ISO 22000 implementation plan: phases, owners, deliverables and decision points

How an ISO 22000 project is organised

Running an ISO 22000 implementation well comes down to three things: a sequence of phases that respects the order food safety work has to happen in, a clear owner for every deliverable, and decision points where management confirms the plant is ready to move on.

The order matters because the standard's operational requirements depend on one another. You cannot finish a hazard analysis until the flow diagrams have been checked on the floor, you cannot rely on a control measure until it has been validated, and you cannot show an auditor that the system works until monitoring, verification and traceability records have built up over real production. The plan below assumes the scope and gap analysis are agreed; our ISO 22000 gap analysis guide covers that first stage, and the ISO 22000 timeline guide covers overall duration in more depth.

Who owns what: the project roles

Six roles carry the project. In a small business one person may hold two; what must not happen is for every role to collapse into the quality manager.

• Sponsor. A member of top management who approves budgets for works, releases people from production and chairs each decision point.
• Food safety team leader. Runs the food safety team, owns the hazard analysis and the hazard control plan, and reports to management on how the system performs. This person needs the authority to stop a line or hold product, not only to recommend it.
• Food safety team. A multidisciplinary group from production, quality, maintenance, hygiene and purchasing, bringing the process knowledge the hazard analysis depends on.
• Process owners. Line managers and supervisors who run the PRPs, complete monitoring records at the time of the activity and handle deviations on their shifts.
• Maintenance and engineering. Own the infrastructure side of the PRPs: layout, segregation, pest proofing, water, equipment design and calibration of monitoring devices.
• Internal auditors. Trained people, independent of the areas they audit, who test the PRPs and the hazard control plan before the certification body does. Our ISO 22000 internal audit guide explains how they work.

The eight phases, with deliverables and decision points

1. Project set-up and the food safety team

Confirm the scope, appoint the food safety team and its leader, agree the project plan and set up the system in software from day one. The decision point: does the team have the time and authority it needs?

2. PRP upgrades

Assess the prerequisite programmes against the applicable ISO 22002 part and legal requirements, then separate what needs a procedure from what needs works. Drains, changing areas and allergen segregation are engineering jobs with lead times. The decision point is capital approval, and it should come early; the prerequisite programmes guide covers the content.

3. Hazard analysis and hazard control plan

Build product descriptions and flow diagrams, verify the diagrams on the floor, analyse hazards step by step, select control measures and categorise them as OPRPs or CCPs. The deliverable is a hazard control plan with critical limits and action criteria. The decision point is the team's sign-off that the analysis reflects the plant as it actually runs. The method itself is set out in our hazard control plan guide.

4. Validation and verification planning

Plan how each control measure will be shown to work before it is relied on, through scientific evidence, testing or challenge studies, and set the verification schedule: swabs, product tests, calibration and record reviews. The decision point is whether any validation result forces a change to the plan.

5. Documentation and records

Put in place the documented information the standard requires, and the forms that people on the line will actually fill in. Keep it lean; our documentation guide sets out what is required and what is optional.

6. Operating period

Run production under the system. Monitoring, verification, calibration, traceability and deviation records accumulate; a mock recall is run and timed. The decision point is whether the records show a pattern across products, shifts and lines.

7. Internal audit and management review

Audit the PRPs and the hazard control plan across the whole scope, correct what is found, then hold a management review that takes decisions. The decision point is the sponsor's confirmation that the plant is ready for the certification body.

8. Certification

The accredited certification body conducts its Stage 1 readiness review and then the Stage 2 audit, and decides. Sterling does not certify. The certification process guide covers this stage step by step.

A Gantt-style view of the plan

The table shows a typical single-site manufacturer with an existing HACCP plan and PRPs that need some works. The week ranges are an estimate, not a commitment; overlapping ranges indicate phases that run in parallel. A plant needing major works or new validation studies will take longer.

Book the certification body while phase 6 is under way. Its lead time is outside your control.

Design™ or Drive™: choosing the level of support

The phases are the same whichever route you take; what changes is who carries the work. With Design™, your food safety team leads each phase and Sterling provides structure, templates, workshops, coaching and review at every decision point. It suits plants with an experienced quality function. With Drive™, Sterling consultants take on the agreed consulting and documentation work alongside your process owners, including drafting the hazard analysis with the team and running the internal audit. It suits plants with a deadline and a thin team. Either way, the knowledge must end up with your people; the auditor interviews them.

What stalls food safety projects

• Capital works approved late. A PRP gap that needs a new wash area or physical segregation will not close with a procedure. If approval waits for the hazard analysis, the works land in the operating period and the audit date slips.
• A HACCP team without authority. When the food safety team leader cannot hold product or change a line without escalation, deviations are handled informally and the records show it. Give the role its authority in writing at set-up.
• Seasonal lines missed. A product made for three months of the year may sit outside the operating period entirely, leaving no monitoring records for its CCPs. Map the production calendar at the start and plan the operating period, or the scope, around it.

ISO 22000 implementation plan: questions buyers ask