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HACCP self-monitoring in a food business

HACCP self-monitoring for SMEs: duties under the LMG and LGV, good procedural practice, industry guidelines, HACCP plan, measurements and records.

Editorial team KMU | base – technically reviewed by an HR specialist from the founding team with experience in accounting and auditing

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Anyone who produces, stores, transports or places food on the market must make sure themselves that it is safe. Official inspection does not replace this duty; day-to-day safety is the business’s responsibility. This guide shows what HACCP self-monitoring requires under Swiss law (the Foodstuffs Act speaks of “self-supervision”), how good procedural practice differs from the HACCP plan, how a very small business can proceed and what has to be documented.

The duty of self-monitoring

The Foodstuffs Act (LMG) states in Art. 26, para. 1: anyone who produces, handles, stores, transports, places on the market, imports, exports or carries in transit foodstuffs or utility articles must ensure that the statutory requirements are complied with; they are obliged to carry out self-supervision. Official inspection does not release them from this (para. 2). The Federal Council regulates the details and provides for simplified self-supervision and simplified written documentation for micro-businesses (para. 3).

The details are in the Foodstuffs and Utility Articles Ordinance (LGV). A responsible person must be designated for every business; if there is none, the management of the business or company is responsible for product safety (Art. 73 LGV). This person checks compliance with the requirements or has it checked, and takes action immediately in the event of deviations (Art. 74, para. 2 LGV). Self-supervision must be adapted to the safety risk and the scale of production (Art. 74, para. 4 LGV).

For food businesses, Art. 75 LGV specifically includes: good procedural practice including protection against deception, the HACCP system or its principles, sampling and analysis, traceability, withdrawal and recall, and documentation. A micro-business under Art. 2, para. 1, point 6 LGV is a business with up to nine employees.

Good procedural practice and industry guidelines

Good procedural practice is the foundation. It consists of good hygiene practice and good manufacturing practice (Art. 2, para. 1, point 8 LGV). Under Art. 76, para. 2 LGV, good hygiene practice includes, among other things, cleaning and disinfection, waste and pest management, process control, personal hygiene, staff training, transport and labelling. The FDHA Hygiene Ordinance (HyV) adds to this: the responsible person must ensure that employees who handle food are supervised according to their activity and are instructed or trained in food hygiene (Art. 22, para. 1 HyV). Keeping food cold and hot must be secured with suitable temperature-measuring devices and checked as part of self-supervision (Art. 27, para. 3 HyV).

Many businesses do not have to reinvent the wheel. Under Art. 80 LGV, the food industry can draw up industry guidelines, which the Federal Food Safety and Veterinary Office (BLV) approves. According to the BLV’s information, the trade associations draw up these guidelines and make them available to businesses; the law in force always takes precedence. For the hospitality industry, for example, there is the guideline “Gute Verfahrenspraxis im Gastgewerbe” (good procedural practice in the hospitality industry, GVG), which the BLV approved again on 21 September 2018. Businesses that do not use an industry guideline must develop and follow an equivalent concept of good procedural practice adapted to the business (Art. 66, para. 5 HyV). The guidelines may provide simplified requirements for micro-businesses (Art. 80, para. 4 LGV).

HACCP: the seven principles

Anyone who produces, processes or treats food must apply procedures based on the HACCP system or its principles, in a form adapted to the safety risk and the scale of production (Art. 78, paras. 1 and 2 LGV). Exempt are primary production and producers who supply consumers directly or via local retail businesses exclusively with small quantities of primary products they have produced themselves (Art. 78, para. 3 LGV).

Art. 79, para. 2 LGV names the components of the HACCP principles:

PrincipleKey question in the business
1. Identify and assess hazardsWhat can go wrong (biological, chemical, physical)?
2. Determine critical control points (CCPs)Where must there be targeted control so that the hazard is under control?
3. Set maximum values (“critical limits”)From which value is it no longer acceptable?
4. Establish monitoringWho measures what, how often and with what?
5. Establish corrective actionsWhat happens in the event of a deviation?
6. Establish verificationHow is it checked that the system works?
7. Create documents and recordsWhat provides the evidence?

The verification under principle 6 must be carried out regularly and without delay if a change in the production process could impair the safety of the food (Art. 79, para. 3 LGV).

Traceability, recall and records

Food must be traceable at all stages of production, processing and distribution. Anyone trading in it must be able to tell the cantonal enforcement authority from whom they obtained it and to whom they supplied it; direct supply to consumers is excluded (Art. 83, paras. 1 and 2 LGV). How to count stock per batch is shown in the guide Stocktaking in the warehouse.

