There are a few other implications as well and I'm sure I've not picked them all up. You have a list of hazard types you must consider, so I've put them into my scope of my HACCP plan to explain radiological hazards for example would be considered where applicable in the "chemical" category.
The other thing I picked up was a greater focus on prerequisites and ensuring these are actively monitored and verified. So what I've done is taken every prerequisite mentioned in my HACCP plan, reviewed it and ensured it's documented then summarised them in a separate document with the monitoring activity and verification. I did kind of baulk at this to start with but when I thought it through I realised that >90% of recalls are prerequisite related. It's rare to see "the chicken wasn't fully cooked" or "pieces of metal are present" normally it's "the allergens were wrong because the wrong packaging was used" or "the wrong date code was applied" etc. So it actually makes sense. That way I was making my HACCP plan more robust rather than undermining it. Of course as a UK manufacturer I have to retain my HACCP plan whatever the FDA thinks. We had an audit last year (not against the FSMA yet though) but the auditor seemed really happy with our approach so far. I'm also trying to get myself on a Campden training course to become a Qualified Individual for the Food Safety Preventive Controls stuff.
The course page is here: https://www.campdenb...-for-Human-Food
