HACCP Without Blind Spots

By: M.R. Trace

Hazard Analysis and Critical Control Points (HACCP) is the backbone of food safety systems. It’s clause-backed, globally recognized, and mandatory in regulated environments. But here’s the uncomfortable truth:

Many HACCP plans look complete—until you audit them.

WHAT I SEE AS AN AUDITOR

I’ve reviewed hundreds of HACCP plans. Some are robust. Most are performative. Here are recurring gaps that compromise safety, traceability, and credibility:

• No mention of rework – Product re-entering the process isn’t addressed. Risk is recycled, not mitigated.
• Waste streams ignored – Disposal logic is missing. What leaves the system isn’t tracked.
• Customer returns excluded – Returned product is outside the hazard lens. That’s a blind spot.
• Flow chart not verified by HACCP Coordinator – No signature, no ownership. Just a diagram.
• Flow chart doesn’t match hazard analysis – Steps are skipped, merged, or mislabeled. The map doesn’t match the terrain.
• High-risk steps identified but not mitigated – Hazards are acknowledged, then left hanging. No CCP. No control.
• No clause-backed justification for exclusions – “Not applicable” is used like white-out, not like logic.

If a step is excluded, it must be evaluated and justified—per clause, not convenience.

METAL DETECTOR ≠ HACCP PLAN

One of the most common missteps I see:
Facilities treat the metal detector as their only Critical Control Point
It’s installed, calibrated, and documented—so they assume the job is done.

But here’s the clause-backed reality:

• Metal detection addresses one hazard type metal fragments.
• It does not mitigate biological, chemical, or other physical hazards (e.g., brittle plastic, glass, bone).
• It’s a last-line defense, not a comprehensive control strategy.

If your HACCP plan has one CCP — and its metal detection—you better have clause-backed justification for every other hazard being controlled upstream.

Otherwise, you’re not managing risk. You’re outsourcing it to a machine.

WHAT A CLAUSE-BACKED HACCP PLAN LOOKS LIKE

• Every process step is mapped, verified, and owned
• Rework, waste, and returns are addressed with hazard logic
• High-risk steps trigger mitigation — not just acknowledgment
• Flow chart and hazard analysis are synchronized and clause-referenced
• HACCP Coordinator signs off — not just in theory, but in practice
• Not applicable is justified with clause-backed rationale, not convenience
• CCPs are validated — not assumed

FINAL THOUGHT

HACCP plans don’t fail because the hazards are invisible. They fail because the system pretends not to see them. If your flow chart is decorative, your hazard analysis is incomplete, your CCPs are unvalidated, and your exclusions are unexamined— you don’t have a HACCP plan. You have a liability.