CCP and Preventive Control in the same Hazard Analysis

If the food manufacturing required HACCP and preventive control both then separate hazard analysis required or preventive control hazard analysis is sufficient. If the CCP is identified under that preventive control (Column 5) then it would be accepted for SQF or BRCGS audit as GFSI is HACCP based food safety.

Preventive Control Hazard Analysis – 1 (ingredient Processing step), 2 (Identify hazards--) ---------

(5) What preventive control measure(s) can be applied to significantly minimize or prevent the food safety hazard?

Process including CCPs, Allergen, Sanitation, Supply-chain, other preventive control

I'm a bit confused by what you've written but from the UK when exporting to the US, I combined my HACCP and preventive control plans.  Anything which was a CCP was already compliant to my reading of the FSMA regs but it was where I had prerequisites controlling significant hazards that I needed more detail.

Remember for FSMA you need to consider hazards for severity and likelihood before the application of any controls.  It's the opposite in HACCP but you can still do it the FSMA way without identifying 100s of CCPs because of the first question on the 2022 Codex decision tree.

The other big differences are the hazards you need to consider (although GFSI have adopted these as well now) so include adulteration where it could be a food safety risk, radiological etc.  But I just included them in my scope and said they'd be included where relevant (and then did that in at least one place in my HA so proved we'd considered them.)