Codex Brings Back the Decision Tree: Identifying CCPs after the 2022 Update

The 2020 revision of the Codex General Principles of Food Hygiene was published without the familiar decision tree. In 2022 Codex adopted a new one as an annex.

Key points

  • The 2022 update of CXC 1-1969 adds a new decision tree for identifying critical control points.
  • The tree is an aid; Codex does not make its use mandatory.
  • The first question now asks whether good hygiene practices already control the hazard.

Why it matters

Many HACCP teams learned to identify CCPs with the earlier Codex tree, and many procedures still reproduce it. The new tree reflects the 2020 text, in which good hygiene practices carry more weight.

How the new tree works

The tree is applied to each significant hazard at each step. It asks whether the hazard can be controlled to an acceptable level by prerequisite programmes, whether a specific control measure exists at the step, whether control at this step is necessary for safety, and whether a later step will control the hazard.

What to do

  • Check which decision tree your HACCP procedure refers to
  • If you change it, repeat the CCP determination and record the reasoning
  • Keep the hazard analysis as the basis: the tree does not replace it
  • Train the HACCP team on the change before the next review

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