Determining critical control points (CCPs) with the decision tree
A critical control point (CCP) is a step in your process where you must control a significant hazard, because nothing later will remove or reduce it. The CCP decision tree is a set of four questions that you answer for each step to decide whether that step is a CCP. It is principle 2 of the 7 HACCP principles.
The decision tree on this page follows the version in the Codex text General Principles of Food Hygiene (CXC 1-1969), revised in 2022. The FAO recommends it as a tool. It is not mandatory. The NVWA (Dutch Food and Consumer Product Safety Authority) checks whether your CCPs are logical and justified. It does not check which method you used.
You only use the decision tree for hazards that your hazard analysis identified as significant. Hazards that ordinary hygiene covers do not need to go through it.
The four questions of the CCP decision tree
You go through the questions for each process step and for each significant hazard. The answer decides whether you continue or stop.
| Question | Yes | No |
|---|---|---|
| Q1. Can the hazard at this step be controlled to an acceptable level with prerequisite programmes (good hygiene practices)? | No CCP | Go to Q2 |
| Q2. Are there specific control measures for this hazard at this step? | Go to Q3 | No CCP. Check whether a later step is a CCP |
| Q3. Will a later step prevent, eliminate or reduce the hazard to an acceptable level? | That later step becomes the CCP | Go to Q4 |
| Q4. Can this step specifically prevent, eliminate or reduce the hazard to an acceptable level? | This step is a CCP | Change the step, the process or the product |
If you find no CCP at questions 2 to 4 for a significant hazard, your process is not right. Change the process or product, carry out a new hazard analysis, and start again at the top.
Question 1: are prerequisite programmes enough?
Prerequisite programmes are the general hygiene rules, such as cleaning, handwashing and separate storage. The Codex calls them good hygiene practices (GHPs). Some of them need extra attention, for example a fixed measurement and recording, but they remain prerequisite programmes.
Example: cross-contamination between raw meat and salad. With separate chopping boards and a fixed working order, you keep that hazard under control. The answer is yes, so there is no CCP.
Question 2: is there a specific measure at this step?
A specific measure targets this one hazard at this one step. Think of cooking, chilling, a metal detector or an allergen check on the label.
Example: bacteria in raw chicken at the “receiving” step. You cannot kill the bacteria at that step. The answer is no: this step is not a CCP, and you look at a later step.
Question 3: does a later step deal with it?
This question prevents you from creating too many CCPs. If a later step removes the hazard anyway, that later step is the CCP.
Example: a small overshoot of the cooling temperature while marinating chicken. The meat is then cooked through. For bacteria that cooking kills, the cooking step is the CCP. Note that this does not apply to toxins that bacteria produce and that survive heat.
Question 4: does this step control the hazard specifically?
If the answer is yes, the step is a CCP. You give it a number and include it in your HACCP plan, with a critical limit, monitoring and a corrective action.
Sometimes two steps work together to control one hazard. Cooking kills bacteria, and rapid cooling prevents spores from growing. The Codex says that you then identify both steps as CCPs.
Example of a CCP worksheet
This worksheet belongs to a caterer that cooks meals, chills them and serves them regenerated the next day. Each row is one significant hazard from the hazard analysis.
| Process step | Significant hazard | Q1 | Q2 | Q3 | Q4 | Outcome |
|---|---|---|---|---|---|---|
| Receiving chicken fillet | Bacteria in raw chicken | No | No | - | - | Not a CCP, controlled by cooking |
| Receiving chilled products | Growth from delivery at too high a temperature | Yes | - | - | - | Not a CCP, receiving check as prerequisite |
| Cooking | Survival of Salmonella and Campylobacter | No | Yes | No | Yes | CCP 1 |
| Chilling | Growth of spore-formers | No | Yes | No | Yes | CCP 2 |
| Portioning | Allergen in the wrong meal | No | Yes | No | Yes | CCP 3 |
| Regenerating | Survival of bacteria after storage | No | Yes | No | Yes | CCP 4 |
| Transport | Temperature too high in transit | Yes | - | - | - | Not a CCP, cool box and measurement |
The outcome: four CCPs. You can see how these CCPs fit into a complete plan, with critical limits and actions, in the HACCP plan example.
The question “Is it a CCP?” often leads to discussion. Write one sentence of justification for each outcome. An inspector or auditor mainly wants to see that you made a deliberate choice.
How many CCPs does a HACCP plan have on average?
There is no fixed number. A sandwich shop that only assembles and sells may have one or none, because cooling and hygiene are handled as prerequisite programmes. A caterer that cooks and chills usually has a few.
Do you have ten or more in a small business? Then you have probably labelled prerequisite programmes as CCPs. That seems thorough, but it means the real critical points get less attention.
CCP or OPRP: the difference in ISO 22000
Are you working towards ISO 22000 or FSSC 22000? Then there is an intermediate category: the operational prerequisite programme (OPRP). This is a control measure for a significant hazard for which you cannot set a measurable critical limit, but you can set an action criterion.
In standard HACCP for hospitality or crafts, you will not come across this term. The difference is explained on the page HACCP and PRPs within ISO 22000.
Once you have identified a CCP, you need to link a critical limit to it. You can find the limits per product group on critical limits in HACCP. For the measurement itself, for example of the cold room, use a temperature log for hospitality.
Common mistakes with the CCP decision tree
- Running the tree for every hazard. Only significant hazards go through it.
- Skipping question 3. Then every step where you measure something becomes a CCP.
- Taking no action when no CCP results. A significant hazard without control means you must change your process.
- Not writing down the outcome. Without a worksheet, you cannot later explain why a step is or is not a CCP.