In my role as a food safety consultant specialising in risk assessment and HACCP, I was immediately interested in the new term ‘HARPC’ and the FSMA preventive controls rule when it was introduced. Keeping up-to-date with the latest risk-assessment systems and food safety laws is important to me so that I can provide the best possible advice to the food industry.
The preventive control rule that applies to all domestic (USA) processors, packers or storage facilities also applies to foreign manufacturers who import food into the United States. There is no doubt that this rule will change the way we assess food safety across the world, and the introduction of HARPC to meet the requirements of the rule will turn HACCP on its head.
There is a need for a combined HACCP and HARPC approach, with a structured methodology that meets both requirements.
Food facilities will continue to be requested by law, by their customers and the certification standards that they adhere to, to comply with HACCP principles. After considerable research, it became apparent to me that there was no guidance available which explains how HARPC could be incorporated with our current HACCP principles. There was guidance information for the requirements of a HARPC plan but much less as to how to carry out an assessment.
At first glance, the requirements of HARPC and HACCP look very similar but there are a number of fundamental differences which make compliance to both systems difficult.
For example, the hazard analysis carried out to meet the preventive control rule, must be carried out without taking any controls into consideration. This is contradictory to the NACMCF and Codex principles, where the hazard is assessed taking the controls into account. The consequences of this change are huge, as the number of significant hazards taken through to the next stage will increase substantially. The problem of how to handle the number of significant hazards without producing an over bearing, unfocused amount of CCP’s presents itself…
The book provides a simple, yet effective solution which meets the requirements for compliance to both HACCP and HARPC.
The book has been designed to provide you with all the information and practical tools that you need to be able to develop your own combined HACCP HARPC plan. The first section provides a comparison of the different standards and requirements for HACCP, the preventive control rule from FSMA and BRC. The BRC standard has been selected as the GFSI recognised scheme for comparison and analysis as this standard provides a detailed approach to the requirements of HACCP – with the aim of developing a best practice system, which will meet all other GFSI recognised schemes.
Each section is colour-coded, for ease of use and orientation. Within each section you will find each requirement fully explained with the methodology for a combined system described. Completed examples provide guidance and exercises for you to complete, this will help you establish your understanding of the methodology. There are ‘Top Tips’ as a summary at the close of each section so you can check you’ve got everything covered as well as an area where you can make your own notes as you work through. The exercises at the end of each section are also available for download so you can use these as templates, if you wish, for your own combined HACCP HARPC plan.
By following each section of the book and completing the assessment using the step-by-step instructions, you should be able to build your combined HACCP HARPC plan that will comply with both HACCP & HARPC requirements. In addition to this, it will also meet the the BRC Global Standard for Food Safety Issue 7.
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