How Do Critical Control Points Fit Into Standard 3.2.2A Compliance?

Use CCPs to strengthen food safety measures in your business.
January 23, 2023

If you're in the food industry, chances are you've encountered the term "critical control points" or CCPs. But how do these essential elements of food safety intersect with Australia's newly updated Food Safety Standard 3.2.2A? Let's delve in.

What Are CCPs & Why Do They Matter?

A critical control point is a specific stage in your food production or handling process where action can be taken to prevent or significantly reduce a food safety hazard. Whether it’s biological risks like bacteria, chemical contaminants, or physical threats like foreign objects, understanding critical control points allows you to make your food safe for consumption.

For example, in a restaurant, these are some of the CCPs:

  • Receiving supplies: Ensuring meat is delivered at the right temperature.
  • Cold storage: Regulating fridge temperatures to inhibit bacterial growth.
  • Food preparation: Mitigating cross-contamination, particularly on surfaces where both raw and cooked foods interact.
  • Cooking process: Verifying that foods are cooked to a safe internal temperature to kill off harmful pathogens.

How HACCP Fits In

Critical control points are one key component of the globally recognised Hazard Analysis and Critical Control Point (HACCP) system, built on seven guiding principles:

  1. Perform a Hazard Analysis: Recognise potential hazards in food production and handling—these could be biological, chemical, or physical.
  2. Pinpoint Critical Control Points: Identify the stages where action can effectively mitigate or eliminate the risks.
  3. Set Critical Limits: Outline the specific criteria—like cooking temperatures—that ensure food safety at each critical control point.
  4. Develop Monitoring Protocols: Keep tabs on these critical limits through methods like temperature checks or visual inspections.
  5. Plan Corrective Measures: Know what actions to take if monitoring indicates a deviation from the set limits.
  6. Verify Procedures: Periodic checks to make sure your HACCP system is doing its job, which can include record reviews, additional testing, and audits.
  7. Keep Records: Maintain meticulous documentation that validates your food safety system, from hazard analyses to corrective actions.

How Do CCPs Work in a Real Food Handling Scenario?

In food businesses, there are many possible critical control points. Here’s an illustration of how a CCP looks in a real food business. The CCP in this case is steaming milk to a specific temperature.


In a coffee shop, one of the popular orders is a latte, which involves steaming milk to mix with espresso. The process of steaming milk is a critical control point because it involves bringing the milk to a specific temperature to ensure both safety and quality.


The primary hazard in this scenario is microbiological. If the milk is not steamed to the correct temperature, there's a risk of bacterial growth, which could lead to foodborne illnesses.

Critical Limit

The milk must be steamed to a temperature range between 150°F (65°C) and 165°F (74°C). This range is sufficient to kill most bacteria while preserving the milk's quality and flavour.


Baristas are trained to use a food-grade thermometer to check the temperature of the steamed milk immediately after steaming. This check is documented for each batch of steamed milk.

Corrective Actions

If the milk does not reach the required temperature range, it must be discarded, and the steaming process starts over with fresh milk. Additionally, the steaming equipment is checked to ensure it is functioning correctly.


Regular audits are conducted to review the temperature logs and observe the milk-steaming process. These audits confirm that the CCP is effectively managed.


All temperature readings and any corrective actions are recorded in a logbook. This documentation can later serve as evidence of due diligence during health inspections.

By identifying and properly managing this critical control point, the coffee shop ensures that it serves delicious and safe lattes to its customers, thereby adhering to food safety standards and regulations.

Understanding and implementing such critical control points can significantly affect the quality and safety of the food and beverages served, aligning well with regulatory compliance and customer satisfaction.

The Link to Australia's Food Safety Standard 3.2.2A

Standard 3.2.2A calls for a Food Safety Supervisor, training for all Food Handlers, and in many cases, keeping thorough records of food safety practices. Understanding and managing critical control points is crucial for aligning with these new mandates, particularly if your operation falls under category one.

The Standard's Additional Safety Tools:

  • Food Safety Supervisor: Every food business must have a certified individual responsible for overseeing food safety.
  • Food Handler Training: Staff must be appropriately trained in managing food safety risks.
  • Record Management: Keep logs of food safety measures for compliance purposes.

Keeping track of Critical Control Points (CCPs) can substantially assist in meeting the record-keeping requirements of Australia's Food Safety Standard 3.2.2A. The standard mandates thorough documentation of food safety practices, a criterion where CCPs naturally fit. 

For each CCP in your operation—be it cooking temperatures, storage conditions, or sanitisation processes—you would typically document essential data like temperature readings, time stamps, and any corrective actions taken. These detailed logs can then become a pivotal part of your food safety records, fulfilling the documentation mandate of the standard. Such comprehensive tracking makes verification easier during audits and inspections, and streamlines compliance efforts.

Optimise Food Safety with Critical Control Points

Mastering Critical Control Points (CCPs) is crucial for complying with Australia's updated Standard 3.2.2A and elevating your food safety protocols. This is especially significant for category one businesses, where CCPs can significantly transform your approach to food safety.

Enhance Your Expertise in CCPs with AIFS

Advance your food safety proficiency by enrolling in specialised training courses from the Australian Institute of Food Safety. These courses, compliant with Standard 3.2.2A and all state and territory regulations, cater to both Food Handlers and Food Safety Supervisors. Dive deep into vital subjects such as CCPs to ensure your team not only meets but surpasses current regulatory standards.

Frequently Asked Questions

How can businesses apply CCP identification in services that don't involve cooking, like raw food or cold-pressed juice establishments?

For businesses involved in non-cooking services like raw food or cold-pressed juice production, CCP identification focuses on areas critical to preventing foodborne illness. This includes the selection and handling of raw materials, cleaning and sanitising of equipment and temperature control during storage and distribution.

Establishments can apply HACCP principles by identifying steps in their process where hazards can be prevented, eliminated, or reduced to safe levels, ensuring the safety of their products.

What are the specific documentation requirements for CCPs under Standard 3.2.2A, and how frequently must records be updated or reviewed?

Under Standard 3.2.2A, documentation for CCPs must include details of the hazard being controlled, the control measures, critical limits, monitoring procedures, corrective actions, verification activities, and records of monitoring.

The frequency at which these records need to be updated or reviewed depends on the nature of the food business and the specific risks involved, but it is generally recommended to review them regularly to ensure ongoing compliance and effectiveness of the food safety program.

Can the implementation of CCPs affect a business's insurance premiums or liability in the case of a food safety incident?

Yes, the implementation of Critical Control Points (CCPs) can positively impact a business's insurance premiums and liability. Demonstrating a proactive approach to managing food safety risks through effective CCP implementation can lead to lower insurance premiums, as it shows the business is taking steps to minimise risk.

Moreover, in the event of a food safety incident, having a well-documented and implemented CCP plan can help in demonstrating due diligence and compliance with food safety regulations, potentially reducing liability.