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HACCP in USA under USDA regulation

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steve p

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Posted 09 June 2011 - 02:02 PM

in section 2 on the BRC standards, the food safety plan-HACCP it stated that Codex Alimentarius HACCP principles shall be used and reference, in the United States its required to follow the regulation. how is the certification bodies in the USA handling this issue


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Posted 09 June 2011 - 08:06 PM

Hi Steve,

On cross checking are the Codex Alimentarius HACCP principles at loggerheads with the USDA Regulation or are they complementary. If they are balanced simply reference both; if they argue then you have an issue to resolve.

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Posted 09 June 2011 - 11:40 PM

Dear steveP,

As Simon replied it would help if you can be more specific.

For example –

What kind of business are you referring to? (I can recall that USDA control Industries ABC and FDA-XYZ although I forget the exact details.)

Is yr question related to the declared set of 7 “Principles” used to carry out the development of the HACCP Plan/system?

Is yr question related to the fact that some industries hv Regulatory CCPs?

My guess is that there is already a (standard) compromise answer to yr question but more info. is required.

Rgds / Charles.C

Kind Regards,




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Posted 10 June 2011 - 03:41 AM

Steve P -
Most FDA-regulated food companies have the flexibility to follow Codex; however there are a few (infant formula, juices) that must follow FDA regulations. All USDA FSIS-regulated food companies must have a HACCP plan meeting USDA FSIS regulations, which do not always seem to mesh cleanly with Codex. There are often regulatory requirements that might not be justified under a purely scientific Hazard Analysis. It is the Hazard Analysis that tends to present the most difficulty.
My FSIS-regulated plants have resolved this by setting up a matrix for each step in the HA. Each step is assigned values for Severity & Likelihood which are multiplied to determine Risk within each hazard class (phys, chem, bio). We then set value ranges that required no control (low), at least a prerequisite program for control (medium), and those with higher values that required a CCP. You can do anything along this line that makes sense and is defensible.
Since this analysis is not required by FSIS, we include it as supporting documentation, but do NOT include it in our HACCP plan's official Hazard Analysis. Also, BRC requires a signed & dated flow chart - again not a regulatory requirement. We keep duplicate FCs, the one in the official HACCP plan is not signed. We have made the decision that we will do the activities as required within the BRC clauses, but will not integrate them into our regulatory HACCP plan. The last thing I need is to be arguing with an FSIS official about something that was not required by them in the first place...All it does is increase the risk of regulatory noncompliance.

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