Foodservice HACCP Procedures: What to Cover

The regulations do not give a list of HACCP procedures that a foodservice venue must have in writing. They require procedures based on the HACCP principles (Art. 5 of Regulation 852/2004) and compliance with the hygiene conditions of Annex II, and which of them you describe in your documents follows from the hazard analysis in your venue. This post is a map: it shows 16 procedures that are usually described in foodservice, with the legal basis for each and a link to the post that develops the topic.

In brief

• Art. 5 of Regulation 852/2004 requires a procedure or procedures based on the HACCP principles and documents proportionate to the nature and size of the venue. It does not specify a list of procedures or a number of documents.
• Annex II to the regulation uses the word "procedures" directly for, among other things, pest control (Chapter IX, point 4). In other areas, for example in cleaning or waste, it sets requirements to be met, and leaves the way of describing them to you.
• The Act on Food and Nutrition Safety directly requires in writing documentation of training or instruction and medical certificates (Art. 59(2)-(5)).
• The European Commission recommends documenting good hygiene practices, but allows simplifications in small businesses (Notice 2022/C 355/01, not legally binding).
• A procedure that works answers the questions: who, with what, how often, where do they record and what do they do when something deviates from the norm.

What the regulations say about HACCP procedures

HACCP-based procedures. Art. 5(1) of Regulation (EC) No 852/2004: food business operators put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles. Para. 2 lists these principles (points (a)-(g)), and point (g) requires documents and records proportionate to the nature and size of the food business. Art. 5(4)(b): every document describing the procedures must be kept up to date at all times. The obligation applies to stages after primary production (para. 3), that is, also to foodservice venues.

Hygiene conditions. Annex II to this regulation contains general hygiene requirements for all food businesses: premises, equipment, waste, water, personal hygiene, handling of food and training. It uses the word "procedures" itself sparingly there: it directly requires adequate procedures for pest control and for preventing domestic animals from entering (Chapter IX, point 4). The rest are requirements, for example that equipment must be cleaned at a frequency that prevents contamination (Chapter V, point 1(a)). How you meet and describe them is your procedure.

Traceability and withdrawal. Art. 18(2) and (3) of Regulation (EC) No 178/2002: you must establish systems and procedures to identify suppliers and recipients of food and make this information available to the authorities on request. Failing to carry out the identification of suppliers or recipients contrary to Art. 18 is a petty offence under Art. 100(1)(7) of the Act on Food and Nutrition Safety. Art. 19(1): when you have reason to believe that food does not meet food safety requirements, you initiate procedures to withdraw it and inform the competent authorities; the provision requires that the procedures be initiated "immediately". Restaurants are counted as retail (Art. 3(7)), and the operator responsible for retail activities initiates, within the limits of its activity, procedures to withdraw products that do not meet the requirements (Art. 19(2)).

The Polish Act. Art. 59(3) of the Act on Food and Nutrition Safety: compliance with the requirements concerning supervision and training (Annex II, Chapter XII) is confirmed by documentation of training carried out or instruction given. Art. 59(2), (4) and (5): medical certificates for sanitary-epidemiological purposes and training documentation are kept in the personnel files, and their copies are at the place of work. Art. 59a: operators of foodservice establishments are to take into account in the procedures on good hygiene practice and the HACCP principles the right of entry of people with disabilities with an assistance dog. Art. 100(1)(8): failing to implement HACCP-based procedures contrary to Art. 5 of Regulation 852/2004 is a petty offence punishable by a fine.

Interpretation without legal force. Commission Notice 2022/C 355/01 observes that Regulation 852/2004 contains no explicit requirement to document good hygiene practices, but it is hard to carry out a hazard analysis and demonstrate compliance without documents and records. It recommends that good practices be documented in a GHP plan, which may be part of the HACCP plan, and that the documentation cover the practices applied, work instructions, verification activities and anticipated corrective actions. At the same time it allows flexibility: in very small businesses it may not be necessary to have documented cleaning procedures, as long as staff can always explain how cleaning and disinfection are carried out. How a sanitary station assesses this in practice, we did not check, so in case of doubt it is safer to have the procedures described.

A list of HACCP procedures in foodservice and their basis in the regulations

The list below is our division into procedures, not a list from the regulations. The column "basis" shows from which requirement each procedure follows. The names of the procedures and their layout are industry practice.

