In this post we’re going to cover how to actually manage your preventive controls, once they’ve been determined by your risk assessment.
This means managing both the preventive controls and also those preventive controls, which are CCPs. To do this, first let’s remind ourselves about the difference between a preventive control and a CCP…
- CCP = “a point, step, or procedure in a food process at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce such hazard to an acceptable level.”
- PC = “Procedures, practices, and processes to significantly minimize or prevent the hazard.”
So, a preventive control minimizes the hazard. A CCP is where control can be applied and eliminates the hazard.
In a typical HACCP plan, you would have a CCP summary which would look something like this:
|CCP||Hazard||Control measure||Critical limit||Monitoring||Correction|
|Corrective action procedure|
In order to comply with HACCP requirements, a CCP summary will still be required, but now we also need to think about how we manage the preventive controls too.
The level of detail required for a preventive control is less than a CCP. The FDA state that a preventive control must have a procedure, which contains the process to be applied and the frequency at which it should be applied. It also needs to cover the correction required when the procedure highlights a problem and, corrective actions when the procedure has not been adhered to.
Plus, records would also be required to prove that the preventive control is being managed effectively and these need routinely checking and signing off.
There will be so many preventive controls, that I think to have a preventive control summary in the style of a CCP summary, would create a lot of extra work and also repetition of the information that needs to be in the procedures anyway. I think as part of the HARPC study, when a preventive control is highlighted, the procedure that manages it, should be referenced.
That means that the structure of the procedure is important. It needs to cover off all of the elements required, plus it needs to be used as a training tool and reminder at the point of use.
The procedure needs to cover the following sections:
- The name of the preventive control
- The hazard that it manages
- The process of monitoring
- The frequency of monitoring to be applied
- Who’s responsibility it is to carry out the monitoring
- Reference to the record
- How to correct the process when the monitoring highlights a problem
- Corrective action, when the procedure hasn’t been adhered to
We've tagged this article as: FSMA