HACCP

Hazard Analysis & Critical Control Point 

Planning to Prevent the Spread of Invasive Species
Edited by

David Britton,

Paul Heimowitz, 

Susan Pasko, 

Matthew Patterson, and 

Jonathan Thompson
June 2011 i USFWS-NCTC

Table of Contents

Acknowledgements ......................................................................................................ii

Chapter 1: Invasive Species Impacts ........................................................................ 1

Invasive Species Impacts .................................................................................... 1

Pathways ............................................................................................................ 2

Invasive Species Legislation ............................................................................... 4

Chapter 2: What is HACCP?....................................................................................... 6

What is HACCP?................................................................................................. 6

The Origins of HACCP ........................................................................................ 7

Planning is Essential ........................................................................................... 7

Five Steps to HACCP Planning ........................................................................... 9

Starting Out in the Right Direction ....................................................................... 9

Chapter 3: Case Studies: When HACCP Could Have Helped ................................ 11

Inks Dam National Fish Hatchery ...................................................................... 11

Ridgefield National Wildlife Refuge ................................................................... 12

Chapter 4: HACCP Planning..................................................................................... 14

Step 1 – Activity Description.............................................................................. 14

A Hypothetical Example.............................................................................. 16

Step 2 – Activity Flow Chart .............................................................................. 19

Step 3 – Potential Non-Targets ......................................................................... 24

Step 4 – Non-Target Analysis Worksheet.......................................................... 28

Analyzing the Risk of Non-targets ............................................................... 30

Developing Effective Control Measures ...................................................... 33

Determining Critical Control Points ............................................................. 38

Critical Control Point Decision Tree ............................................................ 41

Step 5 – Non-Target Risk Action Plan (NTRAP)................................................ 43

Chapter 5: Implementing HACCP ............................................................................ 52

Chapter 6: Glossary.................................................................................................. 54

Chapter 7: References.............................................................................................. 58

Appendix A: Blank HACCP Forms........................................................................... 70

Appendix B: Example HACCP Forms (Completed) ................................................ 75

Appendix C: Risk Assessment Diagrams ................................................................ 83

Risk Assessment Diagram for Aquatic Management Activities .......................... 83

Risk Assessment Diagram for Terrestrial Management Activities ...................... 84

Risk Assessment Diagram for Movement of Natural Resources........................ 85

Appendix D: Critical Control Point Decision Tree ................................................... 86
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Acknowledgements

This course manual was adapted from ―Aquatic Nuisance Species—Hazard Analysis 

and Critical Control Point (ANS—HACCP) Training Curriculum,‖ which was developed

by the National Sea Grant College Program. In particular, the U.S. Fish and Wildlife 

Service thanks Jeffery L. Gunderson, Ronald E. Kinnunen, Patrice M. Charlebois, 

Douglas A. Jensen, Mike R. Klepinger, Eric C. Obert, and Fred L. Snyder for their 

efforts in adapting the use of HACCP for prevention of aquatic invasions.

Many people have contributed to the current version of this manual and associated 

training curriculum. Key partners include the State of Arizona Game and Fish 

Department, the State of Wyoming Game and Fish Department, and the National 

Oceanic and Atmospheric Administration. Valuable feedback from past course 

participants has also enhanced refinement of this manual over time

Thank you to the following sources of photos within this manual:

- Bob Pitman, USFWS

- Stewart Jacks, USFWS

- Steve Sharon, WGFD

- Roger Sorenson, AZGFD/USFWS

- June McIlwain, USFWS

- Robert Lindsey, USFWS

- Peter Pattavina, USFWS

- Paul Nelson, USGS

- Gordon H. Rodda, USGS

- John Hollingsworth, USFWS

- Karen Hollingsworth, USFWS

- Steve Hillebrand, USFWS

- Jay Troxel, USFWS

- Stuart Leon, USFWS

- April Fletcher, USFWS

- Dan Dinkler, USFWS
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Chapter 1

Invasive Species Impacts

Learning Objectives:

At the end of Chapter 1, participants will be able to:

 identify invasive species impacts.

 define non-indigenous species vs. invasive species (and synonyms).

 define target, non-target, pathway and vector.

 identify local and global invasive species pathways.

 list key invasive species legislation

Invasive Species Impacts

Nationwide, the cost of controlling and managing invasive species has exceeded 

billions of dollars. In 2010, Sam Hamilton, former Director of the U.S. Fish & Wildlife 

Service, said that invasive species are ―probably the single greatest threat in our 

country to our native wildlife.‖ 

Invasive species impact our environment and the diversity of life on our planet in many 

ways. The ecosystems into which these organisms are introduced often lack the 

conditions that limit range expansion in their natural habitats (e.g., predators, pests, or 

diseases). This factor, accompanied by characteristics such as high reproductive rates, 

the ability to utilize a variety of resources, and wide tolerances to a range of 

environmental conditions, allow invasive species to spread quickly following 

introduction, often resulting in serious impacts to the environment. Consequences of 

invasion include the extinction of native species through predation, competition for food 

or space, hybridization, and introduction of harmful pathogens and parasites. Nonindigenous species also can profoundly alter ecosystems through changes to the food 

web, fire regimes, and hydrology.

Key Definitions:

Invasive Species – a non-indigenous organism whose introduction does 

or is likely to cause economic or environmental harm or harm to human 

health.

Non-indigenous Species – an individual, group, or population of a 

species that is introduced by human intervention into an area or 

ecosystem outside of its historic native geographic range. Synonymous 

with ―alien,‖ ―non-native,‖ ―exotic,‖ and ―introduced.‖
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In addition to the severe and permanent damage to the habitats they invade, invasive 

species also hinder economic development. Exotic organisms reduce production of 

fisheries, decrease water availability, block transport routes, foul industrial pipelines, 

degrade water quality, and decrease property values. Through damage to human 

enterprises, invasive species inflict an enormous economic cost; the cost to manage

non-native species in the U.S. is currently estimated at $137 billion per year. This 

number is likely an underestimate as it does not consider ecosystem health or the 

aesthetic value of nature, which can influence tourism and recreational revenue.

Additionally, invasive species may 

serve as vectors of human disease. 

Throughout recorded history, 

epidemics such as malaria, yellow 

fever, typhus, and bubonic plague have 

used non-indigenous organisms as 

vectors. Waterborne disease agents, 

such as cholera bacteria (Vibrio 

cholerae), are often transported in the 

ballast water of ships. The effect of 

invasive species on public health 

extends beyond the immediate effects 

of disease and parasites, as chemicals 

used to control invasive species can 

pollute soil and water. Other invasive 

species, including invasive mussels, may increase human and wildlife exposure to 

organic pollutants such as polychlorinated biphenyls (PCBs), as these toxins 

accumulate in their tissues and are passed up the food chain.

Pathways

Invasive species can arrive through many different pathways and vectors, but most 

species considered invasive in North America arrived as a direct result of human 

activity. For example, it is widely accepted that zebra mussels, Dreissena polymorpha, 

were introduced to the Great Lakes through ballast water discharge by ships arriving 

from foreign ports. Shippers did not intend to move zebra mussels when using ballast 

water to safely cross the ocean and manage cargo loading/unloading. Unfortunately, 

many species can survive transoceanic trips in ballast water, essentially ―hitchhiking‖ to 

new ports. Likewise, the horticultural industry has inadvertently provided pathways by 

which plant pests have been imported to the United States, causing problems in 

agricultural and natural areas. Some of our worst insect invaders, such as the 

Formosan termite (Coptotermes formosanus shiraki) arrived in packing and crating 

materials. These are just a couple of examples of how species are moved around the 

planet unintentionally. However, the problem is ubiquitous and all too common.

Zebra mussels attached to a native freshwater 

mussel. Photo Credit: USFWS
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Key Definitions:

Pathway – an activity or process through which a species may be 

transferred to a new location where it could become invasive (e.g., 

shipping, air travel).

Vector – the specific means by which an invasive species moves within a 

particular pathway (e.g., a ship, agricultural products, boots). 

On a local scale, invasive species can be spread unintentionally to new habitats through 

a wide variety of human activities, including work in natural resource management. For 

example, the tiny size of the New Zealand mudsnail (Potamopyrgus antipodarum) and 

its ability to clone itself help this species invade new water bodies by hitchhiking to new 

habitats on targets such as waders, boats, and other aquatic gear. Similarly, terrestrial 

species can be moved via field or farm equipment, clothing, and/or native species that 

are moved to new areas for conservation purposes. Species monitoring, collections, 

natural resource surveys, and stocking of fish are all potential pathways for moving 

invasive species during natural resource management activities. Because invasive 

species are not the ―target‖ of these activities, we can refer to them more generally as 

―non-targets.‖ 

Key Definitions:

Target – anything that is intentionally moved. For example, if your 

management activity calls for you to stock largemouth bass, then your 

targets would be largemouth bass and any equipment and personnel used 

to carry out this activity.

Non-target – anything, including any organism, that is not intentionally 

moved. For example, if your management activity calls for you to stock 

largemouth bass, then any other species of fish (or other organism) would 

be a non-target. Your intent would be to only move largemouth bass.
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The use of ―target‖ and ―non-target‖ in HACCP can be 

confusing to those involved in control of weeds and 

other invasive species. For pesticide applications, 

invasive species are the ―targets,‖ and ―non-targets‖ are 

the beneficial species to be avoided. Confusion over 

these overlapping terms can be reduced if you 

remember that HACCP focuses on preventing

invasions before they happen. From a prevention 

standpoint, we only want the targets of an activity to be 

moved. 

Invasive Species Legislation 

The invasion of zebra mussels in the mid-1980s caused a surge of invasive species

awareness and prompted federal legislation in the form of the Non-indigenous Aquatic 

Nuisance Protection and Control Act of 1990. This act was reauthorized and amended 

to the National Invasive Species Act in 1996. Under these federal programs, specific 

regulations and national management plans are dedicated to the control and 

management of species such as the Chinese mitten crab, New Zealand mudsnail, killer 

sea weed Caulerpa, silver carp, and purple loosestrife. Many other species are not 

covered by a national management and control plan but are still a concern.

HACCP Spotlight: Target vs. Non-target 

Invasive purple loosestrife at Montezuma 

National Wildlife Refuge. John and Karen 

Hollingsworth, USFWS.

HACCP Spotlight: NISA 

Congress passed the Non-indigenous Aquatic Nuisance Protection and Control 

Act of 1990 in response to the invasion of the zebra mussel and other species that 

damaged the Great Lakes. That law brought much-needed attention to the global 

movement of aquatic species. It also established the federal interagency Aquatic 

Nuisance Species Task Force, which became a key resource for regional and state 

efforts. The 1990 law’s strictest and most detailed provisions required that ships 

headed for the Great Lakes exchange their ballast water at sea. The law was 

reauthorized, renamed the National Invasive Species Act, or NISA, and expanded 

slightly in 1996. Then all ships arriving from outside the 200-mile U.S. Exclusive 

Economic Zone were encouraged to exchange their ballast water, but required to 

report whether they had. NISA also authorized important research and linked its 

results to decisions about whether further ballast water regulation was needed.
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In February 1999, Presidential Executive Order 13112 created the National Invasive 

Species Council and the Invasive Species Advisory Committee in response to growing 

concern over invasive species. This Executive Order states that ―each federal agency 

whose actions may affect the status of invasive species shall, to the extent practicable 

and permitted by law...not authorize, fund, or carry out actions that it believes are likely 

to cause or promote the introduction or spread of invasive species in the United States 

or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has 

determined and made public its determination that the benefits of such actions clearly 

outweigh the potential harm caused by invasive species; and that all feasible and 

prudent measures to minimize risk of harm will be taken in conjunction with the actions.‖ 

This broad directive has implications for non-federal agencies as well, particularly those 

working in partnership with federal agencies. But, it also raises risk-management 

questions. What is ―practicable‖? What are ―feasible and prudent measures to minimize 

risk of harm‖? HACCP can help provide the answers.

Understanding pathways and developing plans to remove non-target species and 

prevent biological contamination is necessary to prevent invasive species impacts. 

When it comes to natural resource management activities, these introductions should 

not be considered simply ―accidental.‖ It is our responsibility as resource professionals 

to strive to do no harm. Understanding invasive species pathways and developing plans 

to remove hitchhiking species are necessary to prevent unintended spread. 

Remember, if you are not part of the solution, 

then you are part of the problem.
Chapter 2: What is HACCP?

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Chapter 2

What is HACCP?

Learning Objectives:

At the end of Chapter 2, participants will be able to:

 explain why "planning is essential"

 describe the five steps of HACCP Planning.

 explain the benefits of a strong HACCP Planning team.

What is HACCP?

Hazard Analysis and Critical Control Point (HACCP) Planning is about risk 

management. It features five integrated steps that can reduce the risk of spreading 

invasive species and other non-targets via human-based pathways. HACCP examines 

activities to determine if and when particular invasive species might be unintentionally 

moved. Where this potential exists, the tool helps to identify the most effective 

opportunities during an activity to reduce that risk and the specific control measures

that are needed. Safeguards are included through the use of prescribed ranges, 

limits, or criteria (previously called a control limit) and corrective actions that ensure 

that control measures are operating as intended. Control measures, prescribed ranges, 

limits or criteria and corrective actions will be discussed in more detail in later chapters.

Key Definitions:

Control Measure – an action that can be used to control a potential 

hazard (sometimes referred to as a preventive measure). Control 

measures are the first, and sometimes only, line of defense against the 

spread of non-targets. If control measures fail, corrective actions should 

be implemented.

Prescribed Range, Limit, or Criterion (PRLC) - (previously called a 

―control limit‖) – a specific measureable attribute that can be used to 

determine if control measures are effectively minimizing the risk (e.g., a 

minimum dose of a disinfectant, a minimum exposure time, or an 

acceptable range of temperatures).

Corrective Action - a procedure that must be followed if a control 

measure fails at a critical control point. A corrective action is backup 

procedure used as a second line of defense that may be necessary to 

prevent the spread of a non–target if the first–line defense (a control 

measure) fails to control a non–target.
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The Origins of HACCP 

HACCP has been around for decades and has its roots in the food industry. In fact, the 

Pillsbury Company pioneered the HACCP concept in the early 1960s in partnership with 

NASA as a way to combat food contaminants in the food supply for the U.S. space 

program. Since then, HACCP has been recognized and used around the world as a 

proactive method to ensure product purity. HACCP planning is widely used and 

accepted by industry for good reason: It works! 

The National Sea Grant Program first adapted HACCP to reduce the risk of spreading 

aquatic invasive species. The U.S. Fish & Wildlife Service has since widely adopted this 

method, and has developed many HACCP plans for fish hatcheries, watershed surveys, 

fish passage projects, and other natural resource management activities. Use of 

HACCP to prevent the spread of invasive species has even become an American 

Society for Testing and Materials (ASTM) International standard under the Standard 

Guide for Conducting Hazard Analysis-Critical Control Point Evaluations (ASTM E2590-

09).

Planning Is Essential

Like many plans, a large part of the value of developing a HACCP plan is the planning 

process itself. While examining their planned actions in detail, planners will reveal new 

questions and insights that can identify unrecognized prevention opportunities. In the 

short run, this may not make work easier, but in the long run it can eliminate serious 

problems that could emerge from unintended invasions, and negate any benefits from 

the original work. Therefore, through proper HACCP planning, natural resources will be 

better protected. 

In order to be successful, HACCP planning requires commitment from agency heads, 

managers, and field staff. Involving this range of participants in HACCP plan 

development not only ensures a comprehensive analysis of a specific activity and its 

risks but promotes the ―buy-in‖ necessary to assure effective implementation.

Planning is nothing new for biologists and managers, but applying HACCP planning to 

natural resource work may be a relatively new concept for some of us. Without 

appropriate planning, the management work that takes biologists, technicians, and their 

equipment to many different habitats could be pathways for invasive species spread. 

HACCP planning is a tool that manages the risk of moving non-targets in natural 

resource management activities. 

HACCP identifies high-risk activities and focuses attention on those actions needed to 

reduce the movement of non-targets. Plans documenting risks and methods used to 

remove non-target species give managers the opportunity to weigh such risks for 

species spread against benefits from natural resource actions. For some pathways, the 

risks outweigh resource benefits until better procedures to remove non-target species 
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are identified. HACCP planning provides a systematic method to make consistent 

decisions based on identified risks. HACCP plans also create a reference source to 

document best management practices and standard operating procedures that can be 

shared with other offices, agencies, and the private sector to reduce the risk of species 

spread through pathways with similar characteristics.

