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Food safety planning and HACCP for a cider house

What does HACCP mean for a cider maker, and how is a food safety plan built?

In short

Hazard Analysis and Critical Control Point is the international method for food safety, set out by the Codex Alimentarius in its General Principles of Food Hygiene and adopted into national law in many countries. In the United Kingdom, for example, a food business’s safety system has to meet the HACCP principles.

In plain terms the principles are seven: identify the hazards, find the points where each must be prevented, removed or reduced, set a limit at each, monitor it, put checks in place that the system works, correct what goes wrong, and keep records of all of it.

Two things are commonly misunderstood. HACCP sits on top of good hygiene practice rather than replacing it, and most hazards in a well-run cider house are controlled by that practice rather than by a critical control point. And a plan is the output of one business’s analysis of its own fruit, process and product: a plan copied from a book or a website, this one included, has not been analysed at all.

The steps a hazard analysis walksTen steps from fruit to dispatch, each marked with the kinds of hazard a cider house’s own analysis would look for there. Examples, not a plan: no step is marked as a critical control point.Receiving fruitrot, soil, stonesMCPStoring fruitmould on damaged fruitMCWashing, sortingrotten fruit, debris outMCPMillingmetal, stones in the millPPressingcloths, surfaces, oilsMCJuice handlingsulphite dose, residuesMCFermentationvessel hygiene, residuesMCMaturationadditions, residuesCPackagingglass, over-pressureCPStorage, dispatchrefermenting packsPM microbiological · C chemical, allergensP physical · examples, not a plan
Ten steps from fruit to dispatch, each marked with the kinds of hazard a cider house’s own analysis would look for there. Examples, not a plan: no step is marked as a critical control point.
Described in full
Shape
A chain of ten steps top to bottom. Beside each are three slots for microbiological (M), chemical (C, which includes allergens) and physical (P) hazards; a slot carries its letter where that kind of hazard is an example at that step and is empty where it is not.
Receiving and storing fruit
Receiving: rot, soil and stones — all three kinds. Storing: mould growing on damaged fruit, which is microbiological and, because the mould that rots apples can make patulin, chemical too.
Washing and sorting
All three kinds. It is the step that removes soil, rotten fruit and debris, which is why it is so often where a cider house decides its fruit hazards are controlled.
Milling and pressing
Milling: physical — metal from the machine and stones that got past the wash. Pressing: microbiological and chemical — the hygiene of cloths and contact surfaces, and lubricants.
Juice handling, fermentation and maturation
Juice handling and fermentation: microbiological and chemical — the hygiene of vessels and lines, the sulphite dose, which is also an allergen to be declared, and residues of cleaning chemicals. Maturation: chemical — anything added, and residues.
Packaging, storage and dispatch
Packaging: chemical and physical — glass, and the pressure a pack will hold; the label is where the allergen declaration lands. Storage and dispatch: physical — a pack that is refermenting builds pressure it may not hold.
What it does not show
Which steps are critical control points, what the limits are, or how anything is monitored. Those are decided by a business for its own fruit, process and product, and a plan copied from a diagram has not been decided at all.

What is universal and what is local

The method is universal. The principles and the twelve steps that apply them come from one international text and read the same in every country that uses them; the FAO publishes a working guide organised around those steps.

The obligation is local. Whether a cider maker must have a written plan, what it must contain, whether a small business may use a simplified system, who inspects it and what happens if it is absent are matters of each jurisdiction’s law, and they differ. So does the line between a cider house and a farm selling a little cider at the gate, and between cider and juice, which some jurisdictions regulate under rules of their own. None of that can be read off this page. The responsible authority — in England the local authority’s food team, elsewhere its counterpart — is where it is established.

