Whether you run a restaurant, a bakery, a catering company or a small food factory, food safety paperwork can feel overwhelming. Certificate of Acceptability, R638, prerequisite programmes, HACCP plan… This guide explains in plain language what each one is, which applies to you, and how to build a HACCP plan step by step.
The basics every food business needs: R638 and the Certificate of Acceptability
Regulation R638 of 2018 (Regulations Governing General Hygiene Requirements for Food Premises, the Transport of Food and Related Matters) applies to every business that handles food for sale. Among other things it requires:
- A Certificate of Acceptability (COA) for the premises, issued by your municipality’s environmental health department after an inspection.
- A person in charge who has been trained in food safety.
- Trained food handlers, and hygiene rules for staff.
- Premises, equipment, cleaning, pest control, water, waste and temperature control that meet the hygiene standards.
Environmental health practitioners enforce R638 and can close premises that don’t comply.
Where does HACCP fit in?
HACCP (Hazard Analysis and Critical Control Points) is an internationally recognised system for identifying and controlling food safety hazards, whether biological, chemical, physical or allergens, at the points in your process where they matter most.
In South Africa, Regulation R908 of 2003 deals with the application of HACCP, and the national standards SANS 10049 (prerequisite programmes) and SANS 10330 (HACCP) set out the requirements. Beyond the legal side, retailers, franchise groups, hotels and export customers routinely require their suppliers to have a documented HACCP-based food safety system. For a growing food business, it’s often the difference between getting a supplier listing and not.
Prerequisite programmes to have in place first
- Cleaning and sanitation, with schedules and records
- Pest control
- Personal hygiene, health of food handlers and protective clothing
- Temperature control for receiving, storage, cooking, cooling and display
- Supplier approval and receiving checks
- Allergen management
- Water quality, waste management and maintenance
- Training, traceability and product recall
How to build a HACCP plan: 5 preliminary steps and 7 principles
Preliminary steps
- Assemble the HACCP team: people who know the products and the process.
- Describe the product: ingredients, packaging, storage conditions and shelf life.
- Identify the intended use and consumers: for example ready-to-eat food, or food for vulnerable groups.
- Draw a flow diagram of every step, from receiving to dispatch.
- Check the flow diagram on the floor to make sure it matches what really happens.
The seven HACCP principles
- Conduct a hazard analysis: list the hazards at each step and how they will be controlled.
- Determine the critical control points (CCPs): the steps where control is essential, such as cooking or chilling.
- Set critical limits for each CCP, for example a core temperature of at least 75 °C.
- Monitor each CCP: who checks, how and how often, and where it’s recorded.
- Set corrective actions for when a limit is not met.
- Verify that the system works through internal audits, calibration and record reviews.
- Keep documentation and records that prove all of the above.
Common gaps we find in food safety files
- A HACCP plan copied from another product, with CCPs that don’t match the actual process
- Temperature logs filled in all at once at the end of the week
- No calibration records for thermometers
- Cleaning schedules with no sign-off
- Food handler training not recorded
- No allergen information for staff or customers
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Frequently asked questions
Is HACCP compulsory in South Africa?
All food premises must meet the hygiene requirements of R638. Regulation R908 of 2003 sets out how a HACCP system must be applied where one is required, and in practice most retailers, franchise groups and export customers require their suppliers to have one. Check with your environmental health practitioner or your customer for your specific situation.
What is a Certificate of Acceptability?
It is a certificate issued by your municipality’s environmental health department confirming that your food premises meets the hygiene requirements of R638. You need it before you start trading.
What is the difference between a PRP and a CCP?
Prerequisite programmes (PRPs) are the basic conditions for hygiene across the whole operation, such as cleaning and pest control. A critical control point (CCP) is a specific step in your process where control is essential to prevent or remove a food safety hazard.
How often should a HACCP plan be reviewed?
At least once a year, and whenever you change a product, recipe, supplier, equipment or process, or after a food safety incident or complaint.
Do small restaurants need a HACCP plan?
Every restaurant must comply with R638 and hold a Certificate of Acceptability. A simple HACCP-based plan for your key risks (cooking, cooling, reheating and hot and cold holding) is the easiest way to prove you control them, and inspectors and franchise auditors like to see one.
