By Laurel Maloy, contributing writer, Food Online
FSMA demands every food manufacturer or processor have a food safety plan in place. The effectiveness of your HACCP or HARPC plan has everything to do with the personnel designated to draft and implement it.
Mandated through the Food Safety Modernization Act (FSMA), the principles of HARPC are a must-have for compliance under the new rules. Most facilities must have some form of food-defense plan accepted to the FDA. The plan must be well thought out and drafted, in writing, complete with the responsible parties listed, scheduled monitoring, and validation of the results. This food-defense or food-safety plan must be updated regularly, including any time that personnel changes are made. If you add responsibility for a certain function under your plan, then it must be documented. If you make changes, additions, or deletions to your plan, it must be documented. If the person’s name responsible for a particular HARPC or HACCP element changes, it must be documented. However, first, you must assemble an HACCP or HARPC team, as described here. Things to consider when assembling your HACCP or HARPC team:
Choose An Effective Leader
This should be someone who has exceptional communication skills, is highly-organized and is respected by management and peers. The person should be knowledgeable about, or has received specialized training regarding the scope of any good food-defense plan. Ideally, this person should have, or be in the process of gaining, formal certification in HACCP and/or HARPC requirements.
Engage Personnel With Product-Specific Knowledge And Expertise
If this competence is not available through personnel on site, it may be necessary to recruit outside experts, or to train in-house personnel. Be sure to include personnel with at least basic HACCP knowledge and either a passion for, or expertise in, food safety.
Assemble A Multi-Disciplinary Team
These are team members with a wide range of knowledge. Consider including people with specific knowledge of the equipment, its operation, and specifically, its cleaning. As you develop your HAACP or HARPC plans, make note of the expertise you may need, such as someone with specialized pest-control know-how or with specific proficiency regarding the chemicals you may use in your facility. It may be prudent to include certain skill-sets as part of your future new-hire practices, which may also include tweaking current job descriptions.
Include Team Members With Exceptional Administrative Skills
You will want to be able to describe your product(s), including its composition, its preparation, its packaging, and its method of distribution. A flow diagram of your processes will be necessary, as will on-site confirmation of the flow diagram. You will want someone who is articulate and detail-oriented, with the necessary computer skills, such as word-processing and spread sheet analytics.
Then, just as you have assembled the team and drafted your plan, you must regularly assess it. In those areas where weaknesses are present, consider how best to address the issue(s), and then do it. Big business has no choice but to comply. However, some small businesses may be exempt.
If you fall into the second category, you may want to consider the value a plan such as this brings to your business. The simple act of complying when you are not mandated to do so will elevate your status in the FDA’s estimation. It is also an exceptional tool to reevaluate your processes, possibly resulting in streamlining production, process improvement, and financial gains.
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