DEAS 151: 2023 
ICS 67.020  
 
© EAC 2023                                                                                                                          Second  Edition 2023 
 DRAFT EAST AFRICAN STANDARD  
Hazard Analysis Critical Control Point (HACCP) systems — 
Requirements  
EAST AFRICAN COMMUNITY  DEAS 151: 2023 
ii © EAC  2023 – All rights reserved  
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Violators may be prosecuted . DEAS 151: 2023 
© EAC 2023 – All rights reserved  iii 
 Contents  Page 
Foreword  ................................ ................................ ................................ ................................ ............................  iv 
1 Scope  ................................ ................................ ................................ ................................ ......................  1 
2 Normative references  ................................ ................................ ................................ ............................  1 
3 Terms and definitions  ................................ ................................ ................................ ...........................  1 
4 [General requirements for HACCP system]  ................................ ................................ ........................  3 
4 [Documentation requirements for implementation of HACCP system]  ................................ ...........  4 
4.1 The HACCP manual  ................................ ................................ ................................ ...............................  4 
4.2 Control of doc uments  ................................ ................................ ................................ ...........................  4 
4.3 Control of records  ................................ ................................ ................................ ................................ . 4 
5 Management responsibilities  ................................ ................................ ................................ ...............  4 
5.1 Top management commitment  ................................ ................................ ................................ ............  4 
5.2 Appointment of the management representative  ................................ ................................ ..............  4 
5.3 Resource management  ................................ ................................ ................................ .........................  5 
5.4 Management review  ................................ ................................ ................................ ..............................  5 
6 Requirements for the implementation of HACCP system  ................................ ................................ . 6 
6.1 Application of the HACCP system  ................................ ................................ ................................ ....... 6 
6.2 Application of Prere quisite Programmes (PRPs)  ................................ ................................ ...............  6 
6.3 Development of corrective action sy stem  ................................ ................................ ..........................  7 
7 Development and application of the HACCP plan  ................................ ................................ .............  8 
7.1 Stage 1: Assemble the HACCP Team and Identify Scope ................................ ................................ . 8 
7.1.1 Assemble the HACCP Team  ................................ ................................ ................................ .................  8 
7.1.2  Identify Scope  ................................ ................................ ................................ ................................ ........  8 
7.2 Stage 2: Describe the product  ................................ ................................ ................................ .............  8 
7.3 Stage 3: Identify intended use of the product  ................................ ................................ ....................  9 
7.4 Stage 4: Construct a flow diagram  ................................ ................................ ................................ ...... 9 
7.5 Stage 5: Arrange an on -site confirmation of the flow diagram  ................................ ......................  10 
7.6 Stage 6: Conduct a hazard analysis (Principle 1)  ................................ ................................ ............  10 
7.7 Stage 7: Determine the Critical Control Points (CCPs) (Principle 2)  ................................ .............  10 
7.8 Stage 8: Establish critical limits for each CCP (Principle 3)  ................................ ...........................  11 
7.9 Stage 9: Establish a monitoring system for each CCP (Principle 4)  ................................ ..............  11 
7.10  Stage 10: Establish corrective action plans (Principle 5)  ................................ ...............................  12 
7.11  Stage 11: Establish verification procedures (Principle 6)  ................................ ...............................  12 
7.11.1  Validation  ................................ ................................ ................................ ................................ .............  12 
7.11.2  Verification  ................................ ................................ ................................ ................................ ...........  12 
7.11.3  Review of the HACCP plan  ................................ ................................ ................................ .................  13 
7.12  Stage 12: Establish Documentation and rec ord keeping (Principle 7)  ................................ ..........  13 
7.12.1  Documentation and document control  ................................ ................................ .............................  13 
7.12.2  Record keeping and record control  ................................ ................................ ................................ ... 13 
Annex  A (informative)  The logical sequence for application of the HACCP plan  ................................ .... 15 
Annex  B (informative)  Example of a CCP decision tree -Apply to each step where a specified 
significant hazard is identified  ................................ ................................ ................................ ...........  16 
Bibliography  ................................ ................................ ................................ ................................ ......................  18 
 DEAS 151: 2023 
iv © EAC  2023 – All rights reserved  
 Foreword  
Development of the East African Standards has been necessitated  by the need for harmonizing requirements 
governing quality of products and services in the E ast African Community. It is envisaged that through 
harmonized standardization, trade barriers that are encountered when goods and services are exchanged 
within th e Community will be removed.  
The Community has established an East African Standards Committ ee (EASC)  mandated to develop and 
issue East African Standards  (EAS) . The Committee is composed of representatives of the National 
Standards Bodies in Partner Stat es, together with the representatives from the public and private sector 
organizations  in the  community .  
East African Standards are developed through  Technical Committees that are representative of key 
stakeholders including government, academia, consumer  groups, private sector and other interested parties. 
