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.
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.