First-time HACCP planners tend to pick only well-known invasive species as nontargets to remove from pathways. While these species deserve increased attention, 

biologists recognize that many local species could become invasive if introduced 

outside their native range. HACCP planning for natural resource pathways is intended 

to remove all non-targets, following the precautionary principle. 

The precautionary principle states that if an action could 

plausibly cause harm, but there is not yet a scientific 

consensus that the action is actually harmful, the burden of 

proof that such an action is not harmful falls on those

taking the action. The precautionary principle implies a 

social responsibility to protect the environment from

exposure to harm when careful consideration has found a 

plausible risk. This protection can be relaxed only if 

scientific findings emerge that provide sound, convincing

evidence that no harm will result.

Using the precautionary principle, (HACCP) focuses on potential or known invasive 

species, but could include diseases or species not yet known to be invasive. History 

demonstrates that many invasive species do not reveal their invasiveness until long 

after an introduction occurs. Caution should be practiced in the context of uncertainty. 

The examples used in this manual show how HACCP planning can help prevent similar 

types of spread for other species.

"Always have a plan and believe in it. Nothing happens by accident."

(Chuck Knox, Football Coach)

HACCP Spotlight: The Precautionary Principle 

Invasive brown tree snake (Boiga 

irregularis). Photo credit: Gordon H. 

Rodda, USGS.
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Five Steps to HACCP Planning

There are five steps to HACCP planning:

1. Describing the activity: The activity description includes specific information 

such as the who, what, when, where, how, and why of the project. The 

description offers a historical, working reference to facilitate plan review and 

communication with the facility staff and other resource management agency 

personnel.

2. Charting the flow of tasks for the activity: This step provides an important 

visual tool that the HACCP team can use to complete the remaining steps of 

the plan. Here, a clear and concise, yet complete description of the tasks 

necessary to complete the overall activity is diagramed in a linear fashion.

3. Identifying potential non-targets: Any species that has a reasonable 

potential to be moved or introduced to new habitats should be identified in 

order to implement appropriate control measures to prevent an unintended 

invasion. These may include vertebrates, invertebrates, plants, or other 

organisms (e.g., diseases, pathogens, and parasites).

4. Analyzing non-targets: It is crucial to identify significant non-targets with 

respect to each required task within a larger activity so that effective measures 

to control them may be employed. During the analysis, the significance of each 

potential non-target is assessed by considering risk.

5. Completing the action plan: The action plan addresses specific methods to 

control risks of non-target species. It lists specific information about controls, 

monitoring procedures, methods for evaluation, and corrective actions.

Each of the above steps corresponds to a specific form in the HACCP process, and 

each step builds on prior steps. Blank forms are included in Appendix A (page 70). 

Starting Out in the Right Direction

A successful HACCP program depends on the firm foundation of management 

commitment, HACCP training, and assembly of an effective HACCP team. Attempting 

to implement a HACCP program without these components will likely lead to HACCP 

planning that lacks a thorough assessment of the potential non-targets and commitment 

to apply HACCP planning consistently in the field.

Management Commitment - For HACCP planning to work, it is considerably important 

to have the support of everyone in the agency, from the Director to the biological 

technicians in the field. Without support, the plan will not become an agency priority or 

be effectively implemented.

HACCP Training - Education and training are important elements in developing and 

implementing a HACCP program. Employees who will be responsible for the HACCP 

program must be adequately trained in its fundamentals. HACCP can be a fairly 
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straightforward process, but incomplete understanding of key concepts can lead to 

incomplete plans. 

HACCP Team Assembly - Assembling a team is an essential step in building a 

HACCP program. Although one person might be able to analyze risks and develop a 

plan successfully, a team approach maximizes the breadth of expertise needed to 

comprehensively evaluate an activity, identify all potential non-targets, and brainstorm 

the full spectrum of available prevention options. 

“But I already have this covered in my standard 

operating procedures...”

A list of prevention measures in your standard 

operating procedures is a great way to reduce the 

spread of invasive species, but it is not the same 

thing as a HACCP plan. HACCP is a process that 

requires a team to think comprehensively about what 

invasive species might be introduced through all parts 

of an activity, analyzes the significance of those risks, 

identifies the most effective opportunity to reduce 

risks, monitors whether the risk reduction measures 

are working, and if they’re not, provides a back-up 

plan. HACCP will help you generate a list of prevention measures (e.g., 

decontamination procedures), but simply using a list without going through the HACCP 

process can be a shot in the dark. From this standpoint, HACCP isn’t something more 

comprehensive than a list of best management practices; it is a best management 

practice.

"Man often oppose a thing merely because they have no agency 

in planning it, or because it may have been planned 

by whom they dislike."

(Alexander Hamilton, American President)

HACCP Spotlight: SOP's vs. HACCP 

Was an SOP in place to decontaminate this 

boat before launch? Photo Credit: Steve 

Hillebrand, USFWS.
Chapter 3: Case Studies: When HACCP Could Have Helped

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Chapter 3

Case Studies: When HACCP Could Have Helped

Learning objectives:

At the end of Chapter 3, participants will be able to:

 identify target species and potential non-target species in example 

case studies.

 explain how HACCP could have helped reduce the risk of invasive 

species introductions in two case studies.

Case study: Inks Dam National Fish Hatchery (NFH)

Inks Dam NFH is a warm-water facility operated by the U.S. Fish & Wildlife Service 

(Service) in central Texas. It is used for raising sport-fish for stocking throughout the 

Service’s Southwest Region. One of the programs at Inks Dam NFH is the production of 

largemouth bass, which are stocked in tribal waters of Arizona. The facility pumps raw 

water from nearby Lake Buchanan to fill their ponds. Lake Buchanan contains a suite of 

warm-water fish species native to central Texas. Annually largemouth bass brood-stock 

are spawned in ponds. The fry from the spawning adults are separated and reared in 

ponds, and eventually loaded into the stocking truck and transported to Arizona or New 

Mexico. 

Prior to the implementation of HACCP at Inks Dam NFH, shipments of largemouth bass 

sometimes contained non-target organisms including fish, invertebrates, and plants that 

were then inadvertently spread to receiving waters. This caused fish-management 

challenges and possibly led to the establishment of invasive species in Arizona and 

New Mexico. In fact, a shipment of largemouth bass from Inks Dam NFH was 

determined to be the source of the introduction of gizzard shad across the Continental 

Divide to Morgan Lake, New Mexico in 1998. Loads of bass transported to Morgan Lake 

from the hatchery were found to have as many as nine different species besides 

largemouth bass (fish species included Guadalupe bass, logperch, gizzard shad, white 

bass, bluegill, and dollar sunfish). These shipments were refused but gizzard shad were 

already firmly established in Morgan Lake. Logistics prevent shad from being chemically 

removed from Morgan Lake, which is an important largemouth bass sport fishery on the 

Navajo Reservation. The 1200 acre lake provides water to the APS power plant near 

Shiprock. Lowering the lake would require a power-plant shut-down for an extended 

period. Poisoning the water without lowering the lake would block intakes with dead fish 

and effectively shut down the power plant. In 2000, gizzard shad were found in Lake 

Powell, and have since spread significantly within the Colorado River system. The 

source of the Lake Powell introduction is still officially undetermined. 
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At Inks Dam NFH, the pathways identified as potential sources for introduction of nontarget species included the water in which the largemouth bass were raised. Water from 

Lake Buchanan is directly supplied to the hatchery with the possibility of moving 

numerous species, including Guadalupe bass, several sunfishes, threadfin and gizzard 

shad, logperch, and several others. Other non-targets that could be present in the

ponds include bullfrogs, invertebrates, aquatic plants, and fish pathogens. Another 

potential pathway for non-targets was the water used to fill the stocking truck, which 

originally came directly from the lake. 

The HACCP plan for stocking of largemouth bass from Inks Dam NFH identified an 

opportunity to fill trucks with well water instead of raw lake water (a practice that 

continues today). Additionally, 

hatchery personnel now use 

flow-through holding tanks to 

remove non-target plants and 

invertebrates. Large-mesh dip

nets are used to collect the 

largemouth bass while allowing 

the smaller non-target fish to 

pass through. Finally, hatchery 

personnel inspect all holding 

tanks to ensure that non-targets 

are removed prior to loading the 

fish in the stocking truck.

As a check on the effectiveness 

of these control measures to 

remove non-target species from 

shipments of largemouth bass 

to Arizona, Service biologists 

on the receiving end inspect 

every shipment of fish prior to the bass being stocked. Since the HACCP plans have 

been implemented at Inks Dam NFH, unintended shipment of non-target organisms has 

effectively been minimized. 

Case study: Ridgefield National Wildlife Refuge (NWR)

Ridgefield NWR, located in southwest Washington State, has a total of 5,218 acres of 

marshes, grasslands and woodlands. Management objectives include preserving the 

natural Columbia River floodplain and providing habitat for waterfowl and other wetland 

wildlife. In particular, the refuge was established to secure vital winter habitat for dusky 

Canada geese and other wintering waterfowl. As part of wetland creation/restoration 

projects undertaken at Ridgefield NWR, rice screenings from the Sacramento Valley of 

California were spread and harrowed within borrow areas for eight wetlands that were 

scraped to mineral soil during September 1999. This activity was performed in order to 

establish a seed source for moist-soil vegetation in areas where the seed bank was 

Inks Dam National Fish Hatchery is located 60 miles 

northwest of Austin, Texas. Photo Credit - Bob Pitman & 

Robert Lindsey/USFWS
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removed as a result of the scraping. Rice screenings are composed of seed and other 

non-rice vegetation remaining after cleaning and processing of harvested rice. These 

screenings are primarily composed of moist-soil plants seeds (e.g., wild millet, smart 

weeds) that are considered high-quality food for aquatic, migratory birds. The seed 

mixture applied to the refuge contained predominately wild millet, smartweeds, and an 

unidentified bulrush. 

During the spring/summer 2000, the unknown bulrush germinated in refuge wetlands 

and was subsequently identified as Eurasian ricefield bulrush, a known invasive. In the 

Sacramento Valley, this species has become ubiquitous in wetlands and rice fields and 

is considered a nuisance weed. 

Beyond the original eight 

wetlands contaminated in 1999, 

the invasive bulrush has since 

infested six additional wetlands 

at the refuge. Because this 

bulrush had not been previously 

recorded in the Pacific 

Northwest, the infestation at the 

refuge represented an 

introduction of a new invasive 

species. Accordingly, Ridgefield 

NWR has established an 

aggressive eradication/control 

program. The following are 

potential vectors by which this 

bulrush seed spread to new 

areas: water flow in drainage 

and delivery ditches, farm equipment and vehicles, and wildlife and humans (e.g. refuge 

visitors, hunters and refuge staff). Although the actual mechanism by which this bulrush 

has infested additional wetlands on the refuge is unknown, the likely vector was water 

flow between units. Because drainage water is annually pumped from the refuge into 

the Columbia River, there are further risks of the bulrush escaping into additional sites 

within the Columbia River System. 

Although it is not possible to determine with certainty whether a HACCP plan would 

have prevented the introduction of this invasive plant to Ridgefield NWR, HACCP would 

have facilitated analysis of threats from the source area and helped identify prevention 

measures such as seed purity protocols and quarantine procedures.

"The significant problems we face cannot be solved at the same level 

of thinking we were at when we created them."

(Albert Einstein, Nobel Prize Winner, Physics)

Ridgefield National Wildlife Refuge is located just north of 

Vancouver, Washington. Photo Credit – Friends of the 

Ridgefield National Wildlife Refuge
Chapter 4: HACCP Planning: Step 1 – Activity Description

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June 2011 14 USFWS-NCTC

Chapter 4

HACCP Planning

Step 1 – Activity Description

Learning Objectives:

At the end of Step 1, participants will be able to:

 identify the essential components of a well-written Activity 

Description.

 write an Activity Description encompassing all six description 

components.

Once a HACCP team is established, the members first describe the activity, the method 

of accomplishing the activity, and the intended purpose and need for the activity.

Examples of activities include, but are not limited to the following:

 Forest thinning operations 

 Raising and/or stocking of fish and other organisms

 Wildland fire fighting

 Field surveys (aquatic and terrestrial)

 Habitat restoration projects

 Research field work

 Road construction and maintenance

 Trail building and maintenance

 Introducing an organism for biological control

 Landscaping

 Invasive plant removal projects

The HACCP Plan title and management objective should be clearly stated at the top of 

the Step 1 form. The management objective should state the overall goal of the activity 

or project to be performed. A contact person also should be identified. This person will 

be the point of contact for any questions regarding the HACCP plan; in most situations 

the contact person will be the HACCP team lead, project coordinator, or site manager. 

The activity description should provide historical references and background information 

to help facilitate communication between staff members conducting the activity as well 

as other resource management agency personnel that may be involved. The activity 
Chapter 4: HACCP Planning: Step 1 – Activity Description

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June 2011 15 USFWS-NCTC

description should be a narrative description that includes the ―who, what, when, where, 

why, and how‖ of a particular project:

 Who: The project manager, site manager, or field staff that manage and 

conduct the activity.

 What: A statement about what is done during the activity.

 When: The timing and frequency of the activity (i.e., is it a one-time 

occurrence or does it occur repeatedly such as maintenance, annual 

surveys, or seasonal fish distribution?).

 Where: The location(s) where the activity takes place. 

 Why: A statement about the need and the objective of the activity.

 How: A general statement about the methods used to complete the activity

The Activity Description should be complete, accurate, and thorough, but succinct. The 

objective is to allow someone unfamiliar with the activity to be able to understand the 

context and details of the HACCP plan. 

The form on the following page provides a consistent template for Step 1.

Fieldwork may involve intentionally moving a particular 

species. But, what else are you dragging along? Photo 

Credit: Peter Pattavina, USFWS.
Chapter 4: HACCP Planning: Step 1 – Activity Description

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June 2011 16 USFWS-NCTC

A Hypothetical Example

Chapter 4 will take you through the five steps of HACCP planning. At the end of each 

Step, this manual will use a hypothetical example to demonstrate the application of 

HACCP concepts. Our example is based on a specific activity, riparian habitat surveys, 

conducted by the Cutthroat Trout National Fish Hatchery. Staff members of this facility 

measure riparian vegetation densities within the Thompson River Basin once a month 

throughout the year. The purpose of the surveys is to gather data and information on 

riparian habitat to guide cutthroat trout recovery actions within the Thompson River 

Basin. Specialized survey gear is stored, while not in use, in a warehouse on hatchery 

property. Surveys are begun by first retrieving necessary gear from the warehouse at 

the beginning of the day. Once loaded into a pickup truck, staff members travel with the 

gear to the sampling site chosen for the day. After the gear is unloaded, the staff 

conducts the sampling activity using the appropriate gear. At the end of the day, staff 

members return the gear to the truck, load it, and then return to warehouse. The gear is 

then unloaded and put away until needed for the next survey. Within the Thompson 

Basin, several potential invasive species, parasites or diseases have been determined 

to be of significant concern. These include bullfrogs (Rana catesbeiana), New Zealand 

mud snails (Potamopyrgus antipodarum), Eurasian milfoil (Myriophyllum spicatum), 

purple loosestrife (Lythrum salicaria), Chytrid fungus, and whirling disease (Myxobolus 

cerebralis).
Chapter 4: HACCP Planning: Step 1 – Activity Description

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HACCP Step 1 – Activity Description

Management Objective & Contact Information

HACCP Plan Title

Management Objective: Contact Person:

Phone:

Email:

Activity Description

i.e. Who; What; Where; When; How; Why
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Here is an example Activity Description for the hypothetical example introduced in 

Chapter 4: Step 1 (page 16).

HACCP Step 1 – Activity Description

Management Objective & Contact Information

Title: Hypothetical HACCP Plan

Management Objective:

Habitat survey for the recovery of cutthroat 

trout (CT)

Contact Person: Jonathan Thompson

Phone: (800) LUV-FISH

Email: jonathan_thompson@fws.gov

Activity Description

i.e. Who; What; Where; When; How; Why

Who: Cutthroat Trout National Fish Hatchery personnel

What: Measurement of Riparian Vegetation Density

Where: Thompson River Basin

When: Year-round, once a month

How: Retrieve the appropriate gear from a warehouse at the beginning of 

the day. Travel to the sampling site and conduct the sampling activity. 