Draft East African Standards are circul ated to stakeholders through the National Standards Bodies in the 
Partner States. The comments received are discussed and incorporated before finalization of stand ards, in 
accordance with the Principles and procedures for development of East African Standa rds.  
East African Standards are subject to review, to keep pace with technological advances. Users of the East 
African Standards are therefore expected to ensure that they always have the latest versions of the standards 
they are implementing .  
The committee responsible for this docu ment is Technical Committee EASC /TC 010, Food Hygiene . 
This second  edition cancels and replaces the first edition (EAS  151:2000), whic h has been techn ically revised.  
Attention is d rawn to the possibility that some of t he elements of this document may be subject of patent 
rights. EAC shall not be held responsible for identifying any or all such patent rights.  DEAS 151: 2023 
© EAC 2023 – All rights reserved  v 
 Introduction  
Food safety and  quality are often compromised as a result of efforts to reduce costs and increase efficiency 
along the food production chain. Oftentime s, food production companies are confronted with the challenges of 
hazard  found in their products. These hazards  can be biological, chemical or physical and allergens in nature 
and they can gain entry into food products at any stage of production. The con sequences of their presence in 
food are incalculable: product recalls, with enormous financial losses as a direct consequ ence; loss of image, 
not only for the affected products, but also for other products produced by the company as an indirect 
consequence . Additionally, these hazards  can be injurious to consumers and at worst, fatal. This therefore 
necessitates implementati on of a food safety system to ensure supply of food products that are not harmful to 
consumers.  
Hazard analysis critical control point (HACCP) is a preventive approach to controlling biological, chemical and 
physical hazards and allergens in food business operations. It is a risk management system that identifies, 
evaluates, and controls hazards related to food safety throughout the food supply chain and its 
implementation is guided by scientific evidence of risks to public health.  
HACCP can be applied thro ughout the food chain; from primary production to final consumption and their 
implementation should be guided by scientific evidence of  risks to human health. This varies from postharvest 
activities, restaurants, hotels, schools, hospitals, food processing  units/factories/industries as well as 
pharmaceutical industries. In addition to enhancing food safety, implementation of HACCP can pro vide other 
significant benefits such as: improving product quality, creating a good reputation and boosting customer 
confidence, increasing product sales and profit, reducing final product losses due to non -conformances, and 
enhancing staff morale and loya lty. In addition, the application of HACCP aids inspection and audit by 
regulatory authorities.  
The implementation of HAC CP is guided by seven established principles and when a deviation occurs 
indicating that control has been lost, it is detected and appr opriate steps are taken to re -establish control in a 
timely manner. This ensures that potentially hazardous products do n ot reach the consumer. In addition, an 
effectively implemented HACCP system is capable of accommodating changes such as advances in 
equipment design, new information concerning health hazards or risks, and new processing procedures.  
The successful applicat ion of HACCP requires the commitment and involvement of management and 
personnel and the knowledge and/or training in its application f or the particular type of food business. A 
multidisciplinary approach is strongly recommended; this multi -disciplinary ap proach should be appropriate to 
the food business operation and may include, for example, expertise in primary production, microbiology , 
public health, food technology, environmental health, chemistry and engineering, according to the particular 
applicatio n. 
This document has been prepared to standardise and provide uniformity in application, training and evaluation 
of HACCP based food sa fety systems by the food industry and regulatory authorities. It can therefore be used 
as a guideline for the development  of company/process specific HACCP systems and as a tool for 
assessment by auditing and/or certifying bodies for continuous compliance to HACCP systems developed and 
implemented at different stages of the food chain  
 DRAFT EAST AFRICAN STANDARD  DEAS 151: 2023 
 
© EAC 2023 – All rights reserved  1 
 Hazard Analysis Critical Control Point  (HACCP) systems — 
Requirements  
1 Scope   
This Draft East African Standard specifies the requirements for establishment, implementation and 
maintenance of HACCP system as a preventive system to ensure food safety control measures at each step 
throughout the  food chain . 
2 Normative references   
The following documents are referred to in the text in such a way that some or all of their content constitutes 
requirements of this document.  For dated references, only the edition cited applies. For undated references , 
the latest edition of the referenced do cument (including any amendments) applies.  
EAS 39,  General principles of food Hy giene  — Code of practice  
3 Terms and definitions   
For the purposes of this document, the following terms and definitions apply.  
ISO and  IEC maintain terminological databases for use in standardization at the following addresses:  
— ISO Online browsing platform: available at http://www.iso.org/obp  
3.1  
audit  
systematic, independent and documented proce ss for obtaining objective evidence and evaluating it to 
determine the extent to which requirements are fulfilled.  
