INTRODUCTION HACCP and HARPC share more than just four letters. They’re both food safety standards based on prevention, but they do differ on execution. Their differences and the similarities aren’t as important as the way they fit together for most food processors, though. A HARPC plan shouldn’t be considered as a replacement, but as a necessary upgrade to the conventional HACCP plan. Understanding how the systems fit together is the first step toward implementing both. Key Comparison Points: (1) Is the preventative approach based on a standard, guideline or a set of laws? (2) What food safety risks are considered using the preventative approach? (3) What is the goal of the preventative approach? (4) Who is primarily responsible for the development and maintenance of the preventive plan? (5) At what frequency is the preventive plan being reviewed by the facility? (6) The plan is mandatory for what type of establishments? (7) The plan is excluded or exempted for what type of establishments? (8) Who is the interested party here? For whom is the plan for? (9) What is the documented approach for making the preventive plan? HACCP Based on a guideline recommended by CODEX and NACMCF Conventional – Biological, Chemical, and Physical To prevent, eliminate (or) reduce hazards to a safe level (in that priority) Primarily, a competent HACCP coordinator with assistance from multidisciplinary team At least once a year, or when required For FDA and USDA mandated establishments, or when required for certification purposes Unless mandated or required for certification, HACCP is voluntary, and GMPs are mandatory Stakeholders: auditors, inspectors, and customers 12 Steps of HACCP (includes 7 Principles) HARPC Based on FSMA act and principally, the Final Rule for Preventive Controls for Human Food Beyond the conventional risks for actual and potential food safety hazards Preventive controls that prevent or significantly minimize “known or reasonably foreseeable” risks Trained Preventive Controls Qualified Individual (PCQI) as described in the FSMA Act At least once in 3 years, or when required For all establishments along the food supply chain that serve U.S. consumers, unless exempted Exemption list is provided by FDA, but this does not exempt facilities from following at least CGMPs The FDA 7 Steps of Developing a HARPC Plan 2
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