Return to the warehouse. Gear is unloaded and stored.

Why: To gather data and information on riparian habitat to guide cutthroat 

trout recover actions
Chapter 4: HACCP Planning: Step 2 – Activity Flow Chart

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June 2011 19 USFWS-NCTC

Step 2 – Activity Flow Chart

Learning Objectives:

At the end of Step 2, participants will be able to:

 discuss the relationship between the Activity Description and the 

Activity Flow Chart.

 identify all of the tasks required to complete the activity described in 

Step 1.

 complete an Activity Flow Chart.

An Activity Flow Chart is a method for outlining the sequence of tasks that occur when 

completing an activity covered by the HACCP plan. It is important to include all the 

tasks within the activity. The flow chart should contain a task number, title and 

description. This information is taken from the Activity Description (Chapter 4, Step 1). 

If a task is missed, a significant non-target may not be addressed. 

All tasks covered by a HACCP plan should be included in an Activity Flow Chart. If your 

activity includes any tasks that occur in parallel (simultaneously), then the activity is too 

general for a single HACCP plan. This is one of the most common mistakes made when 

people first start creating HACCP plans. In this case, break the activity into two or more 

sub-activities and create HACCP plans for each sub-activity. Each sub-activity should 

have its own Activity Flow Chart that contains only sequential tasks. 

When an activity involves one or more tasks that are only included to prevent the 

spread of invasive species, the HACCP plan will be stronger if those tasks are not 

included as ―tasks‖ but, instead, are included as control measures for a related task. For 

example, consider a forest survey team that proactively decontaminates its vehicles 

upon entry and exit to a new site. The team might prepare a HACCP plan for this 

activity that includes the decontamination process as one of the tasks, since it is part of 

their normal operations. However, the plan could instead identify the tasks more simply 

as site entry and exit, and then identify the decontamination process as an associated 

control measure. These two approaches may not seem much different, but only the 

latter allows the HACCP plan to provide valuable documentation, monitoring and 

evaluation of the decontamination process, and prescribed corrective actions should the 

decontamination process (control measure) fail. You will learn more about control 

measures and corrective actions in Steps 4 and 5.
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A Note on “Lumpers vs. Splitters”

The number of tasks required to complete the activity 

will depend on the activity’s complexity and whether 

your HACCP team consists of ―lumpers‖ or ―splitters.‖ 

If you have a team of "lumpers" (i.e. they define very 

broad tasks), you will have few tasks and it might be 

difficult to distinguish specific prevention 

opportunities. On the other hand, if your team 

identifies more than ten tasks, your team is probably 

splitting too much. Remember, a HACCP plan will 

not be effective if the tasks defined for your activity 

are too narrowly or too broadly defined. Be specific 

yet concise.

The HACCP team should evaluate the entire activity or operation and make any 

changes required in the flow chart. The evaluation allows each team member to gain an 

overall picture of how the activity is conducted. The Activity Flow Chart is an important 

tool that the HACCP team will use to complete the remaining steps of the plan. In 

addition, an optional diagram of the activity based on the flow chart’s tasks is a useful 

aide in visualizing the activity and completing the risk analysis in Step 4. 

An Activity Flow Chart template is provided on the next page, followed by an Activity 

Flow Chart and an example activity diagram for the hypothetical example introduced in 

Chapter 4: Step 1 (page 16).

"A common mistake people make when trying to design something 

foolproof is to underestimate the ingenuity of complete fools."

(Douglas Adams, Author)

HACCP Spotlight: Lumpers vs. Splitters 

Is this one task or multiple tasks? Photo 

Credit: USGS.
Chapter 4: HACCP Planning: Step 2 – Activity Flow Chart

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HACCP Step 2 – Activity Flow Chart

Outline Sequential Tasks of Activity

Task 1

Title:

Description:

Task 2

Title:

Description:

Task 3

Title:

Description:

Task 4

Title:

Description:

Task 5

Title:

Description:
Chapter 4: HACCP Planning: Step 2 – Activity Flow Chart

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June 2011 22 USFWS-NCTC

Here is an example Activity Flow Chart that shows how the HACCP team completed 

Step 2 for the hypothetical example introduced in Chapter 4: Step 1 (page 16).

HACCP Step 2 – Activity Flow Chart

Outline Sequential Tasks of Activity

Task 1

Title: Load Gear and Drive to site

Description: Drive to warehouse and load appropriate gear for sampling 

activity. Drive to sampling site.

Task 2

Title: Unload gear and conduct survey

Description: Unload gear from vehicle. Prepare gear to conduct 

sampling. Conduct survey.

Task 3

Title: Reload gear

Description: Return to vehicle and l pack up gear.

Task 4

Title: Return to warehouse and unload gear.

Description: Return to the warehouse in vehicle with gear. Put 

equipment away to store for next use.
Chapter 4: HACCP Planning: Step 2 – Activity Flow Chart

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An Activity Flow Diagram like the one below is optional. Sometimes it is helpful to 

sketch the linear sequence of tasks when the tasks for an activity are conducted in more 

than one location. If this helps your HACCP team produce an Activity Flow Chart, then 

please consider using a diagram in addition to the Activity Flow Chart.

Example Activity Diagram

Jacks Parkway

Sharon Ave

Heimowitz Road

Warehouse

Sample Site

1

2 3

4

Road

River

# Task

North

"Proper preparation prevents poor performance"

(Charlie Batch, Two-time Super Bowl Winning Quarterback)
Chapter 4: HACCP Planning: Step 3 – Potential Non-Targets

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June 2011 24 USFWS-NCTC

Step 3 – Potential Non-Targets

Learning Objectives:

At the end of Step 3, participants will be able to:

 discuss the difference between a target and a non-target.

 identify the different non-target categories (Vertebrates, 

Invertebrates, Plants, and Other Organisms).

 identify non-targets that potentially could be moved during your 

activities.

 complete a form for HACCP Step 3.

In Step 3 of the HACCP planning process, the team needs to identify the potential nontargets that may be moved through the tasks identified in Step 2. 

Remember that targets can include yourself, your gear, and/or a species that you intend 

to move. Non-targets are anything that you do not want to be moved from one area to 

another. Non-target organisms can be categorized into four general categories: 

vertebrates, invertebrates, plants, and other organisms (e.g., fungi or microbial 

pathogens). Species considered non-targets vary from state to state, agency to agency,

and biologist to biologist. Your HACCP team should consider ALL potential non-targets 

that have a reasonable probability of being moved through the tasks identified in Step 2.

In later Steps of the HACCP planning process, you will have an opportunity to narrow 

down your list to the truly significant non-targets. For now, if your HACCP team is on the 

fence about whether something should or should not be listed as a potential non-target, 

it probably should be listed (remember the precautionary principle). You may need to do 

some research or consult with local experts to determine which species should be 

considered non-targets (see Chapter 7 for helpful resources, page 58). Discussions 

about non-targets can help focus planning objectives and establish the basic foundation 

for each HACCP plan. In the end, the HACCP planning process may reveal non-target 

species that were not previously recognized as present in the activity area.

Remember our discussion about ―lumpers‖ and ―splitters‖ in Step 2? This concept also 

applies to potential non-targets. If you need a refresher, check out the HACCP

Spotlight on page 20.

The form on the following page provides a consistent template for Step 3.
Chapter 4: HACCP Planning: Step 3 – Potential Non-Targets

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June 2011 25 USFWS-NCTC

HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

Invertebrates:

Plants:

Other Organisms (pathogens, parasites, etc.):
Chapter 4: HACCP Planning: Step 3 – Potential Non-Targets

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June 2011 26 USFWS-NCTC

Here is an example that shows how the HACCP team completed Step 3 for the 

hypothetical example introduced in Chapter 4: Step 1 (page 16).

HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

 Amphibians

 Bullfrog (Rana catesbeiana)

Invertebrates:

 New Zealand Mudsnail (Potamopyrgus antipodarum)

Plants:

 Eurasian milfoil (Myriophyllum spicatum)

 Purple loosestrife (Lythrum salicaria)

Other Organisms (pathogens, parasites, etc.):

 Chytrid fungus

 Whirling disease (Myxobolus cerebralis)
Chapter 4: HACCP Planning: Step 3 – Potential Non-Targets

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June 2011 27 USFWS-NCTC

"To be prepared is half the victory."

(Miguel de Cervantes Saavedra, Author, Poet and Playwright)

Sometimes non-target species are obvious and 

easily spotted. Sometimes they are not. What are 

you moving? Photo Credit - USGS
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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June 2011 28 USFWS-NCTC

Step 4 – Non-Target Analysis Worksheet (NTAW)

Learning Objectives:

At the end of Step 4, the participant will be able to:

 describe the relationship between Steps 1, 2, 3 and 4 of the HACCP 

Planning Process.

 evaluate the significance and severity of each non-target using risk 

assessment.

 define control measure, control point, and critical control point.

 given a significant non-target risk, determine if the control measure 

action is a critical control point or an optional control point.

 complete a Non-Target Analysis Worksheet using information from 

Steps 1, 2 and 3.

The Non-Target Analysis Worksheet (NTAW) is a pivotal step in the HACCP planning 

process because it determines if an activity poses a significant risk for moving invasive 

species or non-targets, and if so, what control measures can be applied to eliminate or 

reduce this risk to an acceptable level. As such, Step 4 is more complicated than the first 

three steps.

The form on the following page provides a consistent template for Step 4.

To complete Step 4, first list the title of each task described in Step 2 (Activity Flow Chart) 

in column 1 of the NTAW. Record potential non-targets identified in Step 3 (Potential NonTargets) in column 2. The third column in the worksheet asks a qualitative question: ―Are 

the potential non-targets significant?‖ The ―yes‖ or ―no‖ answer is subjective. Your 

HACCP team must determine the appropriate answer by conducting a risk assessment of 

the potential to move invasive species for each task.

"An ounce of prevention is worth a pound of cure."

(Benjamin Franklin, Founding Father of the United States)
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to reduce the risk 

of non-targets?

CCP?

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6 

Task #

Title:

Vertebrates

Invertebrates

Plants

Others

Task #

Title:

Vertebrates

Invertebrates

Plants

Others
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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Analyzing the Risk of Non-Targets

Analyzing potential risk is fundamental in HACCP. Risk assessments assist in defining 

the risk parameters surrounding the activity described under the management objective in 

Step 1. Risk assessments can be extremely complicated, using significant quantitative 

data and mathematical models, or they can be simple and more qualitative based on the 

best information available and best professional judgment.

Risk assessments measure the likelihood of an event occurring and the severity of 

negative impacts from such an event. Because it is difficult to predict when an 

introduction of a non-indigenous species will cause ecological, economic, or human 

health damage, the precautionary principle suggests that it is reasonable for HACCP 

planning to assume that a significant risk of introduction will include a significant risk of 

unacceptable negative effects. We are making the assumption that the risk of 

unacceptable negative effects is equal for all species and all situations to simplify this 

process. With all impacts assumed to be significantly negative, this leaves only

―likelihood‖ to be assessed. Here likelihood is defined as the probability of moving nontarget species (determined in Step 3) during individual tasks (from Step 2). HACCP 

makes the general assumption that significant negative impacts will occur following the 

introduction of a non-indigenous species as a part of the risk assessment; however, the 

process may also include an assessment of impacts if necessary, but this is not covered 

in this manual. 

Because HACCP plans are relatively simple risk-management plans, the associated risk 

assessment also can be abbreviated, erring, of course, on the side of caution. It is 

important to keep the ―big picture‖ in mind: the purpose of a HACCP plan is to prevent the 

transport of non-targets. If there is ANY reasonable risk of invasion, we must employ 

effective prevention techniques or control measures (described in Step 4, Column 5). In 

some cases, a risk assessment can be as simple as an informed judgment call without 

using any tools other than common sense. In other cases, it may be necessary to employ 

some sort of analytical tools to help determine whether any potential non-targets are 

significant. Remember that on the most basic level, the risk assessment is used to 

determine the likelihood of moving invasive species during particular tasks. 

On the next page is an example of a flow diagram used for risk assessment for Aquatic 

Management Activities (additional examples are available in Appendix C). 
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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Example of Risk Assessment for Aquatic Management Activities

Do all ac vi es take place

within an immediate

drainage area without

barriers between sites?

Any known differences in

species assemblage between

the origin and des na on sites?

Are any poten al NTS a

significant concern?

LOW RISK

YES

Do all ac vi es take place

within the same

watershed?

NO

YES

YES

NO

Can control measures eliminate

or reduce the occurrence of a

NTS to an acceptable level?

NO NO

YES NO

S IGNIFICANCE LINE

YES

MODERATE RISK HIGH RISK SEVERE RISK

* In the above risk assessment example, tasks identified as moderate, high, or severe risk 

should be considered to have a significant potential to move non-target species and 

control measures are warranted. 

When is a risk acceptable?

The previous Risk Assessment example mentions 

"reducing the occurrence of a non-target (NTS) to an 

acceptable level." The question is "what constitutes an 

acceptable level?" There is no single answer to this 

question, but ultimately your team will need to make this

determination when identifying critical control points

later in Step 4. This is the risk management aspect of 

HACCP. Science can help you determine if your control 

measure will remove, for example, 90% versus 100% of 

a non-target, but your team must ultimately determine 

which of those goals is appropriate to your situation.

HACCP Spotlight Acceptable Risk 
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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June 2011 32 USFWS-NCTC

The example risk assessment on the previous page goes beyond an "informed judgment

call" in order to provide a justification that explains the ―yes‖ or ―no‖ answer for why a task 

does or does not pose a significant risk (in Column 3). The justification, based on the risk 

assessment, will be summarized in Column 4. It is simply a statement of why there is or is 

not a potential for a moving a non-target for the individual task. 

It is imperative to stress that any activity will have some element of risk even if all the best 

procedures are applied. HACCP minimizes risks; it rarely eliminates them. A risk-free 

environment is an ideal situation that just does not exist in the real world. Given practical, 

real-world conditions, the HACCP team should focus on risks that have a reasonable 

likelihood of occurring and must decide what is reasonable and what is not. Even if the 

team determines there is no reasonable risk, it is important to complete a HACCP plan to 

document how you came to this decision. In addition, if and when circumstances change, 

a HACCP plan would make re-evaluating any new risks associated with the activity much 

easier.

The example risk assessment separates tasks into progressive risk levels (low, moderate, 

high, severe) based on task attributes like drainage location, similar species assemblages 

and the presence of non-target species. Increases in risk severity are based on the 

presence of significant non-targets at the task location(s). This process begins to quantify 

the level of risk. By quantifying risk, a HACCP team can evaluate whether or not a task, or 

on a larger scale the activity, should proceed given the level of risk. A task is assigned the 

highest level of risk (Severe Risk) when potential non-targets cannot be effectively 

managed by any control measure. When the risk assessment determines there is a 

severe risk, the task or activity should not occur unless the benefits of this activity clearly 

outweigh the potential impacts of introducing non-targets.

This specific risk-assessment process is only one example. However, any risk 

assessment process can be used if your HACCP team has something more appropriate 

for your activity. Your HACCP team may prefer to use a different tool (even if it is only 

common sense). Any tool is acceptable if it can determine whether moving a non-target is

possible. Nevertheless, it is important to document the risk assessment tool that was 

used (see ―Supporting Documentation‖ in Step 5). 

Once you have completed a risk assessment, any task that is identified as a significant 

risk (―yes‖ in column 3) needs control measures (described in column 5.) 
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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Risk Assessment vs. Risk Management – What’s the 

Difference?

Risk assessment is part of the larger concept of risk 

management. The assessment phase is analytical and based 

on measurements or estimates of severity and probability. 

Risk management also includes more subjective elements 

including risk prioritization, risk tolerance, and associated 

decisions that weigh the benefits and costs of risk 

minimization options.

Developing Effective Control Measures

If the HACCP team determines that a risk is significant, then control measures (i.e., 

preventive measures) are required to reduce the non-target risk to an acceptable level. 

Control measures are actions that can be used to control and remove identified nontargets.

