As an FDA regulated facility, I have done away with HACCP. Well not really, but I have converted our legacy HACCP plans to the legislatively required Food Safety Plans.
Food Safety Plans do not require a flow diagram. I just can't see doing a proper hazard analysis if you don't have a flow diagram. So those have been incorporated.
CCP's in the old HACCP plan are still in the new Food Safety Plan. They are just called a Process Control.
Because Food Safety Plans differ from traditional HACCP in that they do not consider PRP's "before" you do a hazard analysis, you have to get over that mind set.
For example, in a bakery operation, you use flour. There has been historical evidence of salmonella in flour. Therefore it may be a hazard.
With HACCP, many people would have just used some PRP like "COA's are inspected before unloading to ensure the material meets the material specification"
With Food Safety Plans, a piece of paper is not an adequate control for an identified hazard. This is why if you have identified a hazard with a material (flour), the FDA requires you to "scientifically" show that the identified hazard that "may" exist, is dealt with at some part of the manufacturing process. This is why, at least in bakeries, the baking step is now a Process Control, because it is at this step that an identified hazard will be mitigated.
We are also certificated against BRC. The BRC 8 Standard in Section 2 specifically states that "the HACCP Plan (or Food Safety Plan) shall......"
We have been audited against BRC, FDA (for an actual FSMA Readiness Audit) and by a rather large international bakery company that we co-pack for, and all have accepted my mash up.
I simply do not see the need to maintain two plans.
If anything, a Food Safety Plan required under FSMA will be, generally, better than a HACCP Plan in identifying hazards, risk assessing them, and implementing controls that reduce or eliminate any identified hazards.
I get some people that get their back up about all the different requirements, and I'm right there with you. By the same token, I don't want to see some standard that every food manufacturing facility in the world has to comply with. Imagine what that would look like?