One trap for readers searching in North America: much of what is published there as cider HACCP guidance is about sweet cider, the fresh pressed juice sold at farm stands, not the fermented drink. Penn State Extension’s guidance for unpasteurised cider, for example, concerns pathogens such as E. coli O157:H7, Salmonella and Cryptosporidium in raw juice, and a federal requirement that wholesale producers include a step achieving a 5-log reduction in them. That is a juice plan. A fermented cider’s hazards, and the rules that apply to it, are not the same, and a plan written for one does not cover the other.

Good hygiene first

Before any hazard analysis there is a foundation of practice that every food business keeps whether or not it is a critical control point: clean premises and equipment, pest control, water fit for use, trained and healthy people, waste taken away, and suppliers who can be trusted. The Codex code is built this way, with good hygiene practices as its first part and the HACCP system as its second.

For cider the foundation is mostly what the cleaning and sanitation pages already describe. The difference HACCP makes is that it asks for the practice to be written, done the same way each time and checked, so that a clean vessel is a recorded fact rather than a belief.

Walking the process

The analysis starts from a flow diagram of the cider house as it actually runs — confirmed on the floor, not drawn from memory — and goes through it one step at a time asking what could be introduced, could grow or could survive there. Hazards are sorted into three kinds: microbiological, chemical (allergens and cleaning chemicals among them) and physical.

Each one found is judged for significance from how likely it is and how serious it would be. A hazard that is both unlikely and minor is still managed, by hygiene practice; one that is likely or serious enough is the kind for which a step may have to be controlled against a limit.

Hazards a cider house typically looks for

Example hazards by kind — what an analysis looks for, not what it concludes
KindExample in cider makingWhere it usually entersUsually managed by
ChemicalPatulin, a mycotoxin made by the mould that rots applesRotten or damaged fruitFruit selection, storage and sorting
ChemicalResidues of cleaning and sanitising chemicalsVessels, lines, fillersCleaning procedure and rinsing
Chemical (allergen)Sulphite above the declaration thresholdJuice treatment, additionsDose records and the label
MicrobiologicalContamination from soil and from dirty surfacesFruit, presses, clothsWashing, cleaning, the acid and alcohol of a finished cider
PhysicalStones, metal, woodFruit intake, millWashing, sorting, equipment maintenance
PhysicalGlass fragments; a pack that fails under pressurePackaging, refermentationGlass procedure, stabilisation, pressure-rated packs

Critical control points, limits and monitoring

A critical control point is a step at which control is essential to prevent a significant hazard, remove it or reduce it to an acceptable level. Not every step with a hazard is one: the FAO’s guide says plainly that some steps are fully controlled by good hygiene practice, and a plan that calls everything critical has made monitoring meaningless by making it universal.

Where a step is critical it carries a limit — the value that separates safe from unsafe — and a way of watching it: what is measured, how, how often and by whom. A limit is something the business establishes and validates for its own product, from legal limits where they exist, from published evidence and from guidance; a number is not a limit because it appears on a website. CiderHQ gives no limits here for that reason.

Each limit also has a corrective action written in advance: what is done to the product when the limit is missed, and what is done to the process so that it is not missed again.

Validation, verification and records

Validation comes first and asks whether the plan can work: whether the controls chosen are capable of controlling the hazards, on evidence, before the plan is used. Verification comes after and keeps asking whether it is working: records reviewed, instruments checked, the plan revisited whenever the fruit, the process, the equipment or the product changes.

Records are the last principle and the one that makes the others visible. They are what a business shows after an incident as evidence of how it kept food safe, and in a cider house they are largely the batch records it should keep anyway.

What a page cannot do

Nothing here is a food safety plan, and following it does not make a cider house compliant with any law. Whether a business needs a documented system, what form it may take and who approves it are set by the law of the place the cider is made and sold, and are established with the responsible authority. Training in HACCP, and in some places a recognised qualification, may also be required; this page is not that training.

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Sources

What this page rests on. Where a source is marked as registered rather than read, CiderHQ is recording that the body is authoritative on the subject without claiming to have worked through the document itself. See our evidence policy for what each state means.

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