The next two pages (pages 34-35) show how the HACCP Team completed Step 4 for the 

hypothetical example introduced in Chapter 4: Step 1 (page 16). The HACCP team 

determined that potential non-targets were not significant (low risk) during the first two 

tasks, but they were significant during the third and fouth tasks.

Task #1 – ―Load gear and drive to site‖ is low risk for moving non-target species, which is 

justified by the statement within Column 4: ―Risk is low because all equipment was 

cleaned and disinfected following prior use.‖ See page 34.

Task #2 – ―Unload gear and conduct sampling‖ is also low risk. ―Risk is low because 

sampling occurs only at one location, plus all equipment was cleaned and disinfected 

before storage,‖ according to the justification in Column 4 on page 34.

Task #3 – ―Reload gear‖ provides an example where a control measure is necessary. The 

HACCP team determined that all of the categories (vertebrates, invertebrates, plants, and 

other organisms) posed a significant risk since non-target species could be transferred. 

Note the ―Yes‖ for each non-target category in column 3 of the NTAW on page 35.

Task #4 – ―Return to warehouse and unload gear‖ is also a task requiring a control 

measure. All non-target species from each category were determined to pose a significant 

risk since non-target species can ―survive on equipment overnight.‖ Note the ―Yes‖ for 

each non-target category in column 3 of the NTAW on page 35.

HACCP Spotlight: Risk 

Wildland fire operations employ

risk management tools. Photo 

Credit: USFWS.
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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June 2011 34 USFWS-NCTC

HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to stop the spread 

of non-targets?

CCP? 

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6

Task #1

Title:

Load gear 

and drive to 

site

Vertebrates

Amphibians, 

including 

bullfrogs

No

Risk is low 

because all 

equipment was 

cleaned and 

disinfected 

following prior use

N/A No

There are no 

significant nontargets during 

this task.

Invertebrates

NZMS No N/A No

Plants

Eurasian milfoil

Purple 

loosestrife

No N/A No

Others

Chytrid fungus

Whirling 

disease

No N/A No

Task #2

Title:

Unload gear 

and conduct 

sampling

Vertebrates

Amphibians, 

including 

bullfrogs No

Risk is low 

because sampling 

occurs only at one 

location, plus all 

equipment was 

cleaned and 

disinfected before 

storage

N/A No

There are no 

significant nontargets during 

this task.

Invertebrates

NZMS No N/A No

Plants

Eurasian milfoil

Purple 

loosestrife

No N/A No

Others

Chytrid fungus

Whirling 

disease

No N/A No
Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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June 2011 35 USFWS-NCTC

HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to stop the spread 

of non-targets?

CCP? 

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6

Task #3

Title:

Reload gear

Vertebrates

Amphibians, 

including 

bullfrogs

Yes

High risk that 

bullfrog eggs or 

adults may be in 

gear after 

sampling

Visually inspect all gear for 

non-targets and remove 

anything found by hand 

before proceeding to Task 

#4

No

Hand removal, 

cleaning, and 

disinfecting 

would be better 

accomplished in 

Task #4 at a 

decontamination 

station back at 

the warehouse.

Invertebrates

NZMS

Yes

High risk that 

invertebrates 

could be in gear 

after sampling

No

Plants

Eurasian milfoil

Purple 

loosestrife

Yes

High risk that 

plants or seeds 

could be attached

to gear after 

sampling

No

Others

Chytrid fungus

Whirling 

disease

Yes

High risk that 

unwanted 

organisms could 

survive on gear

No

Task #4

Title:

Return to 

warehouse 

and unload 

gear

Vertebrates

Amphibians, 

including 

bullfrogs Yes

High risk that

bullfrog eggs or 

adults may be in 

gear after 

sampling

Remove any vertebrates 

then clean and disinfect all 

equipment using approved 

disinfectant solution to kill 

eggs.

Yes

If the equipment 

is not 

decontaminated 

during this task, 

then it will not be 

clean for use 

next time it is 

needed. This 

task is the point 

of no return.

Invertebrates

NZMS

Yes

High risk that 

invertebrates 

could be in gear 

after sampling

Clean and disinfect all 

equipment using approved 

disinfectant solution.

Yes

Plants

Eurasian milfoil

Purple 

loosestrife Yes

High risk that 

plants or seeds 

could be attached 

to gear after 

sampling

Clean and disinfect all 

equipment using approved 

disinfectant solution and 

rinse undercarriage of 

vehicles with high-pressure 

water spray.

Yes

Others

Chytrid fungus

Whirling 

disease Yes

High risk that 

unwanted 

organisms could 

survive on gear

Clean and disinfect all 

equipment using approved 

disinfectant solution.

Yes
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Because the risk associated with some tasks is considered significant, control measures 

are needed to remove the threat of a non-target. The team determined that the risk could 

be reduced in Task #3 if all gear was thoroughly inspected and all non-targets were 

removed by hand before proceeding to Task #4. However, hand removal, cleaning, and 

disinfecting would be better accomplished in Task #4 once everything was back at the 

warehouse. The warehouse has a decontamination station, disinfectant solution, and high 

pressure sprayers that are not available in the field.

The table below provides a brief list of example control measures. * For a detailed 

explanation and additional examples see ―Suggested References for Control Measures‖ 

in Chapter 7 (page 61).

Method Example

Chemical decontamination

Soak or spray equipment for at least 1 

minute with a 2% bleach solution. If 

invasive pathogens or diseases are 

suspected, a 10% solution should be used

Desiccation

Allow for 5 days of drying time before 

reuse. 

Freezing Expose equipment to 14 °F for 2 hours

Manual Removal Brush, Vacuum, Adhesive Roller

Heat Treatment

Use of steam, hot air, or hot water to bring 

an object’s surface temperature up to 140 

°F for 30 seconds.

Water Washing Pressure wash vehicles at minimum of 90 

pounds per square inch (psi).

Dedicated Equipment Wading gear only used in specific 

watershed

Managing Field Operations Sampling a stream from upstream to 

downstream

As discussed in Step 2, when an activity involves one or more tasks that are specifically 

included to prevent the spread of invasive species, the HACCP plan will be stronger if 

those procedures instead are listed as "control measures" rather than "tasks." Both 

"control measures" and "tasks" are specific procedures required to complete an activity. 

However, control measures require the HACCP plan to provide valuable documentation, 

monitoring and evaluation of the decontamination process, and prescribed corrective 

actions should the control measures fail. Tasks do not have this requirement. "Tasks" 

should be limited to only procedures necessary to complete the management objective. 
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"Control measures" are additional procedures necessary to eliminated or reduce the 

likelihood of moving non-target species should a task present a significant risk. While 

tasks can stand alone, control measures always correspond to a specific task. That is, 

tasks are necessary to advance the management objective. Control measures, by 

themselves, usually do not advance the management objective, but are required to 

mitigate risks encountered while completing some specific task. An effective HACCP plan 

will reflect this distinction.

Developing effective control measures relies on assembling a HACCP team with the 

expertise to understand the overall conditions and potential non-target risks associated 

with the proposed activity. The risk assessment process will guide teams to define the 

possible significance and severity of risks associated with an activity. It is an important 

responsibility of the HACCP team to expand and enlist all available knowledge in Step 4 

to further evaluate these risks and develop appropriate control measures that reduce nontarget risks to an acceptable level.

Keep in mind that there may be 

differences of opinion, even among 

experts, as to 1) the type of control 

measure that will be effective at reducing 

the non-target risk, or 2) whether control 

measures are warranted given the 

severity of the non-target risk. Although 

risk assessments set the initial level of 

risk, the HACCP team must weigh all 

opinions for each risk to determine an 

effective control measure. It is important 

to include brainstorming if there are 

differing views or if conditions 

surrounding the activity are not clear. In 

many cases, uniform protocols for 

managing particular invasive species do 

not exist. This may be due to lack of research, inconsistent results from existing research 

studies, or methods that are highly variable based on the environment and materials 

involved. Having the right level of expertise on the HACCP planning team, and making 

use of available reference materials, will better inform decisions on appropriate control 

measures. The constant evolution of invasive species management is yet another reason 

to think of a HACCP plan as a ―living document.‖

HACCP planning may become difficult if the team focuses narrowly on identifying too 

many specific non-targets. This dilutes your ability to focus efforts and control the truly 

significant risks. Accordingly, it is essential that only significant non-target species be 

controlled with the HACCP plan. The difficulty is deciding what is "significant." As a 

general guideline, a non-target must be controlled if 1) it is reasonably likely to occur 

beyond an acceptable level, and 2) if not properly controlled, the non-target is likely to 

result in harm to the resource.

Filtering “sock” on pond water supply line. Photo 

Credit: Bob Pitman & Robert Lindsey, USFWS
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If control measures cannot be applied to reduce risk, then the HACCP team should reevaluate the management objective, the activity, and individual tasks to determine if the 

non-target risk can be reduced to an acceptable level. This can be accomplished by 

adjusting the activity to remove the issue or expand the team to include more expertise to 

determine if further control measures can be incorporated. After further assessment, if the 

activity or any task still cannot be adjusted to reduce risk to an acceptable level, then the

team must determine if the activity is worth the risk, considering the potential impacts that 

could manifest should an unwanted introduction occur. In general, it is recommended that 

such an activity should be discontinued under the prescribed management objective until 

effective control measures can be implemented to a degree that reduces risk to an 

acceptable level. Notable exceptions might include emergency operations, activities 

performed for national security and/or situations where the ecological benefits clearly 

outweigh the risks associated with potential invasive species.

Determining Critical Control Points

After a control measure has been described, a decision must be made on whether or not 

the task and its associated control measure(s) should be considered a critical control 

point (CCP) for the overall activity (recorded as "yes" or "no" in column 6, with 

justification in column 7). If any potential non-targets have been identified in Step 3, then 

you must identify at least one task as a critical control point within your HACCP plan. 

Later, when you complete Step 5, you will specify the controlled conditions under which 

all activities identified as CCPs are completed.

Key Definitions:

Control Point - any step or task during which potential hazards can be 

controlled. Control points may be critical control points or optional control 

points. Only critical control points are essential for preventing risk, however, 

if resources allow, optional control points may also be employed to further 

minimize risk well below acceptable levels.

Critical Control Point (CCP) - the best point, step, or procedure at which 

significant hazards (non-targets) can be controlled, prevented, or reduced to 

acceptable levels in order to minimize the risk of spread.

Optional Control Point - a task during which control measures could be 

applied to prevent or reduce the risk of significant non-target hazards, but 

control at this point, although potentially helpful, is not essential for 

removing or reducing the significant non-target hazard (usually because 

control measures are more effective if applied during another task).
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For every significant non-target identified during the task risk assessment, there must be 

an associated control measure to address the non-target risk. The point during a task 

when a control measure is implemented is known as a control point. In the hypothetical 

example (Chapter 4: Page 16), Task #4 "Return to warehouse and unload gear" is a 

control point. The associated control measure is "Remov(ing) any visible adult bullfrogs"

and "clean(ing) and disinfect(ing) all equipment using a disinfectant solution." (page 35).

How can you determine if a control point is critical or not? 

Control points are categorized as either optional or critical. Optional control points may 

not be the best point to remove a significant non-target risk, but still may be an important 

ancillary strategy for reducing non-targets within the activity. The control measures 

implemented at an optional control point help in reducing the risk of these non-target 

species impacting a later task. Establishing control measures for optional control points 

often makes sense when there is little cost or effort but much to gain in terms of reduced 

risk.

Critical Control Points (CCPs) are crucial in reducing the non-target risk to an acceptable 

level to complete a successful activity under the management objective. Points may be 

identified as CCPs where the risk of non-target hazards can be prevented once-and-forall. 

Designated CCPs should be limited only to those tasks where control of the 

significant non-target risks can be best achieved. 

Differentiating between CCPs and optional control points varies from activity to activity 

and depends on the uniqueness of the activity. When designating CCPs, you must also 

consider any applicable statutes or rules. For example, if it is illegal to transport a 

particular non-target species over land in a given state, preventing contamination at a 

prior step becomes a CCP, even if from a biological standpoint, the CCP makes more 

sense at the receiving water. 

During the non-target risk analysis in the previous section, you learned how to determine 

where non-targets enter an activity. Often, the best place to control a non-target is at the 

point of entry. But this is not always true. The CCP can be several tasks away from the 

point at which the significant non-target risk is introduced.

A series of questions can help you identify CCPs for an activity. The questions are shown 

in table form and in the form of a CCP Decision Tree (on pages 40-41). You should 

consider completing the Decision Tree for each type of non-target risk listed for each task 

containing control measures. For example, if you have two types of non-targets and four 

tasks within your activity, then you would need to run through the Decision Tree a total of 

eight times (2 x 4 = 8) in order to cover each unique non-target/task combination. 

Properly used, the CCP Decision Tree can be a helpful tool in identifying CCPs, but it is 

not perfect. Use your best judgment. 
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Once each control point is evaluated, any task identified as having a critical control point 

needs to be carried on to Step 5, the Non-Target Risk Action Plan Form, to develop a 

plan for addressing the significant non-targets. In the event that no critical control points 

are identified for the entire activity, the HACCP team needs to reconsider their analysis 

and/or consider whether one or more tasks in the activity need to be modified.

Question 1 Could contamination with the identified non-targets occur or increase 

beyond acceptable levels?

 If ―yes,‖ ask question 2.

 If ―no,‖ then stop. This task is not a control point, which means 

that it is also not a CCP. 

Question 2 Do control measures exist during this task or a subsequent task that 

reduce the occurrence of a non-target to an acceptable level?

 If ―yes,‖ skip question 3 and ask question 4.

 If ―no‖, ask question 3. 

Question 3 Is control at this step necessary to prevent or minimize the hazard?

 If ―yes,‖ you have identified a significant non-target hazard that 

will not be controlled. If you continue, it is likely that you will 

spread the non-target. The task must be redesigned to include a 

control measure. Sometimes there is no reasonable control 

measure available. In such cases, you need to consider whether 

to modify or halt the activity given the potential ecological, 

economic, and legal consequences.

 If ―no,‖ the task is not a CCP for the non-target hazard.

Question 4 Is there a better point within the activity to reduce the non-target to an 

acceptable level (i.e. a previous task or subsequent task)?

 If ―yes,‖ this task is not a CCP for the hazard, but it is an optional 

control point. Continue evaluating subsequent tasks to identify if 

another task is an actual CCP.

 If ―no,‖ this task is a CCP. Control measures must be applied at 

this point (task) in order to prevent the spread of the non-target.
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Chapter 4: HACCP Planning: Step 4 – Non-Target Analysis Worksheet (NTAW)

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June 2011 42 USFWS-NCTC

A HACCP plan can lose focus if control points are 

unnecessarily identified as CCPs. 

If control measures are not applied, then that task does not 

have a control point. This means the task is neither an optional 

control point nor a critical control point (CCP). Only points 

where control measures are implemented are control points. 

Moreover, only points at which significant risks must be 

controlled are considered critical control points. Those new to 

the HACCP planning process tend to designate many optional 

control points as CCPs. This may unnecessarily increase 

effort and reduce efficiency. Although it may make sense to 

have multiple CCPs to address multiple targets that have 

unique control needs, HACCP planning teams should look 

carefully at multiple CCPs that cover the same target 

species...this likely indicates unnecessary redundancy.

HACCP Spotlight: Too Many CCP's

Is this an optional or critical 

control point. Photo Credit: Paul 

Nelson, USGS.
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June 2011 43 USFWS-NCTC

Step 5 – Non-Target Risk Action Plan (NTRAP)

Learning Objectives:

At the end of Step 5, the participants will be able to:

 explain how Steps 1, 2, 3 and 4 of the HACCP Planning process 

apply to the Non-Target Risk Action Plan (NTRAP).

 define the prescribed limit, range, or criterion for control measures.

 describe the process for monitoring and evaluating control measures 

and establish corrective actions if needed.

 describe the importance and use of supporting documentation.

 complete a Step 5 NTRAP form.

In order to complete the final form in your HACCP plan, you will need information 

completed in Step 4 (the Non-Target Analysis Worksheet). Find the tasks that you have 

identified as Critical Control Points (CCPs) in column 6 of the Non-Target Analysis 

Worksheet. An effective HACCP plan must have at least one CCP if there is any 

reasonable chance of reducing the risk posed by non-targets. You will complete a 

separate form for each CCP identified from your Non-Target Analysis Worksheet. Each 

CCP should be addressed by the Non-Target Risk Action Plan (NTRAP). 

