HACCP prerequisite programmes and good hygiene practices: the foundation under the plan

What are HACCP prerequisite programmes?

Prerequisite programmes are the routines that keep a food operation clean, orderly and in control before anyone asks where the critical control points are. The Codex text defines them as programmes "including good hygiene practices, good agricultural practices and good manufacturing practices, as well as other practices and procedures such as training and traceability, that establish the basic environmental and operating conditions that set the foundation for implementation of a HACCP system."

Good hygiene practices, or GHPs, are the largest part of that family. Codex describes them as "fundamental measures and conditions applied at any step within the food chain to provide safe and suitable food." The terms are often used interchangeably, but GHPs are the hygiene measures, while prerequisite programmes also take in agricultural and manufacturing practice, training and traceability.

The current Codex text, revised in 2020 and again in 2022, also names a positive food safety culture as fundamental to any food hygiene system. Prerequisite programmes are where that culture shows: a handwash station that is used, a cleaning record signed by the person who cleaned, a supervisor who stops the line when a chiller alarm sounds.

The good hygiene practice areas in Codex Chapter One

Chapter One of CXC 1-1969 is organised under section titles that give a HACCP team a ready-made structure, followed in the table. The other two columns are Sterling's summary of common practice, not the Codex wording.

Not every heading carries equal weight. A cold store spends most effort on temperature, transport and pest control; a bakery on allergens, foreign bodies and cleaning. Codex itself recognises that small or less developed businesses may lack onsite resources and expertise, so programmes should fit the business, not a large plant's manual.

How prerequisite programmes connect to the HACCP plan

Hazard analysis, the first HACCP principle, asks at each step which hazards are significant and what controls them. For most hazards the accurate answer is a prerequisite programme: cleaning keeps microbial build-up off a slicer, supplier approval keeps a banned colouring out of the spice blend. Only where control at a step is essential to prevent, eliminate or reduce a significant hazard does the team declare a CCP, with validated limits and monitoring.

That division of labour is why the programmes matter so much. A plan with a few well-chosen CCPs is credible only if the hygiene around them holds: skip the cleaning and cooked product picks up what the cook step removed, while the CCP record still looks perfect. Deciding which steps become CCPs is covered in our guide to hazard analysis and the CCP decision tree.

The same logic runs through regulation. In the United States, the National Advisory Committee's HACCP guidelines say the HACCP system must be built upon a solid foundation of prerequisite programs, and FSMA preventive controls for human food include sanitation, allergen and supply-chain controls within the written food safety plan. In the European Union, Regulation (EC) No 852/2004 sets general hygiene requirements in Annex I for primary production and Annex II for later stages, alongside HACCP-based procedures. The Philippine Food Safety Act of 2013 directs official inspection to consider good manufacturing practices as well as HACCP implementation.

A worked example: a chilled sandwich producer

A small producer makes chilled sandwiches for convenience stores. Its HACCP study names pathogens, allergens and foreign bodies as the main hazards, with the cook step for chicken fillings and chilled storage as CCPs. Everything else rests on prerequisite programmes, each mapped to the hazards it keeps down.

When a line swab comes back positive, the producer tightens the cleaning method, re-swabs, retrains the crew and records the outcome. The CCPs never saw the problem; the programme and its verification caught it, which is the evidence an auditor finds convincing.

What the record should show

A prerequisite programme needs three kinds of evidence. First, a short written method stating what is done, by whom and how often, in the operators' language. Second, records made at the time, for any day the auditor samples. Third, verification that the programme is followed and works: inspections, swab or water results, pest trends, complaints and the internal audit.

HACCP Principle 6 asks for verification that the whole system works as intended, and in practice that covers the foundation as well as the CCPs. The verification schedule, and what an internal auditor should test, are covered in HACCP internal audit and verification. Competence for cleaners, handlers and supervisors is covered in HACCP training.

Common mistakes with prerequisite programmes

• Treating them as paperwork before the real work. Teams rush the hygiene procedures to reach the HACCP study; the auditor starts on the floor, where that shows first.
• Turning hygiene into CCPs. When the foundation feels weak, teams make handwashing or cleaning a CCP. These routines rarely have a measurable critical limit or a way to hold product at the moment of failure, so they belong in a well-verified programme instead.
• Copying another site's manual. It names rooms, equipment and chemicals the auditor cannot find.
• No link to the hazard analysis. If the worksheet dismisses a hazard as controlled by good hygiene, it should name which programme does it.
• Records without review. Signed cleaning sheets with no trend analysis show activity, not control.

HACCP prerequisite programmes: questions buyers ask