HARPC for Warehouses

Hello. We are a company in US where we primarily import variety of finished products from Asian countries, mainly Japan and also purchases product domestically. At our facility we solely storage packaged foods and distribute to our customers. As far as PCHF rule goes warehouses and storage facilities are exempt from developing a food safety plan unless those food are TCS foods which then are required to follow the modified requirements in the law.

Currently we hold a HACCP plan (receiving, storage, and shipping) for our refrigerated, vacuum packaged fishery products.  I am having trouble figuring out how to flawlessly combine the modified requirements for TCS food with the seafood HACCP plan it to not be redundant in paperwork and to call it our food safety plan.  

Any advice is appreciated! 

 

 

flawlessly combine

This isn't going to happen...there's going to be WIDE interpretation of how these plans should be presented over the next few years, so instead focus on making sure you write it in a way that is defensible and easy to explain (argue) with auditors.

My recommendation is to really focus on your process preventative controls keeping the CCP terminology, this was the recommendation at my PCQI training. You may also want to add an additional designation for the regulated points (E.g. CCP-S for seafood HACCP rule CCP's) to identify those CCP's that are required in the seafood haccp rule, so that it's easy for auditors looking at those products to identify the points they need to verify/audit while on site.