If the person responsible in a business discovers, or has reason to assume, that foodstuffs or utility articles imported, produced, processed, treated, supplied or distributed by the business have endangered or may endanger health, and they are no longer under the direct control of the business, they must inform the cantonal enforcement authority without delay, take the products off the market (withdrawal) and, if the products may already have reached consumers, recall them and inform consumers of the reason for the recall (Art. 84, para. 1 LGV).

The self-supervision concept and the measures must be documented in writing or by equivalent procedures, in a form adapted to the risk and the scale (Art. 85, paras. 1 and 2 LGV). Micro-businesses can reduce the documentation appropriately (Art. 85, para. 3 LGV). The records of the HACCP system must be kept up to date and retained for an appropriate period (Art. 79, para. 4 LGV). The provision does not name a fixed number of years.

Practical example: Catering Muster GmbH

Catering Muster GmbH is a fictitious company with seven employees and thus a micro-business. It cooks lunches for two day-care centres and delivers them chilled. The industry guideline for the hospitality industry serves as the basis. The managing director is the responsible person.

For the dish “Poulet-Geschnetzeltes” (sliced chicken), she describes the steps goods receipt, cooking, cooling, chilled storage and delivery. When cooking, she sees the hazard “pathogens survive” (biological). She rates likelihood 3 and severity 4, that is 3 × 4 = 12. The decision tree leads to a critical control point. The values in the following table are example values of the fictitious business, not statutory requirements; the industry guideline and the notes of the cantonal authority are decisive.

CCPParameterLimit (example)MonitoringCorrective action
CookingCore temperatureat least 75 °Cper batch, probe thermometerkeep cooking, measure again
CoolingTemperature after time windowat most 5 °C after 90 minutesper batchdiscard batch or reassess

On Tuesday, 3 November 2026, the cook measures 68 °C. She must not deliver the batch, keeps cooking and after ten minutes measures 77 °C again. Because the first value was outside the limit, she must record the corrective action. Four times a year the managing director compares the thermometer with a reference device (verification). If the business changes the recipe or the cooking process, she reviews the plan without delay (Art. 79, para. 3 LGV).

Checklist

  • Responsible person designated (Art. 73 LGV)
  • Industry guideline chosen or equivalent own concept drawn up
  • Staff trained and supervised, training recorded
  • Hazard analysis drawn up per product or product group
  • Critical control points set with limit, monitoring, corrective action and verification
  • Temperature-measuring devices available and calibrated
  • Traceability: sourcing and delivery can be evidenced
  • Procedure for withdrawal and recall defined, contact at the cantonal authority known
  • Plan reviewed after every change to the process
  • Documentation appropriate to the size of the business, records retained

How KMU | base helps

QMS | base maps the steps of self-monitoring in the HACCP module. It is a working tool and replaces neither the industry guideline nor professional assessment.

1. Activate the industry package. Under Operations and records › Industry packages (in the area “More”) you activate the package “Food and hospitality” with “Activate and load templates”. It creates model processes, document drafts and requirements as drafts, which you review professionally and adapt. Activating requires the right for the QMS settings. After that, “Open specialist module” opens the HACCP module.

2. HACCP plan. You record process steps and hazards, decide with a decision tree whether a step is a critical control point, and set limits, monitoring and corrections. The plan is approved under the four-eyes principle: whoever edited it last cannot approve it themselves, and every change returns the plan to draft. The PDF output is structured by the seven principles. The decision tree with four questions and the assessment levels are QMS | base’s own definitions; they do not replace professional assessment.

3. Monitoring. Employees record measured values at the control points. If a value lies outside the limit, the software requires the correction taken and creates an action. Persons responsible receive a notification when measurements are overdue.

4. Verification. For each control point you record the verification with date and result; the next due date follows from the chosen interval, and the responsible person is notified when it falls due.

5. Withdrawal and recall. You record cases with the batches concerned, see origin, subsequent batches and customers, and block the batches, together with subsequent batches if you wish. A case is closed only after the effectiveness check. Traceability is only as complete as the batch movements recorded. The software does not take the notification of the cantonal authority off your hands; if a hazard to consumers is stated and no notification date has been recorded yet, a note reminds you to check the notification of the authority.

If you would like to try it yourself, take a look at the demo or open a trial account. You will find current terms under Pricing; if you have questions, the contact page will help.

Sources

This guide does not replace legal or tax advice. Information as at 27 October 2026.

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