The instructors also went the extra mile with us to compare and contrast the differences and similarities of GFSI based plans (specifically SQF and BRC) and the preventive controls requirements.
They also spent time clarifying the maze that is HARPC/HACCP (there still is HACCP, HARPC is now more accurately called a Preventive Controls based Food Safety Plan) the rolling of radiation into the "chemical" hazards consideration rather than having it be a separate HACCP hazard category, and the idea that while HACCP is designed to control hazards that you can MEASURE (critical limits, CCP's and all that jazz) the Preventive Controls may be in place to control hazards that don't specifically have a limit or aren't "measurable".
So, as Kellio stated, stuff often handled though oPRP's.
A few queries below which I have seen elsewhere on the IT but so far without, afai could find, any official answer. No doubt(?) must have come up in yr course -
(1) afaik, current haccp plans are typically based on assessing the consumer risk in "digesting" a given food product after (if labelled) following any implicit/explicit preparatory instructions/info. So what precisely do FDA mean by "ABSENCE of preventive controls" ? (for example - is this a limited concept such as evaluating the consumer risk incurred by a (small?) "failure" in a (presumably) microbiologically satisfactory process step such as a cooking procedure or a gross change such as removing the step altogether (eg a labelling check from an allergen risk POV). Notably for NRTE (ie 'to be cooked") finished products, does the risk asessment for the hazard analysis exclude the cooking step by the consumer ?)
(2) Is it correct that some harpc Plans are expected to have a lot more significant hazards than typical HACCP plans due to (1) ?
(3) How is the FSMA's PC "System" going to practically interpret the term "significantly minimize" ? (a possibly similar idea was tested ca. 20 years ago for haccp/CCPs and subsequently discarded).
I noted these definitions in the FSPCA manual -
Critical limit: the maximum or minimum value, or combination of values, to which any biological, chemical or physical parameter must be controlled to significantly minimize or prevent a hazard requiring a process preventive control.
Significantly minimize – to reduce to an acceptable level, including to eliminate.
There is no definition of “acceptable level” in the manual.
So what does “Significantly minimize” actually mean ? If the "acceptable level" is intended to be identical to that in, say, iso22000/22004, I suggest that the terminology "significantly minimize" is redundant and misleading. Either way there is obviously a fundamental necessity for the former or latter term to be "defined".
None of the above aspects afai can see are addressed in the FSPCA Course manual.
I can make one comment/opinion regarding oprps. After 10 years, it remains an ISO-screwed-up concept IMO and I doubt that it has delivered any meaningfully practical benefits over traditional haccp, other than perhaps to the Consultant Industry. If there are some similarities between oprps and PCs, I fear it's not a good indicator for harpc unless fda have better explanative capabilities than ISO and a zillion other publications.
Regarding "measure" there are typically 2 types of measurement - Quantitative and Qualitative.
The significance of "measurement" is contentious, eg -
PS - added - the NRTE query may be solved via the new section XXVII in Final Rule. Time will tell.
PPS - added - "acceptable level" is interpreted on pg 55962 of Final Rule as - "By ‘‘acceptable level,’’ we mean a level that will not cause illness or injury or
result in adulterated food." The text on Pg 55947 of Final Rule implies that it equates to the same "acceptable level" as used in Codex's definition of CCP.
P3S - After some thought, i suppose that harpc must use an "absence" card since the haccp PRPs now have to miraculously reappear after the hazard analysis as Sanitation PCs (just like the Sanitation CCPs of ye old HACCP). So a ton of CCPs >> a ton of PCs.
Offhand, the logic of, effectively, raising all control measures to pseudo-CCPs seems a somewhat sledgehammer approach if the primary objective is to increase focus on the hazards dominating the recall statistics. I guess the Proof of the Pudding will ....... eating.