FSMA Fridays: Migrating From HACCP To HARPC (Part Two Of Four)

Check out Part One of this series

In the first portion of FSMA Fridays: Migrating From HACCP To HARPC, Levin and the Acheson Group panel began discussing what members of the food industry should be doing now to migrate from HACCP plans to HARPC plans. Here, in part two of the series, the panel addresses how HARPC falls into a food-safety plan and the available tools to develop a HARPC-focused food-safety plan.

Barbara: David, how does HARPC fit into a company's overall food-safety plan and does this wind up being the same thing?

David: My view of this is that the HARPC is a piece of your food-safety plan. My vision of a food-safety plan is that it really is a holistic, systematic approach, where you are controlling risk in your establishment, and frankly, not just in your establishment. Supply chain, which is not in your establishment, is critical in terms of controlling risk. So, as I said in my response to the last question, is we are starting with looking at everything that we are doing and we are asking if there are significant risks in any part of it.

The next question is “How is that risk being controlled?” This is the classic, “What are the risks? How are we controlling them? Are we controlling them adequately?” That will build into the rest of your food-safety plan, which gets into ensuring the controls are operating appropriately through monitoring. If they need to be validated according to FSMA, then they are validated, so process controls need to be validated. In the current version of FSMA, allergen controls and environmental controls do not need to be validated. That's the regulatory requirement.

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