Procedure	Basis in the regulations	What you usually describe	Detailed post
1. Hazard analysis and critical control points (CCP)	Art. 5(1)-(2) of Reg. 852/2004	Description of the venue and processes, hazards, CCPs, limits, monitoring, corrective actions, verification	7 HACCP principles, CCPs in foodservice
2. Goods receiving	Annex II, Chapter IX, point 1; Art. 18(2) of Reg. 178/2002	What you check at delivery, when you reject a batch, how you record the supplier	goods receiving
3. Storage and the cold chain	Annex II, Chapter IX, points 2 and 5; Chapter I, point 2(d)	Where and in what conditions you keep raw materials, who checks the temperature of the appliances and how often	temperature register, temperature table
4. Chilling and thawing	Annex II, Chapter IX, points 6 and 7	How quickly and where you chill ready dishes, how you thaw and what you do with the drip	freezing and thawing
5. Separation of raw and ready-to-eat, zones	Annex II, Chapter IX, point 3	Kitchen zones, board colours, flow routes, order of work	zones in the kitchen, board colours
6. Allergens and cross-contamination	Annex II, Chapter IX, point 9 (concerns only cleaning of equipment after products with an allergen); allergen list and informing guests: outside the scope of this post, we did not check Regulation 1169/2011	Allergen list in dishes, cleaning equipment after products with an allergen, informing the team	allergen cross-contact, allergens in the menu
7. Cleaning and disinfection	Annex II, Chapter V, point 1(a); Chapter I, point 10	What, with what, how often and who cleans; where you store chemicals (not in food work areas)	cleaning and disinfection
8. Personal hygiene and state of health	Annex II, Chapter VIII, points 1-2; Art. 59(2) of the Act	Clothing, hand washing, reporting symptoms of illness, medical certificates	hand washing, staff hygiene, sanitary examinations
9. Training and supervision	Annex II, Chapter XII; Art. 59(3)-(5) of the Act	Who is trained, when and how, how you document instruction	HACCP training, onboarding
10. Pest control	Annex II, Chapter IX, point 4	Building protection, inspections, who reacts to signs of pests, no access for domestic animals	pest control in foodservice (DDD)
11. Waste	Annex II, Chapter VI	Containers, frequency of removal from the kitchen, place of waste storage	No separate blog post
12. Water	Annex II, Chapter VII, point 1	Source of drinking water, how you look after its quality where it comes into contact with food	water in foodservice
13. Batch traceability	Art. 18 of Reg. 178/2002	How you identify suppliers and recipients, what documents you keep	batch traceability
14. Food withdrawal and incidents	Art. 19 of Reg. 178/2002	Who decides on a withdrawal, how you inform the authorities and guests, how you proceed in case of suspected poisoning	food withdrawal, suspected poisoning
15. Entry of people with an assistance dog	Art. 59a of the Act	Rules of entry for people with disabilities with an assistance dog, taken into account in the GHP and HACCP procedures	See the paragraph "The Polish Act" above
16. Review and updating of documents	Art. 5(2) in fine and (4)(b) of Reg. 852/2004; Annex II, Chapter XIa, point 2(b) and (c) (integrity of the system when changes are made, checking that the documentation is up to date)	Who reviews the procedures and when, what triggers a change, how you confirm that they are up to date	when to update HACCP, food safety culture

We found no number of procedures in the regulations that a venue must have. The scale depends on the menu, the processes and the size of the business, and the documents are to be proportionate to them (Art. 5(2)(g)).

How to write a procedure that works and is not a horoscope

A good procedure is short and answers six questions. If one answer is missing, the team will guess.

1. What does it concern? One activity or area, for example washing boards, not "hygiene in general".
2. Who is responsible? A specific role (the cook on shift, the manager), not "staff".
3. When and how often? For example after each shift or at each delivery.
4. How and with what? Steps, equipment and agents from your venue.
5. What do you record and where? The name of the register, the columns, who signs. The Commission Notice allows electronic registers if they can be made available to the authority on request.
6. What do you do when something deviates from the norm? A corrective action and a record. Art. 5(2)(e) of Regulation 852/2004 requires this for critical points, and in practice it is worth having for the other procedures too.

An illustrative, made-up example: instead of the sentence "disinfect surfaces regularly" you write that work counters are washed and disinfected with the preparation used at the venue after each shift by the person closing the kitchen, and the performance is confirmed by a signature in the cleaning card. Then a new person knows what to do, and the inspector sees how to check it.