3.2  
control  
to take all the actions necessary to ensure and maintain compliance with the criteria and/or requirements 
established in the HAC CP plan  
3.3  
control points  
any point, step or procedure at which control can be applied and a food safety hazard can be prevented, 
eliminated or reduced to acceptable levels  
3.4  
control measure  
any action and activity that can be used to prevent, elimina te or reduce a food safety hazard or reduce it to an 
acceptable level  
  
2 © EAC  2023 – All rights reserved  
 3.5  
correction  
any action to eliminate a detected n on-conformity  
3.6  
corrective action  
any action to be taken when results of monitoring at the critical control point (CCP) indicates a loss of control  
3.7  
critical control point (CCP)  
a step at which control can be applied and is essential to prevent or  eliminate a food safety hazard or reduce it 
to an acceptable level  
3.8  
critical limit  
a criterion which separates acceptability from unacceptability  
3.9  
decision tree  
sequence of questions applied to each step in the food handling process relating to an identified food safety 
hazard to determine which steps are CCPs  
3.10  
document  
a written, drawn, presented or recorded evidence of in tentions of activities to be and/ or performed  
3.11  
flow diagram  
a systematic representation of the sequence of steps of operations used in the production/manufacture of a 
particular food product or sequence of steps associated with the food handling proc ess in the segment of the 
food chain under consideration  
3.12  
food chain  
sequence of the stages in the production, preparation, processing, manufacturing, packaging, storage, 
transportation, distribution, and handling of a food, its ingredients and food c ontact materials, from prim ary 
production to consumption  
3.13  
food handling organization  
business, which during its operations, processes, manufactures, stores, transports, distributes or sells 
foodstuffs or is engaged in any activity which may have impac t on the safety of such f oodstuffs  
3.14  
food safety  
assurance that food will not cause harm to the consumer when it is prepared and/or eaten according to its 
intended use  
3.15 
food safety hazard  
any biological, chemical or physical agent in, or condition  of food, with the potential to cause an adverse 
health effect  
3.16  
HACCP plan  
a document prepared in accordance with the principles of HACCP to ensure control of hazards which are 
significant for food safety in the segment of the food chain under conside ration  
  
© EAC 2023 – All rights reserved  3 
 3.17 
HACCP team  
group of individuals (multi -disciplinary) who develop, implement and maintain a HACCP system.  
3.18  
hazard analysis  
the process of collecting and evaluating informatio n on hazards and conditions leading to their presence to 
decide which are significant for food safety and therefore should be addressed in the HACCP plan  
3.19  
Hazard Analysis and Critical Control Point (HACCP)  
a system that identifies, evaluates and co ntrols hazards which are significant for food safety  
3.20  
monitor  
the act of conducting a planned sequence of observations or measurements of control parameters to assess 
whether a CCP is under control  
3.21  
non-conformity  
non-fulfillment of a specified requirement  
3.22  
prerequisite programmes (PRPs)  
basic conditions  and activities that are necessary to maintain a hygienic environment throughout the food 
chain suitable for the production, handling and provision of safe end products and safe food for human 
consumption  
3.23 
record  
a document that provides objective evidenc e of actions undertaken or results achieved  
3.24  
facility  
any building or area in which food is handled and the surroundings under the control of the same 
management  
3.25 
validation  
obtaining evidence to confirm that the elements of the HACCP p lan are eff ective  
3.26  
verification  
the application of methods, procedures, tests and other evaluations, in addition to monitoring to determine 
compliance with the HACCP plan  
4 [General requirements for HACCP system ] 
For effective implementation of a HACCP based foo d safety system at an y stage of the food chain:]  
a) appropriate good practices shall be in place, documented, fully operational and verified; and  
b) there shall be compliance to the appropriate food safety legislation   
4 © EAC  2023 – All rights reserved  
 4 [Documentation requirements for implementa tion of HACCP system ] 
4.1 The HACCP manual  
The organization shall establish and maintain a HACCP manual that includes:  
a) the scope of the HACCP system,  
b) PRP procedures or reference to them, and  
c) documented procedures established for the HACCP system or refe rence to them. This manual may 
be included in another management system manual or parts of this manual may refer to other relevant 
management system manual(s). The interrelation shall be described appropriately.  
4.2 Control of documents  
The organization shall ensure the establishment and implementation of documented procedures for the 
control of documents. HACCP system documentation shall include documents needed by the organization to 
ensure effective development, implementation and updating of the HACCP  system. The requirements of stage 
12 of the HACCP plan shall be defined in these procedures.  
4.3 Control of records  
Records shall be established and maintained to provide evidence of conformity to requirements and evidence 
of effective operation of the H ACCP system. The requirements of stage 12 of the HACCP plan shall be 
defined in these. Records shall remain legible, readily identifiable and retrievable. The organization shall 
ensure a documented procedure is established to define the controls needed for  the identification, storage, 
protection, retrieval, retention time and disposition of records.  
5 Management responsibilities  
5.1 Top management commitment  
The responsibility for, and commitment to, a HACCP system lies on the top or highest level of man agement.  
The top management shall provide evidence of its commitment and implementation of the HACCP system.  
