Effective prerequisite programmes provide the foundation for non-food HACCP

Two recent developments from very different sectors demonstrate an important principle of HACCP: effective hazard management begins with strong prerequisite programmes.

One concerns a cosmetic product recalled because its fragrance concentration exceeded the safety limit for a leave-on facial product. The other is new government guidance covering the safe management of linen in adult social care.

Although the products and processes are very different, both demonstrate why businesses need reliable underlying controls before deciding whether any hazards require control at a critical control point.

A cosmetic oil was recalled after it was found to contain a fragrance concentration above the safety limit for leave-on facial products. The product could therefore cause skin irritation or an allergic reaction.

The case demonstrates that an ingredient cannot be assessed safely without considering:

• The type of product.
• Where the product is applied.
• Whether it is rinsed off or left on the skin.
• The concentration of the ingredient.
• The frequency and duration of exposure.
• The intended user.

A fragrance may be acceptable in one product category but unsuitable at the same concentration in another.

Effective prerequisite programmes should therefore include supplier approval, controlled formulations, accurate product classification, ingredient specifications, safety assessment, change control and final product release.

These controls provide the reliable information needed for hazard analysis. If the formulation, specification or intended use is inaccurate, the resulting risk assessment may also be wrong.

Read the official product recall notice

Government infection-control guidance published on 28 October 2026 also reinforces the importance of prerequisite programmes.

The guidance covers the classification, handling, segregation, washing and storage of linen in adult social care. It highlights controls such as bagging contaminated linen at the point of removal, separating clean and dirty items, using validated disinfecting cycles and ensuring staff receive appropriate training.

These controls are particularly important for commercial laundries serving care homes and similar organisations.

Read the government guidance on linen management

Biocontamination is clearly a major concern, but it is not the only type of hazard that a laundry may need to assess.

A HACCP study will consider biological hazards, including pathogens surviving an inadequate wash process or clean linen becoming recontaminated.

In addition HACCP also considers:

• Chemical hazards, including incorrect detergent or disinfectant dosing and unacceptable chemical residues.
• Physical hazards, including sharps or other foreign objects remaining within linen.
• Allergenic Hazards linked to both the product and the production environment.

It looks at the potential for hazards occurring at all stages in the production process from raw material supply, through production to finishing, storage, and delivery.

This breadth distinguishes HACCP from the Risk Analysis and Biocontamination Control system in BS EN 14065. RABC is specifically designed to control microbiological contamination in processed textiles. HACCP can provide a wider framework when biological, chemical and physical hazards all need to be considered.

The two approaches can complement each other. A laundry may use RABC to manage textile biocontamination while applying broader HACCP principles to its complete range of significant hazards.

Typically, hazards in the non-food sector are controlled through prerequisite programmes rather than being treated automatically as critical control points.

These programmes may include:

• Supplier and chemical approval.
• Linen classification and bagging arrangements.
• Clean and dirty area segregation.
• Equipment cleaning and maintenance.
• Water-quality management.
• Chemical storage and dosing controls.
• Pest control.
• Personal hygiene and protective clothing.
• Transport and vehicle hygiene.
• Staff training and competence.
• Traceability and load identification.
• Calibration and record control.
• Customer communication and service agreements.

The HACCP team should first establish whether these programmes control the relevant hazards effectively. Only then should it determine whether additional process controls or critical control points are required.

HACCP is not simply a document or a list of possible hazards. It is a structured process for understanding what could make a product or service unsafe, establishing suitable controls and verifying that those controls continue to work.

RI Training provides practical non-food HACCP training tailored to an organisation’s products, processes and risks.

Our training helps teams evaluate their prerequisite programmes, describe hazards accurately and develop controls that can be applied, monitored and verified in the workplace.

If your organisation manufactures non-food products or provides commercial laundry services, please contact RI Training to discuss a tailored HACCP programme.