limits may require determination of
probable maximum numbers of micro-
organisms in the product, as well as
sources such as regulatory standards and
guidelines. The food industry is respon-
sible for engaging competent authori-
ties to validate that the critical limits
will control the identified hazard.
4.Establish procedures to monitor CCPs.
Scheduled testing or observation of a
CCP and its limits is accomplished
through monitoring. Results obtained
from monitoring must be documented.
From a monitoring standpoint, failure
to control a CCP is a critical defect. A
critical defect may result in hazardous
or unsafe conditions for those who use
or depend on the product. Monitoring
procedures must be very effective
because of the potentially serious con-
sequences of a critical defect.Monitoring is a planned sequence of
observations or measurements to assess
whether a CCP is under control and to pro-
duce an accurate record for future use in
verification. Monitoring is essential to food
safety management because it tracks the sys-
tem’s operation. Stevenson and Bernard
(1995) suggested that if monitoring reveals
that there is a trend toward loss of control,
i.e., exceeding a target level, action should
be taken to bring the process back into con-
trol before a deviation occurs. Monitoring
identifies a loss of control or a deviation at
a CCP, such as exceeding the critical limit
and the need for corrective action. Further-
more, monitoring provides written docu-
mentation for use in verification of the
HACCP plan.
If feasible, monitoring should be continu-
ous. It is possible to attain continuous moni-
toring of pH, temperature, and humidity
through the use of recorders. If insufficient
control is maintained, as recorded on the
chart, a process deviation may be identified.
When it is impractical to monitor a critical
limit continuously, a monitoring interval
must be established that is reliable enough to
indicate that the hazard is under control.
This can be accomplished through a statisti-
cally designed data-collection program or
sampling system. Statistical procedures are
useful for measuring and reducing the varia-
tion in manufacturing equipment and meas-
urement devices.
Monitoring procedures for CCPs must be
designed for rapid results because insufficient
time exists for time-consuming analytical
testing. Microbial testing is also normally
unsatisfactory for monitoring CCPs because
of the amount of time involved. Physical and
chemical measurements are more viable
because they may be done rapidly and can
indicate microbial control of the process.
Physical and chemical measurements that
may be incorporated in monitoring include
measurements of pH, time, temperature,
moisture, are preventive measures for cross-
contamination, and specific food handling
procedures.
Random checks may be conducted to sup-
plement the monitoring of certain CCPs.
They may be used to check incoming precer-
tified supplies and ingredients, to assess
equipment and environmental sanitation, air-
borne contamination, cleaning and sanitiza-
tion of gloves, and any area where followup is
needed. Random checks are normally con-
ducted through physical and chemical testing
and microbial tests, as appropriate.
For certain foods, microbially sensitive
ingredients, or imports, there may be no
alternative to microbial testing. However, a
sampling frequency that is adequate for reli-
able detection of low levels of pathogens is
seldom possible because of the large number
of samples needed. Microbial testing has
limitations in HACCP but is valuable as a
means of establishing and randomly verifying