Hahaha, honestly still do the 12 steps and just add "preventive controls" as kinda-CCP's. SQF also requires you to comply with relevant regulation, so as long as you're performing a CODEX based hazard analysis (which really doesn't change, it's the controls themselves that change), you can rely on that clause to address any gap your auditor might want to pick on.
Honestly IMEX i've never had a CB auditor split hairs on the haccp plan adhering strictly to Codex provided it has a realistic hazard analysis and describes the controls used to keep them in check, whether they're PRP's, CCP's, or now PC's.
QA Manager and food safety blogger in Oregon, USA.
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