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Produce Rule Vs Preventive Rule and FDA Registration

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#1 Estrellita3


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Posted 14 September 2018 - 01:14 AM

Dear all,


I hope you can help me to answer this question:


I am working in a company that package Hidroponic Lettuce. The previous Manager have implemented a HACCP plan with a CCP metal Detector. Which as my understanding put us as a Preventive Control Rule NOT Produce Rule. Even though we have a packing house not a processing facility.


Since we are definied as a secondary farm activity, we do not actually need to apply for a FDA Registration. However, the CEO wants that becose the company uses as a marketing tool. I am afraid that if we register under the FDA and get elligible for a visit they are going to see that ours is a packing house with a CPP. I am afraid that can bring us some futher problems. Does any one have any advice on this?

#2 SQFconsultant



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Posted 14 September 2018 - 03:10 AM

Pull the metal detector.
Redesign the HACCP plan.
Tell the owner/president to get GFSI certified (my bias is SQF) and use the certification as a marketing tool.

Warm regards,


Glenn Oster


SQF Certification & Implementation Consultant

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