You don't need to eliminate your HACCP to make is FSMA compliant. Therefore, you will still have your CCPs. Many HACCP plans fail to identify the prerequisite programs that control a hazard, eliminating the need for the CCP. What you are adding is the preventive controls to identified hazards, which are not necessarily a CCP. What FSMA looks for is how are you controlling your potential food safety hazards.... they may be controlled at multiple steps in the process, from purchasing to shipping. What we would refer to as a prerequisite program, FSMA is looking for a preventive control. I've attached a sample of a preventive controls chart, it is very similar to a how you would do a HACCP hazard analysis.
(1) Ingredient/ Processing Step
Identify potential food safety hazards introduced, controlled or enhanced at this step
Do any potential food safety hazards require a preventive control?
Justify your decision for column 3
What preventive control measure(s) can be applied to significantly minimize or prevent the food safety hazard?
Process including CCPs, Allergen, Sanitation, Supply-chain, other preventive control
Is the preventive control applied at this step?
Receiving refrigerated ingredients – liquid pasteurized egg
Vegetative pathogens such as Salmonella
While pasteurization minimizes the likelihood of Salmonella USDA recommends the product be used in cooked foods. Experience has shown Salmonella occasionally occurs in this ingredient.
Process Control - subsequent cook step
Allergen – egg
Egg is an allergen that must be labeled to inform consumers. Cross-contact is not an issue – all products contain egg.
Allergen Control – allergen labeling at other steps
- There are many types of food safety hazards
- The hazard analysis process:
- Identifies known and reasonably foreseeable hazards (potential hazards)
- Evaluates the likelihood and severity of potential hazards to identify those requiring a preventive control
- Identifies process, allergen, sanitation, supply-chain or other preventive controls for potential hazards
- An effective hazard analysis reduces risk and focuses efforts
- A written hazard analysis is required for all products