HACCP and Risk Management in GMP+

HACCP as the foundation of GMP+, not an add-on requirement

Many companies starting out with GMP+ treat HACCP as just one item on a checklist, alongside hygiene procedures or supplier control. That approach produces a weak, box-ticking system that does not hold up under audit. HACCP is a systematic method for identifying feed safety hazards — and since that is the whole point of GMP+, HACCP is the logical starting point for the entire quality system, not an addition to it.

In practice, a well-built HACCP analysis should determine which operational procedures a company actually needs. If the analysis shows the biggest risk is cross-contamination with coccidiostats between batches, the line-cleaning and sequencing procedures should follow directly from that finding, not be copied from someone else's documentation. The obligation to run a HACCP-based system also stems directly from EU feed law, independent of certification — see feed law regulations.

The seven HACCP principles in a feed company's practice

The classic HACCP model rests on seven principles, often described very formally in academic literature. In a feed plant's day-to-day practice, they are best understood as the successive steps of a logical process rather than a checklist.

Hazard analysis is the starting point — the team identifies every realistic biological, chemical and physical hazard at any process stage, from intake to dispatch, and assesses which are likely and severe enough to need control. Determining CCPs means identifying the stages where control is essential to eliminate a hazard or reduce it to an acceptable level. Establishing critical limits means setting a measurable boundary for each CCP — for example, the temperature and time needed during pelleting to achieve a Salmonella reduction.

Monitoring is systematic checking that a limit is being met — a temperature record, a magnet-screening result, a detector reading. Corrective actions define what happens when a limit is exceeded — how the failed batch is handled and how a repeat is prevented. Verification confirms the system genuinely works, not just that it exists on paper. Documentation and records tie it all together — without them there is no way to prove it functions.

Hazard analysis in practice — biological, chemical, physical

A sound hazard analysis starts with an honest review of what could go wrong on site — not copying a hazard list from someone else's documentation. Biological hazards are mainly pathogenic bacteria, Salmonella above all, especially where raw materials may carry it and the process has no heat-treatment step that reduces microbiological risk.

Chemical hazards cover a broader set of risks: mycotoxins in cereals stored under poor humidity conditions, pesticide residues in plant materials, heavy metals in some animal-derived components, and — very relevant on multi-product lines — cross-contamination with coccidiostats, where residue from a treated batch carries into an untreated one unless cleaning and sequencing are properly designed.

Physical hazards are mainly foreign bodies — metal fragments from worn machine parts, glass, wood or plastic entering the product at any stage. For each category, the analysis should ask three questions: can it occur, how likely is it, and how severe would the consequences be.

Setting critical control points (CCPs)

Not every hazard requires a CCP — only those for which no later step reduces the risk enough, and where control at that stage is technically possible and necessary. In typical feed production, the stage most often identified as a CCP is pelleting or another heat treatment — the temperature and holding time needed to reduce microbiological risk becomes the critical limit subject to ongoing monitoring.

A second common example is metal control — a detector or magnetic separator right before packaging, the last barrier against a physical hazard. Depending on the line, a CCP might also cover dosing of certain additives, where an error could exceed permitted levels of an active substance. The number of CCPs at a typical plant is usually small — a handful, rarely more than a dozen — and must follow from that site's own hazard analysis, not a generic list of "typical CCPs".

CCP versus control point (CP) and good manufacturing practice

A common misunderstanding is confusing a CCP with a control point (CP) or with good manufacturing practice elements. A CCP is a stage where loss of control directly threatens product safety with no further chance of correction — hence the formal critical limit and monitoring. A CP matters for quality, but loss of control there does not directly create a safety hazard — checking pack weight, for instance. GMP elements, such as cleaning procedures or a maintenance schedule, form the background against which HACCP can work at all.

This matters in practice: labelling too many stages as CCPs dilutes the system, while missing a real CCP and treating it as an ordinary CP is one of the more serious mistakes an auditor can uncover.

When the HACCP analysis needs updating

A HACCP analysis is not written once and left unchanged for years. It should be reviewed at least once a year, and whenever a significant change occurs: a new raw material or supplier with a different risk profile, a change to the product range, a modified production line, or a quality incident revealing a gap in the analysis.

A separate trigger is a new hazard identified within the industry — via RASFF, GMP+ International alerts, or supplier information. Good practice is to review such sources regularly and assess whether the hazard concerns that site's own materials and processes — if so, it should trigger an update, not just an "FYI" note.

The HACCP team — composition and the role of training

A HACCP system built by one person, without input from people who know the process from the inside, is rarely complete. The team should be cross-functional — the quality lead, a technologist or recipe expert, someone from production, and, depending on scale, purchasing and warehousing. In very small companies the team may be narrower, but it should always combine process knowledge with hazard knowledge.

Training team members — and everyone whose work affects feed safety — is something an auditor checks as carefully as the documentation itself: GMP+ training.

What HACCP looks like during a GMP+ audit

During a certification or surveillance audit, a GMP+ auditor does not just review the HACCP document — they check whether it reflects reality on site: do the CCPs correspond to the process's actual critical stages, are limits monitored at the declared frequency, and are exceeded-limit cases documented with corrective actions.

The auditor typically also asks team members to explain specific decisions — why one stage was a CCP and another was not, where a limit's value came from, and when the analysis was last updated. Evasive or inconsistent answers between people are among the clearest signals that a system exists mainly on paper. The full audit process is covered on GMP+ certification process.

Common HACCP implementation mistakes in small and medium companies

A handful of mistakes recur in consulting practice. The first is copying a ready-made analysis from elsewhere without adapting it to the company's own raw materials and process. The second is over-engineering the system, labelling a dozen or more stages as CCPs "just in case", which dilutes attention and makes monitoring harder where it is genuinely needed.

The third is failing to update the analysis after a change — a new supplier or recipe arrives and the documentation stays unchanged for months. The fourth is monitoring "by eye" without records, which an audit treats as though the check never happened. The fifth, common in smaller companies, is building HACCP in isolation from the rest of the quality system.

A risk-proportionate approach — HACCP does not need to be overengineered

One of the most important principles when implementing or reviewing HACCP is proportionality. The system should match the scale and complexity of production — a small company with a uniform product range can have a simpler analysis and fewer CCPs than a large plant with dozens of recipes and diverse raw materials. The goal is always a system that genuinely controls the hazards specific to that site — the documentation detail simply varies with the company's profile.

A GMP+ auditor assesses whether the system fits the business profile, not some arbitrary template of "ideal" documentation. Companies that copy a system from a large plant often end up with documentation no one actually uses — worse than a simpler system that genuinely works.

Summary

HACCP within GMP+ is not a formality to tick off — it is a real mechanism protecting against biological, chemical and physical hazards across the feed chain. A well-built hazard analysis, correctly identified CCPs and regular updates, scaled to the company, genuinely determine the safety of the feed produced or traded. If you are building or reviewing a HACCP system and need support, get in touch with us.

Glossary

HACCP

Hazard Analysis and Critical Control Points — a systematic method for identifying and managing feed safety hazards, forming the foundation of GMP+.

CCP (critical control point)

A process stage where control is essential to eliminate a hazard or reduce it to an acceptable level.

CP (control point)

A stage relevant to quality or compliance where loss of control does not directly threaten product safety.

Critical limit

A measurable boundary set for a CCP, compliance with which ensures control of the identified hazard.

Cross-contamination

The unintended transfer of a substance, such as a coccidiostat, from one batch to another, most often via a shared production line.

HACCP team

A cross-functional team responsible for developing, implementing and reviewing the hazard analysis and critical control points at a site.