Management Objective

Review the Activity Description (HACCP Step 1) and copy the management objective 

into the first box of the NTRAP (HACCP Step 5). This information is included to remind 

those using the form of the overall reason for the management activity.

Critical Control Point Task

Review your Non-Target Analysis Worksheet (HACCP Step 4) and find the first CCP 

(see column 6). Copy the title of the task that corresponds to this CCP into the 

appropriate box on the NTRAP. Also, add the task number in the adjacent box.

Significant Non-Targets

The same NTRAP form can be used for multiple non-targets as long as they use the 

same control measure. If different control measures are required for different nontargets then an NTRAP form is necessary for each unique control measure/non-target 

combination. Review your Non-Target Analysis Worksheet (HACCP Step 4) and find the 

non-target risks that you identified as significant (See Step 4 column 3). Each significant 

non-target risk must be copied into the appropriate box on the NTRAP. 
Chapter 4: HACCP Planning: Step 5 – Non-Target Risk Action Plan (NTRAP)

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June 2011 44 USFWS-NCTC

Control Measures

For each significant non-target risk, a control measure should be identified and listed on 

the Non-Target Analysis Worksheet (Step 4). Copy the control measures that 

correspond to each significant risk into the appropriate box on the NTRAP.

This form provides a consistent template for Step 5.

HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1

Critical Control Point: 

Task #

Title:

Significant Non-Target(s)

(Step 4, Column 3)

Control Measure(s)

(Step 4, Column 5)

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Monitoring the

Control Measure(s) Who?

How?

Where?

How often?

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Development Team Members

Date Developed: Date(s) Reviewed:

* all gray fields are required
Chapter 4: HACCP Planning: Step 5 – Non-Target Risk Action Plan (NTRAP)

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June 2011 45 USFWS-NCTC

Pages 45-46 show how the HACCP team completed Step 5 for the hypothetical 

example introduced in Chapter 4: Step 1 (page 16).

HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1 Habitat Survey for the Recovery of Cutthroat Trout (CT)

Critical Control Point: 

Task #

4 Title: Return to warehouse and unload gear

Significant Non-Target(s)

(Step 4, Column 3)

Vertebrates, Invertebrates, Plants, and Other Organisms 

(All listed in step 3)

Control Measure(s)

(Step 4, Column 5)

Clean and disinfect all equipment using approved disinfectant 

solution

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Use disinfectant solution that contains quaternary ammonium 

mixed at a concentration of at least 1% but no more than 3%. 

Contact time with gear must be at least 10 minutes.

Monitoring the

Control Measure(s) Who? Hatchery staff

How? Check immersion time with timer. Ensure concentration is correct 

with AQA1507 Quaternary Ammonium Test Kit (or similar)

Where? Decontamination station at the warehouse

How often? Every time that gear is unloaded and stored

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Mix new (fresh) dosage of disinfectant solution and repeat the 

cleaning/disinfectant procedure from the beginning. If gear cannot 

be disinfected, it must be clearly tagged as "contaminated" and 

isolated until it can be disinfected before being allowed back in 

the field.

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Logan River Sampling Protocol, Louanne River Sampling Protocol, Quaternary Ammonium Disinfectant 

Information Sheet, Nevada Noxious Weed List, California Noxious Weed List

Development Team Members Jonathan Thompson, Ronald Smith, Louanne McMartin

Date Developed: 7/29/2010 Date(s) Reviewed: Not yet reviewed

* all gray fields are required
Chapter 4: HACCP Planning: Step 5 – Non-Target Risk Action Plan (NTRAP)

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June 2011 46 USFWS-NCTC

HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1 Habitat Survey for the Recovery of Cutthroat Trout (CT)

Critical Control Point: 

Task #

4 Title: Return to warehouse and unload gear

Significant Non-Target(s)

(Step 4, Column 3) Vertebrates (Bullfrogs)

Control Measure(s)

(Step 4, Column 5) Visually inspect gear and remove all visible adult bullfrogs

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Check all exposed areas at least twice until no visible adult 

bullfrogs remain.

Monitoring the

Control Measure(s) Who? Field crew supervisor

How? Visual observation

Where? Decontamination station at the warehouse

How often? Every time that gear is unloaded and stored

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Have another staff member repeat the control measure.

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Logan River Sampling Protocol, Louanne River Sampling Protocol, Quaternary Ammonium Disinfectant 

Information Sheet, Nevada Noxious Weed List, California Noxious Weed List

Development Team Members Jonathan Thompson, Ronald Smith, Louanne McMartin

Date Developed: 7/29/2010 Date(s) Reviewed: Not yet reviewed

* all gray fields are required
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Prescribed Ranges, Limits, or Criteria for Control Measure

There should be boundaries or criteria that must be met for your control measure to be 

effective. These are referred to as your Prescribed Ranges, Limits, or Criteria 

(PRLC). Prescribed Ranges, Limits, or Criteria (previous versions of HACCP refer to 

this as a ―control limit‖) are specific measureable attributes that can be used to 

determine if control measures are effectively minimizing risk (e.g., a minimum dose of a 

disinfectant, a minimum exposure time, or an acceptable range of temperatures).

If possible, allow for a margin of error around your absolute minimum and/or maximum 

threshold. Routine operating limits should be more stringent than absolute control limits. 

This approach is analogous to safety factors that engineers incorporate into building 

bridges, buildings, and other structures, where a protective measure may be designed 

at ten times the level needed to withstand the maximum known risk factor. For example, 

if a certain chemical concentration, say 5 ppm, is required to control (i.e., kill) non-target 

species, then a manager might set the PRLC above this minimum concentration needed 

to ensure effective treatment. This manager, for example, might set the PRLC to at least 

10 ppm in order to ensure the desired effect.

Alternatively, rather than an absolute limit, there may be a range associated with the 

control measure. For instance, a chlorine bleach solution of at least 5% may be effective 

in controlling New Zealand mudsnails, but 10% may damage equipment. Therefore, 

your range would be at least 5% but less than 10%. The PRLC from the CCP (Task #4) 

in the hypothetical example sets a minimum disinfectant solution of 1% (the range is 1% 

to 3% quaternary ammonium). In this case, adhering to a minimum specific duration of 

contact time (10 minutes) controls the vertebrate, invertebrate, plant, and other 

organisms.

In many cases, a limit for the appropriate control may not be readily apparent or 

available. The hypothetical example’s other control measure (for adult bullfrogs) is to

visually inspect and remove all adult bullfrogs. The PRLC for this control measure is to 

check all areas that were exposed twice and verify that no visible adult bullfrogs remain. 

Checking twice and having nothing remain are the criteria by which effectiveness can 

be confirmed. Tests may need to be conducted or information gathered from sources 

such as scientific publications, regulatory guidelines, experts, or experimental studies if 

the information needed to define a PRLC is unavailable. In the end, a value should be 

selected that errs on the side of caution. Additionally, regular review of existing HACCP 

plans allows for inclusion of new PRLC as better information becomes available. The 

rationale and reference material used to establish controls and their ranges, limits, or

criteria should become part of the supporting documentation for the HACCP plan and 

will help with periodic review.

Every control measure must have some Prescribed Range, Limit, or Criterion. Without 

such, there is no way to ensure effectiveness of the control measure. Be specific and 

keep in mind that you may need supporting documentation to justify your PRLC. List 

your PRLC in the appropriate box on the Non-Target Risk Action Plan.
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Control Measure Monitoring

Control measure monitoring is the process that managers rely upon to maintain control 

at a CCP. Accurate monitoring indicates when a PRLC has not been met. When 

controls are not adequate, corrective actions are needed. Reviewing the monitoring 

records can determine the extent of the problem and the corrective action needed. 

Documented monitoring ensures that activities from the HACCP plan were followed. 

The following monitoring questions need to be answered in the appropriate box on the 

NTRAP.

Who monitors the control measures and the appropriate PRLC to ensure that they 

are implemented appropriately? 

Assignment of the responsibility for monitoring is an important consideration when 

developing a HACCP plan. The individual assigned to CCP monitoring could be the 

manager, biologist, or technician. In some situations, it may be performed best by an 

independent party. Including all personnel in the HACCP planning process builds a 

broad base of understanding and commitment to the program. Any unusual occurrences 

or deviations from controls should be reported immediately to make sure that 

adjustment and corrective action are timely. All records and documents associated with 

CCP monitoring should be signed or initialed by the person doing the monitoring.

How is the control measure monitored? Where does the monitoring occur? 

The purpose of monitoring is to evaluate whether the PRLC has been met. In most 

cases, monitoring must be designed to provide rapid real-time results. There is usually 

no time for lengthy analytical testing because control failures must be detected quickly 

and appropriate corrective actions instituted before the activity provides a pathway for 

invasion. This is best done by monitoring the potential invasion pathway (the activity) 

rather than the habitat one intends to protect. Monitoring control measure effectiveness 

should not rely on simply watching to see if the non-target begins to invade a protected 

area. Containing an established invasion is difficult and sometimes impossible. Reactive 

habitat monitoring often does not provide information until it is too late. Your first priority 

should be to stop an invasion before it occurs. Nevertheless, monitoring for new species 

invasions in addition to HACCP planning is a good complementary strategy. It can help 

point out if there is a major failure in the HACCP plan control measures, but moreover, 

can sometimes facilitate initiating a response while an invasion is still manageable. 

Physical and chemical measurements are preferred monitoring methods because 

testing can be done rapidly. Example physical measurements include the following:

 Time and temperature - This combination of measurements is often used to 

monitor the effectiveness of procedures used to control non-target contamination 

of collection gear, nets, and other natural resource survey equipment and 

materials. An example control measure for this would be drying or freezing 

equipment for a specific time to kill a contaminant.

 Water flow rate - Since plant fragments, eggs, and many invertebrates cannot 

swim against the current, holding fish in flowing water to separate them from 

hitchhikers is one way to control the non-target. Measuring flow rate and the time 
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required for complete water exchange is an example of physical measurements 

that may need to be monitored.

 Visual examination - Observations for the presence of non-target contamination 

of equipment - such as firefighting equipment, agricultural implements, sample 

nets, species collection gear, and boats and trailers - is one way to monitor for 

non-target presence. Note that when visual inspection/manual removal is an 

actual control measure (e.g., as a method to remove weed seeds from field 

clothing), visual examination would not be appropriate to also serve as a method 

to monitor control effectiveness. In that case, the monitoring would involve a 

means to confirm that the visual inspection was conducted properly (e.g., a crew 

supervisor verifying that the crew members conducted their visual 

inspection/manual removal effort for an appropriate amount of time).

How often are the control measures checked to ensure that they are administered 

appropriately? 

Monitoring can be continuous or intermittent. When possible, monitor continuously. 

Continuous monitoring is possible for many types of physical and chemical parameters. 

A monitoring instrument that produces a continuous record does not control the hazard 

on its own; it needs to be observed periodically so that action is taken when needed. 

This too is a component of monitoring. The length of time between checks directly 

affects the corrective action needed when a deviation from a PRLC is found. The 

frequency of intermittent monitoring should be determined from what you know about 

the activity, pathway, and life history of the non-target species.

Corrective Action

A corrective action is only necessary if you have determined that a control measure 

failed, either through direct observation of something that has clearly gone wrong, or 

indirectly measured through a failed PRLC. When control measures are not 

implemented correctly at a CCP, predetermined and documented corrective actions 

should be instituted immediately. A corrective action is essentially a ―back-up plan.‖ All 

control measures within a HACCP plan should have a viable back-up plan because, in 

the real world, control measures will sometimes fail.

Effective corrective actions depend heavily on an adequate monitoring program. The 

primary objective is to establish a HACCP plan that permits rapid identification of 

deviations from a PRLC for the control measure. The sooner the deviation is identified, 

the more easily corrective actions can be taken and the greater the potential for 

minimizing the risk of spread. An individual who has a thorough understanding of the 

activity, pathway, and HACCP plan, and who has the authority to make decisions 

should be assigned the responsibility of implementing corrective actions.

Murphy’s Law states that if something can go wrong, it will. Thus, corrective actions are 

a necessary back-up strategy and are written in advance into the HACCP plan in order 

to protect our resources from a deviation from the PRLC. For example, if a PRLC for 

decontaminating field gear through freezing is not met because of a power failure, does 

the HACCP plan require another round of freezing later, or an alternate 
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decontamination method now, or does it authorize the activity to continue without further 

decontamination? The answer depends on the nature of the risks and activity, but 

without including any answer, a HACCP plan is incomplete. 

Corrective actions must bring the CCP back under control. A corrective action should 

take care of the immediate (short-term) problem as well as provide long-term solutions. 

The objective is to implement a short-term fix so that control can be re-established as 

soon as possible without further deviations. Any unanticipated failure of control 

measures necessitates a re-evaluation of the HACCP plan and the corresponding 

control measure.

A permanent solution to eliminating or minimizing the initial cause or causes for the 

deviation should be implemented if necessary. Specific instructions for corrective 

actions must be available to all workers in the operation and should be part of the 

documented HACCP plan. 

If a control measure failure occurs, a report is helpful as supporting documentation and 

should contain a description of the activity/pathway, a description of the deviation, and 

results of any evaluations.

Supporting Documentation

The purpose of supporting documentation is to provide objective evidence that all 

essential elements of the plan have a scientific basis and represent a valid approach to 

controlling the pathway hazards. There are several approaches to validating the 

HACCP plan, including incorporation of fundamental scientific principles, use of 

scientific data, reliance on expert opinion, or conducting of specific observations or 

tests.

Validation can be performed by the HACCP team or by an individual qualified by 

training or experience. Validation activities may be similar in scope and time 

commitment to the original plan development. Actual components of the plan should be 

validated before relying on the HACCP plan and/or when factors warrant. These factors 

could include changes in the pathway, using new or different techniques, new scientific 

information about potential hazards or their control, or new infestations of invasive 

species. Validation involves a scientific and technical review of the rationale behind 

each part of the HACCP plan from hazard analysis through each CCP verification 

strategy.

Support documents include information and data used to develop the plan. This 

includes the written Non-Target Analysis Worksheet (Step 4) and records of any 

information used in performing the risk assessment, hazard analysis, and establishing 

the controls. Support documents may include information about the current geographic 

range of non-targets that may get into the pathway and sufficient data used to establish 

the adequacy of any barriers to this contamination. In addition to data, support 

documents may also include correspondence with consultants or other experts. Support 

documents should also include a list of the HACCP team and each member’s 
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responsibilities. A section at the bottom of the Non-Target Risk Action Plan is provided 

for this information.

Multiple Critical Control Points

If you identified more than one CCP on your Non-Target Analysis Worksheet, then you 

will need to complete an additional Non-Target Risk Action Plan form for each additional 

CCP that you identified. That is, you need at least one separate action plan for each 

CCP. If a CCP requires different control measures for different non-target species, you 

will need one separate action plan for each control measure/non-target species 

combination. In this case, a single CCP may require more than one action plan. 

Once you have completed an action plan (or plans) for each CCP, your HACCP Plan is 

finished. However, do not just file it away and forget it. Please review the Non-Target 

Risk Action Plan every time your covered activity is performed and re-evaluate your 

HACCP plan frequently, especially if the activity changes.
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Chapter 5

Implementing HACCP

Learning Objectives:

At the end of Chapter 5, participants will be able to:

 explain the importance of HACCP plan implementation, and 

associated options for verification.

 explain how periodic review of HACCP plans is essential.

 describe how sharing plans can help others as well as your own 

HACCP team.

 reflect on the ultimate purpose of HACCP planning.

Supporting Documentation and Periodic Review

Like many plans, a common problem that faces the HACCP process is implementation. 

Many plans are constructed and then become dust collectors on a shelf. This is not the 

intent for a HACCP plan. Plans by themselves are only pieces of paper (or an electronic 

equivalent). The planning process is what is important and should not cease once a 

HACCP plan is completed. Circumstances change! Procedures change! Materials and 

personnel change! We live in a dynamic world where we need to periodically reevaluate our actions to ensure that our precautions are still valid.

