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PrimusGFS
HACCP requirements.

The part of the standard that stops most first-time applicants — explained without the jargon.

Why PrimusGFS asks for a HACCP plan at all

A GAP audit largely asks whether you follow good practices. A HACCP plan asks a harder question: for this specific product and this specific process, where could something go wrong, and what have you put in place to catch it?

That difference is why a plan copied from a template usually fails. A generic plan describes a generic operation. The auditor is looking at your flow diagram, walking your line and checking whether the two match.

You do not need a hazard at every step. Plenty of produce operations conclude they have few or no critical control points, and that conclusion is perfectly acceptable — provided the hazard analysis behind it is documented and reasoned.

What the plan has to contain

01

Product and process description

What you produce, how it is handled, intended use and intended consumer. A ready-to-eat product carries different expectations from one that will be cooked.

02

Process flow diagram

Every step from input to shipping, verified on the floor and signed off. If the diagram misses a step the auditor sees, the whole analysis is in question.

03

Hazard analysis

Biological, chemical and physical hazards at each step, with likelihood, severity and the reasoning for whether it is significant.

04

Critical control points

The steps where control is essential to prevent or reduce a significant hazard, identified through a documented decision process rather than assertion.

05

Critical limits

A measurable boundary for each control point — a concentration, a temperature, a time. "Clean" is not a critical limit.

06

Monitoring

What is measured, how often, by whom, recorded where. This is where the audit evidence comes from.

07

Corrective actions

What happens when a limit is breached, including what is done with affected product and who decides.

08

Verification and records

How you confirm the plan works — record review, calibration, testing — plus the annual reassessment and any review triggered by a process change.

What this looks like on a produce operation

Illustrative only. Your hazard analysis must be done for your own products and process — whether any of these is a critical control point on your operation is a conclusion you have to reach and document.
Process stepTypical hazard consideredCommon control
Agricultural water applicationMicrobial contamination from the water sourceSource testing on a schedule with defined thresholds and documented action on failure
Soil amendmentsPathogens from untreated manureApproved, treated inputs with supplier documentation and application intervals
HarvestContamination from workers, tools and containersHygiene training, sanitation of containers, pre-harvest assessment
Wash or dump tankCross-contamination across a whole batch through the waterSanitiser concentration and pH monitored at set intervals, with limits and corrective action
Cooling and cold storagePathogen growth through temperature abuseTemperature monitoring with recorded limits and an out-of-range procedure
PackagingForeign material, or contaminated packagingSpecification control, protected storage, inspection at use

Where plans come apart in the audit

The flow diagram does not match the floor

A step was added, moved or dropped and the plan was never updated. Verify the diagram physically each year.

Critical limits that cannot be measured

"Adequate sanitiser" is not a limit. A range in parts per million, checked at a stated frequency, is.

Monitoring records with no gaps — and no life

Identical values every day, all in the same pen, filled in the same afternoon. Auditors recognise this immediately.

No record of a breach ever occurring

A full season with zero out-of-range readings usually means monitoring is not happening, not that nothing ever drifted.

No reassessment

The plan is required to be reviewed at least annually and whenever the process changes. A three-year-old untouched plan is a finding on its own.

Nobody owns it

The person named in the plan has left, or has never read it. Training records need to connect the named people to the plan.

Building the plan and keeping it alive

GAP APP's HACCP builder walks the same sequence the standard expects: describe the product, map the flow, work through hazards step by step, set limits, and attach the monitoring records that prove the plan ran.

Because the monitoring logs live in the same system, the plan and its evidence stay connected. When the annual reassessment comes round, the history is already there — and so is the record of every corrective action taken against a limit.

Go deeper on PrimusGFS

The PrimusGFS Modules

Module 1, 2 and 3 explained, and how to tell which ones apply to your operation.

Read the guide →

PrimusGFS Audit Checklist

A module-by-module readiness checklist you can work through before booking the audit.

Read the guide →

PrimusGFS HACCP Requirements

The Module 1 HACCP plan — the section most farms underestimate.

Read the guide →

Cost & Timeline

What drives the price and how long preparation realistically takes.

Read the guide →

PrimusGFS vs Harmonized GAP

Side by side: recognition, HACCP, scoring and who asks for which.

Read the guide →

What GFSI Recognition Means

Why buyers say 'GFSI' when they mean one of seven specific schemes.

Read the guide →

Common questions

Can I use a HACCP template?
A template is a reasonable starting structure, but the hazard analysis has to be done for your own products, process and site. Auditors are experienced at spotting a plan that describes somebody else's operation.
What if my operation has no critical control points?
That is a legitimate outcome for some produce operations, as long as the hazard analysis showing how you reached it is documented and defensible. The absence of CCPs is a conclusion, not a shortcut.
Do I need formal HACCP training?
The standard expects the plan to be developed by someone competent to do it, and many certification bodies and buyers look for recognised HACCP training for the person responsible. Check what your certification body expects for your scope.
How often does the plan need reviewing?
At least annually, and whenever your process, products, equipment or suppliers change materially. Record the review even when nothing changes.

Build a HACCP plan that survives the audit

Flow diagram, hazard analysis, limits and monitoring records in one connected system.

Start Free →HACCP guide

GAP APP provides audit-preparation tools and is not affiliated with, endorsed by or accredited by GFSI, Azzule Systems, SQFI, CanAgPlus, GLOBALG.A.P. or USDA. Certification decisions are made solely by accredited certification bodies and their auditors.