5 replies to this topic

[Cronkk]

Hello,

 

I am in the process of updated our HACCP plan for our NSF audit coming and was wondering could I take out the HACCP Hazard Analysis and replace them with the HARPC Hazard Analysis?  Or do I have to keep HARPC HA separate from my HACCP plan?  I only ask because they are very similar and both basically do the same thing.

[SQFconsultant]

Take it out and replace.

[Cronkk]

Take it out and replace.

Thank you.  I will do that.

[Ryan M.]

Well...from my understanding in the PCQI course from FSPCA there is a bit of difference in the hazard analysis between the two.  HARPC hazard analysis is conducted assuming no programs or controls in place to manage the hazards.  See the article linked below.

 

https://safefood360....accp-and-harpc/

 

I don't know if FDA regulators will come in and expect you to have this type of hazard analysis or if they will take a HACCP type hazard analysis.  It really is too soon to tell.  I think overall, they will be looking for some type of food safety plan that address the process, allergen, vendor / supply chain, sanitation, and recall plan.

 

I see more customers asking our status of implementing the preventive controls rule for human food to ensure we are compliant.  We are considered a small facility so our compliance date is not until September this year.  I'm still working on revising our food safety plan in some way to be ONE plan that meets both HACCP and HARPC requirements.

[Charles.C]

Hello,

 

I am in the process of updated our HACCP plan for our NSF audit coming and was wondering could I take out the HACCP Hazard Analysis and replace them with the HARPC Hazard Analysis?  Or do I have to keep HARPC HA separate from my HACCP plan?  I only ask because they are very similar and both basically do the same thing.

 

Hi biddlecom,

 

^^. I'm afraid FDA decided to change some of the hazard analysis "axioms".

 

But perhaps yr process is ultra-simple.

[Cronkk]

Yeah we don't have to comply to any of the FSMA rules because we are just a distributer of beverage items.  There is no processing or repacking or cold storage.  All we do it receive, store, and ship.  But If I read it correctly we don't have to comply to PCHF but we still have to write the HA for it.  I was just more curios if the NSF auditor would accept the HACRP HA in my HACCP plan.