Supporting documents and periodic review are essential to the implementation of the 

HACCP process on the ground level. As described in the Chapter 4 (Step 5),

supporting documents can be checklists for verifying that work has been completed, 

equipment manuals, standard operating procedures, decontamination literature, or any 

other documents that are relevant to the activity. Peer-reviewed scientific journal articles 

that provide evidence for the effectiveness of a particular control measure could be 

important to document the validity of your established procedures. With time, new 

information becomes available and such information could substantially impact how 

your activity meets your management objectives and could impact the effectiveness of 

your control measures. Conducting a periodic review of the plan ensures that plan 

components stay fresh. During the course of a year, many projects may have employee 

turnover, change standard operating procedures, and/or add activities. Meanwhile, 

additional invasive species continually enter new habitats. A periodic review on at least 

an annual basis will ensure that new pathways for spreading invasive species are 

recognized and controlled. 

It is important to consider HACCP planning as a living document for review with ever 

changing environmental conditions and the possibility of new non-target species 

influencing our field activities. Considering these challenges, we recommend that you 

and your partners make a reasonable effort to review standard operating procedures 

and HACCP documents on a consistent and timely basis. Do not rely on corporate 
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memory that may retire with your most senior employees. Preserve best management 

practices within a fully documented HACCP plan.

One approach for ensuring implementation of HACCP plans is to use the NTRAP from 

Step 5 as a part of compliance documentation. For internal use, this might simply be a 

requirement that the responsible party sign the completed NTRAP and file it for a 

prescribed period of time. Where HACCP planning becomes a requirement for others 

(e.g., recipients of grant funds for restoration projects), the signed NTRAP can serve as 

written documentation that the plan will be or has been be followed. 

Sharing Plans

Sharing plans at http://www.haccp-nrm.org is a way to share your HACCP process 

information. The website can be used to provide examples to other professionals that 

are working to prevent the spread of invasive species in their activities. Also, share your 

HACCP plans with partners and public entities. The more you expose those that might 

be affected by non-target movement and potential invasive species introductions, the 

better the opportunity to reduce the risk through effective communications and 

constructive planning. By putting your HACCP plan online, you also provide a way for 

others to provide valuable feedback. Interested parties or others who perform similar 

management activities may have ideas or suggestions that did not initially come to your 

HACCP team. The on-line database of HACCP plans is available to connect others 

around the globe and further our common goal of conserving our valuable natural 

resources.

HACCP and Conservation Ethics

In the end, creating and implementing a HACCP plan for natural resource activities is

not really about filling out forms, protecting ourselves with the cover of supporting 

documents, or adding a new layer of compliance tracking. It is about doing no harm! As 

stewards of natural resources it is our responsibility to do our best to protect and 

preserve. This responsibility includes not spreading invasive species in the course of 

our conservation efforts. None of us wants to experience the irony of permanently 

damaging the resources that we work so hard to conserve. Conservation must be

properly planned. A good steward will take in the larger picture and evaluate the 

consequences of his or her own actions (or inactions).

“A good plan violently executed now is 

better than a perfect plan next week.”

(George Patton, American General)
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Chapter 6

Glossary

AIS – Aquatic Invasive Species

Alien – an organism that is outside of its native range; an organism that is foreign to its 

current geographic location. See non-indigenous.

ANS – Aquatic Nuisance Species

Aquarium Release – a type of intentional introduction whereby a captive or aquatic pet 

animal, aquarium plant, or contaminated water is released into open waters by 

an aquarium hobbyist.

Aquatic Nuisance Species – a non–indigenous species that threatens the diversity or 

abundance of native species; the ecological stability of infested waters; or 

commercial, agricultural, aquaculture, or recreational activities dependent on 

such waters.

Aquatic Invasive Species – marine, estuarine, or freshwater organisms that, when 

introduced into new habitats, negatively affect aquatic ecosystems as well as 

human use of these natural resources. Also see invasive species. 

ASTM International – formerly the American Society for Testing and Materials.

BMP – Best Management Practices.

CCP – Critical Control Point.

Control – (a) [verb] to manage the conditions of an activity or a non–target to maintain 

compliance with established criteria (e.g. to control a non–target means to 

prevent its spread). (b) [noun] the state in which correct procedures are followed 

and criteria are met.

Control Limit – a specific criterion that must be met for each control measure 

associated with a critical control point. For example, if the application of a bleach 

solution was used as a control measure to prevent the spread of a non–target 

species, the control limit might be the minimum concentration of that solution 

(e.g. ≥5% bleach solution). In this example, a 3% bleach solution would fail to 

meet the control limit.

Control Measure – an action that can be used to control a potential hazard (sometimes 

referred to as a preventive measure). Control measures are the first, and 

sometimes only, line of defense against the spread of non-targets. If control 

measures fail, corrective actions should be implemented.
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Control Point – any step or task during which potential hazards can be controlled. 

Control points may be critical control points or optional control points. Only critical 

control points are essential for preventing risk, however, if resources allow, 

optional control points may also be employed to further minimize risk well below 

acceptable levels.

Corrective Action – a procedure that must be followed if a control measure fails at a 

critical control point. A corrective action is backup procedure used as a second 

line of defense that may be necessary to prevent the spread of a non–target if 

the first–line defense (a control measure) fails to control a non–target.

Critical Control Point (CCP) – the best point, step, or procedure at which significant 

hazards (non-targets) can be controlled, prevented, or reduced to acceptable 

levels in order to minimize the risk of spread.

Established – an introduced organism with one or more reproducing, sustainable 

populations.

Exotic – something that is found outside of its native range; something that is foreign 

(see non-indigenous).

HACCP – Hazard Analysis and Critical Control Points – a system or plan for controlling 

hazards (non–target species) in order to minimize risk and/or detrimental impact 

while meeting a management objective.

Hazard – a non–target species that is reasonably likely to be transported through 

natural resource work and become established, creating negative impacts to 

native species and/or their habitats.

Indigenous – occurring or found naturally in a particular area or ecosystem (e.g. 

species that are indigenous to North America are those that historically occurred 

in North America prior to the arrival of the first European settlers). In contrast to 

endemic species, indigenous species may be found naturally in more than one 

particular geographic area. An indigenous species is a member of its native, 

natural community.

Introduce – the intentional or unintentional process of releasing, or allowing to be 

released, a non–target species into an ecosystem, region, or specific 

geographical location where it is not native 

Introduced Species – a species moved by humans (or by human actions), either 

intentionally or unintentionally, to an ecosystem, region, or specific geographical 

location where it is not native.

Invasive Species – a non-indigenous organism whose introduction does or is likely to 

cause economic or environmental harm or harm to human health. 

Locally Established – an introduced species with one or more naturally reproducing 

populations but with a very restricted distribution and no evidence of natural 
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range expansion (in general, limited to a relatively confined area, such as a small 

lake).

Lumper – a person who categorizes multiple species or tasks into few broadly defined, 

inclusive categories.

Monitor – conduct planned observations or measurements to assess whether a critical 

control point is under control and produce an accurate record for future use in 

verification.

Native – a species that occurs naturally within a specific geographical range (e.g. 

species native to North America existed there before the arrival of European 

settlers). See indigenous.

Naturalized – a well-established species, not originally native to a particular geographic 

area, but has become integrated with native species into the otherwise natural 

food web.

NFH – National Fish Hatchery.

NIS – Non-indigenous species.

Non–indigenous Species – an individual, group, or population of a species that is 

introduced by human intervention into an area or ecosystem outside of its 

historic, native geographic range. Synonymous with ―alien,‖ ―non–native,‖ 

―exotic,‖ and ―introduced.‖

Non–Native – see Non-indigenous Species

Non–Target – anything, including any organism, that is not intentionally moved. For 

example, if your management activity calls for you to stock largemouth bass, 

then any other species of fish (or other organism) would be a non–target. Your 

intent would be to only move largemouth bass.

NTAW – Non–target Analysis Worksheet. This is completed during the fourth step of the 

HACCP planning process.

NTRAP – Non–target Risk Action Plan. Formerly called the ―HACCP Plan Worksheet,‖ 

this is the fifth and final step in the HACCP planning process.

Operating Limits – prescribed limits for control measures used to reduce the risk of 

contamination by non–target species. Operating limits are usually more stringent 

than critical limits. For example, if a certain chemical concentration, say 5 ppm, is 

required to control (i.e., kill) organisms of a non–target species, then a manager 

might set the operating limit above this minimum concentration needed to ensure 

effective treatment. This manager, for example, would, perhaps, set the 

operating limits to 8 to 10 ppm.
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Optional Control Point – a task during which control measures could be applied to 

prevent or reduce the risk of significant non–target hazards, but control at this 

point, although potentially helpful, is not essential for removing or reducing the 

significant non–target hazard (usually because control measures are more 

effective if applied during another task).

Pathway – an activity or process through which a species may be transferred to a new 

location where it could become invasive (e.g., shipping, air travel).

Pathway Management – the act of assessing a pathway, identifying control points, and 

incorporating control measures or corrective actions to reduce or eliminate non–

target species.

PPM – Parts per million.

Prescribed Range, Limit, or Criterion (PRLC) (previously called a ―control limit‖) – a 

specific measureable attribute that can be used to determine if control measures 

are effectively minimizing the risk (e.g., a minimum dose of a disinfectant, a 

minimum exposure time, or an acceptable range of temperatures).

PRLC – Prescribed Range, Limit or Criterion.

Risk – combination of the likelihood of a hazard occurring and the severity of its impacts

Severity – the level of detrimental impact of an introduced non–target species (if not 

properly controlled).

Splitter – A person who categorizes species or tasks into many narrowly defined, 

exclusive categories.

Target – anything that is intentionally moved. For example, if your management activity 

calls for you to stock largemouth bass, then your targets would be largemouth 

bass and any equipment and personnel used to carry out this activity.

USFWS – the United States Fish and Wildlife Service.

Validation – the element of verification focused on collecting and evaluating scientific 

and technical information to determine whether the HACCP plan, when properly 

implemented, effectively controls identified pathway hazards.

Vector – the specific means by which an invasive species moves within a particular 

pathway (e.g., a ship, agricultural products, boots).

Verification – the use of methods, procedures, or tests, in addition to those used in 

monitoring, that determine whether the HACCP system is in compliance with the 

HACCP plan and/or whether the plan needs modification.
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Chapter 7

References

HACCP Websites

www.seagrant.umn.edu/ais/haccp – Minnesota Sea Grant

www.haccp-nrm.org - HACCP for Natural Resource Management – USFWS/UT 

Arlington

www.conabio.gob.mx/invasoras/index.php/Análisis_de_riesgo - HACCP for Natural 

Resource Management in Spanish - Conabio

Invasive Species Databases

www.eddmaps.org - Early Detection & Distribution Mapping System - Center for 

Invasive Species and Ecosystem Health

www.issg.org/database/welcome - Global Invasive Species Database - IUCN

http://nas.er.usgs.gov - Non-indigenous Aquatic Species Database – USGS

http://www.issg.org —Invasive Species Specialist Group—also a list of ―100 of the 

World’s Worst Invasive Species‖

General Invasive Species Information

http://www.anstaskforce.gov —Aquatic Nuisance Species Task Force

http://www.invasivespecies.gov/faq/main.shtml — National Invasive Species 

Council—frequently asked questions

http://nas.er.usgs.gov — Non-indigenous Aquatic Species—information resource for 

the Florida Caribbean Science Center of the USGS—huge list of non-indigenous 

species website links.

http://bluegoose.arw.r9.fws.gov/resources/weeds.html — Invasive species 

resources—links from the U.S. Fish and Wildlife Service invasives webpage

http://biology.usgs.gov/cro/invasive.htm - USGS, BRD, Central Region

http://www.sgnis.org - Sea Grant Non-indigenous Species
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http://www.seagrant.umn.edu/pubs/freeorder.html — Minnesota Sea Grant exotic 

species publications

http://contaminants.fws.gov/Issues/InvasiveSpecies.cfm — FWS Division of 

Environmental Quality Invasive Species webpage

http://www.entryway.com/seagrant —National Aquatic Nuisance Species 

Clearinghouse

http://www.nps.gov/plants/alien/index.htm — Plant Conservation Alliance's Alien 

Plant Working Group—additional information on invasive plants (including specific 

species)

http://www.weedcenter.org —Center for Invasive Plant Management

Images

http://www.northeastans.org/imagelinks.htm — Northeast ANS Panel—links to plant 

& animal ANS images

Government Publications Available on the Internet

http://www.wws.princeton.edu/~ota/disk1/1993/9325_n.html - U.S. Congress, Office 

of Technology Assessment. Harmful Non-Indigenous Species in the United States. 

OTA-F-565 (Washington, DC: U.S. Government Printing Office, September 1993).

http://www.cnie.org/nle/biodv-26.html - Corn, L., et al. Harmful Non-Native Species: 

Issues for Congress. CRS Issue Brief for Congress. The National Council for Science 

and the Environment.

http://www.denix.osd.mil/denix/Public/ES-Programs/Conservation/Invasive/intro.h

tml - Westbrooks, R. Invasive Plants, Changing the Landscape of America: Fact Book. 

Washington, DC: Federal Interagency Committee for the Management of Noxious and 

Exotic Weeds (FICMNEW), 1998.

Books and Publications

ASTM E2590 - 09 Standard Guide for Conducting Hazard Analysis-Critical

Control Point (HACCP) Evaluations. ASTM International, West Conshohocken,

PA. 2008. DOI: 10.1520/E2590-09. www.astm.org.

Bright, C. and L. Starke. 1998. Life out of bounds: bioinvasion in a borderless

world. Worldwatch Institute. W.W. Norton and Company, New York, NY.

ISBN: 0393318141. 
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Burgman, M., Risks and Decisions for Conservation and Environmental

Management, Cambridge University Press, Cambridge, UK, 2005.

Cox, G.W. 1999 Alien species in North America and Hawaii: impacts on natural

ecosystems. Island Press. ISBN: 1-55963-680-7.

Devine, R.S. 1998. Alien invasion: America’s battle with non-native animals and

plants. National Geographic Society. ISBN: 0792274490.

Dillon, M. and Griffith, C., How to HACCP, 2nd Edition, MD. Associates, Grimsby,

UK, 1996.

Fuller, P.L., L.G. Nico, and J.D. Williams. 1999. Nonindigenous fishes

introduced into inland waters of the United States. American Fisheries Society,

Special Publication 27, Bethesda, MD.

Mooney, H.A., and R.J. Hobbs. 2000. Invasive species in a changing world. 

Island Press. ISBN: 1555963782X.

Minnesota Sea Grant/Michigan Sea Grant, ―Hazard Analysis and Critical Control

Point Analysis,‖ MN SG-F11/MSG-00-400. University of Minnesota, Duluth, MN,

2001.

Simberloff et al. 1997. Strangers in paradise: impact and management of non

indigenous species in Florida. Island Press. ISBN: 1559634308.

Van Driesche, J., and R. Van Driesche. 2000. Nature out of place: biological

invasions in the global age. Island Press. ISBN: 1559637579.

Walters, C., Adaptive Management of Renewable Resources, 1986, republished 

by The Blackburn Press, Caldwell, NJ, 2001.

Williamson, M. 1996. Biological invasions. Chapman and Hall. ISBN:

0412591901.

World Health Organization (WHO), ―HACCP: Introducing the Hazard Analysis Critical 

Control Point System,‖ Document WHO/FSF/FOS, 1997.

Videos

MN Sea Grant video. ―Stop Exotics, Clean Your Boat.‖

MN Sea Grant video. ―From Net to Sale: Controlling ANS with the HACCP Approach for 

Baitfish and Aquaculture Industries‖

Information Television Videos:

 ―Aquatic Invaders‖

 ―Plants Out of Place‖
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SUGGESTED REFERENCES FOR CONTROL MEASURES

General Guidelines

Alien Invasive Species: A Toolkit of Best Prevention and Management Practices 

Wittenberg, R., Cock, M.J.W. (eds.) 2001. Invasive Alien Species: A Toolkit of Best Prevention and 

Management Practices. CAB International, Wallingford, Oxon, UK, xvii - 228. Available online at: 

http://www.gisp.org/publications/toolkit/Toolkiteng.pdf 

This document includes an introductory material, methods for prevention of invasive species, riskanalysis, and early detection.

Assessing and Managing Invasive Species within Protected Areas 

Tu, M. 2009. Assessing and Managing Invasive Species within Protected Areas. Protected Area Quick 

Guide Series. Editor, J. Ervin. Arlington, VA. The Nature Conservancy. 40 pp. Available online at: 

http://www.cbd.int/invasive/doc/ias-tnc-guide-2009-en.pdf 

This guide provides protected area managers with guidance on how to create a comprehensive 

assessment and strategic plan for invasive species.

