The main difference between HACCP and HARPC that I see a stated emphasis on prevention. Our HACCP/Food Safety plan is prevention oriented and is getting more so, and would fulfill the requirements that are in the proposed FSMA.
I think that the HARPC system was set up because most facilities were only required to operate using cGMP. So they were not familiar with the risk analysis thought process and the need for monitoring of points where there is a risk of problems. So maybe HARPC is HACCP for cGMP people. The HACCP facilities are exempt maybe because they already are compliant for all intents and purposes.
We've been beefing up our HACCP plan all along, so I think that it's ready to fulfill the HARPC requirements within our HACCP plan.
The beauty of most US regulations is that they are performance based standards. That means that, except for a small subset, you can become compliant with the regulation in what ever way you want, as long as you accomplish the goal. For example, it tells you that your hazard analysis must be risk based, and what hazards to consider, but it does not tell you how to assess the risk.
So, if your HACCP plan fulfills the requirements of the FSMA, you can call it what you like, you will be in compliance.
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