This shall include;  
a) establishment of the HACCP system policy,  
b) commitment to the development and implementation of the HACCP system,  
c) participation  in continual improvement of the HACCP system,  
d) conducting management review of the HACCP system for continued adequacy, suitability and 
effectiveness  
e) communicati on and understanding of the HACCP system within the organization, and  
f) establishing a means for resolving conflict within and outside the organization.  
5.2 Appointment of the management representative  
A management representative shall be appointed by th e top management and shal, irrespective of other 
responsibilities and duties, act as the management  representative of the HACCP system and shall have the 
responsibility and authority to;   
© EAC 2023 – All rights reserved  5 
  
a) ensure that the HACCP system is established, implemented, maintai ned, updated and continually 
improved in accordance with the requirements of this standard,  
b) report on the performance of the HACCP system to top management and any need for improving the 
system,  
c) ensure top management’s commitment is visible, and  
d) ensure a clear route for communication (up, down and sideways) both within and outside the 
organization.  
5.3 Resource management  
Prior to commencing of the HACCP system, the HACCP team leader shall be appointed, and shall assess 
which resources are needed for the HACCP plan and for the establishment, implementation, maintenance, 
updating and continual improvement of  the HACCP system.  
The organization shall provide the necessary and adequate resources. The resources shall include time, 
competent personnel,  suitable and adequate infrastructure, work environment, equipment and funding in order 
to establish, implement, maintain and continually improve the HACCP system.  
Training needs shall be established for all personnel involved with the establishment, impl ementation and 
maintenance of the HACCP system. Effectiveness of training shall be evaluated. Appropriate records of 
education, training, skills and experience shall be maintained.  
5.4 Management review  
The top Management shall review the HACCP system at planned intervals to ensure its continual 
improvement, suitability, adequacy and its effectiveness. Records of mana gement reviews shall be 
maintained.  
A management review shall include : 
a) matters arising from previous management reviews,  
b) a review of the effe ctiveness of CCP monitoring and failure of CCPs,  
c) a review of corrective actions and product disposal,  
d) HACCP plan ve rifications,  
e) HACCP plan reviews and validation of changes to the HACCP plan,  
f) a review of customer and consumer complaints,  
g) a review of recall incidents,  
h) recommendations for improvement,  
i) resource needs,  
j) a review of suitability of the HACCP policy, and  
k) where  applicable, interrelation with other management systems.  
  
6 © EAC  2023 – All rights reserved  
 The top management  shall be responsible for managing HACCP system. An immediate subordinate may be 
appointed to represent the management on managing the system. In this case the appointee shall, 
irrespective of other responsibilities and duties, act as the management repres entative of the HACCP system 
and shall have the responsibility and authority to;  
a) ensure that the HACCP system is established, implemented, maintained, updated and continually 
improved in accordance with the requirements of this standard,  
b) report on the per formance of the HACCP system to top management and any need for improving the 
system,  
c) ensure top management’s commitment is visible, and  
d) ensure a clear route for communication ( up, down and sideways) both within and outside the 
organization.  
6 Require ments for the implementation of HACCP system  
6.1 Application of the HACCP system  
Prior to application of HACCP system to any sector of the food chain, that sector should have in p lace 
prerequisite programmes such as good hygienic practices according to  the EAS 39, the appropriate codes of 
practice and appropriate food safety requirements.  
6.2 Application of Prerequisite Programmes (PRPs)  
The production of safe food products requi res that the HACCP system be built upon a solid foundation of 
prerequis ite programmes. The PRPs shall be appropriate to the organizational needs with regard to food 
safety, be appropriate to the size and type of the operation and the nature of the products  being manufactured 
and/or handled and be implemented across the entire  production system, either as programmes applicable in 
general or as programmes applicable to a particular product or operational line.  
The organization shall consider the following wh en establishing these PRPs:  
a) personal hygiene,  
b) pest control,  
c) cleanin g, sanitizing and disinfecting,  
d) measures for the prevention of cross contamination,  
e) construction and lay -out of building or premises and associated facilities,  
f) supplies of air, water, energy and other utilities,  
g) supporting services including waste and sewage disposal,  
h) the suitability of equipment and its accessibility for cleaning, maintenance and preventive 
maintenance,  
i) management of purchased materials (for ex ample raw materials, ing redients, chemicals and 
packaging), supplies (e.g. water, air, steam and ice), disposals (for example waste and sewage) and 
handling of products (for example storage, distribution and transportation), and  
j) relevant training programme s and relevant records.   
© EAC 2023 – All rights reserved  7 
 Additional to the PRPs, the following shall be done by any organization before implementation of HACCP 
system: a) a complete investigation to determine the suitability of the facility and the equipment to be used 
with regards to d esign, construction and m aintenance, b) identification of shortcomings that might complicate 
the implementation of the HACCP plan. Suitable food handling equipment and facilities shall be available to 
handle the intended product safely, and c) evidence of progress made with the co rrection of the shortcomings 
identified during the investigation. Responsibilities and appropriate time limits shall be set for the completion of 
the intended corrections.  
