When Should a HACCP Plan Be Checked

Introduction

💡 This blog is part of our Food Safety Help Centre – your one-stop resource for food business owners who want clarity, not confusion.

“You don’t know what you don’t know.”

A modern reflection on Socrates wisdom Tweet

“Can you just come in and do a quick check of my HACCP Plan?”

This request usually comes a few days before an EHO inspection.

What most people don’t realise is this: the HACCP Plan review should have happened much earlier. And not knowing when to check it, can ruin your food hygiene rating. Therefore, it’s especially important to review your HACCP Plan if your EHO visit is looming.

So let’s talk about this question ”when should a HACCP Plan be checked?” Because you don’t want to get caught out. If you do, your hygiene rating could drop like a stone (which could be embarrassing, as well as costly)!

What Does Checking a HACCP Plan Actually Mean?

You may be asking yourself ”what does checking a HACCP Plan actually mean?” Well, it does not mean a quick flick through your HACCP folder to see if the document is still there 😉

Properly checking or reviewing your HACCP Plan means you need to:

Make a list of all the food types you handle and/or sell
If you’ve added in new food types since your last HACCP review, then you may need to amend the HACCP flow diagrams (*this is the path that food will follow through your business)
You’ll also need to reconsider the hazards involved, and…
Reconfirm your CCPs (or critical limits) and monitoring control measures
Finally, check whether your HACCP reflects what is happening day-to-day.

The key question to ask is this: Does your HACCP Plan still reflect how your business actually runs today?

Following your review, you will need to amend/update your HACCP Plan and your Food Safety Management System.

How Often Should Your HACCP Plan Be Reviewed?

You should review your HACCP Plan:

✅ At least annually – even if nothing seems to have changed. It’s good practice and shows due diligence.

✅ After any significant changes, such as:

- Ingredient, recipe or menu changes
- New allergens introduced because of new products or brands that you’ve purchased
- Buying new equipment (e.g. vacuum packing machine, blast chiller)
- Introducing new processes (e.g. cook–chill, sous-vide, or meat dry-ageing chamber)

✅ Before an EHO inspection or third-party audit (e.g. SALSA)

✅ After a complaint (e.g. hair in food) or alleged food poisoning claim (even if not confirmed), after a food allergen incident or near-miss, or…

✅ When you start supplying food to higher-risk settings like:

- Schools or nurseries
- Hospitals or care homes
- Or any other vulnerable population.

What Triggers a HACCP Plan Review?

Here are the red flags that mean your HACCP Plan needs to be reviewed. Think of these as triggers that prompt action:

⚡ New equipment (e.g. vacuum packer, blast chiller, sous-vide machine)
⚡ New processes introduced (e.g. reheating, dry ageing beef, food delivery)
⚡ Change in suppliers (e.g. UK to EU, or switching meat or fish sources)
⚡ New products or menu with different risks (e.g. steak tartare, shell-fish)
⚡ Changes to packaging of food products
⚡ Layout changes (e.g. opening a new prep area or site extension)
⚡ Staff role and/or responsibility changes (e.g. new organisational chart)
⚡ Supplying to new customer types (B2B: nurseries, care homes, franchises)
⚡ Changes to legislation
⚡ Emergence of a new risk
⚡Trends / patterns with corrective actions (e.g. customer complaints, product recalls)

Real Example (Name Withheld):
A restaurant group opened a new central production kitchen to serve their multiple takeaway outlets. They added vacuum packing equipment to reduce food waste. No one thought about the HACCP. So the HACCP Plan did not get reviewed and updated. This means that important safety measures to control the risk from vacuum packing were ignored.

During the EHO visit, the inspector identified the new vacuum packing process. As expected, vital controls were missing from the HACCP to make vacuum packing safe. Without these controls, vacuum packed foods lacked protection from the risk of Clostridium botulinum. The food hygiene rating dropped to a 1 score. As expected, the media named and shamed the business. This caused a bit of embarrassment about the drop in food hygiene rating. All of which, could have been prevented, if someone had reviewed the HACCP Plan before the EHO inspection.

Why Reviews Matter (Even When Nothing Changes)

Even if you haven’t made any significant changes, a HACCP Plan review still matters. You should review your HACCP Plan at least annually as a minimum. Here’s why:

Practices drift over time (especially with new staff)
What was once safe can become risky
An up to date HACCP Plan is a proactive way to protect your business and your customers BEFORE problems arise
Reviewing the HACCP Plan keeps your business legally compliant
It is needed as part of a due diligence defence
An out-of-date HACCP Plan may harm an insurance claim – your insurance company may refuse to pay out.

**EHOs expect to see evidence that your HACCP is being reviewed.

How to Stay on Top of HACCP Plan Reviews

Here are some simple ways to stay in control:

Set an annual reminder on your calendar. Remind yourself when your HACCP Plan is due to be checked
Print and pin up a list of HACCP Plan review triggers to remind key staff
Do a quarterly mini-review (does your system still match actual real life operations?)
Train staff to flag changes early.

**Use a HACCP Review Checklist (we’ll link this at the end).

Want Help?

If your HACCP Plan hasn’t been reviewed in over a year, or there’s been some other significant change (e.g. new equipment, processes, menu, premises layout or staff roles) – it’s time for a HACCP Plan Review.

We offer HACCP Plan Reviews as part of the services we offer – whether you’re on the high street or scaling to multiple sites. If you’re not sure where to start, just get in touch.

Find out more about our food safety consulting services.

Final Word: Don’t Wait for the Wake-Up Call

Your food hygiene rating doesn’t just reflect how clean your kitchen is – it reflects how well you run your business.

That means it’s vital that you review your entire Food Safety Management System — including your HACCP Plan.

An outdated HACCP Plan is one of the easiest ways to ruin your food hygiene rating. You could lose one star or more. Therefore – stay ahead. Check your HACCP before the EHO walks through the door.

⬇️ Free Resource: HACCP Review Trigger Checklist (Download)

✅ Not sure if your HACCP Plan needs reviewing?

Use this quick tick-box tool to spot the red flags before they harm your food hygiene rating. Don’t wait until it’s too late — a missed review can cost you.

👉 Download the HACCP Review Trigger Checklist, print it out and use today.

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