One of the new requirements in the AIB standard is as follows:
"The facility follows the Seven Principles of HACCP:
1. The facility has conducted and documented a Hazard Analysis for each raw material and process step. In the case of facilities producing or exporting to the USA or other countries with regulations, regulatory (FDA) requirements for HARPC (Hazard Analysis and Risk-Based Preventive Controls) will be evaluated taking into consideration the defined hazard categories or country-defined requirements."
So, the way I read this, you don't have to comply, yet, with HARPC. You just have to evaluate it and take into consideration the defined hazard categories.
From the text of FSMA:
"(b) Hazard Analysis.--The owner, operator, or agent in charge of a facility shall--
"(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility, including--
"(A) biological, chemical, physical, and radiological hazards, natural toxins, pesticides, drug residues, decomposition, parasites, allergens, and unapproved food and color additives; and
"(B) hazards that occur naturally, or may be unintentionally introduced; and
"(2) identify and evaluate hazards that may be intentionally introduced, including by acts of terrorism; and
"(3) develop a written analysis of the hazards."
Does anyone have any idea how you are supposed to "identify and evaluate hazards that may be intentionally introduced, including by acts of terrorism"? Seems to me that list could be pretty long.
Marshall