These prerequisite programmes to HACCP, including training , should be well establish ed, fully operational 
and verified in order to facilitate the successful application and implementation of the HACCP system.  
6.3 Development of corrective action system  
The organization shall ensure the development of a documen ted corrective action system .  
The system shall define the requirements for:  
a) review of non -conformities,  
b) determination of the cause of the non -conformity,  
c) evaluation of the need for action to ensure that the non -conformity does not recur,  
d) determinatio n and implementation of the a ction needed,  
e) recording of the results of the action taken (correction), and  
f) reviewing the effectiveness of the corrective action taken.  
The corrective action system shall, as a minimum, address the following:  
a) customer and consumer complaints,  
b) internal  audit reports,  
c) non-conformity reports,  
d) outcome of management reviews,  
e) outcome of HACCP plan reviews,  
f) results from HACCP plan validations and verifications, and  
g) failure of CCPs.  
The intent of the HACCP system is to focus on control at CCPs. Re -design of the operation should be 
considered if a hazard which must be controlled is identified but no CCPs are found.  
During hazard identification, evaluation and subsequent operations in  designing and applying HACCP system, 
consideration should be given to the  impact of raw materials, ingredients, food manufacturing practices, role of 
manufacturing processes to control hazards, end -use of the product, categories of consumers of concern an d 
the epidemiological evidence relative to food safety.  
HACCP should be a pplied to each specific operation separately. CCPs identified in any given code of practice 
might not be the only ones identified for a specific application or might be of a differe nt nature. Therefore, 
HACCP application should be reviewed and necessary ch anges made when any modification is made in the 
product, process or any step.   
8 © EAC  2023 – All rights reserved  
 When applying HACCP, it is important to be flexible, where appropriate, taking into account the natur e and 
size of the operation.  
7 Development and application of the HACCP pla n  
The HACCP team shall develop the HACCP plan document in accordance with the principles of HACCP. The 
application of the HACCP plan consists of the twelve (12) stages as identif ied in Annex A (the logical 
sequence for application of the HACCP plan). The seven HACCP principles have been listed and shall be 
applied in the stages below;  
7.1 Stage 1: Assemble the HACCP Team and Identify Scope  
7.1.1  Assemble the HACCP Team  
Top manag ement shall ensure the establishment of criteria for the selection of HACCP te am members to 
assist with the plan, establishment, implementation, maintenance and continual improvement of the HACCP 
system. Every team member shall accept, in writing, his/her assignment and commitment to the HACCP team.  
The HACCP team shall be multidis ciplinary and consist of personnel with specific knowledge of and expertise 
appropriate to the product under consideration, its production processes (manufacture, handling proce ss, 
storage and distribution), its consumption and associated food safety hazar d categories.  
The HACCP team may consist of:  
a) a quality control specialist who understands the biological, chemical, physical and allergenic hazards 
associated with a particula r product group,  
b) a production specialist who has responsibility for or is closel y involved with, the technical process of 
manufacturing the product under study,  
c) a technician who has a working knowledge of the hygiene and operation of the process plant and  
equipment,  
d) any other person with specialist knowledge of microbiology, hygiene  and food technology.  
One person may fulfil several of these roles, provided all relevant information is available to the team and is 
used to ensure that the HACCP system deve loped is reliable. Where such or necessary, skills or knowledge 
or expertise are not available within the food handling organization, advice should be obtained from other 
sources such as individual experts, regulatory authorities, consultant, etc. The serv ices of a consultant may be 
used on condition that the consultant acts only as an  expert advisor to the team.  
The team’s activities should include establishing rules and guidelines for team meeting, the criteria used for 
decision making processes, methodology to be used by the team to determine food safety hazards and CCPs, 
reporting on the status of the HACCP sys tem and the methodology for the establishment of procedural 
requirements or integration with other relevant management system procedures.  
7.1.2 Identify Scope  
The HACCP team shall establish defined and documented scope of the HACCP plan and the team’s ac tivities. 
The scope shall describe the segment of the food chain involved, the products and processes of the food 
business organization.  
7.2 Stage 2: Describe the product  
A full description of the product shall be given in ter ms of relevant safety info rmation such as:  
a) type and composition (for example raw materials, ingredients, additives, etc.),   
© EAC 2023 – All rights reserved  9 
 b) structure and physical – chemical characteristics (for example solid, liquid, gel, emulsion, water 
activity Aw, pH, etc.),  
c) microbi ocidal/static treatments ( for example heat - treatment, freezing, drying, salting, smoking, etc. 
and the extent of the processing),  
d) packaging (e.g. hermetic, vacuum, modified atmosphere),  
e) durability and storage conditions,  
f) method of distribution,  
g) requi red shelf life (for exampl e sell by date and best before date),  
h) instructions for use,  
i) any allergens, microbiological, chemical or physical properties/criteria applicable.  
