Juice HACCP and FSMA

Hi,

I work in a company that makes 100% juice and juice drinks (around 20% juice). Right now we have 2 HACCP plans, one for High Acid Juices and another one for High Acid Juices with Apples because we have an additional CCP on the one with Apples. Our juice drinks are included in our High Acid Juice HACCP. We have an ingredient hazard analysis for each ingredient that we use. My question is, should I have a separate Food Safety Plan for the juice drinks and then the other 2 Juice HACCP or could I have one Food Safety Plan that includes 100% Juice and the juice drinks?

Thank you for your help.

Juice HACCP is regulatory and thus exempt from several rules under FSMA.

This guidance document may be of help.

Marshall

Thank you Marshall, I read that but I have a question. Following Subpart C question #10 of the guidance document I should have a Food Safety Plan for 100% juices and another for the juice drinks. My question is if I can group both types of beverages in the same Food Safety Plan and apply subpart C and G of 21 CFR 117 to 100% juices even though they are exempt. My goal is to know if I need to have 2 Juice HACCP plan plus the HARPC for the juice drinks.

Thank you  

Unfortunately I think you've hit what you need svelasan. You need your existing HACCP plans for all the technical "juices", and you need to develop a separate food safety plan for items that aren't covered under the Juice rule. So you'll have 3 plans. Lucky for you you already have most of the work done, just update the terminology. I aniticpate that trying to combine them will be a needless argument with different inspectors who expect to see a distinction.

Thank you FurFarmandFork!