Biotic Invasions: Causes, Epidemiology, Global Consequences and Control 

Ecological Society of America. 2000. Biotic Invasions: Causes, Epidemiology, Global Consequences and 

Control. Issues in Ecology 5. Available online at: http://www.esa.org/science/Issues/FileEnglish/issue5.pdf 

A scientific literature review that evaluated the impacts of invasive species as well as methods used to 

identify future invaders and take effective steps to prevent their dispersal and establishment. 

Invasive Free Zone Guidebook 

McNamara D. 2007. Invasive Free Zone Guidebook. U.S. Fish and Wildlife Service, Whittlesey Creek 

National Wildlife Refuge. 40pp. 

Available online at: http://www.fws.gov/midwest/whittleseycreek/documents/IFZGuidebook.pdf 

Whittlesey Creek National Wildlife Refuge, U.S. Fish and Wildlife Service. This guidebook provides 

recommendations, information, and insights for creating an Invasive Free Zone; a useful reference for 

anyone working to control invasive species, especially on a large scale.

Inspection and Cleaning Manual for Equipment and Vehicles to Prevent the 

Spread of Invasive Species 

U.S. Department of the Interior Bureau of Reclamation. 2009. Technical Memorandum No. 86-68220-07-

05. 203 pp. Available online at: 

http://www.usbr.gov/pps/EquipmentInspectionandCleaningManual_Sept09.pdf 

This manual provides recommendations for inspection and cleaning of vehicles and equipment as a 

prevention tool to limit the spread of invasive species. 

NOAA Restoration Center Invasive Species BMP’s

Available Online at: http://www.habitat.noaa.gov/restoration/programs/invasivespecies.html

This website provides technical guidance bulletins for the prevention and control of invasive species. 

Transfer of Invasive Species Associated with the Movement of Military Equipment 

and Personnel. 

Cofrancesco, Jr. AF., Reaves DR. Averett DE. July 2007. Army Corp of Engineers, Engineer Research 

and Development Center. ERDC/EL TR-07-8. Washington D.C., 126 pp. 

Available online at: http://el.erdc.usace.army.mil/elpubs/pdf/trel07-8.pdf 

This document provides an overview of the current process that exists to clean, inspect, and regulate the 

movement of invasive species through ports of embarkation and debarkation.
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Decontamination for Watercraft and Aquatic Equipment

Maine’s Safety Net - A Practical Guide to Building Wash Stations 

Friends of the Cobbossee Watershed and Lakes Environmental Association. March 2006.28 pp. 

Available online at: http://www.watershedfriends.com/L.%20L.%20Bean%20handbook.pdf 

This handbook has been designed to assist those organizations and citizens in building Boat Wash 

Stations. 

Preventing Accidental Introductions of Freshwater Invasive Species 

U.S. Department of Agriculture, Forest Service. Available online at: 

http://www.fs.fed.us/invasivespecies/documents/Aquatic_is_prevention.pdf 

This document provides standard sterilization techniques that are effective against New Zealand 

mudsnail, Whirling disease, and Chytrid Fungus. 

Preventing Spread of Aquatic Invasive Organisms Common to the Intermountain 

Region

U.S. Department of Agriculture, Forest Service. Available online at:

http://www.fs.fed.us/r4/resources/aquatic/guidelines/aq_invasives_interim_fire_guidance08_final.pdf

This document provides guidelines for forestry personnel to avoid the spread of aquatic invasive species. 

Protect Your Waters 

Aquatic Nuisance Species Task Force. Available online at: http://protectyourwaters.org 

This site provides recommendations for recreational users who want to help prevent the spread aquatic 

nuisance species. 

Zebra / Quagga Mussel Prevention and Control

Invasive Mussel Guidebook for Recreational Water Managers and Users: 

Strategies for Local Involvement. 

California Resources Agency. October 2008. Available online at: 

http://www.resources.ca.gov/quagga/docs/QUAGGA_GUIDEBOOK.pdf 

Information presented in this guidebook deals exclusively with prevention and containment of invasive mussels. 

Protect Your Boat, Fight Quagga and Zebra Mussels A Guide to Cleaning Boats 

California Department of Fish and Game. October 2009. Available online at: 

http://www.nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=4957 

This guide was compiled specifically for boat owners and watercraft users. The information contains 

general guidelines for all boaters and a basic checklist for inspecting and cleaning boats and recreational 

equipment for Quagga/Zebra mussels 

Protect Your Boat and Engine from Zebra Mussels 

Wisconsin Department of Natural Resources. 

Available online at: http://dnr.wi.gov/invasives/publications/pdfs/protectyourboat.pdf 

This document describes simple and proactive steps boat owners may implement to protect their 

investment and prevent the spread of invasive species into more of Wisconsin’s waters. 

Quagga / Zebra Mussel Infestation Prevention and Response Planning Guide 

National Park Service, Natural Resources Program Center, Fort Collins, Colorado. May 2007. 43 pp. 

Available online at: http://www.nature.nps.gov/water/quagga/QuaggaPlanningGuide_ext.pdf 

This plan serves as a guiding document for park managers to provide for the prevention, early detection, 

and rapid response to quagga mussel infestations in western waters. 
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Rapid Response Plan for Zebra Mussels in the Columbia River Basin: A 

Comprehensive Multi-Agency Strategy to Expeditiously Guide Rapid Response 

Activities. 

Heimowitz P., Phillips S. 2006. 100th Meridian Initiative.42 pp. 

Available online at: http://www.100thmeridian.org/ActionTeams/Columbia/CRB_ZMRR_090106.pdf 

The goal of the plan is to serve as a roadmap to guide rapid response following the detection of zebra 

mussels.

http://www.100thmeridian.org - 100th Meridian Initiative; National website on zebra mussel 

prevention. The website provides tips on decontaminating boats and other gear. 

Decontamination for Land Vehicles, Equipment, and Personal Gear

Comparison of Relocatable Commercial Vehicle Washing Systems 

Fleming J. September 2008. U.S. Department of Agriculture, Forest Service San Dimas Technology & 

Development Center. 0851 1809 - SDTDC. 36 pp. 

Available online at: http://www.weedcenter.org/management/docs/09_VehicleWashingSystemReport.pdf 

This report compares a range of vehicle washing systems with respect to efficacy, economics, waste 

containment, waste disposal, and the viability of any propagules that were collected in the cleaning 

process. 

National Cooperative Highway Research Program (NCHRP) Synthesis 363: 

Control of Invasive Species. 

The Transportation Research Board of the National Academies. 2006. Transportation Research Board, 

Washington D.C. 126 pp. 

Available online at: http://onlinepubs.trb.org/onlinepubs/nchrp/nchrp_syn_363.pdf 

The report explores the extent to which the state departments of transportation are prevent and 

controlling invasive species, restoring habitats, and conducting research. Successful practices and 

documented as well as lessons learned. 

Invasive Species Best Management Practices for Transportation and Utility 

Rights-of-Way 

Wisconsin Council on Forestry. January 2010. 63 pp. 

Available online at: http://council.wisconsinforestry.org/invasives/transportation/pdf/ROW-Manual.pdf 

The guidelines in this manual apply to utility and transportation corridor construction and maintenance 

activities. 

Wisconsin’s Forestry BMPs for Invasive Species. A Field manual for Foresters, 

Landowners, and Loggers 

Wisconsin Council on Forestry. March 2009. 56 pp. 

Available online at: http://council.wisconsinforestry.org/invasives/pdf/FinalForestryBMPManual_03-26-

09.pdf 

This document provides information on prevention, control, and monitoring of priority species in forested 

landscapes. 

Wisconsin’s Urban Forestry BMPs for Preventing the Introduction and Spread of 

Invasive Species 

Wisconsin Council on Forestry. August 2009, 102 pp. 

Available online at: http://council.wisconsinforestry.org/invasives/pdf/UF-BMPConsolidatedManual_090811.pdf 
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This document provides information on prevention, control, and monitoring of priority species in urban 

forests.

Weed Prevention and Control

Guide of Noxious Weed Prevention Practices 

U.S. Department of Agriculture, Forest Service. July 2001. 25 pp. 

Available online at: 

http://www.fs.fed.us/rangelands/ftp/invasives/documents/GuidetoNoxWeedPrevPractices_07052001.pdf 

This document provides a comprehensive directory of weed prevention practices for use in Forest Service 

planning and wildland resource management activities and operations. 

Invasive Plant Prevention Guidelines 

Center for Invasive Plant Management. September 2003. Compiled by J. Clark, Bozemon, MT. 15 pp. 

Available online at: http://www.weedcenter.org/store/docs/CIPM_prevention.pdf 

This document provides guidelines for prevention and for developing weed management areas. 

Invasive Plant Prevention 

U.S. Department of Agriculture, Forest Service. 2002. Invasive Plant Management: CIPM Online 

Textbook. Chapter 10 Invasive Plant Prevention; Adapted from USDA Forest Service Guide to Noxious 

Weed Prevention Practices. Available online at: http://www.weedcenter.org/textbook/10_prevention.html 

This guide provides practical, proactive weed-prevention guidelines. 

Manager's Guide to Roadside Revegetation Using Native Plants 

Steinfeld DE., Riley SA., Wilkinson KM., Landis TD.,Riley LE. 2007. U.S. Department of Transportation. 

Report # FHWA-WFL/TD-07-006. 28 pp. 

Available online at: http://www.nativerevegetation.org/learn 

This guide summarizes an approach to effectively revegetate roadsides and other disturbance areas 

associated with road construction, modification, or obliteration.

Roadside Revegetation: An Integrated Approach to Establishing Native Plants 

Steinfeld DE., Riley SA., Wilkinson KM., Landis TD.,Riley LE. 2007. U.S. Department of Transportation. 

Report # FHWA-WFL/TD-07-005. 423 pp. 

Available online at: http://www.nativerevegetation.org/learn 

This report offers an integrated approach to facilitate the successful establishment of native plants along 

roadsides and other areas of disturbance associated with road modifications
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Executive Order 13112

Federal Register: Feb 8, 1999 (Volume 64, Number 25)

By the authority vested in me as President by the Constitution and the laws of the 

United States of America, including the National Environmental Policy Act of 1969, as 

amended (42 U.S.C. 4321 et seq.), Nonindigenous Aquatic Nuisance Prevention and 

Control Act of 1990, as amended (16 U.S.C. 4701 et seq.), Lacey Act, as amended (18 

U.S.C. 42), Federal Plant Pest Act (7 U.S.C. 150aa et seq.), Federal Noxious Weed Act 

of 1974, as amended (7 U.S.C. 2801 et seq.), Endangered Species Act of 1973, as 

amended (16 U.S.C. 1531 et seq.), and other pertinent statutes, to prevent the 

introduction of invasive species and provide for their control and to minimize the 

economic, ecological, and human health impacts that invasive species cause, it is 

ordered as follows:

Section 1. Definitions

Section 2. Federal Agency Duties

Section 3. Invasive Species Council

Section 4. Duties of the Invasive Species Council

Section 5. Invasive Species Management Plan

Section 6. Judicial Review and Administration

Section 1. Definitions.

(a) "Alien species" means, with respect to a particular ecosystem, any species, 

including its seeds, eggs, spores, or other biological material capable of propagating 

that species, that is not native to that ecosystem.

(b) "Control" means, as appropriate, eradicating, suppressing, reducing, or managing 

invasive species populations, preventing spread of invasive species from areas where 

they are present, and taking steps such as restoration of native species and habitats to 

reduce the effects of invasive species and to prevent further invasions.

(c) "Ecosystem" means the complex of a community of organisms and its environment.

(d) "Federal agency" means an executive department or agency, but does not include 

independent establishments as defined by 5 U.S.C. 104.

(e) "Introduction" means the intentional or unintentional escape, release, dissemination, 

or placement of a species into an ecosystem as a result of human activity.

(f) "Invasive species" means an alien species whose introduction does or is likely to 

cause economic or environmental harm or harm to human health.

(g) "Native species" means, with respect to a particular ecosystem, a species that, other 

than as a result of an introduction, historically occurred or currently occurs in that 

ecosystem.
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(h) "Species" means a group of organisms all of which have a high degree of physical 

and genetic similarity, generally interbreed only among themselves, and show persistent 

differences from members of allied groups of organisms.

(i) "Stakeholders" means, but is not limited to, State, tribal, and local government 

agencies, academic institutions, the scientific community, nongovernmental entities 

including environmental, agricultural, and conservation organizations, trade groups, 

commercial interests, and private landowners.

(j) "United States" means the 50 States, the District of Columbia, Puerto Rico, Guam, 

and all possessions, territories, and the territorial sea of the United States.

Section 2. Federal Agency Duties.

(a) Each Federal agency whose actions may affect the status of invasive species shall, 

to the extent practicable and permitted by law,

(1) identify such actions;

(2) subject to the availability of appropriations, and within Administration budgetary 

limits, use relevant programs and authorities to: (i) prevent the introduction of invasive 

species; (ii) detect and respond rapidly to and control populations of such species in a 

cost-effective and environmentally sound manner; (iii) monitor invasive species 

populations accurately and reliably; (iv) provide for restoration of native species and 

habitat conditions in ecosystems that have been invaded; (v) conduct research on 

invasive species and develop technologies to prevent introduction and provide for 

environmentally sound control of invasive species; and (vi) promote public education on 

invasive species and the means to address them; and

(3) not authorize, fund, or carry out actions that it believes are likely to cause or promote 

the introduction or spread of invasive species in the United States or elsewhere unless, 

pursuant to guidelines that it has prescribed, the agency has determined and made 

public its determination that the benefits of such actions clearly outweigh the potential 

harm caused by invasive species; and that all feasible and prudent measures to 

minimize risk of harm will be taken in conjunction with the actions.

(b) Federal agencies shall pursue the duties set forth in this section in consultation with 

the Invasive Species Council, consistent with the Invasive Species Management Plan 

and in cooperation with stakeholders, as appropriate, and, as approved by the 

Department of State, when Federal agencies are working with international 

organizations and foreign nations.

Section 3. Invasive Species Council.

(a) An Invasive Species Council (Council) is hereby established whose members shall 

include the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, 
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the Secretary of the Interior, the Secretary of Agriculture, the Secretary of Commerce, 

the Secretary of Transportation, and the Administrator of the Environmental Protection 

Agency. The Council shall be Co-Chaired by the Secretary of the Interior, the Secretary 

of Agriculture, and the Secretary of Commerce. The Council may invite additional 

Federal agency representatives to be members, including representatives from 

subcabinet bureaus or offices with significant responsibilities concerning invasive 

species, and may prescribe special procedures for their participation. The Secretary of 

the Interior shall, with concurrence of the Co-Chairs, appoint an Executive Director of 

the Council and shall provide the staff and administrative support for the Council. (b) 

The Secretary of the Interior shall establish an advisory committee under the Federal 

Advisory Committee Act, 5 U.S.C. App., to provide information and advice for 

consideration by the Council, and shall, after consultation with other members of the 

Council, appoint members of the advisory committee representing stakeholders. Among 

other things, the advisory committee shall recommend plans and actions at local, tribal, 

State, regional, and ecosystem-based levels to achieve the goals and objectives of the 

Management Plan in section 5 of this order. The advisory committee shall act in 

cooperation with stakeholders and existing organizations addressing invasive species. 

The Department of the Interior shall provide the administrative and financial support for 

the advisory committee.

Section 4. Duties of the Invasive Species Council.