7.3 Stage 3: Identify intended use of the product  
The intended use should be base d on the expected uses o f the product by the end user or consumer. The 
normal or the expected use of the product by the consumer, consumer target groups or customers for which 
the product is intended shall be defined. In specific cases, the suitability of the product for particul ar groups of 
consumers, such as institutional caterers, travellers, vulnerable groups of the population may have to be 
considered. Attention shall be focused on the likely uses and abuses of the product after it has left the control  
of the food handling or ganization.  
7.4 Stage 4: Construct a flow diagram  
The HACCP team shall prepare a detailed flow diagram for the specified food products or process categories 
relevant to the defined scope of the HACCP plan. The flow diagram should c over all steps in the  operation for 
a specific product. Whatever the format chosen all steps involved in the process including delays during or 
between steps, from receiving the materials to placing the end product on the market, through preparation, 
proce ssing, packaging, sto rage and distribution, should be studied in sequence and presented in a detailed 
flow diagram with sufficient technical data. The same flow diagram may be used for a number of products that 
are manufactured using similar processing ste ps. 
When preparing th e flow diagram, the following should be considered:  
a) the selection of raw material,  
b) equipment layout and characteristics,  
c) sequence of all processing steps (including the incorporation of raw materials, ingredients or additives 
and de lays during or between steps),  
d) rework cycles,  
e) technical parameters of operations (in particular time and temperature, including delays),  
f) flow of products (including potential cross contamination),  
g) segregation of clean and dirty areas (or high/low risk areas),  
h) hygienic environment of the facility, including cleaning and disinfecting programmes,  
i) personnel routes and hygienic practices,   
10 © EAC  2023 – All rights reserved  
 j) packagin g and storage conditions,  
k) distribution, retail and customer handling of the product,  
l) any outsourced processes , and  
m) removal of intermediary products, by -products and waste.  
When applying HACCP to a given operation, consideration should be given to ste ps preceding and following 
the specified operation.  
7.5 Stage 5: Arrange an on -site confirmation of the flow dia gram  
The HACCP team shall confirm the processing operation against the flow diagram on -site during all stages 
and hours of operation, so as to ensure that the flow diagram and technical data as described in clause 7.4 
gives an accurate representation of t he operation. The confirmation of the flow diagram should be performed 
by a person or persons with sufficient knowledge of the processing ope ration. Thereafter, the flow diagram 
shall be amended to take into account any deviations from the original diagram . Reports shall be kept and 
maintained.  
7.6 Stage 6: Conduct a hazard analysis (Principle 1)  
The HACCP team should list all potential foo d safety hazards (such as biological, chemical physical and/or 
allergenic hazards) associated with each step, conduct a hazard analysis and consider any measures to 
control the identified hazards.  
The HACCP team shall use the confirmed flow diagram, incl uding all the technical data as a guide to identify 
all the potential food safety hazards (inherent and introduced) tha t may be reasonably expected to occur at 
each step from primary production, processing, manufacture, storage and distribution until the p oint of 
consumption. Relevant legislation related to the food safety hazards and their control shall also be considered . 
After identification of the food safety hazards, the HACCP team should next conduct a hazard analysis to 
identify for the HACCP plan, which hazards are of such a nature that their elimination or reduction to 
acceptable levels is essential to the producti on of a safe food.  
In conducting the hazard analysis, wherever possible the following should be included: a) the likely occurrence 
of hazards and severity of their adverse health effects, b) the qualitative and/or quantitative evaluation of the 
presence o f hazards, c) survival or multiplication of micro -organisms of concern, d) production or persistence 
in foods of toxins, chemicals or p hysical agents, and e) conditions leading to the above.  
The HACCP team should consider and describe what control measure s, if any exist, can be applied for each 
food safety hazard.  
More than one control measure may be required to control a specific identified hazard(s) and more than one 
hazard may be controll ed by a specified control measure. Also more than one hazard and control measure 
might be applicable to one step in the process.  
Records shall be kept and maintained  
7.7 Stage 7: Determine the Critical Control Points (CCPs) (Principle 2)  
The HACCP team  shall determine whether a particular process step identified in th e flow diagram is a CCP. 
The method by which a CCP is determined shall be recorded, kept and maintained.  
There may be more than one CCP at which control is applied to address the same foo d safety hazard. The 
determination of a CCP in the HACCP system can be facilitated by the application of a decision tree (see 
Annex B), which indicates a logic reasoning approach. Application of a decision tree should be flexible, given 
whether the operati on is for production, slaughter, processing, storage, distribution o r other. It should be used  
© EAC 2023 – All rights reserved  11 
 for guidance when determining CCPs. This example of a decision tree may not be applicable to all situations, 
therefore, other approaches may be used. Training in  the application of the decision tree is recommended.  
If a food saf ety hazard has been identified at a step where control is necessary for safety, and no control 
measure exists at that step, or any other, then the product or process should be modified at  that step, or at 
any earlier or later stage, to include a control me asure.  
