HACCP Validation & Verification

Validation or verification?

We’ve been working on the new BRCGS Packaging Issue 7 standard, to develop our new conversion course, update the documentation packs and also audIT.app. During this time, it’s become apparent that BRCGS still struggle with the terms validation and verification and get them mixed up – so we thought it would be a good idea to do an article as a refresh.

Here’s our simple way of remembering what each one means – so that you know which way around to use them.

When is validation and verification used?

Historically, these terms would only be used when referring to CCPs. Today they’re used more frequently – so you need to understand their meaning, so that you can apply them correctly. In BRCGS Food Safety Issue 9 and BRCGS Packaging Issue 7 a new clause has been added which means that you must now ‘validate’ your HACCP/HARA plan (documentation).

Understanding validation and verification

	Validation	Verification
Definition	A process of proving that something will work.	A process of checking that something is working.
Purpose	You are proving what you are saying is valid (true).	You are verifying that it’s working.
Objective or subjective	Validation should be objective, so it’s carried out using testing and reference documentation such as industry guides. This means that the results of the test or reference documentation, determines if the answer is either correct or incorrect.	Verification preferably is subjective, but it can also be objective – so it can be carried out using checks, tests, or photo standards. This means it’s up to the person carrying out the verification to determine if the answer is correct or incorrect.
Frequency	Validation is carried out before you implement something, after any change, and then sometimes at a set frequency after that (annually for example).	Verification is carried out frequently – so these are the routine checks that you carry out, e.g. hourly, weekly, monthly.

Confusion

There are times when the term validation is used incorrectly. For example, the new clauses in the BRCGS standards state that you must validate your HACCP/HARA plan, prior to implementing any changes to it.

You can’t validate your HACCP/HARA plan, as you can’t prove that it will work. You can validate your CCPs, but you can’t provide evidence to show that your overall plan will work. Therefore, validation in this context isn’t correct.

However, BRCGS also state that you can use subjective methods for validation of CCPs. Whereas HACCP specialists (as we are) would argue that you can only use objective methods.

Subjective definition

Where something is open to interpretation, it’s influenced by a person’s opinion or feelings. So, subjective assessment means that the result is not based on factual data and is interpreted by the individual. For example, checking the quality of a product using a photo standard – the person must decide which one of the photos looks most like the product.

Objective definition

Where something isn’t open to interpretation, it’s based on facts and measurements. For example, weighing a product – the resulting weight decides whether the product is within the acceptable limits or not.

CCPs

Subjective assessment must not be used to assess critical limits, as product safety isn’t open to interpretation. Objective assessment must be used, which allows measurements to be used as evidence – for example, heating to a set temperature for a set amount of time.

Conclusion

It’s therefore no surprise that people get confused about what validation and verification mean and the differences between them. Just remember:

Validation: Prove it!

Verification: Check it!

Examples of validation and verification

Validation

Verification

Carrying out cleaning trials to show:

That the cleaning procedure reduces the contamination to the required level.
What monitoring limits need to be achieved using ATP and micro swabs to validate.

Cleaning checks:

Daily ATP testing to show that the clean has been carried out effectively.

Metal detector trials to show:

What test piece sizes can be achieved.
Where the test piece should go.

Metal detector checks:

Start, hourly and end of run testing of the metal detector using the test pieces.

Carrying out cleaning trials to show:

That the cleaning procedure reduces removes allergen residue.
What monitoring limits need to be achieved using rapid swabs and allergen swabs to validate.

Allergen checks:

Daily allergen rapid swabs to show that the clean has been carried out effectively.

Frequently asked questions

Do prerequisite programmes (PRPs) need to be validated?

No, you can’t prove that a PRP will work. You can only validate aspects of it which require measurement, for example cleaning. You can’t prove (validate) that the cleaning programme will work because you can’t measure it or provide factual data as evidence. However, you can prove (validate) that a specific cleaning method will work, as you can measure the level of debris or allergens on a surface before it’s cleaned, and then measure it again after cleaning.

How do I validate my HACCP/HARA plan?

You can’t validate your HACCP/HARA plan, as you can’t prove that it will work. What you need to do is to approve it. This can be done by having a check list of the tasks that must be completed before an update to the plan is launched, and the team must verify that these have been done before it goes live.

Have your say…

7 thoughts on “Validation and verification explained”

Jana Machytková says:

15th January 2025 at 1:43 pm

Dear Kassy, finally one of the systems (BRCGS) was able to clearly describe the differences between validation and verification…. thanks for that

Reply
Brian Preston says:

15th January 2025 at 12:42 pm

Nice work Kassy. Two words that have been confused since the first introduction of Standards. We all know what we are trying to achieve and there ought to be another word that better describes the actions needed to confirm a working process,

Reply
Steve Ellison says:

15th January 2025 at 12:15 pm

Kassy

I have been teaching HACCP at all levels for over 25 years and have been asked the Validation and Verification question many, many times , most notably by a group of EHP’s.

Your summary is very good, as HACCP professionals this debate is always going to confuse those new to the subject. BRCGS have shown that even they struggle to understand the words! However Codex principle 6 has always stated “elements” of a HACCP plan must be validated to establish that they “will” work and verification procedures must be established to ensure the plan, as a whole, “has” worked as expected.

Reply
1. Kassy Marsh says:
  
  16th January 2025 at 9:26 am
  
  Hi Steve
  
  Please find below extracts from Codex CXC1-1969 (2022) which align with the information provided in this article:
  
  Thanks
  Kassy
  
  Reply
Karen Moran says:

15th January 2025 at 11:34 am

Hi Kassy

Do you have anymore updates on Food Safety legislation.

Thanks

Reply
Greg says:

15th January 2025 at 8:04 am

BRCGS are sometimes not worth the paper they are written on if they say you can use subjective CCP’s. A CCP has to be measurable. Another headache for auditors.

Reply
1. Walt Anderson says:
  
  16th January 2025 at 12:31 pm
  
  I think some of the confusion (in the UK anyway) comes from implementation of Regulation 852/2004 because the FSA did not believe it was possible to fully implement HACCP in small food establishments (takeaways, cafes, burger vans etc.) so we got Safer Food Better Buisiness and they very much allow CCPs to be things like “fully browned on the outside” which is anathema to HACCP purists but anyone with an Environmental Health background will be comfortable with these non-parametric CCP critical limits. Personally I only use parametric (measurable) values in my control measures but I’m not that much of a purist that I would raise a non-con against a site using subjective/non-parametric evaluation so long as they could show consistency of application of evaluation.
  
  Reply