A food business must include refrigerated storage in its hazard analysis. This does not mean that every cold room is automatically a Critical Control Point (CCP).

In short: control of the cold room comes from the site's HACCP procedure. Define the correct conditions for each product, how they are monitored, who responds to a deviation and which records prove that the actions were completed.

What must be defined?

Regulation (EC) No 852/2004 requires permanent procedures based on HACCP principles. The analysis of the actual process determines whether refrigerated storage is a CCP, another control point or part of the business's prerequisite hygiene programme.

For each cold room, document at least:

which products are stored and their required temperature range;
where, how and with which instrument temperature is measured;
how often the result is checked;
who responds to an alarm or limit breach;
how product safety is assessed;
which records are kept and for how long.

Monitoring and retention must be proportionate to risk and match the site's procedure. EU food-hygiene law does not set one universal reading frequency or a general rule to retain every record for “two years beyond shelf life”.

Three parts of temperature control

Limit or action range — set for the specific food from applicable law, the label, supplier specifications and the hazard analysis.
Monitoring — who measures, where, with which instrument, how often and where the result is recorded.
Action after a deviation — protect the product, confirm the reading, assess time and temperature, make a decision and remove the root cause.

Even where a room is not formally a CCP, its temperature must still be controlled well enough to protect the product.

What should the cold room provide in practice?

stable conditions suitable for the product;
a representative place and method for measurement;
an alarm or another reliable way to detect a deviation;
hygienic surfaces with access for cleaning;
separation of products that must not contaminate each other;
records of temperature, alarms, instrument checks, cleaning and repairs;
a plan for protecting stock during a breakdown or power loss.

The controller displays the temperature at its sensor. It does not automatically represent every product in the room. During a deviation, measure in accordance with the site procedure and consider the thermal response of the food itself.

Authoritative sources

This is general guidance. The site's procedure must reflect the business, the products and all applicable sector requirements.

What must be defined?

Three parts of temperature control

What should the cold room provide in practice?

Authoritative sources

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