Can Combine Ingredients for FSMA FS Plan ?
I am new to having to write a HACCP plan all alone, I have always been part of a team. The new FSMA law is very expansive. When writing a food safety plan, if the process is the same but the ingredients differ, do you have to write a plan for each product? Such as, if you have a base product and then add various flavors, do I need to have a seperate plan for each as well? Thank you!
I think starting with a hazard analysis for your "base product" then branching out into individual risks for different "flavors" makes sense. Just make sure it's obvious enough that an auditor will be able to understand how you laid it out.
You do need a separate hazard analysis for each unique ingredient set or process in your facility.
I am new to having to write a HACCP plan all alone, I have always been part of a team. The new FSMA law is very expansive. When writing a food safety plan, if the process is the same but the ingredients differ, do you have to write a plan for each product? Such as, if you have a base product and then add various flavors, do I need to have a seperate plan for each as well? Thank you!
Hi stacey,
Just to add, i hv experience traditional haccp for which if all the flavours have an identical safety interaction in the process, you might be able to combine / use a list titled "Flavours" for haccp purposes. But FSMA/HARPC no idea.
To example, my experience is in seafood area and utilizes various species of shrimp input. They have same hazards/process so, from a haccp POV, can reference as "shrimp" for the hazard analysis + include a preliminary list of varieties to be included.
Even minor process variations not changing the CCPs can sometimes be accommodated in a single flowchart but it depends on the case.
The "HARPC" preventive control plan is a bit different from a traditional HACCP plan, but they can be combined. The FDA has put out a free plan builder software package like their food defense plan builder. Here's the link to the plan, you just download it onto your computer.
https://www.accessda...etyPlanBuilder/
Martha
FSMA allows process oriented food safety plans. Be sure to support that with an ingredient Hazard analysis for each unique ingredient.
Also you will NEED a Team. Even if it is only necessary to meet monthly rely on operational expertise at your facility. Your people will see the why and you automatically have embedded advocates in your operation. Not just a good idea... it works
How many production lines do you have? If only one production line and the process is the same, you'd only need one plan. But in your Raw Material / Ingredient Hazard Analysis, you would need to call out every single ingredient, including the different flavors.