7.8 Stage 8: Establish critical limits for each CCP (Principle 3)  
The HACCP team shall establish critical limits that can be measured quickly and easily and should be 
appropriat e for each CCP.  
Critical limits must be specified and validated for e ach CCP. In some cases, more than one critical limit will be 
elaborated at a particular process step. Criteria often used include measurements of temperature, time, 
moisture level, pH v alue, water activity, available chlorine, chemical analyses and sensory  parameters such 
as visual appearance and texture.  
Where HACCP guidance developed by experts has been used to establish the critical limits, care should be 
taken to ensure that these limits fully apply to the specific operation, product or groups of produ cts under 
consideration.  
These critical limits should be measurable and records shall be kept and maintained.  
7.9 Stage 9: Establish a monitoring system for each CCP (Principle 4)  
Monitoring is the scheduled measurement or observation of a CCP relative to its critical limits. The HACCP 
team shall establish a monitoring system to ensure that control of the CCP is effective. The control measures 
established as part of the monitoring  system shall be such that they can confirm that all CCPs are under 
control .  
During establishment of the monitoring system the following shall be addressed:  
Responsible person or equipment. Responsibilities and authorities for the monitoring of a specifi c CCP shall 
be identified. This person or equipment shall have the knowledge  or capability respectively to ensure effective 
monitoring of the CCP. A person shall be given the responsibility and authority to take all the necessary 
corrective action when the  specified critical limit of the CCP is exceeded. Equipment used for the mon itoring of 
a CCP shall be calibrated.  
Frequency of monitoring. The frequency of monitoring shall be specified. The frequency shall be adequate to 
ensure the control of the CCP.  
Monitoring methodology. A detailed description shall be given to indicate pre cisely how the monitoring shall be 
done.  
The monitoring procedures must be able to detect loss of control at the CCP. Further, monitoring should 
ideally provide this information  in time to make adjustments to ensure control of the process to prevent 
violating the critical limits.  
Where possible, process adjustments should be made when monitoring results indicate a trend towards loss 
of control at a CCP. The adjustments should be  taken before a deviation occurs.  
Data derived from monitoring must be evaluat ed and verified by a designated person with knowledge and 
authority to carry out corrective actions when indicated. If monitoring is not continuous, then the amount or 
frequenc y of monitoring must be sufficient to guarantee the CCP is in control.  
  
12 © EAC  2023 – All rights reserved  
 Most mo nitoring procedures for CCPs will need to be done rapidly because they relate to on -line processes 
and there will not be time for lengthy analytical testing. Physical and chemi cal measurements are often 
preferred to microbiological testing because they may  be done rapidly and can often indicate the 
microbiological control of the product.  
All records and documents associated with monitoring CCPs must be signed by the person(s) d oing the 
monitoring and by a responsible reviewing official(s) of the company.  
Records shall be kept and maintained to prove effectiveness of the monitoring system.  
7.10 Stage 10: Establish corrective action plans (Principle 5)  
The HACCP team shall es tablish corrective action plans for each CCP identified in the HACCP system when 
monitoring of the critical limits indicates deviation from the limits.  
Specific corrective actions must be developed for each identified CCP in order to deal with deviations  when 
they occur.  
The actions must ensure that the CCP has been brought under contr ol. Actions taken must also include 
proper disposition of the affected product and/or unsafe product. Deviation and product disposition procedures 
must be clearly identifi ed and documented in the HACCP record keeping.  
Records of all corrective actions sha ll be kept and maintained.  
7.11 Stage 11: Establish verification procedures (Principle 6)  
The HACCP team shall establish procedures for validation, verification and r eview of procedures to confirm 
that the HACCP system is working effectively.  
7.11.1  Validation  
Validation activities shall include actions and/or evidence to confirm that the established critical limit(s) for 
each identified CCP is effective for all elements of the HACCP system and capable of achieving the intended 
control of the identified  food saf ety hazard(s).  
If validation results show that one or more of the above elements cannot be confirmed, the relevant elements 
shall be modified and reassessed.  
7.11.2  Verification  
The HACCP team shall establish procedures for verification of all HACCP procedures and records. 
Verification and auditing methods, procedures and tests, including random sampling and analysis, shall be 
used, as appropriate to determine the effectiveness of the HACCP system. The frequency of verification 
should be suffici ent to  confirm that the HACCP system is working correctly and effectively.  
Verification should be carried out by someone other than the person who is responsible for performing the 
monitoring and corrective actions. Where certain verification activities c annot  be performed in house, 
verification should be performed on behalf of the business by external experts or qualified third parties.  
Examples of verification activities include review of the HACCP system and plan and its records; review of 
deviations an d product dispositions; and confirmation that CCPs are kept under control.  
Regular internal audits shall be scheduled and conducted to ensure that the HACCP system conforms to the 
planned arrangements and the CCP monitoring system(s) and that the correcti ve action plans are effective. All 
processes relevant to the HACCP system shall be audited.   
