Right, but it is my understanding, from the FSPCA class, that the entire supposition of the "Food Safety Plan" is to assume that there are no PRP's already in place. Therefore you would need to identify preventive controls to mitigate a hazard at any step.
In a nutshell, this is the main difference between HACCP and the acronym that will not die, HARPC.
For example, receiving an ingredient that contains allergens requires a preventive control, maybe not at the receiving step, but someplace along the process. This is of course not HACCP, because HACCP is supposed to have PRP's in place FIRST. This is the biggest problem I have with "HARPC". The intent, as I understand it, is to make food producers think "proactively" rather than be reactive. OK, that makes perfect sense to me, however, if you HAVE programs is place, that will minimize or eliminate a hazard at a later step, are you not being "proactive?".
This whole thing is causing confusion and unnecessary time wasted by thousands of people who just received partial guidance from the FDA on what they want, a week or two before the implementation date for companies that are not considered "small".
Still waiting for the actual "guidance" on these important distinctions that were missing from the draft "guidance" document that was recently promulgated by the FDA.
This is also why "small" businesses have been sitting around, waiting for meaningful guidance, to work up "acceptable" food safety plans. Why spend the time and resources to do something that may be overkill?
Political Rant: Government cannot mandate a one size fits all regulation for a business segment that is so diverse. The vast majority of food producers/processors are not going to willingly kill people. That tends to be bad for business.
End Political Rant: