Yes, I agree with you that for food, both the USFDA and USDA/FSIS seem to have prioritised on the NACMCF version of HACCP. Not too surprising I guess. The EC has similarly focused on Codex.
Historically, the relationship between the 2 standards seems to be rather subtle. It turns out that the Codex and NACMCF standards have been surprisingly closely interwoven for a considerable time, notably via (a) the Codex Hygiene Committee is apparently permanently chaired by US personnel, including (at least sometimes) FSIS executives and (b) the NACMCF standard was officially “harmonised” in respect to Codex by the former's developer group in 1997 so that the two timelines nominally converged.
Nonetheless, even after the harmonization, it is obvious that significant differences still remained. For example NACMCF continued (I assume) its use of CPs and the 2 standards had substantially differently worded definitions of Validation, ie –
Codex – Obtaining evidence that the elements of the HACCP Plan are effective
NACMCF - That element of verification focused on collecting and evaluating scientific and technical information to determine if the HACCP Plan, when properly implemented, will effectively control the hazards.
IMO the NACMCF version was unquestionably superior in respect to clarity of chronology and content.
Subsequently, in respect to validation, it appears that the NACMCF 1997 version has stayed "as is” whereas the Codex version has “sidled” nearer to NACMCF, eg via their 2008 validation document. Currently Codex validation is defined as –
Obtaining evidence that a control measure or combination of control measures, if properly implemented, is capable of controlling the hazard to a specified outcome.
Obviously both USDA/FSIS and USFDA have further introduced their own “flavours” into the core NACMCF structure such as in the FSIS 2015 Validation scheme. The net haccp result is a real jigsaw of bits and pieces. A quite descriptive overview of the US scene (in 2014) is given in this document –
At the risk of overwhelming people, I noticed this IMO rather neat classification of validation "types" which enables a superficial comparison between Codex, NACMCF, FSIS –
Three commonly used strategies for process validation include concurrent, retrospective and prospective process validation.
Concurrent process validation is based on simultaneous collection and evaluation of data from a process concurrently with its application. This is used when there is a change or modification to an established and previously validated process.
Retrospective process validation is validation of product already in distribution based upon accumulated production, testing and control data. This technique is often used in analyzing process failures that result in product recalls.
Prospective process validation is a deliberate, forward-looking, planned approach that determines if the process can be relied upon with a high degree of confidence to deliver safe food. Prospective validation is best suited for evaluating novel processes and must consider the equipment, the process and the product (Keener 2006)
Seemed to me that, initially, both Codex and NACMCF strive to be “Prospective”. FSIS appears to be trying to add a little bit of “Concurrent” on top via Prerequisites.
I predict that FSIS users will shortly be asking (howling?) for a prescriptive set of requirements for typical Prerequisite Programs such as listed in iso22002-1.
PS - I noticed this (1998) snapshot containing very brief summaries of the, then, recent haccp versions. Bit more flavour.
the 90's haccps.png 260.72KB