Understanding the Differences
There are some fundamental differences between HACCP principles and the HARPC requirements, a couple of the most controversial may be that the Preventive Control Rule does not recognize CCPs, or mention the use of a process flow diagram.
The rule also does not specifically state that a scope, including product description, intended use and intended user is required. The rule however, does imply that these elements would be needed, as the inherent hazards from the raw materials and finished product need to be included, plus those around the intended use.
When producing a system that complies to both sets of standards, CCPs, a process flow diagram, a scope, product description and details of the intended use and user are still going to be required.
Tackling the Contradiction in the Systems
There is one fundamental contradiction in the methodology of the two systems, which is all based on how likelihood is assessed.
Both systems require significance of the hazards to be determined, based on a risk assessment of severity and likelihood. The assessment of severity is aligned in HACCP and HARPC and does not pose a problem. The problem arises when the hazards are assessed for likelihood, as shown below:
HACCP: severity is assessed with the current controls taken into account
HARPC: severity is assessed in the absence of any controls
This small change, has massive implications.
In a typical HACCP system, we would include all the hazards that you could possible think of – so that all possible eventualities are covered. If we continue this approach into a HARPC system, and then assess these hazards in the absence of any controls, the number of significant hazards produced would be huge. More importantly, they would not be truly focused on the key food safety risks.
Therefore, when thinking about the hazards that should be included in a HARPC system, using the mind-set of less is more is the right way to go. Pertinent hazards should not be missed, but a structured approach of pin-pointing which hazards should be included is essential.
In my new book ‘Combine Your HACCP & HARPC Plan’ I have included a whole section about how this can be achieved, called the Hazard Extraction Stage. It uses some the elements of HACCP that we are used to, so it’s familiar, but utilizes them effectively to extract the really pertinent hazards for the specific product and process being assessed.
So What About the CCPs?
Once the hazard analysis has been carried out, using severity and likelihood (without the controls being taken into account) to determine significance, all significant food safety hazards must have a preventive control assigned.
In any combined HACCP and HARPC system, CCPs are still going to an essential element. Once the preventive controls have been established, we need to determine which of these preventive controls actually need to be CCPs.
So, to do this we need to have a way of determining them. The typical CCP decision tree is no longer applicable, because if we used it, we would end up with most, if not all of our preventive controls becoming CCPs.
We don’t want to go back to the time when we had loads of CCPs and we lost sight of what process steps are really critical to food safety.
To enable us to establish which of the preventive controls need to be ‘raised up’ to become CCPs, we need to understand the difference between a preventive control and a CCP.
The definitions can be broken down, so just the really key points from them remain. Then they can be compared side-by-side, so the distinction between them is clear.
The definitions are shown below:
Preventive controls prevent or significantly minimize the hazard
CCPs eliminate or reduce the hazard to an acceptable level
A preventive control is something that either prevents a hazard from occurring, or stops accidental contamination from reaching the customer.
A CCP as something that eliminates or reduces inherent contamination in the product.
So, to establish whether each preventive control should actually be a CCP, we need to ask if that preventive control eliminates or reduces the hazard to an acceptable level. Or, is the hazard an inherent contamination risk, and which the process step eliminates or reduces to an acceptable level. If it does, then it is a CCP.
By asking the right question of each of the preventive controls, the CCPs can be determined and they can still be focused on the really critical food safety risks.
If you’d like to learn more about the book ‘Combine Your HACCP & HARPC Plan’, please go to http://www.techni-k.co.uk/HARPC_Book
I’d also be happy to answer any questions you have on HARPC, if you would like to add them to the comments below.
Kassy Marsh is the author of Combine Your HACCP & HARPC Plan, step-by-step. Kassy started her career in the food manufacturing industry in 1998 and has developed an exceptional ability to implement simple and practical solutions, which can be effectively implemented into the factory environment. She is well known for her best practice risk assessments and specializes in food safety principles.
In 2015 she co-authored the book ‘Assessing Threat Vulnerability for Food Defence. This pioneering methodology is now one of the leading risk assessment tools in use for the assessment of food threats.
To meet the increasing demand for a methodology to assess food integrity, in early 2016 Kassy developed and co-authored her second publication ‘Assessing Error Vulnerability for Food Integrity’. This system is now used by a leading UK retailer as a training tool for their supply base.
Since starting her own consultancy business in 2012, she has become well regarded in the field of food safety risk assessment for her ability to provide simple, practical and easily understood step-by-step solutions.
Kassy can be contacted at www.techni-k.co.uk
- Jun 02 2016 07:50 PM
- by Simon