Don’t get caught out using the old Codex decision tree…
In this post we’ll go through the risk of using the wrong decision tree. I’ve also created a free prerequisite template for you, you can get your copy by clicking the button at the bottom of this post.
There are two types of the codex decision tree, the original one and a more modern one that’s been adapted to include the fact that we now use prerequisites to manage the fundamental practises that manage how we make food safely.
When codex was originally developed in the 1990’s, it contained the 7 principles:
Principle 1: list the potential hazards, conduct a hazard analysis and consider the control measures
Principle 2: determine the critical control points (CPPs)
Principle 3: establish critical limits for each CCP
Principle 4: establish a monitoring system
Principle 5: establish the corrective action to be taken if monitoring shows that the CCP is out of control
Principle 6: establish verification procedures
Principle 7: set up documentation of the procedures and records
Although codex talks about control measures in principle 1, it doesn’t mention prerequisites. When Codex HACCP was first introduced, many manufacturers had loads of CCPs, because of a lack of prerequisites. Since then, prerequisites have developed massively and most HACCP plans today have a good set of prerequisites that manage food safety, quality and legality of the products we produce. This in turn, has reduced the need to have as many CCPs.
For this reason the original Codex decision tree was adapted to include an addition question, question 1 ‘is this hazard managed by a prerequisite programme’.
I would strongly recommend that you use the updated version of the decision tree and I’ll explain why…
Let’s take the example of ‘Growth of staphylococcus aureus in the dispatched finished product caused by ineffective temperature control during storage’ at the process step of “storage prior to dispatch.”
If you use the original Codex decision tree your assessment would look like this:
Question 1: ‘Do control measures exist for the identified hazard?’
Answer: – Yes, we have temperature control so we’d move to question 2.
Question 2: ‘Is the process step specifically designed to eliminate or reduce the likely occurrence of the hazard to an acceptable level?’
Answer: – Yes, we store the product in chilled conditions to control the growth of pathogens like Staphylococcus aureus. Therefore the chilled storage becomes a CCP.
Today, the chilled storage of product is widely recognised as being managed by prerequisites, as we have good basic controls in place, the need to control it as a CCP is overkill.
Because of this reason I’ve seen many HACCP plans where this exact hazard has been assessed through the original Codex decision tree, and because the result would mean it’s a CCP and the site doesn’t think that’s right, they’ve ‘fudged’ the answers so that it doesn’t come out as a CCP. This clearly, would put them at risk of getting a non-conformance for this.
If you use the updated decision tree, it would go like this instead:
Question 1: ‘Is the hazard managed by the prerequisite programmes?’
Answer:– Yes, chilled storage is a control, under the prerequisite of ‘Storage and distribution’. Therefore it’s managed by a prerequisite and is not a CCP.
The other benefit of using the updated decision tree is that it means that only the really KEY hazards which are not managed by prerequisites continue on through the decision tree, making you focus on the KEY food safety controls.
Check your HACCP plan to see which decision tree you’re using and if you’re using the original version, make sure that you’ve not ‘fudged’ any of the answers to get the result you want.
When using the updated version of the decision tree it makes the prerequisites that you choose, really important, as this will determine which controls come out as CCPs.
To help you with this I’ve provided you with a list of the prerequisites that we use when carrying out a HACCP study for a site which has BRC Food Safety accreditation. You can use this in your HACCP plan and just add in your procedure references for each control/prerequisite. It’s also a useful way of working out if you have any gaps in your procedures.
To get your free copy of these, just click the button below.