Jpainter - Attached is a white paper from SafeFood 360 about FSMA and the difference between HACCP and the new plan.
Thks for attachment.
Unfortunately it seems to me to contain a variety of errors + some (IMO) debatable content.
(Admittedly it is an attempt to respond to what is already IMO a highly flawed original).
Just for example -
(1) Pages have no numbers on my PC.
(2) Figures partially unreadable after (forced) blow-up.
(3) No specific Example (I think).
(4) Pg 5/23
Operational Prerequisites (oPRPs) - Metal detection, detection & scanning, filtering, sieving
• General Prerequisites (oPRPs) - Cleaning and sanitizing plant, equipment, employee
facilities, as well as managing calibration, maintenance, personal hygiene, and
(typo/s ? - prize for guessing which one(s) is correct ?)
(oprp seems unrelated to the original FSMA since not in its list of definitions [then again, neither is haccp or Prerequisite])
(5) Pg 4/23
Radiological hazards and economically motivated adulteration are identified as chemical hazards (21 CFR 117.130(b))
(text seems to not exist in the original on IT)
(6) Pg 4/23
Haccp is implied to be reactive whereas harpc is proactive. That's (almost) original !
Pg 7/23 the terminologies "consumer complaint" and "product recall" are IMO ambiguous/inappropriate for a safety-intentioned risk matrix even after allowing for "subjectivity"
On the other hand I rather liked this paragraph even though there is a somewhat contentious terminology in it ("quality" includes safety ?)(none of quality/adulteration/EMA are included in FSMA definitions)
21 CFR 117.130(b)(2)(iii) states known or reasonably foreseeable hazards that may occur in food
due to intentional adulteration for economic gain should be considered. Adulteration affects food
quality and product integrity. It is recommended to consider circumstances with a history of adul-
teration for economic gain that could cause illness.
PS - I daresay another list of FSMA/cfr definitions exists since so many seem absent but I couldn't see it.