A critical control point (CCP) is the step at which control is essential to prevent or eliminate a hazard or reduce it to an acceptable level (Regulation 852/2004, Article 5(2)(b)). The most common ones are about time and temperature.
How it is decided
- A decision tree or another method is used. The Commission warns that no decision tree is perfect for everything (Notice 2022/C 355/01, Annex II, section 6).
- If the hazard can be controlled later in the process, the step you are analysing is not a CCP.
- If control cannot be measured against a limit or seen in time (for example, cross-contact with an allergen), it is managed as an operational prerequisite programme (OPRP): with criteria, monitoring and records, just like a CCP.
- It may be that there is no CCP and good practices are enough. But this must be justified by the hazard analysis (section 3.2), and being small is not enough on its own if you serve vulnerable groups or advertise an allergen-free product.
- Frying or roasting in a restaurant may not be a CCP: the high temperature is visible and eliminates the hazard.
Critical limits (principle 3)
They separate acceptable from unacceptable (Article 5(2)(c)). They can be a figure (temperature, time, pH) or something observable, such as a liquid boiling or meat being cooked through. They come from legislation, guides, science or proven experience (section 7).
The figures in Spanish law (Royal Decree 1086/2020, Article 30)
- Prepared meals kept hot: at 63 °C or above.
- Chilled: 4 °C or below if the shelf life is over 24 hours; 8 °C or below if less. Frozen: −18 °C or below.
- Cooling cooked food: the core must drop from 60 °C to 10 °C in under two hours.
- Reheating: at least 74 °C for 15 seconds at the core, within an hour of taking it out of the fridge. Reheated food that is not eaten is thrown away.
A business may use other figures only if it shows the authority they have a scientific basis.
Source: Regulation (EC) No 852/2004 on the hygiene of foodstuffs (consolidated text), Article 5(2)(b) and (c) · Commission Notice 2022/C 355/01 on food safety management systems (good hygiene practices and procedures based on the HACCP principles), Annex II, sections 3.2, 6 and 7 · Real Decreto 1086/2020, flexibility in food hygiene and prepared meals (consolidated text, in Spanish), Article 30