The seven principles
01–02Hazard analysis, then identify the CCPs
Temperature control is a critical control point wherever a loss of control can make product unsafe — chilled storage, cooking and cooling steps, frozen holding. The HACCP plan names the CCP, its critical limit, and the monitoring that proves the limit held. A cold store that is in scope will typically have temperature as a CCP with a defined band, not a vibe.
03Critical limits
The band comes from the product and the regulation, not from what the equipment happens to do. Chilled product in the +2 to +8 °C family, frozen holding at or below −18 °C — the classic reference points in food codes and customer specifications — but the number your plan states must be traceable to your product's actual requirement or legal limit.
04Monitoring: planned observation, at a defined frequency
Monitoring answers 'is the limit being met right now' — who checks, how often, with what instrument, and what they record. Continuous logging with a periodic documented review satisfies most schemes better than a twice-daily manual tick, but the review itself must happen and be signed. A logger nobody reads is not monitoring.
05Corrective actions
What happens when monitoring shows the limit was not met: hold the product, fix the cause, record what was done and who decided. This is the same disposition discipline as any excursion process — the HACCP plan should say in advance what the corrective action is, so the shift lead is not inventing policy at 3 a.m.
06Verification
Verification answers 'is the system working' — a different question from monitoring. Record review, trend analysis, instrument calibration checks, periodic validation of the limit itself. Auditors ask for verification evidence separately, and a pile of readings is not verification until someone has reviewed them against the limit.
07Records
Monitoring records, corrective-action records, calibration records. Food-safety record rules in the US are set by 21 CFR Part 117 subpart F for preventive-controls facilities: records must be accurate, indelible, legible, created concurrently with the activity, and retained per the rule. Note the nuance: §117.305(g) exempts these food electronic records from 21 CFR Part 11 — but they must still meet those accuracy and signature expectations, so 'it's in a spreadsheet' is not a defense if the spreadsheet can be silently edited.
What is a CCP?
Calibration is the record people forget
Every temperature reading is only as good as the instrument that took it. Auditors routinely ask for calibration certificates for the devices behind the charts — traceable to a recognised standard, with the device identified (probe or logger serial, not just “the fridge sensor”) and the check dated.
Defrost, doors, and false alarms
A temperature trace without spikes is usually a trace that is not connected to a real room. Defrost cycles, door openings and loading all move air temperature without moving product temperature. If every one of those is logged as a deviation, the corrective-action file fills with noise and the real event gets lost in it. Monitoring that survives contact with an auditor distinguishes short, explained, bounded events from sustained out-of-band exposure — the latter is the one that needs product disposition.
What this means for traceability rules
US food traceability requirements under FSMA 204 (21 CFR Part 1, Subpart S) apply to foods on the FDA's Food Traceability List.
Temperature records feed that picture too: lot-linked temperature evidence is what turns a traceability exercise from “we shipped it” into “it stayed in spec”.
How Cryovo fits
Cryovo turns raw readings into the monitoring record: registered bands per asset, every out-of-band event with its start, duration and worst value, and a corrective-action trail attached to the event. The review step stays yours — Cryovo makes it a signature on a complete record instead of a hunt through spreadsheets.
General information, not legal or compliance advice for your jurisdiction. Your HACCP plan and its limits are specific to your products and process. New to the vocabulary? See the Help page and the glossary.