© EAC 2023 – All rights reserved  13 
 The audit criteria, scope, frequency and methods that form part of the audit programme shall be defined and 
documented. Selection of auditors and conduct of audits  shall be such that objectivity and impartiality are 
ensured during the audit process.  
7.11.3  Review of the HACCP plan  
The HACCP team shall establish a procedure for the review of the HACCP plan. This procedure shall include 
events that will automaticall y trigger a HACCP plan review (internal and external factors should be 
considered). The HACCP plan shall be updated after such a review. The review may lead to a reduction in or 
the addition of CCPs or the inclusion of additional critical limits in order t o improve the HACCP plan.  
The following potential events can influence or automatically trigger a HACCP plan review: a)customer and 
consumer complaints, b)any report from the marketplace that indicates a health risk associated with the 
product, c)an antic ipated change in customer and consumer use, d)a change in raw materials or product 
formulation, e)a change in the food handling process activities, f) a change in the food handling organization 
layout and environment, g)any modification to food handling eq uipment, h)a change in the cleaning and 
disinfection programme, i) a change in the packaging, storage and distribution system, j) changes to staff 
levels and responsibilities, k)changes in legislation, l) results of validation and verification activities, and m) 
any changes pertaining to PRPs.  
Records of validations, verifications, audits and HACCP plan reviews shall be kept and maintained, and the 
results shall be discussed at management reviews.  
7.12 Stage 12: Establish Documentation and record keepin g (Principle 7)  
The HACCP team shall establish documentation concerning all procedures and records appropriate to these 
principles and their application.  
7.12.1  Documentation and document control  
HACCP procedures should be documented. The HACCP team s hall ensure that procedures for 
documentation and document control are established and maintained. The controls shall ensure that all 
proposed changes are reviewed prior to implementation to determine their effects on the food safety and 
impact on the HACC P system. A method of control for identification of the latest versions of all documents 
shall be established.  
Documentation examples are Hazard analysis, CCP determination, Critical limit determination, etc.  
The document control procedure shall address at l east the following:  
a) approval of documents for adequacy before being issued,  
b) review and update of documents  as necessary and re -approval of these documents,  
c) identification of changes to documents and the current revision status,  
d) ensure that the current v ersions of applicable documents are available at points of use  
e) ensure that documents are legible and readil y identifiable,  
f) ensure that documents of external origin are identified and their distribution controlled, and g) 
prevention of the unintended use o f obsolete documents and application of suitable identification to 
them if retained for any purpose.  
7.12.2 Record keeping and record control  
Efficient and accurate record keeping is essential to the application of a HACCP system. The HACCP team 
shall en sure the establishment of a procedure for the record keeping and control of records. The documented  
14 © EAC  2023 – All rights reserved  
 proce dure shall be established to define the controls needed for the identification, collection, storage, 
protection, retrieval, retention times and disposi tion of records.  
Records shall be legible, readily identifiable, easily retrievable and accessible, and  shall be maintained to 
provide evidence of conformity to the requirements and evidence of the effective operation of the HACCP 
system.  
Records example s are CCP monitoring activities, deviations and associated corrective actions, verification 
procedures performed modifications to the HACCP plan, etc.  
A simple record -keeping system can be effective and easily communicated to employees. It may be integrat ed 
into existing operations and may use existing paperwork, such as delivery invoices and checklists t o record, 
for example, product temperatures.  
Documentation and record keeping should be appropriate to the nature and size of the operation and 
sufficien t to assist the business to verify that the HACCP controls are in place and being maintained. Expertl y 
developed HACCP guidance materials (for example. sector -specific HACCP guides) may be utilized as part of 
the documentation, provided that those material s reflect the specific food operations of the business.   
© EAC 2023 – All rights reserved  15 
 Annex  A 
(informative)  
 
The logical sequence for application of the HACCP plan  
  
16 © EAC  2023 – All rights reserved  
 Annex  B 
(informative)  
 
Example of a CCP decision tree -Apply to each s tep where a specified 
significant hazard is identified  
 
* Consider the significance of the hazard (i.e., the likelihood of occurrence in the absence of control and the 
severity of impact of the hazard) and whether it could be sufficiently controlled by pr erequisite programs such 
as GHPs. GHPs could be routine G HPs or GHPs that require greater attention to control the hazard (e.g. 
monitoring and recording).  
** If a CCP is not identified at questions 2 -4, the process or product should be modified to implemen t a control 
measure and a new hazard analysis should be conducted.  
  
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 ***Consider whether the control measure at this step works in combination with a control measure at another 
step to control the same hazard, in which case both steps should be considered a s CCPs.  
****Return to the beginning of the decision tre e after a new hazard analysis   
18 © EAC  2023 – All rights reserved  
 Bibliography  
[1] CXC 1 -1969 , General principles of food Hygiene  
 
. DEAS 151: 2023   
 
© EAC 2023 – All rights reserved