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

Check out Part One, Part Two, and Part Three of this series

In the third portion of FSMA Fridays: Migrating From HACCP To HARPC, Levin and the Acheson Group panel discussed what the FDA expects to see from food-safety plans once FSMA is implemented and began handling questions from the webcast’s live audience. Here, in the fourth final portion of the series, the panel will continue handling questions from the live audience. Topics include similarities between HARPC food-safety plans and SQF food-safety plans, as well implications within FSMA’s final rules around allergen control validation.

Barbara: David, a question from Joy. She is asking, “the food-safety plan required by HARPC similar to the food-safety plan required by SQF?”

David: Yes, it is. Good question, Joy. They are very, very much aligned. I know some of you who have been in that space may have tracked some of the work that we've done, what we did with SQF, to do a comparative analysis between their current scheme and the first person of the proposed rules. They are very-well aligned.

Our synthesis of that was that if you are SQF level two, you are in a very-good place of compliance with FSMA, at least in terms of the preventive control rule. There are clearly aspects of the whole ball of wax of FSMA that takes you beyond that. Melanie was integrally involved in some of that work, so if you've got anything to add, Melanie, then please.

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