Procedure, instruction, register and HACCP plan: how to tell them apart

• Procedure: a description of how and when a given activity is performed and who is responsible for it.
• Workstation instruction: a shortened version of the procedure for the person at the workstation, often posted in the kitchen.
• Register or card: a form for records of the performance of the activity and of deviations. We discuss examples of forms in the post on free HACCP forms.
• HACCP plan and GHP plan: according to the Commission Notice, a GHP plan is the documentation and records presenting the good hygiene practices applied, and it may be included in the HACCP plan. The full layout of the documentation is shown by the post what HACCP documentation must contain.

Where to start with procedures in the venue

This is our proposal for the order, not a requirement from the regulations. First describe the venue and the processes and carry out a hazard analysis, because it will show which procedures you really need and where you need critical points. Then put the good hygiene practices in order (items 2-12 of the table), and finally add traceability, withdrawal and review of documents. The implementation steps are described in the post implementing HACCP step by step, and the elements of a hygiene plan in the post hygiene plan for foodservice. If you run a small venue, start with the simple version of HACCP.

Where GastroReady comes in

The Foundation package (299 PLN) contains a HACCP book with a GHP and GMP part, registers and procedures, workstation instructions in the Polish version and an implementation guide. The Shield package (449 PLN) adds Support from a GastroReady expert, an English version of the instructions, a pre-inspection checklist and an allergen guide. The Fortress package (749 PLN) adds BDO (Poland's waste database register) documents. Each package requires adaptation to your venue and keeping records every day, and the documentation is evidence of diligence, not a guarantee of the inspection result. The documents are sent by e-mail after payment.

Frequently asked questions

What HACCP procedures must a restaurant have?

The regulations give no list. They require a procedure or procedures based on the HACCP principles (Art. 5 of Regulation 852/2004) and compliance with the hygiene conditions of Annex II. The Act directly requires in writing documentation of training and medical certificates (Art. 59), and the other procedures follow from the hazard analysis in your venue. An overview of 16 typical procedures is in the table above.

Must HACCP procedures be in writing?

The regulation assumes documents describing the procedures, proportionate to the size of the business, and requires that they be kept up to date at all times (Art. 5(2)(g) and (4)(b)). We found no provision that would require every hygiene procedure to be written down separately, and the Commission Notice allows simplifications in very small businesses. In case of doubt it is more practical to describe the procedures, because it is easier to show that they work.

What is the difference between a procedure, an instruction and a register?

A procedure describes who performs an activity, when and how. A workstation instruction is a shortened version of it for the employee at the workstation. A register is a form in which you record the performance of the activity and any deviations. This is a practical division, the regulations do not define them this way.

How many procedures should a small venue have?

There is no number in the regulations. Documents and records are to be proportionate to the nature and size of the business (Art. 5(2)(g)), so a small bar with a short menu will describe fewer than a large kitchen with heat treatment of many groups of products. You start with the hazard analysis and on its basis choose the procedures.

Must procedures take assistance dogs into account?

Yes, if you run a foodservice establishment. Art. 59a of the Act on Food and Nutrition Safety obliges operators of food trade or foodservice establishments to take into account in the procedures on good hygiene practice and the HACCP principles the right of people with disabilities with an assistance dog to enter and use the establishment.

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Legal status as of: 5 November 2026
Legal basis: Regulation (EC) No 852/2004 (consolidated text of 24.03.2021, we found no newer consolidated version at the Publications Office): Art. 5(1)-(4), Annex II, Chapter I, point 2(d) and point 10, Chapter V, point 1(a), Chapter VI, Chapter VII, point 1, Chapter VIII, points 1-2, Chapter IX, points 1-7 and 9, Chapter XIa, Chapter XII; Regulation (EC) No 178/2002 (consolidated text of 1.01.2026): Art. 3(7), Art. 18(2)-(3), Art. 19; Act on Food and Nutrition Safety of 25 August 2006 (consolidated text Journal of Laws (Dz.U.) 2026, item 1399, status as of 28.09.2026): Art. 59(2)-(5), Art. 59a, Art. 100(1)(7) and (8); Commission Notice 2022/C 355/01 (guidance without legal force): Annex I, point 5 and the definition of a GHP plan. The division into 16 procedures, their names, the example and the order of implementation are our proposal and industry practice, not a legal provision. We did not check good hygiene practice guides, guidelines of the Chief Sanitary Inspectorate (GIS), case law, the practice of specific sanitary stations or Regulation 1169/2011 (allergen information). We did not check provisions on waste other than Annex II, Chapter VI.
Last review: 5 November 2026