Combining a HACCP HARPC plan…
Why is there a need for a combined approach?
On first glance there are similarities to HACCP, which could possibly lead you to think that the requirements for both systems are totally aligned. But we need to be careful, as there are a number of major key differences and then also, one main contradiction in the requirements. This means you need to understand these, in order to be able to implement as system which clearly works for both.
Food facilities who have HACCP systems are now faced with the difficult task of trying to adapt their current food safety system, to meet the HARPC requirements. These facilities will continue to be required by their customers, by local law in the countries where they export to and by accreditations such as GFSI to adhere to the HACCP principles. A straight swop from HACCP to HARPC is not going to be an option to many businesses.
So, we need a clear, practical and effective methodology which allows compliance to both HACCP and HARPC.
The hierarchy of PRP’s, Preventive Controls and CCP’s…
As a consequence of combining the HACCP and HARPC, all of the control principles need to come together and work as one. Therefore, the distinctions between PRP’s, preventive controls (PC’s) and CCP’s need to be fully understood.
There is a hierarchy to the controls; PRP’s being the building blocks for facility-wide general controls. PC’s are more specific controls, typically associated with a particular step in the process. And a CCP is one which is above and beyond a PC and is critical to the safety of the food.
This can be seen in the control pyramid below…
CCP: A control which eliminates or reduces the hazard to an acceptable level.
PC: A control which prevents or significantly minimizes the hazard.
PRP: A facility-wide generic control, not specific to one particular process step.
TO REALLY UNDERSTAND HOW AND WHEN EACH OF THE CONTROLS SHOULD BE APPLIED, IT IS ESSENTIAL TO UNDERSTAND THE DEFINITIONS OF EACH.
A CCP is a hazard which is inherently expected in the product, it therefore knows to tackle it, by eliminating it or reducing it to a level at which it is safe (such as cooking).
A PC is one which either prevents the hazard from occurring in the first place, or if the hazard has occurred, it identifies it and minimizes the impact of the hazard, by ensuring that it is not released as good product.
The key differences
There are a number of differences between the conditions of HACCP and HARPC. The Preventive Control Rule is not as specific or detailed in the way in which the plan should be documented or designed, as the principles laid out in NACMCF or Codex Alimentarius. However, although the FDA may not have specifically detailed that certain aspects such as product description, intended use or intended user must be documented, they do elude to the fact; because the hazards that must be assessed would require this information to be understood and included into the system.
In order to produce a system that works for HACCP and HARPC both sets of requirements need to be included which means things like a product description, scope and a process flow diagram.
The major contradiction in the systems is how significance is determined within the risk assessment. HACCP and HARPC require a risk assessment that takes into consideration the severity of the hazard, and then the probability of the hazard occurring. The aim of this is to establish if the food safety hazard is significant, so that if it is, a preventive control is applied. Food safety hazards which are not significant still need to be managed effectively, but these would be controlled through the use of PRP’s. The contradiction in the systems comes during the assessment of significance:
The Preventive Control Rule asks for the probability (or likelihood) to be assessed in the absence of any controls (even those currently in place).
HACCP principles state that the probability (or likelihood) should be assessed taking the controls that are in place into account.
So, what’s the answer?
Even though the two systems contradict each other, it’s OK to follow the requirement for HARPC and assess the hazard without taking the controls into account. However, you need to be mindful that there are consequences in doing so.
By evaluating the hazard without any controls, will mean that the number of significant hazards produced will be much higher than in a typical HACCP plan.
Each of these hazards will need to be have a preventive control applied – which could be a lot if we manage it like a typical HACCP. On top of that, we would then need to assess the preventive controls to work out which are CCP’s and this would probably mean we end up with a lot of CCP’s as well.
Using the typical CCP decision tree to work out which PC’s are CCP’s is not a practical solution, as the result of this will likely mean that most of the preventive controls become CCP’s. A lot of us can probably remember the days when HACCP was first introduced and where facilities had many, many CCP’s – we don’t want to go back to this, as we know from experience it produces a system that is unmanageable and so becomes ineffective.