HARPC is coming - what you need to know
We have found it sometimes hard to find high quality information about HARPC and the new FSMA regulations. So we decided to put together a blog post that is the first in a series that demystifies some of these new concepts.
This first blog is about the differences of HACCP and HARPC and it contains a simple comparison table to illustrate the core differences. We also have a simple step-by-step guide for those who need to comply with the new regulations.
The blog can be found here: http://safefood360.c...-you-need-know/
What do you think - was the article helpful? What would you add to it? What should we write about next?
HI, Mr. Lassi Eronen
I found this post very interesting and usefull, you've synthetised the differences very clearly,
Teresa
Hi Teresa! I'm really glad it was helpful!
Hi Lassi,
Thank you, for that highly informative post!
Hi Lassi,
Thank you, for that highly informative post!
You were fortunate to be able to read it.
A large unremovable object from the "software team" appeared on my screen after a short time blocking the text and requesting an email address.
You were fortunate to be able to read it.
A large unremovable object from the "software team" appeared on my screen after a short time blocking the text and requesting an email address.
Sorry to hear that. The box should have a little X on the top to close it - or clicking outside it should make it go away. Were you reading on a mobile device?
Sorry to hear that. The box should have a little X on the top to close it - or clicking outside it should make it go away. Were you reading on a mobile device?
Hi Lassi,
Problem resolved. Default zoom setting for Firefox chopping off top of object including the x button. Reducing zoom brought it into view.
Clicking outside the object did temporarily work but the object re-appeared in minutes.
Thks for replying.
IMO several features of HARPC have taken HACCP back a quarter of a century or so. Shades of CCP1 / CCP2 and voluminous haccp plans.
I liked the Safefood Link but there is maybe one further key factor in the decision procedure for PCs. HARPC's hazard analysis apparently requires an absence of preventive controls. Opposite to (current) HACCP afaik.
Hi Lassi,
Problem resolved. Default zoom setting for Firefox chopping off top of object including the x button. Reducing zoom brought it into view.
Clicking outside the object did temporarily work but the object re-appeared in minutes.
Thks for replying.
IMO several features of HARPC have taken HACCP back a quarter of a century or so. Shades of CCP1 / CCP2 and voluminous haccp plans.
I liked the Safefood Link but there is maybe one further key factor in the decision procedure for PCs. HARPC's hazard analysis apparently requires an absence of preventive controls. Opposite to (current) HACCP afaik.
Great - thanks for the feedback. I will look into that tool tomorrow and try to make it smaller so that you can easily close it on all settings.
Btw, good point about the difference between RA in HACCP and HARPC. We're picked the same thing in our analysis. I personally find it a strange way to conduct RA - but what can you do.
Great - thanks for the feedback. I will look into that tool tomorrow and try to make it smaller so that you can easily close it on all settings.
Btw, good point about the difference between RA in HACCP and HARPC. We're picked the same thing in our analysis. I personally find it a strange way to conduct RA - but what can you do.
Hi Lassi,
The "x" problem may be more with my PC-Firefox (v.42) than yr end since just tried Chrome and no problem to see the "x"
my desktop is XP/SP2 which is starting to show occasional oddities these days, more so with FFox than Chrome, so if you have no other complaints maybe it's my end :smile:.
IMO several features of HARPC have taken HACCP back a quarter of a century or so. Shades of CCP1 / CCP2 and voluminous haccp plans.
That was my first thought too but I'm currently working on a plan (which wasn't previously run by me) to make HARPC compliant. We have retained our hazard analysis and CCPs as per HACCP but what HARPC has driven us to do (and what I'm furious my predecessor didn't do) is to be far more specific about our prerequisites and the monitoring and verification of them. This is how I set up HACCP plans 5 years ago (in a good way) and unfortunately the industry I'm in now are a bit behind the times. In fact one of of my site plans written by some kind of eejit just says for his summary of prerequisites "look at the quality manual" in big letters. I was sat with an auditor when he proudly showed them this. :doh:
Although prerequisites are sometimes more vague, difficult to monitor etc, we do already do a lot of verification of them, e.g. auditing, swabbing etc so in fact many of the systems are already in place. What we have found though is a few details are missing. So for example, with a machine set up, we need to ensure packs are cleared from a sealing head to avoid damage. When delving into the detail of the prerequisites, we found that the instruction to do this has only ever been verbal but an SOP exists which people are trained against so obviously we're going to tweak this and make sure people are retrained. Getting into the specifics of "where do we say we do this" and "how do we monitor, validate (where we can) and verify we're doing it" is really getting out some interesting detail which our previous (awful) HACCP plan missed.
But my last point was ably summed up on every version of the FSA recall lists they've ever published. Top two recall reasons are normally allergens (which is normally due to the incorrect packaging being applied) and coding. Neither of these are CCPs in my factory nor in any factory I've ever worked in. So if your top reasons for recall are not due to your CCPs, HACCP is perhaps due a shake up.
That said, for the fact it will do my plan some good, I kind of think that's accidental. Do I think the FDA applied HACCP really badly and so needed to rebrand it and that's why HARPC has come in? Yes I do. :shades:
Hi GMO,
Yes, I agree one can understand the FDA’s dissatisfaction with Allergen Control as a PRP as per the recalls. FSIS, I believe, have a vigorous corrective expectation where a PRP is visibly failing to be “verified”.
Perhaps the "commonplace" occurrence of allergen-related/labelling recalls has also created an impression of non-seriousness. I would have thought that the financial losses in having to relabel, possibly repackage, entire shipments would be large enough to cause a major manufacturer concern but seemingly not so.
There seems to be several sides to the issue of allergen labeling recalls– (a) manufacturing facilities’ scientific limitations regarding which products actually contain allergens, (b) disinterest or incompetence regarding allergen labeling requirements / necessity, (c) precautionary labeling. Whether elevating the allergen issue (ie harpc) will simply maximize manouevring via option (c) is unclear to me.
It is also a fact that the original trend ca 2000 to handle potential CCPs like Allergens within Prerequisite Programs was not totally unrelated to a distinct benefit in reduced documentation and auditorial probing. The launch of standards like iso22002 has added another stamp of approval to the (currently) wide scope of PRPs.
One objection to HARPC is that (perhaps similarly to iso’s use of oprp) a primary objective of haccp in focusing attention on “significant hazards” is damaged by the introduction of the Process-System-wide Preventive Control (PC) whose interpretation now contains the wonderfully subjective “significantly minimize the hazard” term. Traditional haccp of course tended to receive the opposite criticism - if a hazard was not a CCP, the hazard was "uninteresting" / relegatable to PRP handling. (iso22000 tried to bridge this gap but IMO has failed to achieve this objective.)
Harpc seems to have another notable blind spot (similar to very early haccp) due its curious (and afaik unexplained) inclusion of the "absence" of PCs while performing the hazard analysis (precise meaning of absence unclear to me). The result looks to be the likely approval of a truckload of PCs for raw finished products which are destined “to be cooked” by the consumer/onward user. Have so far seen no published refutation of this conclusion, eg within the downloadable FSPCA manual.
Time will (soon?) tell. I wonder why FDA could not have simply defined an intrinsic / significant cross-contamination, allergenic hazard as being associated with a CCP. I believe historical precedents exist.