2 replies to this topic

[TimG]

We discussed this a bit a few months ago, but I haven't seen anything definitive on this. It was mentioned that the 2.0 version, specifically from FSPCA, WOULD count as a 2+day HACCP. When looking at the FSPCA site, they don't mention this anywhere in the 2.0 training (unless I missed it).

PC Human Food | PCHF PCQI V2.0 | Fspca

 

I'd love to be able to send my quality tech to this class and have it cover both PCQI and HACCP requirements for customers/SQF.

[jfrey123]

I'd want it in writing from them that their certificate recognizes the participants as HACCP certified in addition to the PCQI.  I don't see FSPCA as one of the accredited HACCP Alliance trainers:  Accredited Introductory HACCP Training Programs - International HACCP Alliance

 

But at a cursory glance at the manual, (Food Safety Preventive Controls (FSPC) Training Curriculum) I also grabbed my First Edition - 2016 off my bookshelf and compared it to the new October 2024 - Version 2 at that link.  V2 goes much heavier into HACCP, that's for sure.

[GMO]

I've been through the PCQI 1.0 training and have the full deck for 2.0.  Personally if you were delivering a HACCP plan outside the US, I would not see it as in depth enough because even when FSPCA try to align to HACCP, they make the odd error from memory in interpretation (at least for how the rest of the world sees it).  I think at one point for example, they declare process PCs as equivalent to CCPs, which they really aren't.

 

To be honest, FSMA created a bit of a problem.  I actually think HACCP is kind of broken in the way that we've now cut back CCPs so much that the controls which are PRP related don't get enough focus.  No oPRPs didn't fix this in my view, all they did was take those slightly grey area controls and made them a little bit darker grey.  So with Process PCs and focus on other areas like sanitation, allergen control etc where mistakes often happen, I think FSMA did a good thing.  Only problem is the outputs are quite different to HACCP and are often a combination of CCPs, oPRPs and PRPs.  That just doesn't work with HACCP.

 

Did HACCP need to change?  I think it did.  But instead we now have two systems that don't quite align.  And you know what?  Our operators couldn't give a fig about it which is the annoying part so it's just techies arguing about stuff that fundamentally doesn't really matter.

 

I have spent so long talking to people about "does this in HACCP mean that in preventive controls?" and finding that global experts disagree.  At some point you have to come to the conclusion that there is a system issue.

 

To my mind therefore what you end up at site is either a HACCP led but broadly PCHF compliant plan so you retrofit the requirements of FSMA in and it sort of works or a PCHF led plan which you retrofit the requirements of HACCP in which sort of works.  But a lot of sites, believe it or not, have two plans!  This is because if you show HACCP retrofitted onto PCHF, those auditors, like me, who "grew up" with HACCP get a bit purist about it all (actually I don't but I see how that can happen) and vice versa.

 

I would still personally put both plans together because frankly, I do not see creating two plans as a value add use of my time but whether the PCQI training is enough for HACCP compliance is very much down to who audits you.  If it's compliant with whatever standards you have and people who mostly see PCHF plans audit you, then you'll be fine.  If it's people who mostly see HACCP plans, I'd get the team leader on a 2 day HACCP course as well as there are nuances I think FSPCA get a bit wrong.