Looking for information and guidance about HARPC?

Looking for information and guidance about HARPC (Hazard Analysis and Risk-Based Preventive Controls for Human Food).
 

Background: Our operation is a Frozen vegetable blending and packaging.

Has anyone implemented HARPC Plan yet?

Would like to know how much documentation is required besides the HACCP Plan?

Any help information you could share, it is greatly appreciated.

Kelio

I have not yet done the hybrid system, which I think is how we will go, but the AIB has a free guide to FSMA and talks about the differences and overlap between HACCP and HARPC systems.  Because the HARPC system looks more like a performance based requirement, as long as your system covers all the bases, it will qualify.  I'm really thinking that having an overall food safety system that has everything in it is the way to work this.  So as long as your HACCP plan is extended to include those few things that are not currently in HACCP, it should work.

The place to go to get the free download is here...

https://www.facebook...237202476309340

Good Luck!

Martha

Martha,

Thank you for your response. I will look into at AIB Guide.

I will talk to you soon,

Arquelio

Hi Kellio,

I have yet to find even a single example of and oPRP from HACCP converted to a preventative control with accompanying monitoring, verification and validation for HARPC. I would like to have some examples myself for substantive oPRP like extraneous matter control, allergen control and Pathogen Environmental Monitoring.

I have found some worthwhile articles and webinars....see below and attachments.

www.foodonline.com has posted transcripts of the FSMA Fridays webinars that have covered HARPC

www.achesongroup.com and www.safetychain.com sponsor the FSMA Fridays webinars. After the live webinars are over they post them to their website and to YouTube

Both the above offer notifications, links and newsletters for FSMA, HARPC, Preventative Controls etc., if you sign up.

Of course HARPC is part of FSMA and so is USA centric, so the only international stakeholders are foreign suppliers to the USA. The key words I have used in searches are FSMA, Risk Based, Preventative Controls, HARPC

regards,

Xylough

Not sure if this will help anyone, but the current National Canadian program Food Safety Enhancement Program, which is HACCP based is a near mirror image of what FSMA is calling HARCP. I have attached a link.sorry, yall have to cut and paste

http://www.inspectio...7674768_eng.pdf. It details all the prerequisite that must be done, all under a HACCP umbrella. Being Canadian and not American, the individual provinces do not have the power to over ride the federal government. So in Canada if you want to export, you must be federally registered and to do so, you must comply with the FSEP requirements.

Not sure if this will help anyone, but the current National Canadian program Food Safety Enhancement Program, which is HACCP based is a near mirror image of what FSMA is calling HARCP. I have attached a link.sorry, yall have to cut and paste

http://www.inspectio...7674768_eng.pdf. It details all the prerequisite that must be done, all under a HACCP umbrella. Being Canadian and not American, the individual provinces do not have the power to over ride the federal government. So in Canada if you want to export, you must be federally registered and to do so, you must comply with the FSEP requirements.

Very nice, thanks!

Martha

It will be interesting to see how the two systems align when the FDA program is ever finalized and implemented. I could hope it would simplify import and export between the two nations if they were on the same page.

regards

Some light reading for your down time Martha. :rofl2:  And for us at this facility, more confusing because we process a game bird, so FDA not USDA. which becomes even more confusing! Yes, food safety is paramount, but global trade matters as well. Interesting to hear any feed back once you have had a chance to have a look see

It will be interesting to see how the two systems align when the FDA program is ever finalized and implemented. I could hope it would simplify import and export between the two nations if they were on the same page.

 

regards

The FDA has already been working on this thought process.  I would hope that they work with Canada on this quickly.  The proposed regs state: 

"...the proposed rule would exclude from most of the standard FSVP requirements (including hazard analysis and verification that identified hazards are adequately controlled) food from a foreign supplier in a country whose food safety system FDA has officially recognized as comparable or determined to be equivalent to that of the United

States, provided that:

• The food is within the scope of FDA’s official recognition or equivalency determination regarding the food safety authority of the country in which the foreign supplier is

located; and

• The importer determines that the foreign supplier of the food is in good compliance standing with the food safety authority of the country in which the foreign supplier is located."

 Martha 

Some light reading for your down time Martha. :rofl2:  And for us at this facility, more confusing because we process a game bird, so FDA not USDA. which becomes even more confusing! Yes, food safety is paramount, but global trade matters as well. Interesting to hear any feed back once you have had a chance to have a look see

LOL.  I'll email it home and download it on my Kindle Fire.  Easier reading for my not-so-young eyes.   At least it's not in French.  :giggle:

If it aligns well with FSMA, maybe things will actually get easier between the 2 countries.

Martha

Slightly :off_topic:

Well. having just  looked at the FSMA-inspired Draft for High risk foods which was kindly recently linked on this forum i anticipate the FDA's Reseach arm are considerably  enjoying their partnership with FSMA.

This document has echoes of the original Micro.Risk Assessment  Methodology which launched haccp into stardom. proved to be manna from Heaven for the research publication-minded community but was quietly phased out witin 2-3 years and replaced with a progenitor of Codex etal.

IMO the whole affair has a similar flavour to the gestation process for the notorious Pathogen Reduction Rule. Simplifications can be expected.

Thanks / Charles.C

To All,

Thank you for your responses. I got a wealth of information from all of you. I will continue to follow this post.  I have some resistance from Senior management about this subject and I need all information and education possible.

A Quick Hi!!!! to the Canadians.

Thank you for your postings.

Resistance from senior management - sigh

It's not resistance as much as maybe because we are small, some of the implementations seem like unnecessary overkill and it's tough to explain when no one's flying a red flag too publicly to say "this is coming and we need to buck up and comply and that's going to require some investment"

Resistance from senior management - sigh

 

It's not resistance as much as maybe because we are small, some of the implementations seem like unnecessary overkill and it's tough to explain when no one's flying a red flag too publicly to say "this is coming and we need to buck up and comply and that's going to require some investment"

Actually, many places are flying the red flags, if only to get people to buy their services or promote their business.  What people don't realize is that, in the US, as a regulation is changed, the old information disappears from the CFR listing, and only the new regs are visible.  So the "old" GMP will no longer exist, and HARPC will be put into its place.

Our site is less than 40 people, and we manufacture some non-food products, but we are pretty much FSMA ready.  If you are GFSI, then you should be fine.

If you are very small, you have more time to comply.  I urge you to check that out.

Some links for information and help.

http://www.safetycha...om/fsma-fridays

http://www.aibonline...FSMA\index.html

http://www.fda.gov/F...egulation/FSMA/

Martha

We have less than 15 people on site and we are not GFSI - also since we aren't manufacturing, just repacking at this facility, we can't yet see the value to spending to go into GFSI quite yet..

We have less than 15 people on site and we are not GFSI - also since we aren't manufacturing, just repacking at this facility, we can't yet see the value to spending to go into GFSI quite yet..

There are exemptions for businesses who have less than $1,000,000 in sales.  For those, compliance is not required for 2 years.  By then, maybe your management will be more comfortable and ready to comply.  And you can initiate the changes over time, which is less costly.

http://www.fda.gov/F...A/ucm334115.htm

Martha

There are exemptions for businesses who have less than $1,000,000 in sales.  For those, compliance is not required for 2 years.  By then, maybe your management will be more comfortable and ready to comply.  And you can initiate the changes over time, which is less costly.

 

http://www.fda.gov/F...A/ucm334115.htm

 

Martha

Either fortunately or unfortunately (depending on how you look at it) we don't fall in that category..

I appreciate the links though! Education is all I have but there's SO MUCH out there!