what instrument and where in the cabinet.
- Check product or a food simulant, not only the display reading.
- Write the corrective action in plain steps on the log sheet itself so it is there when needed.
- Corrective action covers two things: the food that may be unsafe, and the cause (a door left open, a failed fan, a dirty condenser).
- Record what was done and who decided, so the decision can be reviewed later.
Verification: proving the system works
Verification is the check on the checks. A supervisor reviews and signs the logs weekly, looks for patterns such as one cabinet always running warm after lunch, confirms thermometers read correctly, and occasionally takes an independent reading to compare. If you use data loggers, someone should review the downloaded data, not just trust that alarms would have fired.
Review the whole plan when something changes: a new menu item, a new refrigerator, a move to delivery-only service, or after any incident.
Keeping records that are useful
Records prove that controls were applied and help find causes when something goes wrong. FSSAI's published Schedule 4 says records of storage and other operations should be kept for one year or the shelf life of the product, whichever is more; check the current text for your business type. Keep records simple, legible and close to the equipment, and make filling them in part of the shift routine.
Frequently asked questions
- Does a small restaurant need a full HACCP plan?
- Requirements depend on the type and scale of business and your licence conditions, so check with FSSAI guidance or your food safety officer. Whatever the formal requirement, the HACCP way of thinking, identifying hazards, setting limits, monitoring and acting, is useful for any kitchen and costs very little to apply to refrigeration.
- What is the difference between monitoring and verification?
- Monitoring is the routine check, such as a cook reading the fridge temperature at 10 a.m. Verification is a separate check that the monitoring and the plan are working, such as a manager reviewing a week of logs, testing the thermometer and confirming that corrective actions were taken.