The Invasive Species Council shall provide national leadership regarding invasive 

species, and shall:

(a) oversee the implementation of this order and see that the Federal agency activities 

concerning invasive species are coordinated, complementary, cost-efficient, and 

effective, relying to the extent feasible and appropriate on existing organizations 

addressing invasive species, such as the Aquatic Nuisance Species Task Force, the 

Federal Interagency Committee for the Management of Noxious and Exotic Weeds, and 

the Committee on Environment and Natural Resources;

(b) encourage planning and action at local, tribal, State, regional, and ecosystem-based 

levels to achieve the goals and objectives of the Management Plan in section 5 of this 

order, in cooperation with stakeholders and existing organizations addressing invasive 

species;

(c) develop recommendations for international cooperation in addressing invasive 

species;

(d) develop, in consultation with the Council on Environmental Quality, guidance to 

Federal agencies pursuant to the National Environmental Policy Act on prevention and 

control of invasive species, including the procurement, use, and maintenance of native 

species as they affect invasive species;
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(e) facilitate development of a coordinated network among Federal agencies to 

document, evaluate, and monitor impacts from invasive species on the economy, the 

environment, and human health;

(f) facilitate establishment of a coordinated, up-to-date information-sharing system that 

utilizes, to the greatest extent practicable, the Internet; this system shall facilitate access 

to and exchange of information concerning invasive species, including, but not limited 

to, information on distribution and abundance of invasive species; life histories of such 

species and invasive characteristics; economic, environmental, and human health 

impacts; management techniques, and laws and programs for management, research, 

and public education; and

(g) prepare and issue a national Invasive Species Management Plan as set forth in 

section 5 of this order.

Section 5. Invasive Species Management Plan.

(a) Within 18 months after issuance of this order, the Council shall prepare and issue 

the first edition of a National Invasive Species Management Plan (Management Plan), 

which shall detail and recommend performance-oriented goals and objectives and 

specific measures of success for Federal agency efforts concerning invasive species. 

The Management Plan shall recommend specific objectives and measures for carrying 

out each of the Federal agency duties established in section 2(a) of this order and shall 

set forth steps to be taken by the Council to carry out the duties assigned to it under 

section 4 of this order. The Management Plan shall be developed through a public

process and in consultation with Federal agencies and stakeholders.

(b) The first edition of the Management Plan shall include a review of existing and 

prospective approaches and authorities for preventing the introduction and spread of 

invasive species, including those for identifying pathways by which invasive species are 

introduced and for minimizing the risk of introductions via those pathways, and shall 

identify research needs and recommend measures to minimize the risk that 

introductions will occur. Such recommended measures shall provide for a sciencebased process to evaluate risks associated with introduction and spread of invasive 

species and a coordinated and systematic risk-based process to identify, monitor, and 

interdict pathways that may be involved in the introduction of invasive species. If 

recommended measures are not authorized by current law, the Council shall develop 

and recommend to the President through its Co-Chairs legislative proposals for 

necessary changes in authority.

(c) The Council shall update the Management Plan biennially and shall concurrently 

evaluate and report on success in achieving the goals and objectives set forth in the 

Management Plan. The Management Plan shall identify the personnel, other resources, 

and additional levels of coordination needed to achieve the Management Plan's 

identified goals and objectives, and the Council shall provide each edition of the 

Management Plan and each report on it to the Office of Management and Budget. 
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Within 18 months after measures have been recommended by the Council in any 

edition of the Management Plan, each Federal agency whose action is required to 

implement such measures shall either take the action recommended or shall provide the 

Council with an explanation of why the action is not feasible. The Council shall assess 

the effectiveness of this order no less than once each 5 years after the order is issued 

and shall report to the Office of Management and Budget on whether the order should 

be revised.

Section 6. Judicial Review and Administration.

(a) This order is intended only to improve the internal management of the executive 

branch and is not intended to create any right, benefit, or trust responsibility, substantive 

or procedural, enforceable at law or equity by a party against the United States, its 

agencies, its officers, or any other person.

(b) Executive Order 11987 of May 24, 1977, is hereby revoked.

(c) The requirements of this order do not affect the obligations of Federal agencies 

under 16 U.S.C. 4713 with respect to ballast water programs.

(d) The requirements of section 2(a)(3) of this order shall not apply to any action of the 

Department of State or Department of Defense if the Secretary of State or the Secretary 

of Defense finds that exemption from such requirements is necessary for foreign policy 

or national security reasons.

WILLIAM J. CLINTON

THE WHITE HOUSE,

February 3, 1999.
Appendix A – Blank HACCP Forms

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Appendix A - Blank HACCP Forms

HACCP Step 1 – Activity Description

Management Objective & Contact Information

HACCP Plan Title

Management Objective: Contact Person:

Phone:

Email:

Activity Description

i.e. Who; What; Where; When; How; Why
Appendix A – Blank HACCP Forms

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HACCP Step 2 – Activity Flow Chart

Outline Sequential Tasks of Activity

Task 1

Title:

Description:

Task 2

Title:

Description:

Task 3

Title:

Description:

Task 4

Title:

Description:

Task 5

Title:

Description:
Appendix A – Blank HACCP Forms

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HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

Invertebrates:

Plants:

Other Organisms (pathogens, parasites, etc.):
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HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to reduce the risk 

of non-targets?

CCP?

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6 

Task #

Title:

Vertebrates

Invertebrates

Plants

Others

Task #

Title:

Vertebrates

Invertebrates

Plants

Others

Additional copies of this worksheet may be necessary, depending on how many tasks 

are required by your activity. Typical HACCP plans have between four and ten tasks.
Appendix A – Blank HACCP Forms

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HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1

Critical Control Point: 

Task #

Title:

Significant Non-Target(s)

(Step 4, Column 3)

Control Measure(s)

(Step 4, Column 5)

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Monitoring the

Control Measure(s) Who?

How?

Where?

How often?

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Development Team Members

Date Developed: Date(s) Reviewed:

* all gray fields are required

Additional copies of this worksheet may be necessary, depending on how many Critical 

Control Points are found in your activity. Typical HACCP plans have one or two CCPs.
Appendix B – Example HACCP Forms (completed)

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Appendix B - Example HACCP Forms (completed)

Hypothetical Example HACCP Plan

This example is based on riparian habitat surveys, a specific activity conducted by the 

fictitious Cutthroat Trout National Fish Hatchery. Staff members of this facility measure 

riparian vegetation densities within the Thompson River Basin once a month throughout 

the year. The purpose of the surveys is to gather data and information on riparian 

habitat to guide cutthroat trout recovery actions within the Thompson River Basin.

Specialized survey gear is stored, while not in use, in a warehouse on Hatchery 

property. Surveys are begun by first retrieving necessary gear from the warehouse at 

the beginning of the day. Once loaded into a pickup truck, staff members travel with the 

gear to the sampling site chosen for the day. After the gear is unloaded, the staff 

conducts the sampling activity using the appropriate gear. At the end of the day, staff 

members return the gear to the truck, load it, and then return to warehouse. The gear is 

then unloaded and put away until needed for the next survey. Within the Thompson 

Basin, several potential invasive species, parasites or diseases have been determined 

to be of significant concern. These include bullfrogs (Rana catesbeiana), New Zealand 

mud snails (Potamopyrgus antipodarum), Eurasian milfoil (Myriophyllum spicatum), 

purple loosestrife (Lythrum salicaria), Chytrid fungus, and whirling disease (Myxobolus 

cerebralis).

On the following pages is a completed HACCP plan that covers the activity described 

above.
Appendix B – Example HACCP Forms (completed)

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HACCP Step 1 – Activity Description

Management Objective & Contact Information

Title: Hypothetical HACCP Plan

Management Objective:

Habitat survey for the recovery of cutthroat 

trout (CT)

Contact Person: Jonathan Thompson

Phone: (800) LUV-FISH

Email: jonathan_thompson@fws.gov

Activity Description

i.e. Who; What; Where; When; How; Why

Who: Cutthroat Trout National Fish Hatchery personnel

What: Measurement of Riparian Vegetation Density

Where: Thompson River Basin

When: Year-round, once a month

How: Retrieve the appropriate gear from a warehouse at the beginning of 

the day. Travel to the sampling site and conduct the sampling activity. 

Return to the warehouse. Gear is unloaded and stored.

Why: To gather data and information on riparian habitat to guide cutthroat 

trout recover actions
Appendix B – Example HACCP Forms (completed)

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HACCP Step 2 – Activity Flow Chart

Outline Sequential Tasks of Activity

Task 1

Title: Load Gear and Drive to site

Description: Drive to warehouse and load appropriate gear for sampling 

activity. Drive to sampling site.

Task 2

Title: Unload gear and conduct survey

Description: Unload gear from vehicle. Prepare gear to conduct 

sampling. Conduct survey.

Task 3

Title: Reload gear

Description: Return to vehicle and l pack up gear.

Task 4

Title: Return to warehouse and unload gear.

Description: Return to the warehouse in vehicle with gear. Put 

equipment away to store for next use.
Appendix B – Example HACCP Forms (completed)

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HACCP Step 3 – Identify Potential Non-Targets

Non-Targets That May Potentially Be Moved/Introduced

Vertebrates:

 Amphibians

 Bullfrog (Rana catesbeiana)

Invertebrates:

 New Zealand Mudsnail (Potamopyrgus antipodarum)

Plants:

 Eurasian milfoil (Myriophyllum spicatum)

 Purple loosestrife (Lythrum salicaria)

Other Organisms (pathogens, parasites, etc.):

 Chytrid fungus

 Whirling disease (Myxobolus cerebralis)
Appendix B – Example HACCP Forms (completed)

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HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to stop the spread 

of non-targets?

CCP? 

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6

Task #1

Title:

Load gear 

and drive to 

site

Vertebrates

Amphibians, 

including 

bullfrogs

No

Risk is low 

because all 

equipment was 

cleaned and 

disinfected 

following prior use

N/A No

There are no 

significant nontargets during 

this task.

Invertebrates

NZMS No N/A No

Plants

Eurasian milfoil

Purple 

loosestrife

No N/A No

Others

Chytrid fungus

Whirling 

disease

No N/A No

Task #2

Title:

Unload gear 

and conduct 

sampling

Vertebrates

Amphibians, 

including 

bullfrogs No

Risk is low 

because sampling 

occurs only at one 

location, plus all 

equipment was 

cleaned and 

disinfected before 

storage

N/A No

There are no 

significant nontargets during 

this task.

Invertebrates

NZMS No N/A No

Plants

Eurasian milfoil

Purple 

loosestrife

No N/A No

Others

Chytrid fungus

Whirling 

disease

No N/A No
Appendix B – Example HACCP Forms (completed)

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HACCP Step 4 – Non-Target Analysis Worksheet

1 2 3 4 5 6 7

Tasks

(From Step 2)

Potential 

Non-targets

(From Step 3)

Risk Assessment

Are any nontargets significant?

Yes or No

Justification

Justify your 

answer in 

Column 3

Control

What control 

measures can be 

applied during this 

task to stop the spread 

of non-targets?

CCP? 

Is this 

task a 

CCP?

Yes or 

No

Justification

Justify your 

answer in 

Column 6

Task #3

Title:

Reload gear

Vertebrates

Amphibians, 

including 

bullfrogs

Yes

High risk that 

bullfrog eggs or 

adults may be in 

gear after 

sampling

Visually inspect all 

gear for non-targets 

and remove anything 

found by hand before 

proceeding to Task #4

No

Hand removal, 

cleaning, and 

disinfecting 

would be better 

accomplished in 

Task #4 at a 

decontamination 

station back at 

the warehouse.

Invertebrates

NZMS

Yes

High risk that 

invertebrates 

could be in gear 

after sampling

No

Plants

Eurasian milfoil

Purple 

loosestrife Yes

High risk that 

plants or seeds 

could be attached

to gear after 

sampling

No

Others

Chytrid fungus

Whirling 

disease

Yes

High risk that 

unwanted 

organisms could 

survive on gear

No

Task #4

Title:

Return to 

warehouse 

and unload 

gear

Vertebrates

Amphibians, 

including 

bullfrogs Yes

High risk that

bullfrog eggs or 

adults may be in 

gear after 

sampling

Remove any 

vertebrates then clean 

and disinfect all 

equipment using 

approved disinfectant 

solution to kill eggs.

Yes

If the equipment 

is not 

decontaminated 

during this task, 

then it will not be 

clean for use 

next time it is 

needed. This 

task is the point 

of no return.

Invertebrates

NZMS

Yes

High risk that 

invertebrates 

could be in gear 

after sampling

Clean and disinfect all 

equipment using 

approved disinfectant 

solution.

Yes

Plants

Eurasian milfoil

Purple 

loosestrife

Yes

High risk that 

plants or seeds 

could be attached 

to gear after 

sampling

Clean and disinfect all 

equipment using 

approved disinfectant 

solution and rinse 

undercarriage of 

vehicles with highpressure water spray.

Yes

Others

Chytrid fungus

Whirling 

disease Yes

High risk that 

unwanted 

organisms could 

survive on gear

Clean and disinfect all 

equipment using 

approved disinfectant 

solution.

Yes
Appendix B – Example HACCP Forms (completed)

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HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1 Habitat Survey for the Recovery of Cutthroat Trout (CT)

Critical Control Point: 

Task #

4 Title: Return to warehouse and unload gear

Significant Non-Target(s)

(Step 4, Column 3)

Vertebrates, Invertebrates, Plants, and Other Organisms 

(All listed in step 3)

Control Measure(s)

(Step 4, Column 5)

Clean and disinfect all equipment using approved disinfectant 

solution

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Use disinfectant solution that contains quaternary ammonium 

mixed at a concentration of at least 1% but no more than 3%. 

Contact time with gear must be at least 10 minutes.

Monitoring the

Control Measure(s) Who? Hatchery staff

How? Check immersion time with timer. Ensure concentration is correct 

with AQA1507 Quaternary Ammonium Test Kit (or similar)

Where? Decontamination station at the warehouse

How often? Every time that gear is unloaded and stored

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Mix new (fresh) dosage of disinfectant solution and repeat the 

cleaning/disinfectant procedure from the beginning. If gear cannot 

be disinfected, it must be clearly tagged as "contaminated" and 

isolated until it can be disinfected before being allowed back in 

the field.

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Logan River Sampling Protocol, Louanne River Sampling Protocol, Quaternary Ammonium Disinfectant 

Information Sheet, Nevada Noxious Weed List, California Noxious Weed List

Development Team Members Jonathan Thompson, Ronald Smith, Louanne McMartin

Date Developed: 7/29/2010 Date(s) Reviewed: Not yet reviewed

* all gray fields are required
Appendix B – Example HACCP Forms (completed)

HACCP Planning to Prevent the Spread of Invasive Species

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June 2011 82 USFWS-NCTC

HACCP Step 5 – Non-Target Risk Action Plan (NTRAP)

(Use this form for any "Yes" from Column 6 of HACCP Step 4 - Non-Target Analysis Worksheet)

One page for each Critical Control Point

Mangement Objective

From Step 1 Habitat Survey for the Recovery of Cutthroat Trout (CT)

Critical Control Point: 

Task #

4 Title: Return to warehouse and unload gear

Significant Non-Target(s)

(Step 4, Column 3) Vertebrates (Bullfrogs)

Control Measure(s)

(Step 4, Column 5) Visually inspect gear and remove all visible adult bullfrogs

Precribed ranges, limits, or citeria 

for control measure(s):

(PRLC)

Check all exposed areas at least twice until no visible adult 

bullfrogs remain.

Monitoring the

Control Measure(s) Who? Field crew supervisor

How? Visual observation

Where? Decontamination station at the warehouse

How often? Every time that gear is unloaded and stored

Corrective Action(s) 

if Control Measures Fail 

(or PRLC cannot be met)

Have another staff member repeat the control measure.

Supporting Documents

(For example, Management Plan, Checklist, Decontamination Techniques, SOPs, Scientific Journal Articles, etc.)

Logan River Sampling Protocol, Louanne River Sampling Protocol, Quaternary Ammonium Disinfectant 

Information Sheet, Nevada Noxious Weed List, California Noxious Weed List

Development Team Members Jonathan Thompson, Ronald Smith, Louanne McMartin

Date Developed: 7/29/2010 Date(s) Reviewed: Not yet reviewed

* all gray fields are required
Appendix C – Risk Assessment Diagrams

HACCP Planning to Prevent the Spread of Invasive Species

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June 2011 83 USFWS-NCTC

Appendix C - Risk Assessment Diagrams
Appendix C – Risk Assessment Diagrams

HACCP Planning to Prevent the Spread of Invasive Species

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June 2011 84 USFWS-NCTC
Appendix C – Risk Assessment Diagrams

HACCP Planning to Prevent the Spread of Invasive Species

____________________________________________________

June 2011 85 USFWS-NCTC
Appendix D – Critical Control Point Decision Tree

HACCP Planning to Prevent the Spread of Invasive Species

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June 2011 86 USFWS-NCTC

Appendix D – Critical Control Point Decision Tree